Save The Western Ghats

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To,
The Secretary,
Ministry of Environment, Forest and Climate Change,
Indira Paryavaran Bhawan, Jorbagh Road,
Ali Ganj, New Delhi-110003
esz-mef@nic.in

Sub: Western Ghats ESA : Request to finalise the 7th DRAFT notification taking into consideration the recommendations submitted.

Dear Sir/Madam,
I am writing regarding the Draft Notification for the Western Ghats Ecologically Sensitive Area dated 27 July 2026.

At a time when the Karnataka Government is opposing the proposed ESA, there is considerable fear and confusion among people about what ESA will actually mean for their homes, land, agriculture and livelihoods. The Karnataka Government has reiterated its opposition to the seventh draft and has said it will submit objections to MoEFCC.

We believe people need access to clear information about what the notification actually says before the ESA is rejected in their name. The current notification and a simple explanation of what is prohibited, regulated and permitted should have been made available in Kannada and other relevant local languages and placed before the Gram Panchayats in the proposed ESA villages.

We have also been trying to understand what the proposed ESA means on the ground. As a start, we spatially mapped the proposed ESA villages in Udupi and Kodagu and looked at them in the context of existing Protected Areas and ESZs, rivers and headwater streams, wildlife corridors and livelihoods.

What we saw reinforces why this protection is important.

In Udupi, many of the headwater streams that feed the district's rivers originate within landscapes proposed as ESA. Protecting these headwaters is therefore also about protecting Udupi's rivers and the water security of people downstream. https://forrivers.life/all-about-esa/esa-analysis-udupi-district/

In Kodagu, many headwater streams within the proposed ESA feed the Cauvery, as well as streams flowing towards the Kumaradhara and rivers of Kerala. These water systems support people within Kodagu and millions beyond the district. https://forrivers.life/all-about-esa/esa-analysis-kodagu-district/

Our mapping also shows that ecologically important landscapes extend beyond existing Protected Area and ESZ boundaries. Many of these villages were also identified as highly ecologically sensitive in the 2018 report by the Expert Committee constituted for assessing the carrying capacity of the Western Ghats in Karnataka based on several factors including streams,waterbodies, rainfall and biodiversity.

In Kodagu, these landscapes also connect important wildlife habitats. Further fragmentation can reduce safe movement routes for elephants and increase encounters with people, putting lives, crops and livelihoods at risk.

Rivers, groundwater, forests, wildlife and people are all connected. Protecting these landscapes is therefore also about protecting people, livelihoods and water security.

We also heard concerns about long-pending Section 4(1) forest notifications and the difficulties these have created around land rights, housing and even basic infrastructure. These are important issues that need to be resolved by the Karnataka Government. But they are existing issues and should not be confused with the proposed ESA restrictions.

People should not have to choose between resolving these long-pending issues and protecting the Western Ghats. The Karnataka Government and the Central Government need to resolve these existing issues separately. But these issues should not be used as a reason to reject the ESA notification, especially when the notification itself clearly states that existing ownership of property and ongoing agriculture and plantation activities will not be affected.

We request MoEFCC to finalise the proposed ESA as a minimum protection framework and consider the following recommendations for strengthening it.

1. Protect the natural flow of Western Ghats rivers
The proposed ESA regulates hydropower projects, but remains silent on pumped-storage, river-diversion and inter-basin transfer projects. All of these clearly  have significant impacts on rivers, forests and catchments.

The 2018 Karnataka Expert Committee had already raised concerns about numerous mini-hydel projects in the Western Ghats including Udupi District and the impacts of altered river flows on hydrology, ecology and biodiversity, extending downstream towards estuaries.

The proposed 2,000 MW Sharavathi Pumped Storage Project shows the scale of concern. It involves a fragile Western Ghats landscape and has raised concerns around forest diversion, tunnelling and construction, habitat fragmentation and cumulative impacts on the Sharavathi river and the endangered Lion Tailed Macaque’s habitat.

In 2019, the Karnataka Western Ghats Task Force recommended that no new river-diversion projects be taken up after Yettinahole in the Western Ghats  and specifically said that proposals such as diversion of Sharavathi waters to Bengaluru should not be allowed.

Rivers cannot be looked at only as water available for power generation or diversion. Altering their natural flows can affect the entire catchment, its biodiversity and the people and ecosystems downstream.

Our recommendation for strengthening the ESA 7th draft notification: No new hydropower, pumped-storage, river-diversion or inter-basin transfer projects in ecologically sensitive Western Ghats river systems, including projects that are proposed, under consideration or at any stage of approval.

Protecting the Western Ghats must also mean protecting its catchments and allowing its rivers to flow naturally.

2. Protect the Western Ghats from further fragmentation by major linear infrastructure
The proposed ESA restricts some large, high-impact activities. But roads, railways and tunnels are not specifically prohibited.

