Review of Bhavanapadu 2640 MW TPP of ECEPL - A Ritual & Eyewash ?

The Expert Appraisal Committee (EAC) on Thermal Power Projects in its 24 th meeting held on 2-3 May 2011 recommended that that the Ministry may rescind the stop work order issued on March 01, 2011, at the proposed power plant site of Bhavanapadu 2640 MW TPP of ECEPL at Kakarapalli, since at this stage, a zero base level assessment of the project is not a feasibility.

 

Reject Recommendation of EAC and Cancel EC

 

In accordance with Sub- Para 8 (vi) of EIA Notification, the deliberate concealment and/or submission of false or misleading information or data which is material to screening or scoping or appraisal or decision on the application shall make the application liable for rejection, and cancellation of prior environmental clearance granted on that basis.

It is therefore requested that the recommendation of EAC be rejected outright and the E.C granted to Bhavanapadu 2640 MW TPP of ECEPL at Kakarapalli, be cancelled by MOEF, after giving a personal hearing to the project proponent and following the principles of natural justice, based on the following facts & ground realities::

a) The NEAA in its Order dated 30-8-2010 observed that various reports including that of sub-committee of EAC were found to be incorrect
     and EAC & in turn the MOEF has relied on these reports for granting Environmental Clearance(EC) for the project.

 

b) The NEAA also observed that as stated by the expert of BHNS and agreed by  Dr.Kaul, a renowned expert on Wetlands, elevation of

     the project site by the project  proponent, after the grant of EC nearly a year ago, has caused irreversible changes  in the character

    of the ecologically important wetland.

 

c) In the 17 th Meeting of the Standing Committee of National Board for Wild Life held on 22-12-2009, under the Chairmanship of the

    Minister for E&F, the site inspection  report of Dr.Asad Rahmani and Dr, Asha Rajvanshi had clearly stated that Naupada  Swamps

    area was an excellent habitat for Migratory Birds and was classified as IBAS.  It also stated that the entire area of the project,

    starting from approach road to the project site is marshy land and the EIA Report of the applicant ignored Bio diversity of the area.

 

d) AP High Court, while dismissing WP NO..9360/2009 observed that " A plain reading  of the reproduction from the counter of the

    Respondent - State makes it clear that clearance was granted by the State after due deliberation and application of mind" ---
   "It is amply clear that the Power Project area is not part of Naupada Swamp and as  such bereft of any ecological importance"

    This is far from the facts and the ground realities

 

Penal Action

 

Instead of filing false criminal cases against innocent villagers peacefully agitating against Kakarapalli Power Project, necessary penal action be initiated, in accordance with Sections 15,17 and 19 of The Environment (Protection) Act, 1986, against Project Proponent and the Officials responsible for suppressing the info and/or submitting incorrect/misleading info/data about the project site.

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Misuse of Diesel by Telecom Mobile Network Towers

The Diesel is heavily subsidized mainly for the benefit of Agricultural activities, Transportation of Goods and Passengers (Trucks/Railways/Busses). But the Telecom Sector is misusing the subsidized Diesel to power their mobile network towers, causing an estimated burden to the extent of Rs 2500 Crores to the Government.

 

National Action Plan On Climate Change

 

 The National Action Plan on Climate Change is initiated by Prime Minister of India for protecting the poor and vulnerable sections of the Society, through an inclusive and sustainable development strategy sensitive to Climate Change. The focus is on promoting understanding of Climate Change, adaptation and mitigation, energy efficiency and natural resource conservation by active participation of Public Private Partnership and the Civil Society.  

 

Natural Resource Conservation

 

 The Oil, like Coal is fast depleting non-renewable natural resource contributing to Climate Change. Therefore the consumption of Diesel needs to be curtailed in all sectors by judicious adaptation of Demand Side Management Measures, Energy Efficient Devices, and Renewable Sources of Energy..

                                         

Misuse of Diesel by Telecom Mobile Network Towers

 

 The Telecommunication Sector providing mobile telephone services, seems to depend on Diesel Generators, misusing heavily subsidized Diesel, for powering their mobile network towers to a large extent, mainly because of a) interruptions of grid power supply, b) location of Towers in remote places, and c) comparatively higher tariff of grid power.

