Saturday, August 1, 2020

My City My Responsibility - Environment Clearance NOC or Clearing the Environment!!!

Dear All,

Source: Doughnut economics

Listening to all the VOICE by a group of environmental activists and others on the draft EIA notification, I was compelled to throw some light on the agencies and their capacities who authorize an EIA that is the MOEFCC, CPCB and the SPCB during a few years of my work as an Environment Consultant.  

I am an Environmental scientist and immediately after my masters I got an opportunity to work on Green Building Certifications and Environment Impact Assessments (EIA). I was super excited to know that now I can do my bit and create a positive impact on the Environment. Environment is an interdisciplinary and interwoven field full of complex connections and linkages. Its just like a food web that we see in our ecosystem, full of inter-connections. So I felt like working in a primarily 'non-environment' related field is the best opportunity to create these linkages and bridge the gap. That's why I will forever be grateful to have worked in an architectural firm with a group of architects, engineers, management folks and fellow environmentalists. 

When I got introduced to the concepts of green building certification, it was very tough for me to integrate these concepts in LIVE projects. I literally struggled each day right from working on softwares like AutoCAD along with architects and other consultants to the real estate developers in understanding their view point about development and a lot of core concepts on safety, ecology and overall well-being. Nevertheless I found my balance, and could eventually create some positive impact.

One striking feature about the green building certification is that the systems are set, and are locally adapted to an extent and can be effectively managed over a long period. Since I mostly worked on residential projects, I realized engaging the occupants residing in a green building needs to be enforced in order to make the project successful and sustainable. Green building certification process begins right from the planning stage of the project and hence there's a lot of scope for getting green building principles implemented on the ground. Even if not, there are things that can be retrofitted and they still work with a 50% chance. The other 50% mostly depends on the operation and maintenance of the environmental services post occupancy and that's where a green building concept FAILS! Nevertheless a lot of real estate developers undertake this initiative and its appreciable. However only a few of them do it genuinely out of concern for the sake of environment conservation, kudos to them! We need more such kind of environment conscious real estate developers!!!

Regarding Environment Impact Assessments (EIA), as per the 2006 notification, construction projects that have built up area upto 20,000 sqm and above are required to undergo an EIA. My first hand experience with the real estate developers initially was like 'ok here are the Environment NOC people just give them whatever they need and get this done'. But then during the State Appraisal committee hearings in Mantralaya, Mumbai these developers experienced the seriousness of this NOC, since it can be a criminal offence if they do not adhere to the required compliance. The committee constitutes of experts from varied fields - scientists, architects, engineers, retired IAS officers, ecologists etc. and their comments are quite straight forward, critical and to the point. It was a great learning experience for me. During these hearing though the project complies with all the required papers, a lot depends on the attitude of the developer, his status, ties and relation with the inside people in order to get the clearance. The entire process to finally get an Environment clearance NOC is very much bureaucratic and frustrating, for everyone associated with it and THE Environment. This may have changed now with the whole Ease of doing Business notion but not in favour of Environment!

Both the processes, green building certification and EIA are flawed because they consider the environmental aspects in isolation. These processes fail to create societal connections except some local protests and fail to make associations with other ongoing urban development policies in the light of climate change and sustainability. There is always a debate on Environment vs Development, please click here to read the blog by Dr Priyadarshini Karve that HOW this debate in itself is futile.

After getting the required certification and NOC, the system completely lacks a reality CHECK of the compliance as per the NOC, though it is mandatory by law. It is crucial to see if the project adheres to the norms. On ground, things are very different for most of the projects, with a few exceptions! But a sound coordination between the Ministry, Central Pollution Control Board (CPCB) and the State Pollution Control Board (SPCB) along with the local urban body is gravely missing. Its a gamble, nobody says it but everybody knows it - the pollution control board has nothing to do with environment and climate change, they are merely corrupt liaisoning agents. So the point I want to make is, unless the ties between all these agencies are strengthened with sound knowledge about environmental aspects, climate change and above all sustainability with respect to urban development any EIA or green building activity is simply a money minting process. There is a need to design efficient capacity building programs at all these levels in order to build better enviro-legal system and make urban development sustainable!

In case if you have any comments or suggestions you can email them at OR check out this LINK for more info on the Draft EIA notification and objections. Last date is 11th August 2020.

Pournima Agarkar. 

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