To, The Chief Minister, Government of Telangana Praja Bhavan, Hyderabad E-mail: [email protected] | To, The Minister, Ministry of Environment, Forests and Climate Change (MoEF & CC) Indira Paryavaran Bhawan, Jor Bagh Road, New Delhi – 110003 E-mail: [email protected] , [email protected] |
Sub: – Appeal not to proceed with the proposed VLF Radar Station in Damagundam Reserve Forest, Vikarabad District, Telangana jeopardizing ecology – Project inauguration and work without due process, necessary approvals, Public Disclosure of Environmental Impact Assessment (EIA) Report and Conduct of Public Hearing is undemocratic – Reg
Sirs,
We are writing on behalf of an independent people’s campaign called Damagundam Adavi Parirakshana Vedika (Save Damagundam Forests Forum, Telangana) committed to the protection of ecologically sensitive areas in the state, in particular the pristine Ananthagiri Hills, which is home to the Damagundam Reserve Forests.
We would like to express our serious concerns regarding the proposed “Project AMBER” Very Low Frequency (VLF) radar station by the Eastern Naval Command (Indian Navy) within the Damagundam Forest Reserve, over 2,900 acres, for which environmental clearance and forest clearance is supposed to have been accorded by the Union Environment Ministry way back in 2016 and 2017. The Project is slated to be officially inaugurated on 15th Oct, 2024.
As is well-known, the Damagundam Reserve Forest is a vital ecological zone, home to diverse flora, fauna and an essential buffer for flood control in the Hyderabad region. We have noted with great concern that the Environmental Impact Assessment (EIA) Report of the said Project has not been made public, citing reasons related to “national security.” While we fully understand the security needs of our nation, the lack of democratic process and absence of transparency and accountability to the people regarding the environmental impacts of this project raises significant questions that must be addressed through open public scrutiny. We would, therefore, urge the following:
1. Public Disclosure of the EIA Report: Public disclosure of the EIA is critical for assessing the potential environmental and social impacts, particularly in terms of forest degradation, biodiversity loss, groundwater capacity, and the likely impacts on flora, fauns, water bodies as well as local communities who depend on the forest for their livelihoods. We therefore request that the Environmental Impact Assessment (EIA) for the VLF radar project be made publicly available, in English and Telugu, in accordance with the spirit of the Right to Information Act, 2005, and the EIA Notification, 2006, notwithstanding the ‘exemption clause’, therein.
Furthermore, there is significant inconsistency in the publicly available information regarding the number of trees to be felled for the project. While Captain GM Rao, officer-in-charge of project implementation and management team states that only 899[1] trees would be cut, the Principal Chief Conservator of Forests (PCCF) provided a drastically higher figure of 1,93,562[2] trees. These conflicting numbers were announced within a week of each other, raising concerns about the transparency and accuracy of the data being presented. Such discrepancies only emphasize the need for clear and reliable information to be made public.
2. Requirement for a Public Hearing: The decision to bypass the public hearing requirement, claiming exemption under the Section 7, III Stage (3) 1 (f) of the EIA Notification, 2006, by citing ‘national security concerns’, does not reflect a democratic approach. Public hearings are an essential part of the environmental review process, ensuring that all stakeholders, including local communities, environmental groups, and scientific experts, have the opportunity to voice their concerns and provide crucial input. We are also given to understand that the High Court of Telangana in WP No. 44/2020 has in multiple interim orders, referred to this as an Extremely Low Frequency (ELF) radar technology project, instead of Very Low Frequency (VLF) radar station, as has been proposed by the Project authorities and cleared by MoEF & CC. This is a matter of serious concern, as ELF radar poses considerably more severe risks to the environment and public health due to its hazardous electromagnetic radiation. This calls for an urgent public hearing to clarify the nature of technology involved (whether ELF or VLF and what that would further entail) and address the environmental issues. The absence of a public hearing not only denies stakeholders the opportunity to scrutinize the project but also perpetuates the misinformation regarding the radar technology and its potential environmental impacts.
3. Absence of Valid Approvals & Due Processes: We are given to understand that the Consent to Establish (CTE) the said Navy Radar Project (under Red Category) issued by the Telangana State Pollution Control Board (TSPCB), with a 5-year validity on 20-1-2017, expired on 20-1-2022. Thus, there can be no ground to inaugurate or commence the Project in the absence of CTE or its extension beyond 20-1-2022. Project inauguration and project work in the absence of valid approvals would also amount to contempt of the orders of the Telangana High Court in WP (PIL) No. 44/2020. There is a need to critically review all the conditions in the clearances granted previously and status of their compliance on the ground; also in the light of the Forest Rights Act, 2006, Biological Diversity Act, 2002 and Telangana Rules, 2015 etc. Likewise, the actual extant of endowment land within the reserve forest needs to be ascertained, as per original land records and diversion of the same in violation of law and previous orders of High Court needs to be reviewed.
