Anyone, commening on draft Evnironment Impact assessment 2020? 

Here is the link:

The Ministry has invited objections or suggestions, if any, on the proposal contained in the draft notification within a period of 60 days from the date on which copies of the Notification are made available to the Public. The objections or suggestions, if any, may be forwarded to the Secretary, Ministry of Environment, Forest and Climate Change, Indira Paryavaran Bhawan, Jor Bagh Road, Aliganj, New Delhi110 003, or to the e-mail address at

The draft EIA notification 2020, which is going to replace the EIA notification 2006, was put in the public domain on March 12 and the Ministry of Environment, Forest and Climate change (MoEFCC) has sought views and comments from all stakeholders on it within the next 60 days.

Please add your expert comments here too so you can build on one anothers comments.




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  • Under the section :- 16. Procedure for grant of Prior Environment Clearance for modernization based on increase in production capacity through modernization; though it may help in rapid expansion of many industrial projects, the basic concept of EIA maybe overlooked.
    This would instead provide a platform for industries to expand in quicker means without due public consultation.
  • 1. Draft EIA has provision of Expert Appraisal Committee but there is no role is defined that who will review the Final EIA report submitted by Project Proponants. As most of the EAC members does not ready the EiA report and only attend final presentation.
    2. In section 13(1) EIA manual should be be mandatory as EIA manuals are about 10 years old. Therefore it should be not mandatory to follow.
    3. Draft Notification does not have provision of remedies, if DM sit on public hearing file and hold the event for several months. Even after SPCB agreed.
    4. A combined Public hearing with inclusion of both district administrations/SPCB is better and practical to make EIA process smooth and faster as SPCB will be same for both district in a state. Even in case of project in different districts, the Project proponent should be asked to submit the application for Public hearing and draft EIA report & executive summary as defined in Appendix-1 for both districts. Only venue, time and date of Public Hearing should be same, it will save resources, manpower of both districts, police and project proponents etc. The proceedings may be prepared and signed jointly by both district officials.
    5. Section 15(6) Currently there is no time slot is given to each project for EAC meetings. Director of Board and other officials of project proponent organization has devote whole day for EAC meeting. By giving time slot of each project, a lot of man hours of project proponent can be saved. Therefore a word “time slot” may be added in this section “at least ten days prior to the scheduled date and time slot of meeting of the Appraisal Committee.”
    6. However, in draft notification, as per sub-section 19(1)(I) (C) the validity of other projects like Thermal Power Plants would be ten years and no provision of extension of validity in ordinary cases is in draft notification. In case of restriction on construction by NCLT/other court, three years more extension can be given. It may also be requested to add Force-majeure clause with condition of extension of validity due to NCLT/other case.
    7. The compliance report since EC to closure of project will require many compliance reports and huge database which may be difficult to maintain by regulatory authority with no meaning. Only latest yearly compliance report should be available on regulator’s website and old compliance reports should be deleted.
    8.In section 20(10) the referred government institute of national repute should have expertise in Environmental Science & Engineering and its associated fields.
    9. In section 23(6) –provision of Bank guarantee should not be there. There is no provision of bank guarantee in Environmental (Protection Act) 1986 or Water Act,1974 and Air Act, 1981. Therefore, sought of BG for non-compliance of a condition is not legally justified.
    If a non-compliance cannot be reversed like excess land, reduced green belt, natural draft/induced draft cooling tower, timely submission of a document/action plan or other issues, which does not harm the environment directly, should be recommended by expert committee to amend the EC condition to regularize the non-compliance.
    10. In section 23(1) and 23(7) There is no uniformity in system of BG against Non-compliance for Category ‘A’ projects. BG will be recommended by expert committee while BG will be deposited in SPCB/UTPCc. The recommendation of release of BG from RO, MOEF&CC or RD, CPCB. On the basis of recommendation, SPCB will release the BG. In whole process many authorities are involved. The work from BG stipulation, deposition, recommendation for release and return of BG should be done by one authority i.e. Secretariat of Expert Committee or R.O. MOEF&CC.
    11. In section-6 maximum age of EAC member is 70 years during nomination for 3 years tenure of EAC. A 70-73 years old person will not be fit physically/mentally as committee members. Therefore maximum age should be 65 years.
    12. During appraisal of EC, proposed conditions in EC should be shared with project proponent during EAC meeting.
    13. In section-9, a provision of review of Final EIA report should be assign to Technical Expert Committee. The procedure and qualifications of this committee members should also given.
    14. There should not be another committee for review the non-complaince of EC conditions. Expert Appraisal committee as defined in section 3(4) should also handle non-compliances of EC conditions.
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