 

Suggestions

 

 The following measures are suggested for consideration and implementation, in the spirit of National Action Plan On Climate Change, after discussion with the Telecom Sector and other concerned agencies:

 

a) The bulk supply of Diesel from the retail outlets should be  stopped, by March 2012,  so as to ensure that subsidized Diesel is not misused by the bulk consumers such as Captive/Emergency Diesel Generation sets used by Industry, Mobile Network Towers, Commercial establishments , Domestic Sector etc

 

b)   The bulk supplies of Diesel to the above users are to be made from the Refinery Outlets only,  at the price to be revised upwards to bring at level with the market price and avoid the burden of  subsidy from April 2012.

 

c)   The new Mobile Network Towers,  are not to be permitted to use Diesel Generators with effect from April 2012 onwards

 

d)   All existing Mobile Network Towers should completely phase out their Diesel Generators by March 2013 by opting to Solar Power with adequate Battery back up.

 

e)   All Mobile Network Towers should change over to the use of at least 50% of Green Power (Solar PV) by March 2014

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Environmental Clearance Process nothing to do with Land & Livelihoods

        

 The Hon'ble Minister for Environment & Forests , GOI , in an obvious attempt to distance himself from likely violence during evictions at the POSCO site in Orissa, is reported to have stated that "Environment and Forest Clearance Process should not be used to fight other battles that have to do with important issues like, Land Acquisition, Compensation and Livelihoods."

 

EIA Process

 

 The Public Consultation of EIA refers to the process by which the concerns of local affected persons/communities and others who have plausible stake in the environmental impacts of the project or activity are ascertained with a view to taking into account all the material concerns in the project.

 

Human Environment

 

 The Environment (Protection) Act, 1986, the implementation of which is mandated with MOEF, drew its inspiration from the proclamation adopted by the United Nations Conference on the Human Environment, which includes Water, Air & Land and the interrelationship, which exists among and between water, air, land and human beings, other living concerns ,plants, micro-organism and property.

 

The protection and improvement of the Human Environment is a major issue, which affects the well being of people and economic development throughout the world; it is the urgent desire of the people of whole world and the duty of all governments "Vide  Article 48-A of The Constitution of India.

 

SOCIO-ECONOMIC ASPECTS

 

 The EIA process is required to take into consideration the adverse impacts of the Land-Use change due to the proposed project and its likely Socio-Economic effects on local communities, and other cultural values, before according Environmental Clearance to the project.  

 

 The Environment, Land and Livelihoods are inseparable and form integral part of the Project Appraisal and Public Consultation

 

Conclusion

 

 The present process of Public Consultation and Environmental Appraisal of the projects for granting Environmental Clearance has become a ritual and farcical, ignoring the main issue of protection and improvement of Human Environment and the consent from the affected village level Grama Sabha.

 

 Otherwise, we would not have had the Land and Livelihood problems of Sompeta, and Kakarapalli in AP State, Jaitapur in Maharashtra and now POSCO episode. In Orissa.

 

 Hope the Government of India and MOEF will stop using different yard sticks for granting Environmental Clearances for the projects, in different States, with a view to gain Political Mileage.?

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Hyderabad International Airport , Shamshabad - Monitoring

The monitoring and review of the status of compliance of specific conditions stipulated by MoEF GOI, in its letter of 6-3-2003, granting Environmental Clearance for Hyderabad International Airport ( HIA) Shamshabad, is very unsatisfactory, .not transparent & accountable to the public at large, for ensuring their effective compliance.

Supreme Court Order   

    

The Hon'ble Supreme Court in its Order dated 1-12-2000, ruled that the government could not grant exemptions to the provisions of G.O.111, prohibiting polluting activities, in the catchment up to 10 Kms from Full Tank Level ( FTL) of the Lakes, unmindful of the fate of Lakhs of citizens of Twin Cities, to whom drinking water is supplied from these lakes. Such exemptions carelessly passed ignoring the "Precautionary Principle" could be catastrophic

 

Monitoring of Acidification of Himayat Sagar

 

By the very fact that an area of 314.0 acres, out of about 2200.0 acres of prohibited catchment area of Himayat Sagar, is being utilized for the airport activities, the monitoring & review of compliance needs special attention.  The acidification of lake waters due to toxic emissions from the aircraft, during landing and taking-off operations, needs to be regularly monitored by a suitable agency, in the light of the provisions of Sub Para 3(e) of GO. 111 dated 8-3-1996

