• 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.

  • 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.

  • 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 and surrounding it from all sides.

  • 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. 

  • Paragraph 4, item 11 clearly indicates that new commercial construction shall not be permitted up to 1 km or upto 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 and make way for it.

  • 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.

It is proposed that the felling of trees shall be regulated in accordance with the provisions of the concerned Central or State Act and the rules made thereunder. The Tree Protection Committee of the State of Telangana was constituted under a GO. If it is it established as per the WALTA Act which was constituted for this is a big question. Tree felling cannot even be an option to be allowed.