4. National Security vs. Environmental Transparency: While national security is considered essential, it should not come at the expense of environmental transparency. Countries like the United States, through the National Environmental Policy Act (NEPA), ensure that even military projects undergo environmental assessments with public input, as seen with radar systems. Australia’s VLF radar project in Exmouth followed a similar approach with open public consultations, proving that transparency and security can coexist. India can adopt these best practices, ensuring accountability without compromising national interests. This precedent demonstrates that India, too, can find a way to maintain national security while upholding its commitment to environmental transparency, accountability to the people and democracy.
5. Ecological Significance of the Damagundam Reserve Forest: Damagundam Reserve Forest, along with Ananthagiri Hills and surrounding forests in Vikarabad, plays an integral role in flood control for the Musi River Basin and nearby areas. This network of forests protects Himayat Sagar and Osman Sagar reservoirs, vital infrastructure established after the devastating Musi River floods (1908) to shield Hyderabad from similar disasters. The health of these forests is critical to the natural water cycle in the region. The forested soil, when well-maintained, allows for proper water percolation, ensuring that rainwater filters into the groundwater system. However, with forest degradation, including deforestation and soil depletion, the soil becomes compacted and loses its ability to absorb water. This leads to increased runoff, which not only reduces groundwater recharge but also contributes to water scarcity for local communities. When water cannot penetrate the soil, it flows directly into streams and rivers, increasing the risk of flash floods, particularly during heavy rainfall.
Furthermore, healthy forests act as “rain magnets,” drawing moisture-laden clouds and encouraging rainfall. The destruction of this green cover diminishes this natural function, allowing rain clouds to pass over without releasing precipitation in the catchment area. Instead, these clouds may continue toward Hyderabad, causing cloudbursts and overwhelming the city with intense, short-term rainfall, resulting in flash floods. This effect exacerbates urban flooding while simultaneously diminishing the forest’s role in managing regional water resources.
Without the forest’s natural buffering and groundwater retention capabilities, the Himayat Sagar and Osman Sagar reservoirs will face added strain. The reservoirs rely on the slow, controlled flow of water from the surrounding catchments to manage their levels and regulate flooding. If runoff increases due to soil degradation and loss of forest cover, these reservoirs could overflow, failing in their primary purpose of flood control. Consequently, Hyderabad’s flood management systems would be severely compromised, putting the city at a higher risk of flooding, especially during extreme weather events, while also threatening the long-term availability of groundwater. The lack of maintenance of the forest cover with density of vegetation as 0.2 (20%) in 2011 as per the Field Inspection Notes of Divisional Forest Officer, Telangana making it a predominantly degraded forest highlights the urgency of the situation. Adding further stress from the proposed radar station could lead to severe and irreversible consequences for groundwater levels, biodiversity, and flood management.
6. Importance of Exploring Alternative Sites: Given the significant environmental sensitivity of the Damagundam Reserve Forest, we urge the Ministry to direct the Project Authorities to explore alternative locations for the radar station. An area with insignificant ecological impact would better balance the needs of national security with the imperative of protecting Telangana’s fragile ecosystems. If an alternative location can be identified, it would prevent the irreversible environmental degradation of Damagundam while still fulfilling the strategic objectives of the Indian Navy.
According to the India State of Forest Report (ISFR) 2021, Telangana faces significant environmental vulnerability, primarily due to a combination of deforestation, land degradation, and climate-induced stress. The state’s forest cover has seen declines in certain areas, which heightens the risk of biodiversity loss, reduced water retention, and soil erosion. Telangana’s geographical location and dependence on monsoon patterns make it particularly susceptible to extreme weather events like droughts and floods. Furthermore, its semi-arid climate and large agricultural base exacerbate these challenges, as the loss of forest cover impacts both water security and the resilience of ecosystems.
Rapid urbanization and industrial expansion, particularly around Hyderabad, are putting further pressure on forested regions, leading to fragmentation and degradation of vital ecological zones such as the Damagundam Reserve Forest and Ananthagiri Hills. These trends, combined with inadequate forest regeneration and conservation efforts, leave Telangana vulnerable to exacerbated environmental crises, threatening its natural resources and long-term ecological stability.
