Mr. Dilip Rau, Administrator, BBMP, Bangalore 560 002, Ph No. 2248 5317 Respected Sir, On May 15, 2009, half page advertisements were issued in leading dailies costing at least Rs 50 lakhs to the public exchequer, announcing intent of felling trees at CNR Rao Circle and Hosur-Laskhar Road. The ad requested the public to file objections to the planned felling within 7 days to the Deputy Conservator of Forests, Bangalore (North Division) by 23 May 2009, Saturday. Many organizations and individuals filed objections to such mass felling of avenue trees. Less than hours from the expiry of the commenting period, without responding to any of the objections, Mr. M. R. Suresh, KFS, Asst. Conservator of Forests and Tree Officer, Bangalore (North) ordered the felling of trees at CNR Rao circle. This decision was taken unilaterally in clear contravention of the provisions of the Tree Act & the High Court decision March 16 in WP No. 7107/2008 (PIL filed by Environment Support Group and ors. vs. State of Karnataka and ors.), to which BBMP is a respondent. The High Court has categorically stated that all Respondents must "strictly follow" the provisions of the Karnataka Town and Country Planning Act and Karnataka Preservation of Trees Act when implementing urban infrastructure projects. There are many disturbing aspects to this: 1. Violation of ruling of Karnataka High Court: As already pointed out in our PIL in the Hon'ble High Court of Karnataka, the road-widening proposal of BBMP needs to be first formulated as a Scheme by BDA under Chapter 5 of the Karnataka Town & Country Planning Act and then placed before the public for objections. The Hon'ble High Court has upheld this contention and has been pleased to issue an order directing BBMP to strictly adhere to the Karnataka Town & Country Planning Act before widening roads. No such Scheme has been formulated by BDA to date. 2. Rationale for project not explained: The rationale for the proposed projects has not been explained as required under Section 4(1)(d) of the RTI Act. Merely saying that these projects have become unavoidable in the interest of "development" does not constitute a rationale. The rationale needs to be justified on the basis of statistics and studies to prove that the current traffic density on the road warrants such a measure; that the proposed measures will improve the traffic situation in terms of de-congestion and speed of traffic; that the project is sustainable on a long-term basis, i.e., that the road will not need to be widened again after five years due to increase in motorized traffic. 3. Rationale for tree felling unexplained: The rationale for tree felling has not been explained. The announcement does not explain what alternative road designs and measures to save the trees were explored and why they were found infeasible. 4. Adherence to NUTP: The announcement does not explain what the finished road-design will be - whether there will be a green strip for planting trees; whether there will be cycle and non-motorised vehicle lanes or BRTS lanes to make the allocation of road-space more equitable and to segregate different modes of traffic, as per the National Urban Transport Policy, which may provide a rationale for the project. It also does not state whether the possibility of retaining the tree-line while altering the road-design to conform to the requirements of the NUTP were considered and if they were, why they were found infeasible. 5. Traffic is doubling every 5 years. Can we double road width every 5 years The efficiency of road space usage is currently very low, must first be improved, before thinking of increasing the road space. Keeping in view all of these concerns, I/we demand the following: 1. BBMP must immediately stop the felling of trees and other construction work in CNR Rao Circle. 2. Action must be taken on the concerned officials who approved the cutting of trees without responding to the objections raised by the citizens. 3. BBMP should hold statutory public consultations, before continuing this project. 4. BBMP should announce the list of objections received and the reasons for rejecting or accepting the objections. 5. Other alternatives to Road Widening and underpass construction should be considered while trying to decongest the roads, such as: a. Reduce traffic by encouraging public transport and discouraging private transport. b. The BMTC already carries half the population of Bangalore in just 5000 buses, which are less than 1% of the total vehicles plying on the city's roads. c. Improve efficiency of road space usage by using coordinated signals, better road surface, disallowing parking (which takes 25% space on most roads). d. Promote walking and cycling as transport for short distances. e. Introduce frequent shuttle bus service in core city area. f. Make city centres car-free and declare old Bangalore areas as heritage sites. g. Create walking plazas in the city on weekends. I/We hope that you support these progressive initiatives and immediately suspend the tree cutting work in CNR Rao circle. With regards, The undersigned