Ministry of Environment and Forests · NBWL

“We want a robust National Board for Wildlife”: Submission from several organisations and individuals

4 August 2014


  • Shri. Narendra Modi,

Prime Minister of India and Chairperson, National Board for Wildlife

  • Shri. Prakash Javadekar,

Minister of State of Environment, Forests and Climate Change (IC) and

Chairperson, Standing Committee, National Board for Wildlife

  • Shri. V. Rajagopalan,

Secretary, Ministry of Environment, Forests and Climate Change

  • Shri. S. S. Garbyal,

Director General of Forests and Special Secretary,

Ministry of Environment, Forests and Climate Change

Subject: Request to urgently amend the flawed constitution of the National Board for Wildlife (NBWL) as indicated in Notification issued by MoEF dated 22 July 2014 & not hold any meetings based on this flawed notification.

Respected Prime Minister, Hon. Minister and Sirs,

It is with great concern that we write to you about the constitution of the new NBWL as indicated in the Government Notification dated 22ndJuly 2014.

The term of the previous NBWL and its standing committee ended in Sept 2013, as was noted by the then chairperson of the standing committee and recorded in the minutes of the latest (Sept 2013) meeting of the standing committee (see: “At the outset, Hon’ble Chairperson while welcoming all participants to the 30th Meeting of Standing Committee of NBWL expressed deep appreciation of the contribution of the non-official members in the meetings of the Standing Committee of NBWL and their selfless dedication for the cause of conservation. She added that the present term of NBWL was coming to an end on 5th September 2013 and that the discussions and deliberations made by the present members during the Standing Committee of NBWL meetings had helped the Chair in taking judicious decisions.” (Emphasis added.)

So country was without NBWL and standing committee for more than the ast ten months and the country expected that the government would constitute a proper NBWL honouring the letter and spirit of the Wildlife Protection Act and the need to protect wildlife and biodiversity in protected areas. The concerned people of the country stand disappointed by the July 22, 2014 notification.

At the outset, the Notification dated 22 July 2014 is ambiguous about the constitution of the NBWL and its Standing Committee. It is not even available on MoEF website.  The notification seems to be in violation of the Wildlife Protection Act in letter and spirit and is not in the interest of the wildlife, biodiversity or protected areas in the country. A comparative reading of Sept 2003, May 2007 and Sept 2010 notifications of the MoEF about constituting NBWL further strengthen this view.

The notification only mentions a small subset of the NBWL members as listed in the Wildlife (Protection) Amendment Act, 2002. The limited list  is in violation of the Wildlife (Protection) Act, 1972 and its subsequent amendment in 2002 by way of the Wildlife (Protection) Amendment Act, 2002. The Director General of Forests is on record having said that this is the entire NBWL. (Please see: This confirms the illegality of the notification.

We would respectfully like to submit that a notification issued by the government cannot override or violate an Act passed by the Parliament, with the ascent of the Hon. President of the Union of India.

Main points of divergence between Wildlife (Protection)Amendment Act, 2002 and the Notification issued on 22nd July, 2014 are as follows:

  1. Clause (e) of the Wildlife Protection Amendment Act, 2002 states:

“(e) five persons to represent non-governmental organisations to be nominated by the Central Government”

However, the Notification dated 22 July 2014 does not nominate any NGO. The only name notification gives for NGO member, namely GEER is not an NGO.

The nominated “Gujarat Ecological Education and Research (GEER) Foundation, Gandhinagar, Gujarat” is a Gujarat Government organisation and not an NGO. Its website is, says, it has been set up in 1982 by the Forests & Environment Department, Government of Gujarat” and the Chairperson of its board is Chief Minister of Gujarat while majority board members too are from Gujarat Government. Thus GEER stands disqualified from being nominated as an NGO.

  1. Clause (f) of the Wildlife (Protection) Amendment Act, 2002 states:

“(f) ten persons to be nominated by the Central Government from amongst eminent conservationists, ecologists and environmentalists”

However, the notification dated 22 July 2014 replaces this by just two people.

