EIA, QCI and the EC Notification

[Ajay B Dwivedi]

Every professional in the field around is running to get thr coveted accreditation. I would like to have the following things highlighted.

1. The original Notification of 14-09-2006 never called for mandatory accreditation.
2. The compulsion of QCI accreditation has been implemeted by an office memo(OM). There have been so many amendments to the original notification.
3. Legality of the OM becoming a mendate has to be checked. We must recollect the fact that in case of CEPI the development could have been stalled through an OM(Jan 2010). Later things got diluted to a significant extent very soon. This proved that OM had got something basically wrong.
4. The QCI accreditation team for accreditation is not having resources to evaluate. For example, one of the activities infrastructure projects like road development or canal network where the assessment of a professinal "team" of QCI assesses the aspirant consultant without a single professional who is experienced himself of having executed an infrastructure project.
5. This is proved by the fact that approaching the deadline they are not through to evaluation of their first chunk of accreditation, i.e. organizations which went in process before 30-06-2010 are still awaiting evaluation.
6. The scheme in itself has been framed to monopolize the profession and comes in clear violation of constitutional rights of our country.
7. QCI has to remain focussed to their business not interfere to the Ministry's powers to mutate / break / separately interprete any content in the Notification verbatim. This is done by QCI with activities being broken up further from the Notification.
8. If all Ministries start working on OMs where is the necessity of Lok Sabha or Notification. This sort of operation should have been challnged in Court of Law.
9. The project proponent (PP) is not exempted from any process and there the EAC puts forward the governance of the Notification. So the route of convenience (for the officials only) is used.
10. State EACs have only been given an indication to follow the NABET / QCI accredited consultants. This was probably with a consideration that majority of development projects like housing projects, area development projects, local road widening projects etc. where local considerations are likely to out score the major environmental issues would be better dealt by local people with simple considerations. This type of procedural requirements will only add complications and thereby corruption only.
11. Rethink really for improving the quality of the EIA and worthiness thereof has any connection with QCI. I remember in my early days as professional in 1989 also EIAs were there and even without accreditation they were in a much better quality and the motive was served. Since 1994 reports have been prepared through official procedures and nothing objectionable has ever gone without being accounted for.

The enforcement through QCI appears to be in bigger interest of QCI rather than the EC process.

Quality EIAs and better EMPs can also be availed from people who are not necessarily extra-ordinary professionals. Ministry has to rethink over the simplification of the process in better interest of the progress of the Nation.

[Dr. Hemalkumar Naik]

Good to write such points..I had clarify all such longback but there are some authorities of MoEf and can take any action with out publishing in Gazzetes under regulatory framework. However, the other issues of legality is there which can make the scheme implementation dificult rather imposible as you already written matter of MONOPOLY etc. There are many points and metters which you have covered and i feel its good, But still when you talk about legal frame work you must go deep with EPA as amended timely as well as the rules enacted thereunder.

Further, I must appeal all professional to support genuinely the QCI scheme. However, MoEF & QCI shall also focus on quality and morethan that making a system to improve sytem of environmental welfare/improvement through the scheme instead of making stringent condition for EIA operations. Well there is a huge matter to discuss on this point. But i as a professional like to see such scheme for EIA in India.