Environmental impact assessment reports for Gujarat projects show consultants preparing them do not assess ground realities

Women shout slogans before boycotting an environmental public hearing for proposed nuclear power plant at Nava Gam, Bhavnagar
Women shout slogans before boycotting an environmental public hearing for proposed nuclear power plant at Nava Gam, Bhavnagar

Mahesh Pandya, director, Paryavaran Mitra, Ahmedabad, has written a letter to Dr V Rajagopalan, secretary, environment and forests, Government of India, on the basis of a study his voluntary organization recently undertook of 166 consultants who are at various stages of accreditation with the premier body assigned with the task, National Accreditation Board for Education and Training (NABET). Focusing on an analysis of the consultants involved in preparing environment impact assessment for projects in Gujarat, he details the main issues which NABET has overlooked:

 In a recent study, Paryavaran Mitra found unprecedented loopholes in the accreditation process of the consultants who prepare Environmental Impact Assessment (EIA) reports for various developmental projects. The accreditation is carried out by the National Accreditation Board for Education and Training (NABET). EIA is one of the most crucial tools for ensuring sustainable development through evaluation/ identification of positive or negative impacts associated with an upcoming project.  EIA reports continue to be the key analytical, scientific and technical documents on which decision making rests. In Gujarat, Paryavaran Mitra has been involved in reviewing EIA reports and has participated in environmental public hearings (EPHs), which have taken place on the basis of these EIA reports. Recently, it carried out an analysis of the EIA reports to see if they are up to the required standards.

To improve the quality of EIA reports, the Ministry of Environment and Forests (MoEF), Government of India, has made it mandatory for the consultants, public sector undertaking (PSUs) and the environment sections of different companies working in the area of EIA to get themselves registered as accreditation consultants with NABET. In its analysis, the main focus of attention of the Paryavaran Mitra has been to find out if the scheme is serving its purpose in the present situation.

Under the “Scheme for Accreditation of EIA Consultant Organizations”, NABET is supposed to update its list of accredited EIA consultant organizations every month.  As per the list of February 5, 2014 list (click HERE to download), there are 166 consultants accredited under it. Of these, 141 are provisionally accredited. This implies that only 25 consultants can be called accredited consultants. As per the NABET, “Provisionally accredited consultants are those who do not yet have all 12 functional areas covered by approved experts. Their status shall be updated every month.”

The 12 areas of expertise which are required for carrying out EIAs are land use, air pollution monitoring, prevention and control, meteorology, air quality modeling and prediction, water pollution monitoring, prevention and control, ecology and biodiversity, noise and vibration, socio- economic aspects, hydrology, ground water and water conservation, geology, soil conservation, risk and hazards management, and solid and hazardous waste management, including municipal solid wastes.

The Paryavaran Mitra’s analysis focused on some of the important upcoming projects of Gujarat for which environmental public hearing (EPH) was held in 2013-14. It has found that the accreditation body, NABET, responsible to ensure that the consultants maintain a certain degree of quality, has overlooked certain very important factors while providing accreditation.

First of all, there is lack of clarity regarding provisionally-accredited consultants. Limitations of the provisionally-accredited consultants have not defined by the accreditation body.  Whether provisional consultants can undertake particular EIAs, or comprehensive ones, has not been clarified. If they have the same status as the accredited consultants, what is the need to keep their status as provisional?

Secondly, there is lack of clarification regarding the functional areas. As per NABET guidelines, provisionally-accredited consultants are those who do not yet have all the 12 functional areas covered by approved experts, but the areas in which they are lacking has not been specified.

Thirdly, there is no clarity on competency for assessing bigger projects. For bigger projects, where impact is likely to be on the all environmental segments, ideally, the fully-accredited consultants alone should be allowed to participate in the interpretation of data.  But Paryavaran Mitra has found that, in 2013-14, IEA reports for big projects like the Delhi-Mumbai Industrial Corridor (DMIC), the National Highway Authority of India (NHAI), the Adani ship-breaking project, etc., were prepared by provisionally-accredited consultants.  Hence the question whether provisionally-accredited consultants are competent enough to do IEA for projects whose impact involves all environmental segments is not clear.

Fourthly, the time limit for upgrading the list should be strictly followed. NABET claims that it updates the status of its provisionally-accredited consultants every month.  But Paryavaran Mitra has found that this is not true. One can illustrate this with the example of Mantec consultants, whose status since July 2013 remains the same till now (as of February-end 2014). Clearly, the consultants do not need to upgrade their capacity as they enjoy doing all types of EIA reports with their provisionally accredited status.

The bottom line of our analysis is that, there is no clarity regarding provisionally-accredited consultants, and despite their poor quality, as reflected in EIA reports, these consultants are given big projects, especially government projects. In fact, Paryavaran Mitra has come across instances where EIA is carried out by two consultants. One of them prepares the EIA report, while the other one validates it – which may be due to accreditation issues.  After studying the accreditation scheme, Paryavaran Mitra has not found any clarification which allows them to do so.  Moreover, the quality of these EIA reports is not up to the mark.

