Comments on the Draft Western Ghats Ecosensitive Area Notification 2024
Vidhi & ATREE Submit Joint Response to Government on the Western Ghats Eco-Sensitive Area Notification
The Ministry of Environment, Forest and Climate Change (MoEFCC) invited public comments on the sixth Draft Notification for the Western Ghats Ecologically Sensitive Area (WGESA), issued on 31st July 2024. This draft proposes to designate over 56,800 square kilometres of the Western Ghats as an Ecologically Sensitive Area (ESA) under The Environment (Protection) Act, 1986, covering parts of six states: Gujarat, Maharashtra, Goa, Karnataka, Tamil Nadu, and Kerala.
In response, the Climate & Ecosystems team at Vidhi, in collaboration with the Centre for Policy Design, Ashoka Trust for Research in Ecology and the Environment (ATREE), has submitted a joint response offering detailed comments and recommendations on the draft. The submission focuses on improving monitoring and enforcement mechanisms, enhancing stakeholder engagement, and promoting eco-friendly and sustainable development within the proposed Western Ghats ESA.
Key Recommendations include:
- Phasing out existing thermal power plants and ‘Red’ category industries, with exceptions for new Primary Healthcare Centres.
- Complete ban on large river-valley projects, while smaller hydropower projects should be classified as ‘Category-A’ under the EIA Notification, 2006.
- Environmental Clearance for Wind Projects: All wind power projects within the ESA should be classified as ‘Category-A’ projects, requiring prior Environmental Clearance.
- No new or expansion of highways, railways, or high-voltage transmission lines. However, rural roads connecting existing settlements, schools, and Primary Healthcare Centres to district roads and highways, as well as the maintenance and modernisation of existing roads (without expanding the right of way), should be exempted.
- Cumulative Impact Assessments for regulated activities to provide a comprehensive understanding of the environmental effects of multiple projects in proximity to each other.
- A formal ‘pre-scoping public consultation’ process to involve local stakeholders in validating proposed projects, ensuring greater public awareness and participation before impact assessments begin. Exclusions from the public consultation process under the EIA Notification, 2006 should not apply to projects proposed within WGESA.
- A robust monitoring and evaluation framework, including the creation of an independent Decision Support and Monitoring Centre (DSMC), composed of experts in ecology, sociology, and economics, to regularly assess the region’s ecological state,monitor the impact of permitted/regulated activities, and also facilitate effective and timely grievance redressal.
- Addressing socio-economic impacts on local communities by promoting sustainable livelihoods through eco-friendly tourism, sustainable agriculture, and other green initiatives that balance environmental conservation with income generation.
You can download the complete submission from the link below to read the detailed comments and suggestions on the Draft Notification of WGESA.
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About the Authors
Debadityo is a Senior Resident Fellow and Lead, the Climate & Ecosystems team at Vidhi. His research interest lies in the intersection of ecology, law, and policy. He graduated with B.Sc. (Hons) in Zoology from the University of Delhi in 2009 and completed M.Sc. (Tech.) Environmental Science & Technology from Banaras Hindu University in 2012. He has also undertaken training on Tropical Forest Restoration from Yale School of Forestry and Environmental Studies in 2016. He has over 12 years of professional experience in issues related to the environment and wildlife protection. In the past, he has worked with organizations like Vikram A. Sarabhai Community Science Centre, Legal Initiative for Forest & Environment, WWF-India, Wildlife Trust of India and several grassroots organizations. He is founder and trustee of Vindhyan Ecology and Natural History Foundation (since 2012). He is a recipient of the Sanctuary Wildlife Service Award' (2019) and is member of IUCN-Species Survival Commission’s Bear Specialist Group and EKOenergy network, Helsinki. Debadityo has also initiated litigations in the National Green Tribunal on issues related to environmental clearance, declaration of eco-sensitive zones and compensation for environmental damage.
Shashank is a Research Fellow at Vidhi. He works with the Climate and Ecosystem team wherein he focuses on legal and policy issues related to current government measures around climate and environment. Prior to joining Vidhi, Shashank worked as a LAMP (Legislative Assistant to Member of Parliament) Fellow with a Lok Sabha MP wherein he worked on environment, disability and tech related matters. He also drafted two Private Members' Bill for the MP which were introduced in Lok Sabha. Shashank was also a Javed Abidi Fellow at NCPEDP wherein he worked on issues related to inclusivity and accessibility. His work as a Javed Abidi fellow primarily focused on the exclusion of disabled people from the political landscape. He likes to write on multiple policy related issues and his articles have regularly featured across platforms. Shashank graduated from Dr Ram Manohar Lohia National Law University with BA LLB (IP hons) in 2021
Rohit is a Programme Manager (Conservation Data & Policy) at Vidhi's Climate & Ecosystems team. His core interest lies in advancing an evidence-based and inclusive policy-making process in conserving India's ecological wealth. He graduated in Zoology & Biochemistry from St. Xavier's College (2011) and completed his M.Sc. in Wildlife Biology & Conservation from the National Centre for Biological Sciences (2014). He worked with the Bombay Natural History Society (2014-17), studying the critically endangered bird Bengal Florican’s ecology and proposed several habitat conservation measures. He also contributed to the species’ inclusion into Appendix-I of the Convention on the Conservation of Migratory Species (CMS) in 2020. At the Wildlife Institute of India, Dehradun (2017-20), he studied the breeding biology of river-island nesting birds at National Chambal Sanctuary and implemented a participatory nest protection program for the endangered Indian Skimmer through Wildlife Trust of India’s Rapid Action Project (RAP) Grant in 2020. Subsequently, as a senior researcher in WII's Conservation Advisory & Policy Cell (2021-24), he conducted ecological impact assessments, drafted wildlife conservation/mitigation plans, and collaborated with statutory bodies like the NBWL, FAC and state forest departments in various assignments. Rohit has over 20 research publications and has conducted fieldwork across varied ecosystems and geographies of India.
Shailee recently graduated with B.A. LL.B. (Hons) from National Law University Odisha. During the course of their law school, Shailee has worked with the Chief Justice of India, Dr Justice DY Chandrachud, public policy clinics, and law firms among others. Their passion for exploring the nuances of environmental law, animal rights, and policy has defined their professional trajectory. Beyond this, Shailee's interests extend to gender justice and data protection laws, reflecting both a professional calling and a deeply personal commitment. In their free time, you would find them cozy with a book, petting their paw-friends, or baking
