EIA has been legislated in India since 1994 as a requirement for Environmental Clearance (EC). We all know that in most cases, conduct of EIA is perceived more as a "permitting tool" than a process that stimulates alternatives, anticipates impacts/risks and prepares a prevention and control strategy/plan and importantly "value adds" to the original project/program proposal.
EIA reports are often prepared on the fly.
The EIA process is expected to be "concurrent" to project development and not a "terminal" activity when all configurations of the project are frozen. EIA process is also expected be transparent in communicating project and impact/risk related information to stakeholders and seek their involvement. Ground realities are however often different. How could we overcome this limitation?
One of major weaknesses of our EIA system is our project-limited approach. We haven't yet legislated regional, sectoral/strategic EIAs. We therefore miss consideration of cumulative and regional impacts and hence fail to safeguard environment on a regional basis. Our development plans for instance fail to mainstream environmental and social considerations
A lot can be done to improve the present system. I would like to open a discussion on this topic.
Comments
Dear Colleagues
Greetings from Environmental Management Centre
You may be aware, the World Bank has been actively engaged in supporting the Government of India as well as various State Governments in building capacity in Environmental Management. Environmental Impact Assessment (EIA) has been one of the focal areas of support given its critical role in shaping environmentally sound development, involving public and monitoring of the outcomes to adapt and take corrective actions.
Unfortunately, EIA is not offered as a course in many of the graduate programs in India. There are hardly any Continuing Education Programmes on EIA as available to the professionals or those interested. There are no professional associations that network on EIA in India and share expertise and experience.
In order to address this gap, I have been asked by the World Bank to blueprint and establish an EIA Training and Knowledge Network (EtKON). EtKON will result into establishment of EIA Training Centres with thematic specialization.
The objective of EtKON is to:
a) plan, develop and deliver a world class EIA training and capacity building program that is tailored to meet the requirements of specific infrastructure sectors, international and domestic financial institutions and a variety of stakeholders; and
b) to provide a platform to both national and international experts and a forum for sharing, discussion and engagement on relevant aspects of EIA.
c) to understand the current status and requirements in order to deliver quality training to a wide cross-section of stakeholders such as Regulators, Project Proponents and Investors, Environmental professionals and NGOs, etc.
A collaborative website will be developed to serve as a backbone and serve as a knowledge network.
In order to understand the Training Needs in EIA, I am initiating a nation-wide survey by contacting diverse group of stakeholders such as Regulators, Project Proponents and Investors, Environmental professionals and NGOs etc. Results of TNA will be factored in EtKON.
The TNA is solicited in an electronic form that is hosted at
URL http://www.emcentre.com/EIA-Training-Need-Assessment.htm
The form is simple to fill and is customized to each stakeholder.
I would be most grateful if you spare few minutes of your valuable time and complete this form. I look forward to your cooperation and valuable inputs. The TNA report when completed will be made available on EtKon’s website.
Best regards
Prasad Modak
Executive President
Environmental Management Centre, India
Practising Sustainability to the advantage of all"
A-25, Royal Industrial Estate, Second Floor, Naigaon X Road, Wadala, Mumbai – 400031
Tel/Fax : 91–22-2414 7481 or 2410 8255
Visit www.emcentre.com
Mobile: +91 98201 26074
Profile: http://www.linkedin.com/prasadmodak
Effectiveness of EIA also depends on the representativeness of data collected for the purpose, be it collected on fly or against a fullfledge monitoring job. More often or not skilled professionals with excellent experience do not spare enough time and PPs do not have sufficient funds for reliable and representative data.
Government authorities have best resources for example the Met Dept (IMD) may find that Rajkot (Gujarat) weather station shall suffice the requirement of the data for the district. It (IMD) does not have a weather station located in Morbi - located about 60 Km away from this city. If a consultant collects the data at Morbi - this data is "not authoritative".
Point is what is not considered important from the point of view of department primarily meant to maintain these records, should not be considered important from a department whose primary aim is to engineer the environments. If so required, the DoEFs at State Level or MoEF at the center should use their good offices rather than making the matter an instrument working against some PP in name of reliability.
The proedure has to be objective and based on a mathematical model which only should be used to conclude the outcome of the data and be compared with the same model run on data available with MoEF. The use of such models has to be prescribed by authority. Use of different models for the same data may yield different results for same data.
Arranging good meets in a closed room where committee members themselves are seen differing in their opinions can be avoided. The procedure can be hastened and the effectiveness can be improved.
Census book is the Gita for most socio-economic consideration but when you go to the site the conditions may be seen differently by the consultant than the Government official. For example, a road widening case without any land acquisition may not need any EIA as per the activities listed in the Notification but if you consider the roadside plantation that may get lumbered away may be significant.