In the Western Ghats, these are not just lines on a map. Cutting across a mountain, widening a road or tunnelling through it can impact forests, wildlife corridors, slopes, streams and the way water moves through a catchment.

What we do above the ground or below it can affect the mountain, the forest, the biodiversity and the water that flows from it.

These are also landslide-prone landscapes. The NRSC Landslide Atlas records 1,094 mapped landslides in Karnataka, including 993 associated with the 2018 event  with the mapping showing a strong concentration along the Western Ghats. Disturbing already fragile slopes can further increase risks to people living in these landscapes.

Our recommendation for strengthening the ESA 7th draft notification: No new major roads, railway lines or tunnels through ecologically sensitive Western Ghats landscapes, including projects that are proposed, under consideration or at any stage of approval.

This should not restrict local village roads needed for access and everyday life, or the repair and maintenance of existing roads. The distinction should be clearly stated in the final notification.

Protecting the Western Ghats must also mean protecting its mountains, forests, catchments, biodiversity and the people who depend on them.

3. Make the 2018 carrying-capacity report public and act on its recommendations

Following directions of the National Green Tribunal in 2016, MoEFCC constituted a multidisciplinary Expert Committee to assess the carrying capacity of the Western Ghats in Karnataka. The Committee submitted its Report of Carrying Capacity of Environmentally Sensitive Areas in the Western Ghats Region of Karnataka in July 2018.

The Committee brought together expertise from the Indian Council of Forestry Research & Education,Salim Ali Centre for Ornithology and Natural History, Indian Institute of Forest Management, Water & Land Management Institute, National Institute of Hydrology, Centre for Ecological Sciences at IISc, Karnataka Biodiversity Board, Department of Tourism, Chief Wildlife Warden, Water Resources Development Organisation and MoEF&CC.

A March 2026 Deccan Herald report states that the Committee assessed the 1,533 ESAs identified by the High-Level Working Group and classified 1,281 villages as very highly sensitive, recommending them as “no go” areas for developmental activities. Importantly, it also reported that the Committee recommended cumulative-impact assessment of more than 26 hydropower projects and their impacts on rivers.

This is an important assessment commissioned by MoEFCC itself, yet the report does not appear to be publicly available and its recommendations do not appear to have been systematically acted upon. Deccan Herald reported in March 2026 that projects had continued to receive approvals without reference to the report.

Our recommendation for strengthening the ESA 7th draft notification: Please make the 2018 carrying-capacity report public, place the action taken on its recommendations in the public domain and ensure that its findings are considered before permitting further projects in the Western Ghats.

We already have an assessment of how much pressure these landscapes can take. It should be made public and used in decisions about what more we allow in the Western Ghats.

4. Put much stronger limits on large construction and land clearing
The proposed ESA restricts new building and construction projects only when the built-up area reaches 20,000 sq m or more.

To understand this scale, Club Mahindra Madikeri has a reported built-up area of about 22,258 sq m. The current threshold is therefore close to the built-up scale of a large resort, not an ordinary home.We are using the resort only as an example to help put the 20,000 sq m threshold in perspective.

These landscapes are already seeing land-use change from resorts, private developments, roads and other construction. And built-up area alone does not tell us how much of the landscape has been altered.

A development can involve clearing native vegetation, cutting slopes, constructing internal roads and parking areas, paving land, extracting groundwater and altering natural drainage, even if the built-up area remains below the threshold.

Our recommendation for strengthening the ESA 7th draft notification: The ESA should limit the size of resorts,commercial tourism projects, gated communities and other large private developments. The current 20,000 sq m threshold is too high for such development in an ecologically sensitive landscape, especially a landscape that has already been degraded.

A lower threshold should apply to these categories  along with limits on how much land can be cleared, paved or otherwise disturbed. Streams, riparian areas, native vegetation, steep slopes and natural drainage should receive specific protection.

Essential public infrastructure such as hospitals, schools and other facilities needed by local communities should be treated separately from large commercial developments, with appropriate environmental safeguards. The Gram Sabha should have an important role in deciding what essential infrastructure the community needs, in keeping with the provisions already included in the ESA notification.

In an ecologically sensitive landscape, we cannot look only at how large the building is. We also need to look at how much land is being cleared and how much the landscape is being changed.

5. Make the official ESA spatial data publicly available
The ESA is fundamentally a spatial notification. Yet it is difficult for a person living in one of the listed villages to understand exactly where the proposed ESA boundary lies and what part of their landscape is included.

For our Udupi and Kodagu analyses, we had to spatially reconstruct the proposed ESA using village lists and other publicly available spatial datasets.

Our recommendation for strengthening the ESA 7th draft notification: MoEFCC should release the official ESA boundaries as downloadable KML and standard GIS formats such as shapefile or GeoJSON, along with the final notification.

