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

[sn verma]

The entire TOR is a futile exercise. Why they have TOR in the first place is difficult to comprehend. We have been doing EIA since more than 20 years. I feel that the TOR should be standardized according to the projects involved (e.g bulk drugs, organic intemediates, mining etc.). If the minutes are checked on the MOEF website, they are the are more or less the same depending on the type of project.

Consider the case of Micro and SSI units who giving maximum employment to our rural unemployed people. (None of the multinationals will give employment to less educated youth of the villages). Coming back to the discussion, cost of going to Delhi for TOR is handsome amount of money considering green field / expansion project of say 40-60 lakhs.

If they have standard TOR then lot of time can be saved and it is good fortune that no body has fainted while waiting for their turn since they do not have their own conference hall or any seating arrangement. I remember just before the CWG games, the PP were sitting outside on the road, under trees. It was pathetic situation. Only lately MoEF has made excellent arrangements to PP to wait for their turns

 

[Ratnakar Pandey]

Those sectors which have model TOR in place also can not monitor the baseline data until or unless TOR is approved by MoEF.

[Ajay B Dwivedi]

Sir,

When the Govt pays money to people on suffering damages in Railway accidents because they bear responsibility. Having accepted the accuracy of data the EIA consultant has to be indemnified against any litigation also arising out of the data furnished on completion of the EIA. The EIA consultant is grossly unprotected and requires some sort of indemnification included when reliability is so much sought after thing. Here, the fun will now begin, EIA will be prepared for PP, By Consultant, Submitted to MoEF / SEAC, Accredited by QCI/NABET, Sampled by NABL accredited laboratory.

Does this much exercise warranty any accuracy.

This may be read deviated from the subject, but primary data collection, if we put in terms of the system is required to be done as an activity is ""Under Control" of the primary subject. Here, secondary data is considered secondary because the role of PP is restricted to "influential" only. So if MOEF wants it done that way be it.

Ratnakar Pandey said:

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.

[RAGHAVA]

Dear Sir,

 

we understod your concept however,THe Terms of Referene is issuesforhte projedt site and site coordinates. More presicely my intentions is that we send a rather 5-8 pages qustionnaireof TOR application and the committe after going to the application made provideds the necessar TOR forthe specifici project without calling the PP to the presentation itself so that so much of stationery is saved and also that the travelling by any means which creates which creastes pollution to atmosphere also decreases.

 

may be i cna continuedthis discusion since i had to leae my child i am rushing

[Veeraprasad Mukka]

Mr. Pandey,

 

You are absolutily right. It well reduce the timeline of EIA also.

as per my experience, Add. TOR is almost similar what Project proponent submitted except veryfew. however, in between we can collect the primary and secondary baseline date

Tnks and Regards

Veera prasad Mukka

 

 

[Kuntamalla Sudershan Rao]

There is no hard and fast rule that the EAC questions are restricted to ToR issued. It is often seen that EAC members talk other than their discipline. In reality the baseline studies will not be changed in many cases except in few.

[Ajay B Dwivedi]

If you go through the Notification, you realize that PP has to propose TORs. EAC/SEAC is empowered to approve them. This can be done at the end of the meeting. The beurocracy of these EACs and the inherent habit of Govt official of slipping away from bearing responsibility but they always want to enjoy powers vested through the system. Otherwise, PPs can get confirmation in written at the end of the meeting itself. Let the things be minuted at their ease.

When you have 10 projects within 10 km radius why data cannot be used interchangably. Noo  need to waste resources, this ultimately leads to malpractice. When there is no difference in TORs how the reports will be different? If after a number of repitition there is no reliability in data found it reflects that data expected are not in fitness of matters. Every EIA consultant's data cannot be unreliable. Similarly, every data produced by Govt machinery cannot be reliable either. Rationality lies midway.

TOR proposed by PP has to be authorized at the end of the meeting in written. If the authorities are not in a position to do so, the PP should take it for granted.

[sn verma]

 

In reality even if some one collects the data before the TOR's are issued, what difference is it going to make. The data is not going to vary within one year, except there is massive change in the land use pattern, which is not going to be the case like those projects located in a notified Industrial Estate. (projects located in notified industrial estate are not going to go to Delhi for EC clearance as they will be cleared by SEIA).

I agree with Mr. Dwivedi and would like to add one point is that the committee should become practical and infact they should order the PP to collect the data from the PP whose project has already been collected, analyzed and cleared by the committee (not more than a year depending on the change in the landuse pattern) or MOEF themselves can part with the data for a nominal charge. 

In reality MOEF based on the projects cleared or not cleared can update the environmental atlas of an area after each month as per the decisions made during the meetings.

 

Imagine the situation, if such a condition becomes a reality,. The project will or will not be cleared in a jiffy and Mr. Montek Singh Alhuwalia can sleep peacefully since the industrial growth will inch forward rapidly toward his target.

[Ajay B Dwivedi]

Here, every consultant is literally made to dance to two different tunes one from authority and the other from the PP. 

PP is in a hurry to 'get rid' of the 'pollution board' issue.

(PP seldom distinguishes CPCB/MoEF/SPCB/DoEF/EAC/EIAA - so for him it is Pollution Board)

Authority thinks consultants are their toy and are always dance to tune of their commandments.

PP does not recognize what the baseline survey is.

Consultant is a tailor who is paid to stitch a half pant that reaches his foot.

PP has got the consultant at the bottom of the priorities.

With so little to be listed the Consultant is a creature who has to bear all responsibility with no honor / dignity.

Look at the QCI / NABET they want consultant to be responsible for every data but do not want to protect the consultant in any corner by any mistake.

This may seem vague but it has got connection with the practice of not allowing monitoring before TOR issuance.

[sn verma]

Now by bringing in the NABET you have opened the Pandora's box.

[Ratnakar Pandey]

Sir,

 

Very good comment !!!

Ajay B Dwivedi said:

Here, every consultant is literally made to dance to two different tunes one from authority and the other from the PP. 

PP is in a hurry to 'get rid' of the 'pollution board' issue.

(PP seldom distinguishes CPCB/MoEF/SPCB/DoEF/EAC/EIAA - so for him it is Pollution Board)

Authority thinks consultants are their toy and are always dance to tune of their commandments.

PP does not recognize what the baseline survey is.

Consultant is a tailor who is paid to stitch a half pant that reaches his foot.

PP has got the consultant at the bottom of the priorities.

With so little to be listed the Consultant is a creature who has to bear all responsibility with no honor / dignity.

Look at the QCI / NABET they want consultant to be responsible for every data but do not want to protect the consultant in any corner by any mistake.

This may seem vague but it has got connection with the practice of not allowing monitoring before TOR issuance.

[Prof Dr V N Sivasankara Pillai]

Baseline data set is collected to define the pre-project status. Based on the nature of the project, its magnitude and site conditions, impacts vary. Impact will depend on the coordinates of wind direction, water migration, human settlements and ecology of impacted space. It is often necessary to model migration of chemical species and fauna, which depends on the topography as well. Hence it is wiser to collect detailed baseline data only after approving ToR.

Regarding accreditation: It is more important to impart education in ethics. It may be based on a syllabus staring from school to doctoral to professional.

It is also desirable to conduct certification program for consultants for their knowledge and skills in different sectors. Of course, basic education requirements cannot be diluted, since it contributed to holistic knowledge.