“(i) Prof. Raman Sukumar,

(ii) Dr. H.S. Singh.”

  1. Clause (v) of the Wildlife (Protection) Amendment Act, 2002 states:

“v) one representative each from ten States and Union territories by rotation, to be nominated by the Central Government”

However, the notification dated 22 July 2014 replaces this with just five states.

In view of the above, the notification dated 22 July 2014 violates Wildlife (Protection) Amendment Act 2002 and should be urgently taken back. Any meetings or any decisions taken by this board will not stand legal scrutiny.

Apart from the legal issue, it is important for a board like NBWL to have a broader regional representation of independent experts, NGOs and members and this was one of the the objectives behind  nominating these members on the NBWL and its standing committee. We hope that the government will appreciate this issue. Indian Wildlife, biodiversity and its habitat like the protected areas, forests, rivers, wetlands, etc., are under tremendous pressure and we hope the new government is committed to conserve our rich wildlife heritage.

We therefore look forward to urgent action on the points mentioned above by immediately taking back the 22nd July 2014 Notification and replacing it with a notification that spells out constitution of NBWL respecting the WLPA in letter and spirit and also respecting India’s wildlife and its dwindling habitat. We hope that no meetings of the NBWL happen before a correct constitution of the board.

Looking forward to your response on the points raised above.

 Yours sincerely,

  1. No.
Name/ Organisation Location  
 1. Kalpavriksh Environment Action Group Pune
 2. Dr. Bhaskar Acharya, Researcher, Bangalore Bangalore
 3. Dr. Sunil K. Choudhary University Dept. of BotanyT.M.Bhagalpur UniversityBhagalpur-812007, India
 4. Dr. Rajeev Raghavan South Asia Co-Chair, IUCN SSC/WI Freshwater Fish Specialist GroupMember, IUCN SSC Red List CommitteeMember, IUCN WCPA/SSC Joint Task Force on Biodiversity and Protected Areas
 5. Shripad Dharmadhikary Pune
 6. Himanshu Thakkar, SANDRP 86-D, AD block, Shalimar Bagh, Delhi, 09968242798 Delhi
 7. Lyla Bavadam
 8. Ranjana Pal
 9. Dr. Latha Anantha, River Research Centre, Kerala
 10. Cara Tejpal, Conservationist Delhi
 11. Girish A. Punjabi, Researcher, Pune
 12. Nachiket Kelkar, Ecologist Bangalore
 13. Shardul Bajikar, Ecologist, Mumbai Mumbai
 14. Adv. Indavi Tulpule Murbad, Thane
 15. Anand Arya Delhi
 16. Vijay Diwan, Aurangabad Social Forum Aurangabad
 17. Manshi Asher, Himdhara, Himachal Pradesh,
 18. Jitn Yumnam, Citizens Concern for Dams and Development, Committee on the Protection of Natural Resources in Manipur, Centre for Research and Advocacy Imphal, Manipur
 19. Samir Mehta, River Basin Friends Mumbai
 20. Bharat Seth, International Rivers Delhi
 21. Joy KJ, SOPPECOM Pune
 22. Deepali Nandwani
 23.  Ravi, Namita and Medha Potluri.
 24. Jagdeep Chhokar
 25. Nitu.S
 26. Munish Kaushik
 27. Ramanathan Sriram
 28. Soma Jha
 29. Dr. V K Gupta
 30. Sabyasachi Patra
 31. Manoj Gupta
 32. Sarita Kumar
 33. Dipu Karuthedathu,Member BNHS, Co-Moderator of keralabirder egroups 301, Jaya Emerald, Maruthinagar, Bangalore
 34. Aditya Panda Naturalist | Wildlife Conservationist | Photographer Bhubaneswar
 35. Virat Jolli
 36. Santanu ChacravertiDISHA Kolkata
 37. Smita Pradhan
 38. Amrita Neelakantan
 39. Pranav Capila
 40. Bipasha Majumder
 41. Anurag Sharma
 42. Anubhuti Sharma
 43. Jl Singh
 44. Vandana Singh
 45. Sumit Dookia
 46. Nikhil Devasar
 47. Jassal J S
 48. Jaikant Saini Bharatpur,Rajasthan
 49. Ranjan Panda, Water Initiatives, Odisha Sambalpur, Odisha
 50. Parineeta Dandekar, SANDRP, 09860030742 Pune