It is said that sight is a faculty but seeing is an art, similarly, preparing the EIA and the effectiveness of the EIA will always be a function of the person leading the monitoring, a few ppms or a few micrograms here and there do not make much difference on the overall report. It is the interpretation and the observations or in the other order that will help a lot.
Hi Colleagues
As we turn over to the New Year of 2011, I would like to bring in optimism in this blog discussion.
We all probably know whats wrong, what are the concerns and many have shared their bitter experiences of the "system"
We should perhaps now focus on concrete supportive, catalytic and corrective measures. Here are my suggestions
a. We talked about need for training and capacity building - Can the members of this forum and discussers of the blog cite me good examples of EIA training resources, potential training institutions in India? Or are we zilch in this arena?
b. I am sure not all EIAs carried out are "bad"; Can you point based on your experience examples of "good" EIAs? Have you come across EIA that has "value added" to the original project concept & scope? Are there any models to follow?
c. Mention has been made on the "problems" with accreditation. Can we jointly develop a feedback for the Ministry to consider? If you post me specific suggestions, then I am willing to take responsibility of collation and edits to prepare first draft.
There can be more such points. But let me pose these three first and invite your "positive contributions".
Best regards and a happy new year
Prasad Modak
Dear Dr Modak,
Thank you for your poditive response.
I had been teaching PG students a course in EIA from 1994-2004. I had to do this when we found that experts from PCB could not deliver the basics, since their exposure was limited to access to some EIA reports. With m experience in Analytical Chemistry and industrial chemistry, I thought I could do it better, and it proved true. We were incorporating site visits, mock EIAs and attending public hearings. Finally we were persuaded to an EIA by a government agency. We found it a thrilling experience. Fortunately we had all departments and experts within the institution (Cochin University of Science and Technology), and they were willing to cooperate.
I would be happy to share my experience with you and support your efforts.
Sincerely
V N Sivasankara Pillai
09847151631
sivasankarapillai@gmail.com
EIA and its related issues begin not with consultants primarily. It is the PP who has to have "time" first of all. We are also witness to post-facto EIA reports. As Mr Raghavacharyulu has pointed out and so to say confessed frankly about the fabricated reports. More often or not these reports are prepared under pressure from the PP, authorities, public interests, financial constraints, lack of trained personnel and what not.
The biggest problem with the profession is that no consultant is prepared to accept the fact that EIA may not be their cup of tea. There are so many areas where one can work with excellence and need not have compromise with individual components of the report. Every step and every component can be done in hundreds of ways. With generic structures prescribed the evaluating authorities go rigid only and tend not to evaluate the things in perspect of the situation. SLEACs need not be very rigid on the accreditation because projects are small compared to the Moef's projects. MOEF ALSO NEEDS TO CONSIDER THAT SIMPLY BECAUSE OF LOCATION THE INDUSTRY SHOULD NOT BE FORCED TO APPROACH MOEF. The cost of co-ordintation at times increases and the budget constraints are the things which make the fabricated things sneaking in. WHAT IS REQUIRED IS A GOOD DATA BANK AND COMMON LABORATORIES WHERE THE CONSULTANT CAN APPROACH FOR RELIABLE DATA AND AUTHENTIC ANALYSIS. (Irrespective of the issues NO AUTHORITY EVER ACKNOWLEDGES DATA OF ANY CONSULTANT)
Now, Just because there is a scheme floated by authority, horse trading for accreditation is on. I doubt to have good results because to save the works at individual level the quality of work and the quality of consulting agency will deteriorate ONLY.
I agree with Raghavacharyulu. QCI / NABET will not serve the purpose. It is the fixed set of EMPS that have to be done judiciously at the end will decide whether the impact on the environment is to be reduced or not. Improved paperwork is never going to improve the environment.
Good Morning Dear All,
Read some nice suggestions on the Discussion started by sir Prasad Madhav Modak. Many have opined that training in ethics or training to EIA co-ordinator is better idea to improve the Effectiveness of the quality of EIA. However, i would like to reiterate that if we go back to 90's or before 2002 the quality of EIA reports were much better than the reports made at present. Why the quality of EIA has degraded rather than improving?
