To, 

Shri Eknath Shinde, 

Hon' Chief Minister, Maharashtra

To,

Mr Abhijit Bangar, 

Municipal Commissioner, 

Thane Municipal Corporation

We, the concerned citizens of Thane, bring to your attention the alarming degradation of our city's lakes due to the Thane Municipal Corporation's Restoration and Beautification Project under Amrut 2.0. This initiative, aimed at rejuvenating water bodies, is paradoxically causing irreversible harm to Thane's ecological treasures.

The ongoing restoration work, with a staggering cost exceeding 50 crores, is progressing at an alarming pace, particularly at Railadevi Lake and Upvan/Pokhran Lake. Our primary concerns are outlined below:

1.      Debris Dumping:

Construction debris is being indiscriminately dumped into Upvan and Railadevi Lakes, obstructing freshwater inlets and potentially contaminating groundwater sources.

Altering the natural slope of the lakes, especially in the case of Railadevi Lake, threatens critical habitats for turtles and other aquatic life.

 

 

 

 

2.      Reduction of Lake Size/Flood Mitigation Capacity:

Encroachment on Railadevi and Upvan Lakes diminishes their size and subsequently reduces water-holding capacity, escalating the risk of flooding in Thane.

 

 

3.      Tree Destruction:

We fear that numerous native trees have been felled or heavily pruned at both Upvan and Railadevi Lakes, compromising the ecological balance and biodiversity crucial to the lake ecosystem.

Tree basins covered with debris violate the Tree Act and contradict TMC's commitment to the Bombay High Court for deconcretizing trees in the city.

 

 

 

 

 

4.      Improper De-Siltation:

Unscientific de-siltation using JCBs without expert involvement has led to the tragic loss of soft-shell turtles, exotic tortoises, and countless fish struggling for survival.

 

 

5.      Absence of Scientific Studies:

TMC's lack of a scientific/ecological study to understand the existing flora and fauna hampers the restoration work's effectiveness.

6.      Threat to Aquifers:

The absence of aquifer mapping beneath Thane's lakes poses a severe threat to groundwater, necessitating a thorough study and publication of relevant data by TMC.

7.      Impact on Urban Heat Island Effect:

Disruption of water bodies through concretization jeopardizes their role in mitigating the urban heat island effect, a critical factor in the age of global warming.

In addition to the above concerns, the project is gravely violating The Urban Flood Management Guidelines of September 2010 and the National Disaster Management Guidelines of September 2017, which explicitly state:

i) "No building or development activity should be allowed in the bed of water bodies like rivers, nallahs, stormwater drains, and the Full Tank Level (FTL) of any lake, pond, tank, or pond/tank bed lands.

ii) The above water bodies and courses shall be maintained as recreational/Green buffer zone and no building activity other than recreational use shall be carried out within:

a.) 30 m from the boundary of lakes of area less than 10 Ha/ponds/tank bed lands."

Additionally, The Indicative Guidelines for Restoration of Water Bodies from June 2019 highlight:

a.) The importance of maintaining a buffer zone around lakes and ponds, with a periphery of at least 50 to 100 meters, as a green belt or a no-activity zone.

b.) Within this buffer zone, no impervious cover should be allowed, and it should mainly consist of plantations with a dense population of deeply rooted plants, trees, shrubs, and grasses to absorb nutrients that may be introduced from anthropogenic activities.

It is observed that in clear violation of the above guidelines, there has been ongoing construction activities in the mentioned green buffer zone of the lake, which serves no recreational use other than to prepare the ground for the eventual construction of a structure surrounding the lake's edge.

Our demands:

a. We urgently appeal to you to issue a stop-work order and establish an expert committee comprising geologists, hydrologists, botanists, wildlife experts, and other relevant professionals. 

b. This committee should meticulously review the project, ensuring alignment with the actual objectives of the Amrut scheme. Thane's lakes are not only ecological assets but also integral to our cultural identity, and their preservation is paramount.

c. Take the citizens' view into consideration and implement the restoration project with nature-based solutions and a democratic approach. 

Thank you for your prompt attention to this matter.

Sincerely,

Concerned Citizens
(anchored by Muse Foundation)