A Myopic Condition of India’s EIA System

Myopia is a condition in which close objects appear clearly, but far ones don’t and the objects blur. Myopia is essentially an inability to see things clearly unless the objects are relatively close to your eyes. Myopia is also called near-sightedness or short-sightedness.

The Indian EIA system has a history of nearly 25 years. This journey has been mundane with no visionary thinking by the Ministry of Environment & Forests & Climate Change (MoEFCC). The approach so far has been project limited, rather procedural and short-sighted. Higher levels of EIA such as Programmatic, Regional, Sectoral and Strategic have not been discussed at all and in the seriousness they deserve. I therefore call India’s EIA system as a case of Myopia. Our use of EIA has been essentially for project clearance and not for a forward planning. This myopic condition requires a correction.

Recently, MoEFCC shared a draft of the new EIA Notification and held consultation meeting with stakeholders in New Delhi. I was hoping that this time at least – we will see a change, but I was rather disappointed.  Apart from tweaking the schedule, proposing another tier of decentralization and supplementing the notification with a large number of formats (mainly drawn from the “Parivesh” software system developed for on-line application and assessment) – it appeared that there was no thought given to elevate EIA for forward planning and mainstream sustainability. It is a sheer pity as we still do not have a mechanism to foresee, assess and manage the cumulative, indirect and long-term impacts of development (not just of the project) and associated risks.

Figure below shows the project categories, types of EIAs, overarching Environmental & Social Management Framework and the relationships.

EIA at Programmatic, Regional, Sectoral and Strategic levels is not new. Many Development Financing Institutions (DFIs) have been “pushing” higher levels of EIA in the national environmental governance. The World Bank and Asian Development Bank have been using such EIAs while preparing their plans for supporting a region or a sector or a national policy or a program in partnership with the borrowing country. Several countries have legislated Strategic EIA (SEA) including countries like China and regions like European Union (EU). China legislated SEA as early as in 2003. As India is facing problems of water on a scale never before, tools such as Regional, Sectoral and Strategic EIA become extremely relevant. But neither the MoEFCC nor Ministry of Water Resources seem to be interested. Hopefully the newly formed “Ministry of Jalashakti” will.

I did one of the first Sectoral EIAs in 1996 on “India – Hazardous Waste Management Project”. This Sectoral EIA included inventorization, plan to strengthen Pollution Control Boards, introduction of less hazardous and cleaner technologies and safe design of hazardous waste treatment and disposal sites. The recommendations in the report were built based on five regional consultations and two expert workshops (involving financing intermediaries and technical experts). A complex web of stakeholders was mapped and a toolbox of policy, regulations, technology development, financing, monitoring and reporting was prepared to manage the proposed 330 million USD line of credit. The World Bank financed this work on behalf of MoEF. You may like to download this report written some 20 years ago from the World Bank’s website. Unfortunately, the project was not approved.

Subsequently, more Sectoral EIAs were carried out in India such as for Mumbai’s Urban Transportation Project and for Tamil Nadu’s Transport sector development plan. These Sectoral EIAs were carried out mainly because of the requirement of World Bank’s Environmental and Social Safeguards. The methodologies used in such Sectoral EIAs and the outcomes were not discussed in professional circles, nor there was any interest at the MoEF’s EIA division and at State Department of Environment or at the level of city administration to “know” these forms of EIA.

In the period when the term “carrying capacity” was introduced and much talked about, NEERI conducted a few Regional EIAs of hot spot areas. These studies were not driven by EIA Notification but by interests of some of the State Pollution Control Boards, State Department of Environments and in some cases were sponsored by MoEF. Judicial pressures contributed to undertake such Regional EIAs. The methodologies used for these Regional EIAs were more of a simple aggregation of project level impacts and did not reach a higher maturity in terms of use of geospatial tools and importantly alternatives and stakeholder consultation.