Is it because of the policy legislations or because of Environmental Consultants or because of Project Proponents.............? Will training alone to the EIA co-ordinator will bring about the change. N0......... During 2003-2004 i don't exactly remember the year, a PIL was filed against the project proponents that they are running / expanding the projects without valid Environmental Clearance and notice was gien to all those proponents to cease there operations immediately and obtain EC to resume their operation. This has brought a dramatic change in the entire Indian History for obtaining Environmental Clearance. Project proponent has started demanding the consultants to obtain EC for their project on an emergency basis (if not exxxxxxxaggggggerating on the very next day). Rather if the project proponents are educated or a clear awareness program on Environmental Clearance and its importance is inculcated in the enterpreneurs then automatically the quality of EIA will also improve. Moreover the methodology of Baseline data collection prescribed by the authorities should also be modified in such a way that the data can be collected without any hindrance and is more appropriate. for example Ambient air quality: the data has to be collected twice in a week for four weeks in a month and for 3 months of a season and now we have to use three instruments i.e one for gaseous sampling and one for PM 2.5 and one for PM10. The noise or the wave disturbance created by these instruments does not allow the local villagers to run the machine for the stipulated time. As the consultants return back after keeping instrument immediately they switch off the machine. Now-a days there are so intelligent that they are even able to move the time totaliser to prove that the machine has run for 24 hrs. This way how one can get a representative quality of air. so the Environmental consultant has also accoustomed to this sort of behaviour and started engineering the results. Sorrry but this is a naked truth not only with respect to any environmental consultant but also with NAMP stations established by Central Pollution Control Board of and other institure of National Repute including IIT's or NEERI. How many people has got courage to accept the truth of this. There is a urgent need to revise the baseline data collection system. this should be the first change to improve towards betterness. secondly, project proponent should change his attitude of getting environmental clearance for his project by anymeans. Because a consultants job is to get Environmental Clearance for his proponent just like a lawyer defending a case to win for his client.
what i strongly feel is giving mere training or a rigorous training to EIA coordinator may not bring a quality EIA report. Sorry i am not diplomatic t explainer. But these are the naked truths which are hampering the quality of EIA report in our country. (there are many more things which i think everone in this field know which need not be explained more precisely can be put on the paper)
Raghava
Dear Hemal and Prof Pillai
Thanks much for expressing your interest and extending support for capacity building project on EIA. I will keep you in loop as project starts rolling. I am beginning with Training Needs Assessment (TNA) in the first week of January. If you have come across or done yourself any formal TNA on EIA in India, then do let me know.
I see that most are weary on the quality of training (and trainers) on EIA as available in India. First of all EIA focused training programmes are not offered and when offered, they tend to be more "academic" (as Hemal rightly states). So indeed, we should come up with something more relevant, effective and innovative.
I have been conducting EIA training programmes for past 20 years or so and would like to share with you all some of the materials and pedagogy structures that have been followed. These training programmes are case study driven where participants work on a real case study in groups, interdispersed with short lectures. Most programmes run on residential basis with field visits (on which case studies are sometimes constructed). Programmes include role playing exercises, screening of short films, dinner speeches etc.
Recently, I conducted a 5 day training programme for some 25 EIA Consultants from Philippines, Thailand and Cambodia that used many of these "ingredients". I will cite the URL where I will upload some of this material for the purposes of sharing. It will be good if members of this network start sharing materials that are found to be good and have been "tested" to be found effective. Let us see something positive.
Prasad Modak
Dear Proff. Pillai and Dr. Nandini,
As there is some general aspects of EIA studies & NABET scheme, which we need to understand. As the scheme says a coordinator is must to rule for a specific sector and the other experts are supportive to coordinator to judge the exact impacts and probable mitigation measures. this is the main focus of the scheme but as Proff. pillai mentioned, many people having lot of experience in EIA are failing to qualify as per NABET. The issue is improper evaluation by NABET assessment authority. There is one other operational issue also, which is very well clarified by the Dr. Nandini's statement - "EIA is a multi-disciplinary procedure". Here the thing or word of prime importance is "multi-disciplinary". QCI assessment has framed certain requirements like sector specific experience and yet they insist on such criteria. here it must be noticed that 99% percent expert from sectoral experience will not be fit for integration of impacts & related details of the particular sector of his/her expertise. Such person will not be able to prepare a combine state to fit with the quality requirement of the EIA for particular sector. As this is very general that no one can be perfect in all subjects of EIA study and it is also very true that a person without having sector specific knowledge will be best for preparation of integrated rather comprehensive statement for impact and allied information like mitigation & EMP etc. without having experience of production or operation in specific sector.
As the subject Environment itself suggests that it is a great & huge field and a person with sound/good experience in the Environment regardless of any specific sectoral experience will be best for EIA rather that a coordinator having sector specific experience. I hope i have been able to convey the facts and necessity of EIA quality by the aforesaid statements.
