The Ministry of Environment, Forest and Climate Change (MoEF&CC) has given recommendations for streamlining environment clearance and post-clearance process, on October 25. The recommendations, directed at officials working in the Impact Assessment division, talk about revalidating data, specifying conditions and maintaining clear activities and accounts.
The ministry’s circular comes after an audit report by the Comptroller and Auditor General (CAG) in 2016 found delays in all stages of impact assessment, failure to check compliance and no study of the cumulative impact. The CAG report had suggested ways for the ministry to take action. One was that EC clearances should contain different conditions specific to the nature and type of the project. Another was that the ministry should issue directives to the States on compliance and monitoring. In fact, a key suggestion of the report was that MoEF&CC should make amendments in the Environment Impact Assessment (EIA) notification of 2006 to address issues comprehensively, instead of resorting to office memorandums.
Environment ministry’s recommendations
In its circular, the ministry finds irregularity in data, as figures in audit reports do not match with information available with it. Besides, the data was not arranged according to year or sector and was of poor quality. Thus, the recommendations call for regular revalidation of data and for ensuring baseline data is accurate.
On the issue of accounting, the recommendations suggest that EIA reports and environment clearance (EC) letters should state the cost of activities classified under Environment Management Plan and Enterprise Social Responsibility, along with timelines for their implementation. It also suggests separate accounts and opening another bank account for EC. Another suggestion was that the EIA report should be prepared by an accredited consultant having no conflict of interest.
The recommendations further stress on clarity in clearance conditions, asking for information on areas developed and species planted, to be decided after consulting third parties and forestry or agricultural departments. The conditions of the EC should mention installation of monitoring stations and discuss frequency of monitoring parameters like air, water, noise and other factors. An action plan in the EIA report would also help fulfilling EMP commitments. The number and names of posts to be engaged by the proponent for implementing environment parameters should also be provided in appraisal of EC application.
Finally, the recommendations ask the impact assessment division to ensure EIA reports are written as per the terms of reference of the EC, complying with the structure and addressing concerns raised in public hearings.
Not all CAG recommendations find place in ministry circular
The ministry’s circular has made some pertinent suggestions about data representation, better accounting, clarity of terms and cleaner EIA report making. However, it falls short in addressing some other issues highlighted in the CAG’s audit report. For instance, the CAG report asked the MoEF&CC to give fresh ECs only after previously specified conditions were complied with. Another suggestion talked about surprise-checks at the premises of the project proponents. A third suggestion was about putting in place a mechanism to ensure compliance reports are regularly received and uploaded by the ministry on their websites.
Yet, none of these suggestions have been reflected in the circular.