Why baseline data can not be collected for EIA studies before TOR approval from MoEF

[Ratnakar Pandey]

Why we cannot start Baseline data collection for EIA study as per model TOR by simply informing to MoEF about project & giving them undertaking that whatever decided by EAC/SEAC will be incorporated and addressed into EIA/EMP Report  - This will shorten the EIA study time & ultimately project development time – Express your views

[Prof Dr V N Sivasankara Pillai]

ToR defines the content and methodology of EIA. Content is defined, among other things, based on baseline data. Especially EMP is formulated to improve the quality of the environment. There is nothing wrong in collecting secondary data before defining ToR. Collection of primary data will be incomplete if ToR is not defined.

[GOPI KANTA GHOSH]

It is deliberately avoided

[Dr. Hemalkumar Naik]

it is allowed and numbers of consultants are practicing it. You just need to inform this to EAC during TOR presentation. Till date numbers of project have been cleared based on the data collected before TOR or simultaneously with TOR process. The additional scope of work if required by Awarded TOR shall be incorporated in EIA. Even you can use data you collected for other project in Same study area. So just do better plan and go ahead with transparent quality practice for baseline data.

[Ajay B Dwivedi]

The provision in EIA Notification simply does not allow PP to do things without approval. What you get as TOR is additional TOR. PP's proposal for TOR can be considered accepted only if the same is minuted and communicated by acceptable means to the Govt.

If the PP is in a hurry, he should have done the thought process earlier. Govt and public are not concerned for any of the aspirations of the PP and the anticipations of EIA consultant

[sn verma]

It was being allowed and there was nothing wrong in it, this is my perception. However it is not being allowed now. Even if you tell the committee that you have started the monitoring work, they simply do not agree. The pp does suffer in this regard. For eg some pp decides to go for an EC, he spends about a 15 day to a month to decide on the consultant. The consultant is finalised in March. The consultant will take about 10-15 days to fill up form 1 and submit. The EC hearing date gets fixed in April or May depending on the date of submission of the form 1. So the summer season period is gone. Monsoon period is not allowed so one can start the monitoring only in November. So who suffers? the PP of course. On one hand Montek Singh cribs that the industrial growth is going down. so its a catch 22 situation for the industry.

In lighter vein, as the marriage season is fixed in particular months only, the industry should also be given dates when to start the thought process for filing of the EC, when to award the work, when to file form 1 if he wants the clearance to be obtained within shortest time (provided of course, the PH goes well). 

 

[Ratnakar Pandey]

Dr. Naik,

 

What ever you have quoted is not in practice, MoEF is not allowing to PP for baseline data collection before TOR approval, i personally met the few of committies member secreteries but they straight said no you can not.

 

Dr. Hemalkumar Naik said:

it is allowed and numbers of consultants are practicing it. You just need to inform this to EAC during TOR presentation. Till date numbers of project have been cleared based on the data collected before TOR or simultaneously with TOR process. The additional scope of work if required by Awarded TOR shall be incorporated in EIA. Even you can use data you collected for other project in Same study area. So just do better plan and go ahead with transparent quality practice for baseline data.

[Ratnakar Pandey]

Dear Sir,

TOR only specifies the scope of the EIA study, most of things are disclosed in model TOR & technical giudance manual of the major red category industries means how to monitor & what to monitor ....etc

but MoEF delibrately is not allowing the baseline data collection for EIA although it has no harm.
Prof Dr V N Sivasankara Pillai said:

ToR defines the content and methodology of EIA. Content is defined, among other things, based on baseline data. Especially EMP is formulated to improve the quality of the environment. There is nothing wrong in collecting secondary data before defining ToR. Collection of primary data will be incomplete if ToR is not defined.

[Ajay B Dwivedi]

Data collection on basis of TOR for meteorological parameters individually for different projects in the same area is simple waste of resources. I've always had an idea that such data generated in specific areas say at one place in every district should suffice requirements. Amongst consultants we have sufficient data as of now.