MoEFCC should also create a simple public spatial database and interactive map where a person can search for their village and see the official ESA boundary and relevant notification details.

This information should also be made accessible to Gram Panchayats in Kannada and other relevant local languages. If people are expected to understand and respond to a spatial notification, the underlying spatial information should have been made publicly and easily accessible.

6. Make conservation economically meaningful for people
If people living in these landscapes are helping protect forests and water systems that benefit all of us, conservation should also support their livelihoods.

Natural Capital Accounting and Valuation of Ecosystem Services (NCAVES) study by IISC as part of a collaboration between UNEP, United Nations Statistics Division (UNSD), the Ministry of Statistics and Programme Implementation (MoSPI), Government of India and ENVIS Division, The Ministry of Environment Forests and Climate Change (MoEF&CC), Government of India  estimated the value of services from Kodagu's forest and agricultural ecosystems at ₹14,460 crore in 2019. ₹12,892 crore i.e  more than 89% came from forests alone. For Udupi district, the estimated value was around ₹14,700 crore, with ₹12,300 crore i.e, more than 80% coming from forests.

This is not money that people receive. It is an estimate of the value of benefits these landscapes provide through water, groundwater recharge, soil protection, carbon storage and other ecosystem services.

This is also not a new recommendation. The Kasturirangan High Level Working Group specifically recommended arrangements for Payment for Ecosystem Services in both ESA and non-ESA regions of the Western Ghats. It also proposed financial mechanisms to support states and local communities for protecting these natural resources. The question of financial incentives has also been brought up in MoEFCC's previous deliberations with the state governments on the Western Ghats ESA.

Our recommendation for strengthening the ESA 7th draft notification: Please take this forward in the final notification and create a clear mechanism for financial incentives and Payment for Ecosystem Services (PES).

People and communities protecting native trees, forests, headwater streams, riparian areas and other natural ecosystems should be supported for the ecosystem services these landscapes provide far beyond their boundaries. If these landscapes provide benefits to millions of people, some of that value should flow back to the people who protect them.

7. Ensure ESA villages are not economically isolated

The 2018 report by the Expert Committee constituted for assessing the carrying capacity of the Western Ghats in Karnataka recognised the risk of economic disparities between ESA and neighbouring non-ESA villages and recommended economic clustering, preferably within the same panchayat.
Our recommendation for strengthening the ESA 7th draft notification: Include this approach in the ESA framework with focused investment in healthcare, education, essential services and livelihood opportunities compatible with the ecological sensitivity of these landscapes.

This approach can also support stronger limits on large construction within ESA areas. Essential facilities such as hospitals, schools and other services do not all have to be located within the ESA itself. Planning ESA and neighbouring non-ESA villages together can help provide these services within accessible clusters, while reducing the pressure for large construction within ecologically sensitive areas.

Protecting ESA villages should not mean isolating them from essential services or economic opportunities. We need to plan these landscapes and neighbouring settlements together.

Our additional requests to MoEFCC:
At a time when the Karnataka Government is opposing the proposed ESA, we believe it is particularly important that people living in these landscapes have access to clear information and can understand for themselves what is actually being proposed.

We request MoEFCC to make the current notification and a simple explanation of its provisions available in Kannada and other relevant local languages and ensure that these reach the affected Gram Panchayats.

We also request MoEFCC to release the official KML/GIS data and a publicly accessible spatial database and map, so that people can clearly understand the proposed boundaries and how their villages are included. We are not suggesting that the finalisation of the ESA should wait for the creation of these resources. These can be released alongside the process and should not become another reason for delay.

There is also an important issue around how the objections and suggestions received during this consultation are considered. While the Karnataka Government has rejected the proposed ESA, there are also many concerned citizens, researchers and organisations in Karnataka who believe that the Western Ghats need this minimum protection, while asking for the notification to be strengthened. Many of us are using the current objection and suggestion period to submit these views to MoEFCC.

We therefore request that the position of the State Government is not taken as representing all the views from Karnataka.

There are different voices from Karnataka. While the State Government has chosen to reject the ESA, there are also many of us asking for it to be finalised and strengthened. We request that these voices also form part of the record and the decision-making process.

Most importantly, we request MoEFCC to complete this consultation and finalise the Western Ghats ESA as soon as possible. The current draft should not be allowed to remain pending until the end of the 545-day statutory period or lapse and lead to yet another draft notification.

After more than a decade of draft notifications, we request MoEFCC not to delay this protection any further. Please finalise the ESA at the earliest and consider the recommendations being submitted through this consultation for strengthening it.

Our analysis of just Udupi and Kodagu shows why this protection matters. These are not isolated patches of forest. They are headwaters, river catchments, wildlife habitats and landscapes that support farming and livelihoods, while providing water and other benefits to millions of people beyond these landscapes.

Protecting the Western Ghats is also about protecting people and water security.

Sincerely,

#SaveTheWesternGhats

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