Then, there are consultants who do nothing but copy-paste job while preparing IEA report. The EIA report of M/s Krishanji Pharmaceuticals Industries, Rajkot, is one such example of copy-paste, about which Paryavaran Mitra pointed out in its comments during its EPH. As per the MoEF office memorandum No J-11013/41/2006-IA.II (I) dated October 5, 2011 regarding the ownership of EIA report and other documents by project proponents, “If at any stage, it is observed or brought to the notice of this ministry that the contents of the EIA report pertaining to a project have been copied from other EIA reports, such projects shall be summarily rejected and the proponent will have to initiate the process afresh including conduct of public hearing.”

It also states that “separate action will be initiated to delist such consultants from the list of accredited consultants.” Although Paryavaran Mitra brought this to the notice of the authorities, no action was taken against the consultants or the project developers.

Finally, there is a glaring case of EIA report having been prepared by a non-accredited consultant. Although there is no consultant in India accredited for carrying out EIA for a nuclear power plant, the EIA report for the upcoming project of Nuclear Power Corporation of India Limited in Bhavnagar was prepared by a consultant, which is not accredited and is having a poor track record. In Paryavaran Mitra’s view, half of the quality issues can be resolved by taking strict action during accreditation process itself. It has been constantly writing letters to NABET regarding the issues involved, but never got any reply or any action against any of the consultants.

Big upcoming projects of Gujarat and their consultants:

  • National Highway Authority of India, for the construction of new 6/8 lane:  Vadodara – Mumbai Expressway passing through Vadodra, Bharuch, Surat, Navsari and Valsad districts in Gujarat. Its EPH was held on February 18, 2014. To be 379 km long, 90 per cent of the land on which the project is to be implemented has to be acquired. Issues involved include evidence of copy-paste, poor images and maps, lack of information, and overall poor quality of EIA. The EIA was carried out by Intercontinental Consultant and Technocrats Pvt. Ltd, New Delhi, which is provisionally accredited.
  • Delhi-Mumbai Industrial Corridor Corporation Limited, (DMICDC), district Ahmedabad whose EPH was held at Dholera on January 3, 2014, for developing a modern township in the name of special investment region. In all, 920 sq km area of 22 villages will be affected, of which 47.46% is agricultural land. Issues involved include lack of quantitative analysis, lack of biodiversity study, and lack of anticipated impact of the project with respect to climate change. The EIA was carried out by SENES Consultants India Pvt Ltd, which is provisionally accredited.
  • Tata Chemicals Limited, which involves mine leases (of 16.21 hectares (ha), 21.04 ha, 6.07 ha, 12.27 ha, and 15.99 ha). Its EPH was held on December 4, 2013. Issues involved include reserved forest and wildlife sanctuary in very close proximity of the area, limestone leases of Tata Chemicals and other owners are within the same area, and lack cumulative impact analysis. The EIA report has been carried out by Mantec Consultants Pvt Ltd, which is provisionally accredited.
  • M/s Kandla Port Trust, Kutch: Its EPH was held on December 18, 2013. It involves three categories of EIA schedule. It lacks cumulative impact analysis. EIA was carried out by Mantec Consultants Pvt Ltd, which is provisionally accredited.
  • National Highway Authority of India: The project involves widening and improving the existing highway to two lanes with paved shoulders/ 4 lanes /6 lanes along Bhavnagar-Pipavav- Porbandar -Dwarka section of the National Highway-8E. Its EPH was held on October 5, 2013. Total of 260 km pass through six districts, including 63 km through the coastal region. Issues involved are 3.91 ha of reserved forest is to be acquired, there are conflicting data in the report, and there is insufficient environmental impacts analysis. The EIA has been carried out by STUP Consultants Pvt Ltd, which is provisionally accredited.
  • M/s Adani Port and Special Economic zone Ltd, Kutch, for building modern shipbuilding facility. Its EPH held on July 30, 2013, and the project is to be implemented on 40.7432 ha of reclaimed land. Issues involved include environmental and health hazard due to asbestos-containing waste material and ships effluents. There is lack of cumulative impact analysis. EIA report has been prepared by the Mecon Limited, which is provisionally accredited.
  • M/s Nuclear Power Corporation of India Limited., Bhavnagar, whose EPH was held on March 5, 2013. The nuclear power project would be implemented on 603 ha of acquired agricultural land. Issues involved include use of radioactive chemicals, poor performance record. The EIA report was prepared by the Engineers India Limited, Gurgaon, which is not accredited for nuclear project.s

Projects which were done in collaboration by two consultants:

  • M/s Deedy Chemical Pvt Ltd, Gandhinagar: Its EPH was held on January 28, 2014. It is category A project but the assessment was done by consultants with provisional accreditation for category B, by San Envirotech Pvt. Ltd in association with EQMS India Pvt. Ltd. San Envirtech is provisionally accredited for category B projects.
  • M/s Kutchh Road and Building Division, Kutch: Its EPH was held on February 12, 2013. Its impact includes adverse effect on the sensitive ecosystem of the region. In all, 79.474 ha of forest landis in involved. There is lacking biodiversity study. The EIA report was prepared by Wapco Ltd in association with Consulting Engineers Services (India) Pvt Ltd. Wapco is provisionally accredited.
  • M/s Krishanj Pharmaceuticals Industries, Rajkot whose EPH was held on January 10, 2013. Its EIA is of very poor quality.  Evidence was found of copy-paste. The EIA was prepared by Pragathi Labs & Consultants Pvt Ltd and TR Associates, both of whom are provisionally accredited.
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