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An objection letter was submitted to the Forest Advisory Committee (FAC) raising eight key objections to the proposed Sharavathi Pumped Storage Project. These eight objections are documented here.
28 Jul 2025
To,
Chairman and Members,
Forest Advisory Committee,
Ministry of Environment, Forests and Climate Change,
Indira Paryavaran Bhawan, Jorbagh Road,
New Delhi -110003
Sub: Objections to the Proposed Sharavathi Pumped Storage Project (PSP)—Request for Rejection of Stage I Forest Clearance
Respected Members of the Forest Advisory Committee,
We write to formally register our strong objections to the Sharavathi Pumped Storage Project (PSP).
These objections are based on 8 key grounds, each elaborated in detail in the sections that follow. In light of these concerns, we respectfully urge the rejection of Stage I forest clearance, in accordance with the spirit and intent of the Forest (Conservation) Act, 2023.
Relevant documents and supporting evidence are referenced inline throughout this submission.
1. Rejection of the proposal by Deputy Inspector General of Forests
Deputy Inspector General of Forests, Praneeta Paul, after inspecting the Sharavathi LTM Wildlife Sanctuary in May 2025, recommended that the pumped storage project not be approved, citing disproportionate ecological fallout. Her report lists 14 critical concerns, including the project’s location within a fragile evergreen ecosystem, the threat to endangered species like the Lion-tailed Macaque, and major legal, ecological, and geological risks.
2. Alternatives Ignored Despite Legal Mandate and the Existence of Viable Location and Technology Options
Forest clearance processes in India mandate a thorough analysis of project alternatives to ensure that less damaging options are considered before approvals are granted. In the case of the Sharavathi Pumped Storage Project (PSP), the choice of location is primarily justified on the grounds that existing dam infrastructure in the Sharavathi basin makes the project technically and financially “attractive.”
As a result, alternative sites outside the sanctuary—or entirely different storage solutions—were neither seriously explored nor presented with equal diligence. Notably, with over 4.7 times the required PSP capacity already in the environmental clearance pipeline, the Sharavathi project is clearly redundant. Viable alternatives such as Battery Energy Storage Systems (BESS) and large-scale energy efficiency measures have not been meaningfully evaluated, despite receiving strong policy support in the National Electricity Plan (2023–27) and other national planning documents.
3. Deliberate Project Segmentation Evades Cumulative Impact Assessment, Creates Fait Accompli constituting a clear Violation of Supreme Court Orders
The Sharavathi Pumped Storage Project includes multiple interdependent components—tunnels and powerhouse, transmission lines, and two bridges, including the Sharavathi River bridge at Nagarabastikere. However, clearance has been sought only for the tunnels and powerhouse at this stage. Segmenting the project and seeking approvals for different components at different times is a clear violation of Supreme Court directives and the EIA Notification, 2006.
Both the tunnels/powerhouse and the transmission line are essential and inseparable parts of the same project, regardless of whether they are executed by different agencies (KPCL and KPTCL). This strategy of deliberate segmentation to evade environmental scrutiny not only undermines legal due process but also creates a fait accompli—explicitly prohibited by multiple Supreme Court rulings.
4. Ignored Landslide Risk and Geological Instability
The proposed project site falls within moderate to high landslide susceptibility zones, as identified by the Karnataka State Natural Disaster Monitoring Centre (KSNDMC). Undertaking large-scale drilling, tunneling, and construction in such geologically fragile terrain poses grave risks to human safety, wildlife, forest ecosystems, and the integrity of public infrastructure.
This is not a question of if a disaster will occur, but when. And when it does, it will not be an “Act of God”—it will be an ‘Act of KPCL’: the foreseeable consequence of forcing infrastructure into ecologically unstable and legally protected landscapes, in defiance of scientific evidence and precautionary principles.
5. Loss of Significant & Irreplaceable Natural Carbon Stocks and Sequestration capacity
The evergreen forests targeted by this project are major carbon sinks, storing and actively sequestering large volumes of carbon. Their destruction would irreversibly damage India’s climate goals, especially at a time when forest-based carbon mitigation is central to national and global climate strategies.
6. Undermines Escalating Biodiversity Loss
According to the SDG India 2025 report, species in India are facing escalating threats and are at greater risk today than they were two decades ago. The Sharavathi LTM Sanctuary, one of the world’s richest biodiversity hotspots, is no exception. Fragmenting this forest will trigger cascading impacts, already visible in the plight of endangered species such as the Lion-tailed Macaque, Tiger, and Pangolin.
A compelling parallel comes from Montana, where grizzly bear #11072847 attempted to cross Interstate-90, 46-times in 53-days, illustrating the profound dangers of fragmented habitats.
7. Compensatory Afforestation Proposal Violates Legal Norms and Ecological Principles
The identified land for Compensatory Afforestation (CA) violates the Compensatory Afforestation rules, as it lies within the buffer zone of the Bhadra Tiger Reserve. Additionally, the identified land is Shola Forest, which qualifies as’ forest ‘forest’ under the definition laid down by the Hon’ble Supreme Court of India in the landmark ‘Godavarman’ case.
Moreover, the old-growth evergreen forests of the Sharavathi Valley—with their complex ecological functions, high biodiversity, and millions of years of evolutionary history—cannot be replaced through compensatory afforestation. While ecological equivalence is not always explicitly defined in statutory law, it is inherent in the spirit and purpose of India’s environmental legal framework.
8. Undermines National Commitments and Policies
The project directly violates India’s obligation under the National Forest Policy, the Green India Mission, and the National Biodiversity Strategy and Action Plan (NBSAP) 2024–2030.
All of the above eight are described in detail below
📄 The detailed objections for each of the eight points, as submitted to the Forest Advisory Committee (FAC) with supporting references, can be accessed here. The website will be updated with the full text at a later date.