Additional endorsements:

51. Dr. Sudhirendar Sharma, Delhi

52. Rohit Prajapati, Prayavaran Suraksha Samiti, Gujarat

53. Dr. Jagdish Krishnaswamy, Landscape Ecologist, Bangalore

54. Goa Foundation, Goa

55. Mhadei Research Centre, Goa

56. Shankar Sharma, Karnataka

57. Sahil Nijhawan, Delhi

58. C. Udayshankar, Andhra Pradesh

59. M.D. Khattar

60. Kaustuv Chatterjee

61. Shri Santosh Martin, ex-honorary wildlife warden, Bellary district, UP

62. Ms. Carmen Miranda, Chair, Save Goa Campaign UK, London

63. Nandikesh Sivalingam, GreenPeace India





Sewage Management of Nagpur: The story & the sub-stories

MSPGCL (Maharashtra State Power Generation Corporation Ltd) has signed a Memorandum of Understanding (MoU) with Nagpur Municipal Corporation (NMC) to supply treated water from municipal sewage plant as the water linkage to meet additional demand of MSPGCL’s proposed expansion plan. MSPGCL has agreed to pay NMC Rs 150 million (15 crores) every year for the next 15 years as royalty fee. MSPGCL has two existing thermal power plants (TPP) near Nagpur City. One of the TPP is 840 MW capacity at Khaperkheda, and the other is of 1100 MW is at Koradi. MSPGCL has planned for three new power units – one at Khaperkheda and two at Koradi, each with 660 MW capacity. MSPGCL has also agreed to construct a new sewage treatment plant with tertiary treatment capability with the capacity to pump the treated water to its thermal power stations.

Koradi Thermal Power Plant

Reusing treated sewage water for thermal power project is a welcome move. However it cannot be seen in isolation. Overall performance of MSPGL and NMC in terms of use of water as a resource and treatment has also to be looked at. Putting together several pieces of information reveals that there is a lot more to this decision. As far as sewage treatment of Nagpur is concerned, NMC is opting for public private participation through sewage treatment. There are layers of irregularities to this decision as well.

Given below is a quick overview of happenings.

MSPGCL opts for treated sewage due to rejection of fresh water allocation for the TPP from Pench River[i]: MSPGCL had the existing allocation from Pench River for 55 Million m3/ year. With the addition of three new power units, MSPGCL was looking for additional water requirement of 58 Mm3/ year starting in 2015, when the new power plants come online.

Following a request from MSPGCL, the Irrigation department of Government of Maharashtra, increased the water allocation from 55 to 67 Mm3/year with a maximum use of 75 Mm3/year within 10 percent variation. However, this was projected to be insufficient for all three units, and there was no additional freshwater allocation available for MSPGCL from any other source.

Idea of using treated sewage water as a water linkage for TPP stemmed from the concept of NEXUS[ii]. NEXUS is a concept and an approach that aims to boost potential to increase overall resource use efficiency and benefits in production and consumption by addressing externalities across sectors.

To resolve the issue of water availability for MSPGCL, USAID, through its project titled Water Energy NEXUS Phase – II (WENEXA – Phase II), initiated a feasibility study that included demand assessment and evaluation of alternate water sources. The study assessed feasibility of use of high quality tertiary treated water from the city of Nagpur’s wastewater plant. WENEXA – Phase II project also implemented a six month long pilot plant to showcase achievable output water quality and get buy-in from both NMC as well as MSPGCL that reuse is effective and feasible.

MoU between MSPGCL and NMC has been signed in year 2009 based on results of this study, pilot plant data and the potential for getting good quality reclaimed water in short period of time. Based on this agreement, NMC being a municipality, approached the central Government and received a grant for a sum of Rs 800 million towards the project under the Jawaharlal Nehru National Urban Renewal Mission (JNNURM), while the remainder of the cost Rs 1200 million to be borne by MSPGCL.