Further, the QCI need to revise its assessment scheme by a written open book examination for coordinator/FAEs without focusing on the present criteria of experience. The exam must be based on the dummy details of a fake project (which applied sector) and the coordinator shall be asked to prepare a notes for EIA report including all necessary details of IMPACTS, Mitigations, Risk & hazards etc..... Open book system will enable one to show his/her potential to act or operate as Coordinator. The exams shall also include a primary/first stage of a schematic operation planning by Coordinator by which the coordinator can get work done certain necessary & important task done from the concerned FAEs and other associated staffs. This two examination system will make the assessment system as well as EIA quality almost up to the mark of appreciation.
Under the topic lots of discussion points are described but i could not see the professional approach and actual actions required for Improvement of EIA study. Many People practicing in EIA field have undergone number of specific training and even lot of experience of particular task after the training for specific task. Even then most of the people are not being able to put the quality (even 30-40% of desired), which is desired / required at the present to up bring our EIA/EC system for Environmental Protection, improvement & conservation. I would like to cite one point over here about the training that the Training on theoretical or prototype practical will not fulfill the actual requirement. We need to plan a unique training program under which a group shall be given some practical work for deferent projects. Members of One group shall be assigned for deferent project/sectors in addition to the subject of one's own principal subject of academic route.
In the inception, training for planning (budgetary & operational) business and Quality EIA operation for better productivity (Profit & EIA quality) must be given. In the final stage of the training all person shall submit the project report (a portable EIA report preferably after 5 days of first stage) based on standard data from reference (no actual data as it is collected for site specific details) with necessary QA QC methods & outcome as well as project specific unique suggestion including necessary alternative for cost & environment improvement. The portable EIA report than shall be assessed for the quality & deficit of one's knowledge. Then the assessor must prepare special notes on final training requirement module on instant basis to cover all deficit issues cited in the reports of all persons under the training. Such training need almost a ten days program and i am sure that after such training the person joined the training will feel happy with great improvement in professional approach of one's own. Such people will surely practice with great profit and unique EIA quality which is the main theme of the present discussion.
Well the training & development for EIA quality is something like great business if we talk about necessity. I would suggest that such training shall be planned as "Management Counseling, Training & Development" through a cycle of deferent aspects including finance, administration, Operation, Techno-Scientific skill development etc etc ..
At end i would like of convey a message to Mr. Prasad that I will feel happy if i can be part of training (no a generic but a custom made training as i said) if he wish to plan some unique training scheme & module. Till date i have seen lot of training programs by Some prime institutes & great people but the actual outcome is almost none. Further, i would like to cite that the requirement of EIA quality is related with Service Business sector, Corporate sector etc rather than Academic Sector. The task for a person from academic background is Purely a Research and everyone knows only 10% researches of Academic pattern has been implemented in-situ. A lecture for research to put on paper and training for a small practical to put in field is matter of North & South. Most of the training is being organized by a Academic Person and this is the prime reason of failure in getting desired outcome of training. 99% training programs are great in making great profit only but only 10% programs are good for real outcome as planned theme for training. So what is required to plan is "Professional Training for Profitable Business with Professional & Social Ethics given by Professional Person as Trainer".
I HAVE WRITTEN MANY HARSH WORDS FOR MANY PERSON. BUT THESE ARE MY OPINION & CONCLUSION REVEALED FROM MY EXPERIENCE OF >10YRS. IF ANY WORD OF MINE HURTS ANY ONE, I WOULD LIKE TO CONVEY MY APOLOGY FOR THAT IN ADVANCE.
THANKS
Dear Prof. Modak,
It is a nice idea to start training program for EIA personnel. We have to start with creating awareness about professional ethics, course content for each specialization depending on the basic qualification of personnel involved in EIA etc. We have to include even a style guide for EIA reporting in general and for each sector.
A reference to the minutes of QCI-NABET will reveal the present status. Many people who have been the teams and successfully cleared projects, are not qualified as per QCI-NABET scheme. What I wanted to make out is that we have to tread cautiously, offer courses, evaluate and award grade, or pass/fail to trainees.
If you embark on such a project, I would be glad to associate with you.
Hi Dr. Modak
Essentially, it’s important to acknowledge that an EIA is a multi-disciplinary procedure. A team needs to be formed with specialists, each of whom is equipped with the core competencies to assess pollutant impacts & suggest interventions to mitigate them. Most industrial environments contain multiple pollutants. Hence this team, in addition to their specialty areas, will also have to work jointly with other specialists to predict cumulative pollutant effects, some of which may be synergistic.
This is a working-style that needs to be inculcated as presently it’s not widely prevalent. The first step towards this goal would hence be the constitution of the basic team of specialists on noise, vibration, air-quality, chemicals etc .Subsequently, responsibility for the EIA as well as the interventions suggested can be attributed to the concerned specialist.
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