Later, I had an opportunity to conduct Strategic Environmental Assessment (SEA) at a river basin level  at the behest of the World Bank. This was around 2002-2003. The Government of Tamil Nadu was accessing a support of USD 1 billion from the World Bank to strengthen the management of some 14 river basins. In order to demonstrate the effectiveness of SEA, we chose Palar river basin. Palar river carries rainfed flows for not more than two weeks in a year and the water collected in this period is made available from the massive network of tank system. The basin supports agriculture and the leather tanneries. Figure below shows the challenges faced by the Palar basin over period of time.  Only tools like Strategic EIA can address such complex and escalating issues.

I led the conduct of SEA for Palar river basin for nearly a year. After several bilateral meetings, small group discussions and establishing a Geodatabase supported by remote sensed imageries at Institute of Water Studies (IWS), we organized a 3-day residential workshop in Kanchipuram. This workshop was held to discuss and develop the framework of SEA based on studies carried out  to come up with an action plan considering various scenarios of basin development. A systems thinking provided the canvas and keeping in mind the perspective of “resource sufficiency” and necessity of “equity”. There were 40 key stakeholders that included regulators like TN Pollution Control Board, Water Resources department, Departments of industry, forests, agriculture and health, Research institutes like the Central Leather Research Institute, NEERI and Madras School of Economics, NGOs and farmer community. Importantly, Ministers of Finance, Water Resources and Environment and senior bureaucrats the Secretary level attended the workshop and participated in the discussions.

The workshop demonstrated how a “collective” and  “systems thinking ” by stakeholders helps to bring out a rounded, commonly agreed and sustainable river basin management plan.  Establishment of a Palar River Basin Management was another outcome of the SEA work. Formation of such a Board that was chaired by the Chief Minister of Tamil Nadu was a significant achievement – as the first such Board constituted in the Asian region. Unfortunately, recommendations arising out of the SEA of Palar river basin faced difficulties for implementation due to the political shift in the State. It is really sad that this hard work finally led only to a publication! You may like to read the Palar river basin case study in one of the World Bank publications.

Consideration of climate change in impact assessment of regional development projects is now becoming a practice in most countries including the multilateral DFIs. The EIA systems in these countries have been thus “modernized”.  Vulnerability is now added to the terms “impact” and “risks” and Adaptation considerations are made in developing environmental and social management plans. In India, we have not made any attempt in this direction, excepting titling the earlier the MoEF to MoEFF&CC!

Only elevated forms of EIA can accommodate consideration to climate change. You may wish to read my paper on Climate Change considerations in EIA that was presented at the 2013 proceedings of the IAIA conference.

I still do not  understand the myopic vision of MoEFCC on the subject of Impact Assessment. Is it because we don’t have people at the Ministry who understand the need, or do the professionals involved in the system of Environmental Clearance are least bothered to think beyond their business? Perhaps who cares towards a “system thinking” and a “vision” that looks far ahead.

I met my Professor friend and expressed my concerns. He gave me a patient hearing but did not speak much. He seemed busy.

“Dr Modak, yesterday I received list of officers from MoEFCC who suffer from myopia and are short-sighted. I am just packing the boxes of spectacles  for each one of them made based on their optometry reports”.

I didn’t know what to say!! Wish the solution was that simple!

You may like to refer to some of my following related blogs




The cover image is sourced from https://www.aao.org/eye-health/diseases/myopia-nearsightedness

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  1. Dear Dr.Modak,
    Very informative and lucid as always.It’s indeed hight of apathy exhibited thus far by the agencies responsible for developing programs for sustainability.Only can pray,that good sense prevail and right steps are taken in near future.
    By the way,any development on next 60 shades of green.
    Kind regards,

  2. Extremely informative and honest…I am currently writing a paper on 25 years of EIA in India and was thinking on the very same lines. A cursory look at the EIA research and the few SEA experiences over the last three decades clearly highlight how much India really needs Environmental Assessment above the project level. Its very disheartening to see that inspite of so many experts highlighting its need, nothing has changed…

    1. Dear Urmila – will be interested to know more about you paper. Do share with me if and when possible. I have several posts on this topic on this blog site. You may like to refer to them. Use search bar. Kind regards

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