Problem statement:

Expert Committee for Eco-sensitive Zones (of Ministry of Environment and Forests) has recommended re-notification of eco-sensitive zone (ESZ) for Kasu Brahmananda Reddy (KBR) Park, in Hyderabad, Telangana, based on the proposal of State Forest Department, reducing it from a minimum of 25 metres of available open area to a range of 3 to 29.8 metres. (Ref: http://www.moef.gov.in/sites/default/files/kesu%20brahmananda.pdf)

This proposal for a drastic reduction, of already shrunk ESZ, is a step that completely negates the objectives and principles of ESZ. This revised proposal of a zone ranging from 3 metres to 29.8 metres does not reflect the actual condition and status of KBR Park, and goes against the very concerns stated in the opening lines of the draft notification. This revised proposal is primarily to help in allowing construction of multi-level flyovers, namely Strategic Road Development Programme, which would destroy the very existence of the Park.

In the past, a ring road around the Park also encroached into the Park area, reducing the extent of walk-way, which acts as an existing ESZ. This is the second such road project pushing for land immediately surrounding the park boundary. It appears government in general, Forest Department in particular, is treating this as a land bank to release periodically for commercial exploitation, not as a land of ecological and environmental importance.

Objections to Draft Notification:

1. The draft notification seems insensitive to the current extent of open area around the KBR National Park is just 25 to 35 meters, which is just 0.3% of the recommended ESZ of 10 km. It is appalling that the draft notification, instead of attempting to extend this boundary by placing restrictions on human activity is recommending reducing it to near zero.
2. The draft notification has been put into a standard template and is completely ignorant of the locale of the KBR National Park as specified in the opening line of the draft notification that “is located in a densely populated residential and commercial area”. As such, paragraphs 2(5) through 2(9), 3(1-c) through 3(1-e) , 3(2), 3(3) and many more have no relevance.
3. Noise pollution and particulate matter settling inside the KBR National Park are already an issue. Provisions in paragraphs 3(6) and 3(7) make this draft notification void in light of the State Governments plans to construct multi-level flyovers almost stooping inside the National Park itself from all directions.
4. It is common knowledge that construction of flyovers results in increasing vehicular traffic, hence increased traffic congestion and vehicular pollution. The draft notification by way of paragraph 3(14) and 3(15) pretends to be unknowing of this fact and puts the onus on regulations, officers and institutions which have limited authority and susceptible to Government influence.
5. Paragraph 4, item 11 clearly indicates that new commercial construction shall not be permitted up to 1 km or up to extent of ESZ whichever is nearer. Hence, the only intent of this draft notification, specifying an ESZ that is smaller than the current open space available around the KBR National park is to bypass the rules set forth by MoEF (for protection of flora, fauna, and the ecology, thereby protecting human life itself) that prevent construction of multi-level flyovers around the KBR National Park.
6. The entire local community (Hyderabad) has been protesting regarding the new proposal for over three years and the State has chosen to ignore the same. Sufficient evidence by way of photographs, newspaper clippings and videos can be found in the Gallery section of www.SaveKBR.com facebook page “Citizens for Hyderabad”, and facebook group “Hyderabad Rising”. The MOEF cannot ignore the sentiments of people and expert opinions on how this draft notification reducing the extent of ESZ and also the plan for constructing multi-level flyovers encircling the KBR National Park are detrimental to the very problems they intend to solve.
7. Thus, the proposal in draft-notification is completely unscientific and irrational. It is as good as having no zone at all. The Committee seems to have erroneously proposed ‘zero zone’ for KBR Park, completely negating its mandate.

 Solution:

• Committee should examine how meaningful this almost zero zone would be. Eco-sensitive zone, around KBR Park, should be at least 1 km to have meaningful conservation of this national park.
• This draft-notification has to be amended taking into consideration the specific circumstances of the KBR National Park, understanding the poor assessment of the State Government in sending such proposals, and the objections raised in this petition.
• The Committee should insist on the State Government to explore real and sustainable alternatives to overcome the traffic problems in the city, such as improving transit facilities, promoting bicycling and walking, and restrict vehicular movement – all of which do not need encroaching upon the already very limited open space that exists around the KBR National Park.