                                         

Monitoring of Specific Conditions

 

In the light of Supreme Court directive and the fact that prohibited catchment area of Himayat Sagar is being utilized by HIA., the specific conditions in particular, stipulated while granting E.C  for HIA, are required to be monitored and reviewed for their effective compliance/implementation

Flight Scheduling and Noise Levels

The specific condition of special importance is that "Flight Scheduling and airport zoning should be properly done to reduce noise levels and their impact during night time. The noise levels should be as per the prescribed norms/standards." It may be of relevance to note, that REIA Report, predicted post project decrease in noise pollution in some areas abutting the proposed airport and the incremental noise level due to airport are pegged at 60 dBA. This aspect needs to be verified for its effective compliance & confirmed

Bird Hits & Smog

The other aspects are the possible "Bird Hits" endangering the safety of aircraft and the lives of the air- passengers & the proposed remedial measures, and the likely adverse impact of Smog in the area on the flight schedules, particularly in winter months, because of the presence of a number of air-polluting industries around the area and the proposed remedial measures etc     

Need for Epidemiological Study

The evaluation of Cancer Risks attributed to Air Pollution in Southwest Chicago published in April 1993 by EPA USA, attributed 10.5% of the total cancer cases within 16 square-mile area surrounding Midway Airport, Chicago, to emissions from aircraft. 

 

Seattle- King County Department of Public Health studied the health effects of citizens in Georgetown, an area surrounding the King County International Airport and released a report on June 20, 1997.The statistical comparison of the hospitalization rates for Georgetown with those for King and North King Counties in Seattle, show :

 

     * a 57% higher asthma rate

     * a 28% higher pneumonia/influenza rate

     * a 26% higher respiratory disease rate

     * a 83% higher pregnancy complication rate

     * a 50% higher infant mortality rate

     * Genetic diseases are statistically higher

     *a 36% higher cancer death rate with pneumonia and influenza among
        the top five leading causes

 

 Therefore, there is an immediate need to undertake Epidemiological Study of the surrounding area of Hyderabad International Airport, Shamshabad, to assess and evaluate the long term health impacts on the citizens and for initiating the required mitigation measures.

Lack of Confidence in Monitoring / Regulatory System

 The following facts, showing the speed with which the HIA Project, of considerable adverse environmental impacts on the drinking water source, in violation of the provisions of G.O.111 and Supreme Court Order, had been granted NOC by APPCB, within about 20 days from the Date of Environmental Public Hearing, speak volumes about bureaucratic / political highhandedness.

       * 28-12-2002    Public Hearing

       * 28-12-2002-   Minutes of PH issued

       * 30-12-2002    Technical Committee first meeting held

       * 08-01-2003    Technical Committee second meeting held

       * 17-01-2003    CFE Committee meeting held

       * 18-01-2003    NOC granted by APPCB

       * 07-02-2003    Application Received by MOEF

       * 06-03-2003    Environmental Clearance of MOEF granted 

Authority taking precedence over Prudence could be dangerous. 

 

Depletion of Forest in the name of Eco-Tourism Projects

 Intent of Location of Eco-Tourism Projects in RF

 

The A P State Govt. designated, AP Forest Development Corporation Ltd (APFDC) as its nodal agency for implementation of Eco-Tourism projects, namely a)Botanical Gardens, b)Night Safari & Eco-Parks and c)Bird Park in Kothaguda Reserve Forest (RF) Area, under Public Private Partnership (PPP) mode. The MOEF, GOI, vide Letter dated 23-03-2006, accorded approval for diversion of 110.87Ha of Forest Land, for development of Eco-Tourism projects in Kothaguda RF in RR District, in favour of APFDC, stipulating certain conditions.

 

The selection of Kothaguda RF Area for development of eco-tourism projects, amidst fast developing locality, adjoining High-Tech City, appears to be motivated by the real estate value of the land. The Eco-Tourism Management Plan, prepared by APFDC claims that the project is aimed to counter the shrinkage of natural vegetation, water bodies etc and the emerging concrete jungle in Mega City of Hyderabad. But judging by the happenings so far, the project may actually end up contributing to what are supposed to be countered.

