They said the country was without NBWL and standing committee for several months and the "country expected that the government would constitute a proper NBWL honouring the letter and spirit of the Wildlife Protection Act and the need to protect wildlife and biodiversity in protected areas".
"We stand disappointed by the July 22, 2014 notification. It is ambiguous about the constitution of the NBWL and its Standing Committee. It is not even available on MoEF website. The notification seems to be in violation of the Wildlife Protection Act in letter and spirit and is not in the interest of the wildlife, biodiversity or protected areas in the country. A comparative reading of Sept 2003, May 2007 and Sept 2010 notifications of the MoEF about constituting NBWL further strengthen this view," said the letter.
It said that the notification only mentions a small subset of the NBWL members as listed in the Wildlife (Protection) Amendment Act, 2002. "The limited list is in violation of the Wildlife (Protection) Act, 1972 and its subsequent amendment in 2002 by way of the Wildlife (Protection) Amendment Act, 2002. The Director General of Forests is on record having said that this is the entire NBWL. We would respectfully like to submit that a notification issued by the government cannot override or violate an Act passed by the Parliament, with the ascent of the President of the Union of India," it added.
The letter also said that the notification does not nominate any NGO. The only NGO nominated Gujarat Ecological Education and Research (GEER) Foundation.
"It has been set up in 1982 by the Gujarat forests and environment department and the chairperson of its board is chief minister of Gujarat while majority board members too are from Gujarat government. Thus GEER stands disqualified from being nominated as an NGO," it said.
Among the signatories are Kalpavriksh Environment Action Group, Citizens Concern for Dams and Development, Committee on the Protection of Natural Resources in Manipur, Centre for Research and Advocacy and South Asia Network on Dams, Rivers and People.
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