Why do we have to do the same exercise again and again. If the predominant wind direction in a city was from SW to NE next year you cannot expect any change in same period that will affect the impact. Why every report has to contain such data for 'n' number of times.

If you go through TORs you find out that for any and every activity covered under EIA, data generation is more or less same. So if someone is putting up a mine or a bulk-drug factory, it does not make any difference in TORs issued to a greater extent. So such common / compulsory data generation has to be segregated and this data once submitted to SEAC / EAC should not be repeated in TORs for a specific and stipulated period by authorities issuing them.

If SEAC/EAC  has to have "more reliable data" they should utilize their machinery in place of asking the PP or the Consultant to do so and then certify the data to be "unreliable".

Like in case of CRZ where the data sought these days is on a scale of 1:4000 whereas the satellite is collecting the data on 1:25000 scale by simle enlargement it is not possible to have the data because the spatial resolution / dpi strength does not increase.

This is where they should use this limitation included in the Notification and limit the PP from collecting the data and not for other items where futile duplication of data is practiced for pleasing the PP and increasing the gross weight of the report.

[Harishankar Soni]

Dear Members,

Good Morning,

As per EIA Notification 2006 & as amended 2009, the project proppnent shall apply TOR for the green field project with three alternate site along with selected site. TOR approval is basically scoping and detailing of the EIA content/component as well as approval of proposed site. if any reason selected site is not approved by EAC then baseline data collected in particular site goes waste. Hence in my opinion baseline data is to be collected after approval of TOR.

 

[Ajay B Dwivedi]

All people participating are extremely experienced and still we read "told", "discussed", "debated" but we seldom read "minuted", "circulated" and "notified". Point is we have to do what has come in written only. So the entire question of working for TORs things without any written protocol has to be avoided.

[Ratnakar Pandey]

I do agree with you on a portion & would like to specify that it is only applicable for some of the selected sectors, if i quote here hydropower sector where the matter of alternate site is no possible then how 
  much it is practical ???? knowing that project gestation period is quite higher.
Harishankar Soni said:

Dear Members,

Good Morning,

As per EIA Notification 2006 & as amended 2009, the project proppnent shall apply TOR for the green field project with three alternate site along with selected site. TOR approval is basically scoping and detailing of the EIA content/component as well as approval of proposed site. if any reason selected site is not approved by EAC then baseline data collected in particular site goes waste. Hence in my opinion baseline data is to be collected after approval of TOR.

 

[Ratnakar Pandey]

Sir,

For this discussion my focus is primary data collection  not any published/secondary data. as for as concern of data reliablity you have coorectly quoted & i also endorse that MoEF/EAC must have their own data validation mechanism.

Ajay B Dwivedi said:

Data collection on basis of TOR for meteorological parameters individually for different projects in the same area is simple waste of resources. I've always had an idea that such data generated in specific areas say at one place in every district should suffice requirements. Amongst consultants we have sufficient data as of now.

Why do we have to do the same exercise again and again. If the predominant wind direction in a city was from SW to NE next year you cannot expect any change in same period that will affect the impact. Why every report has to contain such data for 'n' number of times.

If you go through TORs you find out that for any and every activity covered under EIA, data generation is more or less same. So if someone is putting up a mine or a bulk-drug factory, it does not make any difference in TORs issued to a greater extent. So such common / compulsory data generation has to be segregated and this data once submitted to SEAC / EAC should not be repeated in TORs for a specific and stipulated period by authorities issuing them.

If SEAC/EAC  has to have "more reliable data" they should utilize their machinery in place of asking the PP or the Consultant to do so and then certify the data to be "unreliable".

Like in case of CRZ where the data sought these days is on a scale of 1:4000 whereas the satellite is collecting the data on 1:25000 scale by simle enlargement it is not possible to have the data because the spatial resolution / dpi strength does not increase.

This is where they should use this limitation included in the Notification and limit the PP from collecting the data and not for other items where futile duplication of data is practiced for pleasing the PP and increasing the gross weight of the report.