 

Misuse of Forest Land for Real Estate/ Commercial Structures

 

 The main intention of the developers of the so called Eco-Tourism projects appears  to make use of the Forest Land, in prime area, strategically located amidst fast developing locality adjoining High-tech city, for non forestry activities and real-estate purposes in the years to come. As per the information available, the particulars of constructions likely to come up in Eco –Tourism projects are furnished below:

 

a)Botanical Gardens

 

 The Built up area of the following Buildings to come up in Botanical Garden is reported to be 1,59,063 Sq. Mtrs

 

i)             Hospitality Block consisting of 18 Cottages (Type 1,2 & 3)

Ii)       Convention Center with Hotel

iii)           Retail sector consisting of 2 Office Blocks

iv)            Merchandise and Multiplex Theaters consisting of 8 Screens.

v)            Nursery Super Market

vi)           Entrance Plaza and Commercial Block

 

The height of the Building for Hotel and Convention Center is 21.46 Mtrs with Basement-1+Stilt/Ground Floor + 1 Upper Floor The height of the Building for Retail and Multiplex Occupancy is 21.41 Mtrs with Basement-1+Stilt/Ground Floor + 1 Upper Floor

The area to be utilized for Visitors Amenities, excluding Roads, Pathways etc works out to be about 15% of the total area of 51.83 Ha

 

b) Night Safari & Eco- Parks

 

The original project cost is estimated to be Rs.3000.11 Lakhs (Rs 30 Crores) and an additional cost of Rs.4461.89 Lakhs ( Rs.44.62 Crores) is proposed to be invested in phases II & III as per the Commercial Needs and depending on the future demands. The Restaurant & Snack outlets in each of the proposed 5 Eco-Park sectors, five  Blocks of Cottages (each with 50 Room facility), along with 350 seat Theater for five shows, 3 D & 4 D Theaters & Entry Plaza with Shops and Restaurants are some of the construction activities proposed in Night Safari & Eco parks The area to be utilized for Visitors Amenities, excluding Green belts, works out to be about 15% of the total area of 45.61 Ha

 

c) Bird Park

 

The Built up area of Multiplex with 4 Screens and Hotel Block consisting of Basement-1+ Ground+ 1 Upper Floor with Mezzanine   to come up in Bird Park is reported to be 56,072 Sq. Mtrs. The area to be utilized for Visitors Amenities, excluding landscaping etc works out to be more than 25% of the total area of 12.43 Ha

 

Public Apprehensions about Eco Tourism Projects

 

 The so called Eco-Tourism projects, if allowed to be implemented in the present form, will result in creation of permanent structures in the form of Hotels, Convention Centers, Multiplexes, Shopping Malls, Commercial Complexes Restaurants, Parking Lots etc, in more than 15 % of the total area of the project,, leading to irreversible change of Land use, against the basic principle of Eco-Tourism for which the Forest Land of 110.87 Ha was diverted.

 

 The Kothaguda Forest Land, one of the very few large green belts in Hyderabad City, should not be diverted for the so called Eco-Tourism projects, with the hidden objective of using it for non forestry purposes namely Real Estate and Commercial Purposes with the sole object of benefiting the developers.

 

Going by the bitter experience of the so called Eco-Tourism projects around Hussein Sagar, resulting in heavy commercial activities, leading to shrinkage of Water body, Water Pollution due to commercial activities and Air pollution from heavy vehicular traffic in the area Eco -Tourism Projects, in Kothaguda RF Area will be no different.

 

 Judging by the proposed massive investments by the developers and their intent, to make use of the Forest Land, in prime area, strategically located amidst fast developing locality adjoining High-tech city, for non forestry activities and real estate purposes, it is bound to be misused for their own benefit & not for improvement  of environment and Public good.,

 

 From the changes that had taken place to the original proposal during the last 7 years, and in the absence of effective and adequate monitoring and supervisory mechanism both at Central and State levels and , the utter  lack of accountability at various levels , the Public  is very apprehensive about the so called Eco-Tourism projects.

