Representation flags concerns over NBWL functioning, forest diversions and future energy choices

By A Representative 

On the occasion of World Nature Conservation Day and International Tiger Day, Karnataka-based power and climate policy analyst Shankar Sharma has submitted a detailed representation to the Union Government urging a comprehensive review of India's developmental paradigm, environmental governance and long-term energy policy in the context of climate change, biodiversity conservation and sustainable economic growth.

Addressed to the Union Ministers for Environment, Forest and Climate Change, Power, New and Renewable Energy, Finance, and the Vice Chairman of NITI Aayog, through the Cabinet Secretary, with copies to the Prime Minister and the Union Council of Ministers, the representation argues that India has reached a defining moment where environmental security must be recognised as an integral component of national security, economic stability and public health.

While affirming the need for continued economic development, industrialisation and expanding electricity infrastructure, Sharma contends that future development should be guided by rigorous scientific analysis, transparent public participation and objective assessment of long-term ecological, social and economic costs. He argues that the increasing frequency of heat waves, floods, droughts, groundwater depletion, pollution and forest degradation demonstrates that climate change is no longer a future challenge but an immediate national concern requiring a fundamental shift in policy priorities.

A major focus of the representation is the functioning of statutory environmental institutions, particularly the National Board for Wildlife (NBWL) and its Standing Committee. Referring to a recent Public Interest Litigation before the Delhi High Court filed by retired forest and wildlife officials and conservationists, Sharma notes allegations that the NBWL has effectively become a "clearing house" for projects involving diversion of forests and protected areas. According to the petition, the Standing Committee approved around 97 per cent of 2,186 project proposals between 2014 and 2026, allegedly resulting in diversion of nearly 95,724 hectares of forest land with inadequate ecological scrutiny.

The representation argues that such allegations warrant an independent institutional review rather than defensive responses. It also questions the practicality of evaluating dozens of complex infrastructure proposals in a single meeting, observing that projects affecting forests, wildlife habitats and river valleys require multidisciplinary examination involving ecology, hydrology, climate science, economics and social impacts. It recommends strengthening environmental governance through cumulative impact assessments, alternatives analysis, independent expert review, transparent decision-making and meaningful public consultation.

The communication cites the proposed 2,000 MW Sharavati Pumped Storage Project in Karnataka's Western Ghats as an example of the challenges confronting environmental decision-making. According to Sharma, the project has faced sustained opposition from local communities, retired Indian Forest Service officers, scientists and conservationists because of its proposed location within a protected wildlife sanctuary and ecologically significant tropical rainforest. He argues that the project illustrates the need for more rigorous examination of alternatives before approving projects involving diversion of protected forests.

The representation stresses that India's forests provide critical ecosystem services, including rainfall regulation, groundwater recharge, biodiversity conservation, carbon sequestration and climate moderation. Since protected areas constitute less than 4.5 per cent of India's geographical area, Sharma argues that any diversion within such landscapes should receive the highest level of scientific scrutiny. He maintains that biodiversity conservation should be viewed as an investment in long-term economic prosperity rather than an obstacle to development.

The representation also examines India's rapidly growing electricity demand arising from industrialisation, artificial intelligence, data centres and increasing cooling requirements associated with rising temperatures. Rather than relying primarily on environmentally intensive generation technologies, Sharma advocates greater emphasis on energy efficiency, demand-side management, distributed renewable energy, rooftop solar, decentralised wind generation, battery storage systems and smart grids.

Special attention is devoted to the environmental implications of artificial intelligence and data centres, which are emerging as major consumers of electricity and water. Sharma recommends that India formulate a national policy requiring large data centres to meet a substantial share of their electricity demand through dedicated renewable energy and storage systems while carefully regulating their location and water consumption, particularly in water-stressed regions.

A significant portion of the representation compares Pumped Storage Projects (PSPs) with Battery Energy Storage Systems (BESS). While acknowledging the role of pumped storage in balancing renewable electricity, Sharma argues that recent technological advances have significantly improved the economics and flexibility of battery storage. He notes that battery systems generally require much shorter construction periods, occupy less land, achieve higher efficiency and have a substantially smaller ecological footprint than large pumped storage projects located in ecologically sensitive river valleys.

The representation cites recent studies suggesting that battery storage can be more economical in many applications while avoiding irreversible impacts on forests and biodiversity. It also highlights reports of substantial renewable energy curtailment due to inadequate storage capacity and argues that rapidly deployable battery systems could address such challenges much sooner than pumped storage projects, which often require eight to ten years to complete.

The communication also questions the renewed emphasis on nuclear power, including Small Modular Reactors. While recognising the low operational carbon emissions associated with nuclear energy, Sharma argues that issues relating to high capital costs, project delays, radioactive waste, water requirements, accident risks, liability arrangements and decommissioning costs require transparent national debate before committing substantial public resources to large-scale nuclear expansion. He recommends comprehensive comparison of nuclear power with rapidly advancing renewable energy and storage technologies.

The representation further argues that environmental decision-making should move beyond engineering feasibility and financial viability by incorporating ecological economics into project appraisal. It recommends mandatory application of comprehensive cost-benefit analysis, options analysis, cumulative environmental impact assessment, biodiversity valuation, ecosystem services accounting, climate risk assessment and long-term financial risk analysis for major infrastructure and energy projects.

Among its principal recommendations are a Cabinet-level review of India's environmental governance framework; strengthening statutory environmental institutions through greater transparency and scientific rigour; mandatory alternatives analysis before approving projects involving diversion of forests and protected areas; an independent national comparison of pumped storage and battery storage technologies; formulation of a national policy for environmentally responsible development of AI and data centres; review of the long-term role of nuclear power; greater emphasis on decentralised renewable energy and smart grids; and integration of biodiversity valuation into major public investment decisions.

Concluding the representation, Sharma states that India's remarkable developmental achievements must now be matched by equally visionary environmental stewardship. He argues that forests, rivers and biodiversity constitute irreplaceable national assets whose destruction would impose long-term economic and social costs. The representation urges the Union Government to undertake a comprehensive review of environmental governance, natural resource management and long-term electricity planning so that India's future development proceeds on a path that is economically prudent, environmentally sustainable and socially equitable.