Economic subjects | Project management » Assessment of Alternatives in EIA reports of Development Projects in India

Source: http://www.doksinet Assessment of Alternatives in EIA reports of Development Projects in India During 2009 - 2014. Abstract The statute on prior environmental clearance issued in 2006 by Ministry of Environment, Forests and Climate Change (MoEF&CC), Government of India qualifies the requirement of alternatives assessment to scoping stage of Environmental Impact Assessment (EIA) process. The present study reviews the assessment of alternatives in EIA reports, both at scoping and final appraisal stage during 2009 - 2014 in India. Scoping document known as terms of reference and EIA reports of various development projects were reviewed to identify whether scoping prescribed alternatives assessment, and whether the EIA reports described and assessed the alternatives. The quality of description and assessment of alternatives is also appraised. 150 EIA reports related to industrial, irrigation and hydroelectric, and infrastructure projects, available on the website of

MoEF&CC were studied. It was observed that 55 reports consisting of 32 projects from Industry, 9 projects from irrigation and hydroelectricity, 3 projects from oil and gas exploration, and 11 projects from infrastructure sectors, mentioned or described alternatives. It was observed that the assessment of alternatives was prescribed during scoping, for 17 projects mainly for infrastructure, followed by industry, and irrigation and Hydroelectric projects. The description and assessment of alternatives mentioned in these 55 reports was studied. It was observed that description of alternatives was cursory in most of the EIA reports of industry, oil and gas exploration sector without any assessment. The description and assessment of alternatives was detailed in the case of infrastructure, irrigation and Hydroelectric projects. The probable reasons for neglect of alternatives assessment in EIA reports in India is discussed. 1 Source: http://www.doksinet Introduction Discussion of

alternatives is considered as the "heart of the environmental impact statement" by the US council on environmental quality, as early as 1978 (CEQ 1978). Assessment of alternatives facilitates informed decision making in identifying environmentally benign option, and ensures that the proponent explores additional options including no option alternative. The assessment or discussion of alternatives is mandatory or discretionary in the EIA reports in most of the countries, with varying degree of importance and effectiveness, while the funding agencies like world bank, IFC, EBRD, and ADB made analysis of alternatives mandatory for major projects (Imperia working paper, 2013). Many studies observed that the identification and evaluation of alternatives is a recurrent weakness in EIA guidelines and documents (Barker and Wood 1999; ERM, 2000; Sadler, 1996; Spooner, 1998), while few studies made an observation that it is impractical to identify all alternatives, to select

the best alternative and to assess all consequences (Barlett, 1997; Kornov and Thissen, 2000). Even though, the assessment of alternatives is considered a good practice of EIA report preparation, the discussion on alternatives begins at scoping stage, with few of them abandoned as they are not benign, and are impractical at various stages of assessment, and may not necessarily reflect in the report. The environmental impact assessment study was made mandatory by Ministry of Environment, Forests and climate Change (MoEF&CC), Government of India in may 1994 vide SO 60 (E) and public hearing in April 1997 vide SO 318 (E), to obtain environmental clearance for various developmental projects. A new notification was issued vide SO 1533 dt. September 14, 2006 by the MoEF&CC suppressing the earlier notification of environmental clearance, incorporating additionally, screening and scoping process for prior Environmental clearance. The 1994 notification sought the reasons for selecting a

project site, and the details of alternative sites, while the current notification sought analysis of alternatives only when scoping exercise resulted in need for alternatives of technology and or site. Thus discussion of alternatives in Indian EIA reports is discretionary and is contingent on scoping by regulatory body. The MoEF&CC has been displaying the scoping documents known as "terms of reference" and EIA reports submitted by the proponents on their website, which is in public domain. 2 Source: http://www.doksinet The present study reviews the scoping documents and EIA reports of about 150 development projects available on the website of MoEF&CC, submitted during the period 2009 - 2014. The objective is to identify; whether scoping prescribed alternatives assessment, whether the EIA reports described and assessed alternatives, and the quality of alternatives assessment in the EIA reports. Materials and Methods The scoping documents known as Terms of

reference and final EIA reports are displayed on the website of MoEF&CC. The terms of reference and final EIA reports were reviewed for a prescription of alternatives assessment in TOR, b. discussion of alternatives in EIA reports, c number of pages devoted for alternatives assessment, and d. appraisal of alternatives mentioned. The appraisal of alternatives was done using the Types of Alternatives mentioned in Guideline on Alternatives (2010). Results and Discussion The total number of projects reviewed are 150 (Table 1). The reports where in assessment of alternatives was prescribed in TOR were identified and presented in table 2. The reports where in assessment of alternatives was conducted are identified and presented in table 3. The total number of pages devoted to alternatives assessment is presented in table 4. The appraisal of alternatives is presented in table 5. Majority of the projects reviewed belong to industry sector followed by river valley and hydroelectric