 

Conclusion

  

 As the so called Eco Tourism Projects in Kothaguda RF area, have the same potential of "ADARSH"' Land Scam in Mumbai, and "LAVASA" near Pune, immediate action needs to be initiated to stop and abandon the so called Eco-Tourism projects in Kothaguda Forest Block, strategically located providing the Lung-Space, in prime area amidst fast developing locality adjoining High-tech city of Hyderabad  

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Nuclear Safety is not an Issue of MOEF?

A day after a protester was killed in police firing in Jaitapur- west coast of India, protesting against the proposed largest Nuclear Power Park in the world, Sri Jairam Ramesh, Hon'ble Minister for Environment & Forests, GOI  is reported to have said what happened in Jaitapur is "most depressing" and it caused him "great anguish."

.

The minister is also reported to have added that MOEF has "nothing to do with" land acquisition, compensation, economics of nuclear power and nuclear safety-- "Those were not issues that the MoEF is either competent to deal with or it is mandated to deal with. Looking into the environmental aspects of the Nuclear Power Project is the only mandate of his ministry. One should understand this fact,"

 Human Environment major Issue!

 

The Environment (Protection) Act, 1986, the implementation of which is mandated with MOEF, has important constitutional implications with international background. The Act clearly drew its inspiration from the proclamation adopted by the United Nations Conference on the "Human Environment" in June 1972 and reaffirmed in June 1992.  

 

 "The protection and improvement of the Human Environment is a major issue, which affects the well being of people and economic development throughout the world; it is the urgent desire of the people of whole world and the duty of all governments".

                                         

The Environment (Protection) Act 1986

 

The Act is enacted to enable coordination of activities of the various regulatory agencies, creation of an authority or authorities with advocate powers for environmental protection, regulation of discharge of Environmental Pollutants, speedy response in the event of accidents threatening environment and deterrent punishment to those who endanger Human Environment,( water, air & land and the interrelationship, which exists among and between water, air, land and human beings, other living concerns ,plants, micro-organism and property),Safety and Health.

 

How can Environmental Aspects be dealt without Nuclear Safety?

How can MOEF, entrusted with the task of enforcing Environment (Protection) Act 1986, can say that nuclear safety Is not the issue that the MoEF is mandated to deal with? How can MOEF Look into the environmental aspects of the Nuclear Power Projects, without addressing Nuclear Safety? These are very serious issues to be left in ambiguity and must be sorted out without any delay

The AERB, in its present form, entrusted with the task of Nuclear Safety, should be scrapped and an independent, autonomous and technically competent body to monitor and regulate Nuclear Safety should be constituted as part of proposed NEAMA, independent of DAE which controls NPCIL.

Conclusion

The people of this country have the right to know about economics of nuclear power and nuclear safety (Articles 21, 39 and 48-A of The Constitution of India), irrespective of the mandate of MOEF.

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Hyderabad City- Already Breathing Less-Going to be Much Less

                                                                 

 Hyderabad -<아>Pressure on Land 

 

The Hyderabad Master Plan-2020 makes provision for land-use requirement for an anticipated 2021 population of around 136 Lakhs for Hyderabad Metropolitan Area, against the population of about 70 Lakhs, as given below:

 

                                                                             Area in Sq. KMs in

                                                                           2001                     2021       

  Utilization                                                   Area       %           Area       %    

 

a) Residential                                              290     15.56        576      30.90

 

b) Commercial/

     Industrial/

     Institutional/

     Transportation                                       250    13.41         480      25.75

 

c) Water Bodies /

     Reserve Forests                                   203    10.89        203      10.89

 

d) Agriculture/

    Recreation/

    Hills/ Conservation                                 1121    60.14        605      32.46

 

                                     Total                      1864   100.00      1864    100.00 

    

Reduction of Lung Spaces

 

 The scrutiny of the above data shows tremendous pressure on Hyderabad urban land for Residential, Commercial etc uses, shooting up from 540 in 2001 to 1056 Sq.Kms in 2021 nearly doubled and as a result the Agriculture, Recreation, Conservation etc area shrinking from 1121 to 605 Sq.Kms by 2021, nearly by half. The organized recreational/open spaces occupy less than 1% land providing hardly per capita recreational area of 1.16 Sq.Mtrs, against minimum basic requirement of 3.00 Sq.Mtrs. But with further official reduction of the lung spaces, not to speak of illegal encroachments, will make the breathing of the City more difficult.

