Environment impact assessment should be replaced by conflict assessment. The former belongs to a world view that is nature-unfriendly.
Chennai, Feb 07: "THE KING is dead. Long live the king" aptly sums up the private and public views of top Ministry of Environment and Forests (MoEF) officials towards environmental impact assessments (EIAs) for major projects. In private, they ruefully agree that EIAs have failed in India. In public though, the recent move to extend EIA regulations to cover major urban projects, for example large housing colonies, implies the reverse. Impact assessments have generated business worth a few hundred crore rupees per annum, but their failure may be causing environmental damage many times that value. Four factors contribute to the failure of EIAs. The first is the lack of proper guidelines. The weak 1994 EIA guidelines remain only on paper.
The EIA for a power plant suggested that the Karnataka coast receives snow and has coral reefs along its shore! The EIA for a magnesia plant reported average background air pollution levels in rural Visakhapatnam district to be significantly higher than the most polluted cities in India; and predicted sea rise due to global warming to be more than half a metre by 2025, but still recommends that the plant be located on the seashore. An addendum for a power plant in East Godavari district of Andhra Pradesh computed hazard ranges for a boiling liquid expanding vapour explosion in a non-pressurised tank — an impossible event with such tanks. The study for a large ammonia tank in Murmagao port did not consider the risk due to scores of ammonia trucks plying 12 kilometres daily through the heart of Vasco city. And in more than one instance, forests around proposed projects have been obliterated from satellite images before submission to the MoEF.
More importantly, EIAs do no impact assessment. Most EIAs present only pre-project baseline data and make post-project air quality predictions with models that are not yet properly validated in India. Common to all EIAs is the absence of credible impact assessment on human health and ecology. Yet, they make win-win conclusions that the proposed project will have little or no environmental impact, but will benefit all. Why then has environmental quality around most industrial areas deteriorated despite EIAs being done for nearly two decades?
The second factor for the failure of EIAs is the lack of verification of their data and impact statements. Since regulating agencies rarely make site inspections, it is not uncommon for EIA baseline data to be generated other than from the field. On odd occasions, if the EIA data does not match another data set, the difference is explained as being due to variation of environmental quality with time (seasons, even days). There is no incentive to improve confidence in data by collecting it year-round, as EIAs are one-time submissions meant to obtain environmental clearances. Once a clearance is obtained, predicted impacts are almost never verified.
The third factor is the lack of standard procedures for evaluating EIAs. Consequently, projects such as the magnesia plant pass through regulatory agencies without trouble.
The fourth factor is the lack of transparency and public review of EIAs. Impact assessment reports are not public documents. Only when they are occasionally prised out of regulating agencies do their errors and gaffes come to light. Impact assessment should be replaced by environment conflict assessment (ECA). The former belongs to a world view that is anthropocentric and nature-unfriendly. The latter would help begin the long journey to a more nature-friendly worldview. An ECA would include all elements of a good EIA, risk assessment (RA) of impacts on human health and ecology, and an assessment of the potential conflict between the project and a) humans, b) nature. This will allow for better verification of the impact statement. India has the experience of having done a few health RAs and at least one ECA. An RA for the Goa copper-recycling foundry indicated that had the plant used the raw material proposed in its EIA, a third of Goa's population would be at unacceptable cancer risk levels.

Good guidelines for doing ECAs must be framed. Based on a United Nations Environment Programme document, EIAs must include a description of: the project; the potentially affected environment; practical alternatives sites, technologies, products; short and long-term impact and conflict assessment of the project and its alternatives; assessment of measures to mitigate impacts of the project and its alternatives. The EIAs must provide an indication of: gaps in knowledge; regional impacts; and a brief non-technical summary of the ECA. Guidelines for evaluating ECAs must also be framed.