NMC officials said that STP work had started in March 2012 and was expected to be completed by March 2014. The plant is 50% complete. The pipeline from the STP to the two thermal power units is also half complete. Trial run will take place in 2014 or early 2015[iii].

The centre on December 22, 2006 approved the STP project with installed capacity to treat 135 million liters per day (MLD) sewage water at a cost of Rs 130.11 crore.

Due to delay and other reasons the project’s cost increased to Rs 195 crore during work order stage[iv].

NMC’s monthly progress report on JNNURM projects says 56% of the works have been completed. Expenditure on the project comes to Rs 95.76 crore as of January 31 (2014). The centre approved Rs 26.02 crore, and state had released Rs 10.40 crore as on January 31. NMC and MSPGCL had contributed Rs 50.80 crore.

MSPGCL polluting river Kanhan Here is it relevant to note that MSPGCL is discharging untreated effluent from Khaparkheda and Koradi power plants into Kanhan River containing toxic fly-ash. NMC draws this water at its 240 MLD water treatment plant (WTP) and supplies it to the almost 40% of the city, mostly North and East Nagpur.

Print media report of January 2013[v] states that the discharge spot is near Sillewada village that is located near the 500 MW unit of Khaparkheda plant. Sillewada is not located along any major road and only locals know about its existence. Moreover, the discharge spot has to be reached on foot through bushes.

Map Koradi TPP

The report also states that water of the river is highly polluted with poisonous substances like lead, arsenic, mercury and heavy metals that cause a host of ailments including cancer. MSPGCL uses coal having 50% fly ash against maximum permissible limit of 34%. The electrostatic precipitator and bag filters of Koradi plant are not functioning. MPCB has not taken any action against MSPGCL for blatant violation of norms.

Kanhan River

MSPGCL’s expansion plan for the 36-year-old Koradi plant was given environmental clearance on January 4, 2010[vi] against condition of installing Flue Gas Desulphurisation (FGD). While considering the request of MSPGCL to review the condition regarding installation of FGD system was considered by Expert Appraisal Committee (EAC) in its 54th meeting on August 6-7, 2012, the Committee noted that the data submitted by MSPGCL appeared to be inadequate and inconclusive.

The EAC also noted that there were several complaints of fly ash management for Koradi Plant. That a PIL was pending in the Nagpur Bench of the High Court of Bombay was purportedly with respect to hazards of fly ash from power plants run by MSPGCL including the Koradi plant[vii].

NMC plans a barrage at polluted River Kanhan for drinking water supply NMC plans to construct a barrage at the confluence of Kanhan and Kolara rivers[viii]. The project aims to increase water supply from Kanhan water treatment plant, which would benefit East, North and few parts of South Nagpur. NMC had constructed water treatment plant with installed capacity to treat 240 MLD water. However, the plant cannot function to full capacity due to shortage of raw water from Kanhan River.

A proposal has been tabled before the standing committee seeking approval for Rs 1.82 crore for the construction of barrage[ix]. The standing committee was set to give its nod in the meeting organized on July 14, 2014.

Sewage treatment for Nagpur The city of Nagpur is generating over 450 MLD sewage daily of which NMC is presently treating only 80 MLD[x]. (Details of water supply and sources of water provided in Annexure I)

NMC is operating sewage treatment plant (STP) with an installed capacity of 100 MLD at Bhandewadi and treats 80 MLD water at the STP since 2001. The total cost of treating water comes to around Rs 3 crore per year. In these ten years, NMC has let treated sewage water flow in untreated sewage water of Nag River. Remaining untreated sewage flows into the Nag, Pilli and Pora rivers. The untreated sewage from Nag River flows into Kanhan river, then Wainganga river and finally into Gosikhurd dam.

Bhandewadi Sewage Treatment Plant

NMC has plans to earn additional revenue of Rs 25-30 crore per year from treated sewage water. Now NMC has decided to enhance STP capacity to 200 MLD on PPP model. The private operator will enhance the plant capacity followed by operation and maintenance on his own. The operator will sell this water to the interested parties like industries).