 

Forests & Water Bodies

 

Even though no change is projected in the area covered by Forests and Water bodies, the ground reality is that much of the area shown as Forest / Water body has been diverted / encroached for other purposes. The State Government has been liberally allotting large areas of land covered under Reserved Forests & Water Bodies to various individuals & organizations, granting  relaxations on selective basis, in the name of promoting Eco-Tourism projects with Public Private Partnership (PPP), by unilaterally modifying the land use, unmindful of  its long term adverse impacts

 

The diversion of 110.87Ha of Forest Land, in the name of development of Eco-Tourism projects- Botanical Gardens, Night Safari & Eco-Park and Bird Park- in Kothaguda RF, in the close vicinity of Madhapur High-tech City, is a classic example of depleting much needed urban Green Belts and Lung Spaces. The Citizens of Hyderabad are already experiencing the adverse impacts of so called  Eco-Tourism Projects –Necklace Road, IMAX Theater, Jala Vihar, Eat Street etc around Husain Sagar- by way of shrinkage of the Water Body &  its pollution and Traffic congestion, Air Pollution etc The location of Imliban Bus Station in Musi River is another example of reduction of water body.

 

 Urban  Land Has Become A Commodity

 

 .The Housing Boards, HUDA,  & other agencies are resorting to auction of lands to meet short-term requirements of funds Of course, HUDA itself had   become a Real Estate Developers and resorted to auctioning  large chunks of land in the conservation areas, of Jubilee Hills, Madhapur and other areas, with the sole object of mobilizing funds to cater for projects like Fly- Overs, Outer Ring Road, etc unmindful of the land requirements of the generations to come and their well being. Similarly APIIC had been allotting large chunks of lands to real estate developers and corporate bodies and granting various relaxations on selective basis, in the name of attracting investments and providing employment opportunities, unmindful of the land use and its long term adverse impacts.

 

 No Plan Is A Good Plan for A Violator

 

 A plan may be a good plan or a bad plan, but for someone who wants to break the law, no plan is a good plan. If the citizens are ready to buy apartments in buildings that visibly violate all health and safety norms, if they patronize shops / malls that have no parking space and also build houses in tank beds that will be flooded in the monsoon, no amount of policing can fully enforce any land use. It is worse if the State itself becomes the Violator or the Culprit. 

 

 The Comprehensive Land Use & Environmental Protection should be the integral part of the Master Plan. The Zoning Plans and Building Rules should be subordinate to Master Plan. The Protection & Preservation of natural resources and community's ecological infrastructure should be the major concern. These include- Water, Energy, Open Spaces, Water Bodies, Rivers, Forests etc. The Conservation and not mitigation of the damage being done, should be the focus of development, under universally accepted "Precautionary Principle"

 

 Mother of all Urban Land Auctions

 

 The  HUDA Auction of the prime piece of land of 5.8 acres (23,500 Sq.Mtrs) adjoining Check Post Junction of Jubilee Hills for a staggering Rs. 1.42 Lakhs per Sq.Mtr, earning whooping Rs. 333.70 Crores, is Mother of all Auctions of Urban Land in the State at that time.

     

 This transaction, which has the potential of converting Jubilee Hills Check Post Junction to another Punjagutta Junction, is in violation of Urban Land Ceiling of 1,000 Sq Mtrs, Building Rules for FSI of 1:1.5, Height Restriction etc, which are reported to have been relaxed on a selective basis, which is discriminatory and against the public interest and opinion.  This short sighted act of auctioning the invaluable piece of prime land adjoining KBR National Park, takes away the Buffer Zone and a strip of 5.5 km Walkway, permitting a massive commercial activity right on the fringe of the National Park.  

 

Mr.Jagmohan, Former Minister for Urban Development, Govt. of India said that "Cities had been taken Over by the Land and Builders Mafia"  

                    

 Let Us NOT SELL and SAVE for Future Generations 

 

 The important aspect to remember is that Hyderabad Metropolitan Area (HMA) alone is not Andhra Pradesh and Madhavapur, Jubilee Hills and Banjara Hills alone is not HMA. Hyderabad endowed with heritage and nature will have to be saved for the future by proper land use planning and management and not by treating it as a Commodity for meeting short term needs, which amounts to selling the future of HMA !

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