The Ministry of Environment, Forest and Climate Change (MOEF) has issued a draft notification regarding forming an Eco-Sensitive Zone (ESZ) around the wayanad wildlife sanctuary. The boundaries of this ESZ is such that half of Sulthan Bathery falls in ESZ and many towns and villages in Wayanad falls in ESZ. This will cause tremendous hardship to people, seriously affecting the businesses and farmers. MOEF has provided a 60 day window for the public to provide comments

Here are the reasons why I object to the current ESZ draft notification.

1. This draft is prepared with no involvement from the public. The guidelines for declaration of ESZ require an official from Local Self Government, yet the procedure of involving the local body was not followed. No explanation was provided by wildlife officials, and officials are hesitant to provide additional information. This is a violation of the procedure laid down in the document called “Guidelines for declaration of eco sensitive zones around national parks and wildlife sanctuaries” issued by MOEF on 9th February 2011. Though this process was started in 2011, there were absolutely no communications from the government or the forest department regarding this in the last nine years and people were completely kept in the dark. Any further draft declaration should be made only after a public hearing after due publicity, and officials should accurately reflect the public sentiments in hearings with MOEF.

2. People of wayanad are very caring of forests and that is the reason for forests close by to thickly populated areas. The general population treats the forests with respect and has often taken action and have reported vested interests who harm the forests. The population has protested the unscientific conversion of forests by wildlife officials to single yield and water consuming crops such as Teak and Eucalyptus. 

However, when basic life and liberty of the general population is threatened, we protest as in the case against nighttime closure of NH766. The protests drew a crowd of over 4 lakh people. Hence ESZ declarations without involvement of citizens have the possibility to turn people from caring to environment to being hostile, which benefits none.

3. Any forceful implementation of ESZ in human habitats and agricultural lands will have serious consequences in terms of law and order as most people coming under the proposed ESZ are completely dependent on agriculture for their daily sustenance. Any restrictions on their livelihood is likely to cause serious trouble and can create very serious consequences for law and order and keeping up of social order.

4. Agriculture products common in Wayanad are  Pepper, Tea, Cocoa, Arecanut, Coconut, Banana, Coffee, Rice etc.. None of these are for local use alone, and involvement of mechanical tools such as harvesters are required to be competitive, and often require non locals.  Restrictions are imposed on agricultural activities under section 4.21 which says “Ongoing agriculture and horticulture practices by local communities along with dairies, dairy farming, aquaculture and fisheries” are permitted only for the use of locals. This will result in reduction of both demand and supply, which will eventually result in widespread loss of livelihood of many. This is a violation of the fundamental right of citizens. It is petitioned not restriction of any kind be placed on agriculture and the governing laws should be normal laws of the land and not forest laws.

5. Bathery is a very heavily populated municipality. Many hospitals, colleges, bus depot, government offices, malls, hotels, movie theaters and shops fall into the proposed ESZ. The restrictions imposed by the proposed ESZ will result in eventual death of the municipality and loss of livelihood of many. A growing municipality requires expansion and hence adjoining areas should also be excluded. It is petitioned that the entire Sulthan Bathery municipality area and adjoining areas should therefore be excluded from ESZ.

6. The ESZ draft notification limits ability for farmers to fell trees. The strict process of obtaining permission makes it impossible for small farmers to fell trees. With the uncertainty and fear of the future, farmers will have no incentive to plant new trees or maintain existing trees. This will result in a tree less ESZ, which will eventually not be beneficial for farmers or the environment. It should be noted that sandalwood tree felling was banned in the past in this area and that resulted in no sandalwood trees now. It is petitioned that no restrictions be placed on felling of trees to encourage farmers to consider trees as an asset to maintain and re-grow.

7. The process of approval to build residences and to renovate existing residences is cumbersome and requires approval by the monitoring committee. Furthermore there are restrictions in wells and solid waste management. This cumbersome process and regulations will make house constructions impractical for locals, and locals will be further separated from their agricultural land. It is petitioned that no restrictions be imposed on building residences and the required infrastructure. 

8. Development, enhancement and maintenance of infrastructure, road and electricity is regulated. This will eventually result in a situation where infrastructure will eventually degrade. It is petitioned that ESZ be restricted only to fringe areas within the forest where no such infrastructure is required in the future. 

9. We do not understand the connection between digging of borewells / open wells by farmers in their own farmland with protection of wild animals. Item no 30 under the restricted list says that ‘open well, bore well, etc. for agriculture or other usage should be regulated and the activity should be strictly monitored by the appropriate authority’.  We don’t understand the logic behind it, and it creates serious doubts in the mind of locals regarding the intentions of the government. 

10. The restrictions proposed with regard to  basic civic amenities like roads, electric cables, communication towers, vehicular traffic at night, digging of wells etc have the potential to make the areas under ESZ uninhabitable in the long run and will force people to go on exile voluntarily. This goes against the very basic principles enshrined in Indian constitution and amount to discrimination based on geography. The people living inside the ESZ have all the legal documents and have been living in the same areas for decades with all proper legal titles and deeds. So, imposing this kind of restrictions on their daily lives is nothing but discrimination based on geography which goes against equality guaranteed under Indian constitution.

11. Declaration of ESZ zone results in an immediate loss of property value and a significant loss of annual income. Yet no compensation of any kind is offered to the property owners falling within the ESZ zone. Since most of the farmers are already net carbon negative, the main beneficiaries are inhabitants of cities who’s per capita carbon emission is very high. It is unfair that the farmers bear the brunt of ESZ with no compensation. It is against natural justice to not offer compensation for farmers and owners of land, when such compensation is offered for other development activities. It is petitioned that a one time compensation and yearly compensation be offered to landowners and farmers who fall within ESZ. 

12. A main issue that causes human animal conflict in wayanad is lack of tree diversity in the forest caused by unscientific cultivation of revenue generating high water consuming trees such as teak and eucalyptus. It is petitioned that the forest be conserved and restored to its natural form so that wild animals have adequate food and water within the forest. 

13. The boundaries of the proposed ESZ are not marked on the ground even after publishing the final notifications. How can people know the exact boundary of the ESZ if it is not marked on the ground? The geo coordinates given in the notifications are not accurate. Only 23 geo coordinates are given to demarcate an area of 54 square kilometres which is completely inadequate. We urge you to release geo coordinates for every 100 metres and the marking of the same on ground so that people know the exact position of boundaries. This must be done before finalising the notification.  

14. The proposed monitoring committee to implement the ESZ guidelines is completely anti-democratic and goes against the principles of participatory forest conservation. The committee has no representatives from the local gram panchayaths or block panchayaths or local population. We request you to add the below members to the monitoring committee in addition to the 9 members currently included.

President of Thuirunelli gram panchayat in Wayanad District

President of Pulpally gram panchayath in Wayanad district

President of Poothady gram panchayath in Wayanad district

President of Noolpuzha gram panchayath in Wayanad district

Chairman of Sulthan Bathery municipality in Wayanad district

Gram panchayath members whose territory falls within the ESZ

Block panchayath members whose territory falls within the ESZ

District panchayath members whose territory falls within the ESZ

Agricultural officers from the respective Krishi bhavans of all panchayaths falling under the proposed ESZ.

The executive powers of the monitoring committee are vested with Wildlife warden, Wayanad wildlife sanctuary. This can lead to complete forest raj and terrorising of locals with the draconian provisions suggested. Therefore, we request you to keep the district collector of Wayanad districts as the executive member in charge of implementing the guidelines in the respective districts.