In light of the above, we strongly urge the following:
- Ensure that the Eastern Naval Command, does not proceed with the Navy Radar Project in the absence of EIA, Public hearing, effective exploration of alternative sites and valid approvals, including a valid Consent to Establish from the TSPCB.
- Direct Public disclosure of the EIA report for the VLF radar station project, in English and Telugu, within the next 30 days, both via online and offline modes, including in all the affected areas.
- Conduct a fair public hearing to allow all stakeholders, including local communities and environmentalists to raise their concerns and seek clarifications regarding the technology and Project’s socio-environmental impacts.
Given the ecological sensitivity of the Damagundam Forest and its importance in regional flood control and groundwater recharge, we strongly recommend exploring alternative locations for the radar station that do not compromise critical environmental zones. The long-term ecological risks of locating the radar station in this forest reserve far outweigh the immediate strategic benefits, especially when alternative, less ecologically damaging sites may be available.
We trust that the Hon’ble Chief Minister of Telangana and Hon’ble Minister, MoEF & CC will take prompt action to ensure that the Project does not proceed in the Damagundam Forest and socio-environmental review process is conducted with necessary transparency and public involvement to protect this vital ecosystem.
Yours sincerely,
- Dr. K. Babu Rao, Retired Scientist and Human Rights Forum
- Sagar Dhara, Co-Convenor, South Asia Peoples Action for Climate Crisis (SAPAAC)
- Laxmaiah, Pudur Ex-sarpanch, Pudur JAC member (Vikarabad)
- Sandhya, National Convenor, Progressive Organization of Women (POW)
- Y. Geetha, Damagundam JAC, Vikarabad
- Meera Sanghamitra, National Alliance of People’s Movements (NAPM)
- Sajaya, Women and Transgender Organizations JAC
- Kondaveeti Satyavathi, Social Activist
- P. Shankar, Dalit Bahujan Front (DBF)
- Ruchith Asha Kamal, Climate Front India
- Ravi Kanneganti (Telangana People’s Joint Action Commitee)
- Siddhartha, Climate Front Hyderabad
- Prasanna Raya, Social Activist
- Arunya Jyothi, Voice of Earth
- Ravi Babu Pittala, Environmentalist, Joint Secy, Orugallu Wildlife Society (OWLS) & Vice President, United Forum for Environmental Protection (UFEP) Warangal, Telangana, AP
- Sanath Jai Surya, Telangana Praja Chaithanya Vedika
- Kalyan Kakarla, Activist
- Er G Kondala Rao, Environment lover, Ghantasala Kala Vedika
- G. Jhansi, Progressive Organization of Women (POW), Telangana and Andhra Pradesh
- Ravi Shankar Reddy Damagatla, Concerned Citizen
- Kalyani Raya, Concerned Citizen
- Penchal kumar Raya, Concerned Citizen
- NSV Saranya, Concerned Citizen
- Nikita, Climate Action
- Vinay Vangala, Social Activist
- Sonde Ansar, Adivasi Rights Activist (Law Student, Osmania University – OU)
- Srinivas, Pudur Village JAC member,
- Suban, Pudur JAC member
- P. Ramakrishna, CITU
- P. Yadagiri JVV, Vikarabad
- Srinivas Nayak, Girijana Sangam, Vikarabad,
- Padma Vangapally, Independent Journalist and Activist
- Ashok Kumar Gaddameedi, Law student at Osmania University, Resident of Vikarabad.
- Y. Mahendar, District President AIKMS, Vikarabad
- Srinivas, Damagundam JAC, Vikarabad
- Rajesh Damagundam JAC, Vikarabad
- Mallesh, AIKMS dist secretary and Damagundam JAC, Vikarabad
- Mathru Pawar, Final Year Student at Nizam College
- G. Ramulu IFTU, Vikarabad
- Thulasi Chandu, Journalist
- Karthik Yadav Mekala, True Helping Hands
- Rahul Kodarapu, Activist, Justice Movement of India
- Natasha Ramarathnam, Environmentalist
- Pranay Juvvadi, Environmentalist
[1] https://www.deccanchronicle.com/tabloid/hyderabad-chronicle/navy-sees-red-over-threat-to-forest-1828065
[2] https://www.thehindu.com/news/national/telangana/telangana-pccf-denies-rumours-of-large-scale-tree-removal-for-naval-radar-station/article68670952.ece