projects. It may be noted that the prescription of alternatives assessment in Terms of reference is observed in 11.3% of the reviewed reports, and is mainly observed in Infrastructure projects dealing mainly with linear projects like highways, where in alignment alternatives are critical. However about 55 reports have alternatives assessment with majority of them falling in industry sector followed by infrastructure sector. The maximum number of pages devoted to alternatives assessment is 6 and the minimum is 1. It may be noted that 40% of the reports have one page devoted for alternatives assessment while 41.8% of the reports have 2 to 4 pages devoted for alternatives assessment The type of alternatives discussed in the EIA reports, reflect 55% of infrastructure sector reports have assessed routing alternatives due to the linear nature of the projects. 31% of 3 Source: http://www.doksinet the industry sector EIA reports reviewed, have discussed alternative treatment

technologies. 50% of the reports except for oil and gas exploration sector, have not discussed alternatives at all, despite mentioning alternatives assessment. The reasons for low importance for alternatives discussion in the EIA reports are due to; 1). non prescription of alternatives discussion in Terms of reference, 2). lack of awareness of criticality of discussing alternatives in decision making among regulators, 3). Expansion projects which do not have alternative sites, 4). Implementing Generic EIA structure by consultants, without reading the qualifying statement for alternatives assessment in the EIA notification, and 5). lack of knowledge among consultants Table 1. EIA Reports Reviewed and Sectors S.No 1 2 3 4 Sector Industry Infrastructure River Valley and Hydroelectricity oil and gas exploration Total No. of Projects 72 15 39 24 150 Table 2. Terms of Reference Documents Prescribing Alternatives Assessment S.No 1 2 3 4 Sector Industry Infrastructure River Valley and

Hydroelectricity oil and gas exploration Total No. of Projects 4 11 2 0 17 Table 3. EIA Reports with Alternatives Assessment S.No 1 2 3 4 Sector Industry Infrastructure River Valley and Hydroelectricity Oil and Gas exploration Total No. of Projects 32 11 9 3 55 4 Source: http://www.doksinet Table 4. Number of Pages Devoted to Alternatives Assessment in EIA Reports S.No 1 2 3 4 Sector Industry Infrastructure River Valley and Hydroelectricity Oil and Gas exploration Total Number of reports 1 page 2-4 Pages 4-6 Pages 12 16 4 5 3 3 6 2 1 0 1 2 23 22 10 Table 5. Type of Alternatives Discussed in EIA Reports Type of Alternative Sector Industry Infrastructure River Valley and Oil Hydroelectricity and Gas exploration Location 4 3 Activity Design or Layout 2 1 Technological 10 2 3 Demand Input Routing 6 Scheduling and Timing Scale and Magnitude "No-Go Option" 1 Others* 16 5 6 *Others denote no description of alternatives despite keeping the heading of alternatives

Conclusion The discussion of alternatives in EIA reports in India is poor, as the terms of reference do not prescribe the same during scoping stage for majority of the projects and due to lack of prescribed methodology for alternatives assessment in EIA reports. 5 Source: http://www.doksinet References 1. Barker, A, and C Wood, ‘‘An Evaluation of EIA Performance in Eight EU Countries,’’ Environmental Impact Assessment Review 19, 387–404 (1999). 2. Bartlett, RV, in R Clark and L Canter, eds, ‘‘The Rationality and Logic of NEPARevisited,’’ Environmental Policy and NEPA: Past, Present and Future, St. Lucie Press, Boca Raton, Florida, 1997 3. Environmental Resources Management (ERM), Revision of EU Guidance Documents on EIA: First Interim Report, European Commission DGXI, Edinburgh, Scotland, July 2000. 4. Imperia Working Paper, Impact significance assessment and evaluation of alternatives - International guidelines and cases, Finnish Environment Institute, 2013. 5.

Kørnøv, L, and W A H Thissen, ‘‘Rationality in Decision-making and Policy-making: Implications for Strategic Environmental Assessment,’’ Impact Assessment and Project Appraisal 18, 191–200 (2000). 6. National Environmental Policy Act - Regulations, Council for Environmental Quality (1978). 7. Notification SO1533 issued by MoEF&CC, Government of India dt September 14, 2006. 8. Notification SO60 (E) issued by MoEF&CC, Government of India dt May 4, 1994 9. Notification SO318 (E) issued by MoEF&CC, Government of India dt April 10, 1997 10. Sadler, B, ‘‘Environmental Assessment in a ChangingWorld; Evaluating Practice to Improve Performance (final report),’’ International Study of the Effectiveness of Environmental Assessment, Canadian Environmental Assessment Agency and International Association for Impact Assessment, Hull, Que´bec, Canada, 1996. 11. Spooner, B, in A Donnelly, B Dalal-Clayton, and R Hughes, eds, ‘‘Review of the Quality of EIA Guidelines,

Their Use and Circumnavigation,’’ A Directory of Impact Assessment Guidelines, 2nd ed., International Institute for Environment and Development, Russell Press, Nottingham, UK, 1998. 12. Troell, J, Bruch, C, Cassar, A & Schang, S (2006) Transboundary environmental impact assessment as a tool for promoting public participation in international watercourse management, in: L. Jansky & J I Uitto (Eds) Enhancing Participation and Governance in Water Resources Management: Conventional Approaches and Information Technology (Tokyo: UNU Press). 13. Website Ministry of Environment, Forests and Climate Change, Government of India, http://environmentclearance.nicin last viewed November 10, 2014 6