PPP project for NMC’s own STP started before JNNURM approval On 27 Sep 2013, the NMC standing committee approved a proposal to construct a sewage treatment plant (STP) on public-private partnership (PPP) basis. It issued a work order to a joint venture of private companies -Vishwaraj Infrastructure Limited (VIL), Drake & Scull Water and Power LLC, and Vasundhara Drills and Drainage Private Limited.

The project is a part of the sewage system plan submitted to the central government under JNNURM scheme. Interestingly the work order has been issued even before the plan has received a nod from the centre. The tendering process for this project started in September 2010. However, the JNNURM plan was submitted to the centre only in February 2013[xi]. Also there is a difference of around Rs 400 crore in the operation and maintenance cost of NMC and the operator awarded tender.

Strong political linkages in PPP projects Media reports that Vishwaraj Infrastructure Ltd. is believed to have strong political linkages with the ruling party[xii]. VIL is also involved in the PPP contract for water supply of Nagpur city. Concession agreement for the water supply PPP has also been signed with a consortium of VIL and Veolia Water India Ltd[xiii].

Selective application of NEXUS and PPP for Sewage Treatment On one hand though MSPGCL is taking waste water for water linkage of TPP, on the other hand it is severely polluting Kanhan River. It only shows that concept of NEXUS has been adopted selectively and not holistically. Moreover the trigger for using waste water is actually the rejection of more fresh water allocation from Pench River by WRD. Releasing polluted water to the river is in clear contradiction with the NEXUS concept which talks about catering to the externalities across the sector. Both NMC and MSPGCL have adopted the concept of NEXUS only to ensure monetary gains. The link goes further and the Kanhan River water made toxic by MSPGCL plants is set to be supplied for the people of Nagpur city.

While reuse of treated sewage by thermal power plant is welcome, in this case, it is being done only after the plant failed to get freshwater supply in the first place. The proposal is still a welcome move. However, when we take the full picture into account we see that the same thermal power project is polluting city’s water supply. PPP for sewage treatment seems to be adopted more to serve political links than the needs of the city. The project is being pushed even before it gets requisite sanctions.

We had earlier written about the reality of the 24X7 water supply claims vs reality in the same city of Nagpur. One thing that clearly comes across the two articles is that in India’s Urban Water Sector, as can be seen from Nagpur example, there is no drive to achieve greater democracy, or greater transparency, accountability and participation. Till such inclusive management is achieved, no amount of new ideas, finances, technologies, infrastructure or partnerships is going to help.

Amruta Pradhan

Annexure I

Present water sources for Nagpur Present Annual Raw Water reservation from various sources for city water supply & respective present drawal is as below:


Source: DPR of ‘24×7 Water Supply Project for Nagpur City’
Source Annual Reservation Actual Drawal
Mm3/year MLD Mm3/year MLD
Kanhan River 55.00 150.70 43.80 120.00
Pench Project (Pench Right Bank Canal) 112.00 306.88 143.00 400.00
78.00 213.72
Gorewada Lake 5.80 16 6.80 20.00
Total 250.80 687.30 217.60 540.00


As per billing by Irrigation department to NMC. Losses through Canal seepage in the length of 48.50 Km length of travel is @ 20-25% as per the observation of Water audit & Leak detection Study.


Present Treated Water Supply from Various WTPs is as follows-

Source: DPR of ‘24×7 Water Supply Project for Nagpur City’
WTP Capacity
Kanhan Water Works 120.00 MLD
Pench Phase I 136.00 MLD
Pench Phase II 140.00 MLD
Pench Phase III, Stage I 100.00 MLD to 120.00 MLD
Old Gorewada 16.00   MLD
  1. 00 to 530.00 MLD




[ii] It aims to reduce trade-offs and generate additional benefits to outweigh the transaction costs associated with stronger integration across sectors. NEXUS focuses on cross-sectoral management that boosts overall resource use efficiency. Turning waste and by-products into a resource for other products and services like waste energy integration is one of the most important focus areas.