Impact Assessment of Environmental Impact Assessment


One of the reasons why the Ministry of Environment & Forests (MoEF) introduced the Notification on Environmental Impact Assessment (EIA) in 1994 was perhaps to create new business avenues for environmental consultants to monitor laboratories and related assignments. In fact, as per the Notification, EIA reports were required for projects listed  in a Schedule based on certain thresholds (the logic of which is not known even today) and  the project proponents looked for agencies that could help them get Environmental  Clearance (EC) at the least cost and in the shortest possible time.

The consulting fraternity in India responded to this need and mastered the art easily,  using technology from Microsoft – i.e. MS Word (with control C and control V being the main tools). During the EC process, committees were created at the State and Central  levels, and members of such committees got an opportunity to showcase their expertise and ask questions so that the EC process resembled a long tunnel – the journey being in “darkness”. When Public Hearing was included in the EC process, it opened another Pandora’s Box – creating a role for environmental activists.

Some truly believed, and naively so, that the ‘impact of EIA’ in India had been a positive  one and ensured that major developmental projects included environmental and social considerations to reduce risks and add a value. If one were to ask project proponents and consultants today, they would be able to quote very few instances or case studies wherein real benefits of EIA had been realized. Getting an EC ‘somehow’ has been the main driver in most cases.

EIA in India has not yet seen the maturity that the country deserves. In many cases EC has been a political process and not that of scientific inquiry. ECs are issued on project basis – i.e. isolated – and not on cumulative or regional considerations. Who cares for the carrying capacity? Tools like Strategic Environmental Assessment that are legislated in many countries are not even discussed. Integration of Climate Change (CC) in the EC process of
large projects is not even thought about yet. Now that MoEF has a new name with CC added to it, consideration to Climate Change should be given in the EIA process. Am I being too optimistic here?

So since 1994, more than 2 decades now, has EIA benefited India in helping improve our projects (concept, scale, design, siting and technologies) and protect/conserve our environment? Has EIA provided better alternatives? It’s time that we do an impact assessment of EIA in India.

For Students – You may like to visit websites of State Environmental Appraisal  Committees and analyze the statistics on EC, time taken for clearance, conditions stated  and cumulative impacts that are not considered.
Visit http:// in particular.

Why should Green Products cost more?

You walk in a supermarket in the section of green products and often get intrigued why the prices are a wee higher from the equivalent” “brown” products. For some, this price hike is justified as these products have a “brand” so to say. Sporting an Organic T shirt in a party or serving an Organic Coffee post a celebrity lunch has that “distinguishing” feature that you are essentially paying for! But fundamentally, why should you pay more for green products?

Many believe, and rightly so, that the market size of green products is rather small today and economy of scale does not simply come in as an advantage to the manufacturer or retailer.  Green products get produced in small lots, more like boutique items and hence tend to cost more. It is weird that manufacturers go out of their way to make green products that cost more money – consumer does not buy them and then the manufacturer says “See, no one wants them!

A green product should ideally be resource-lean and generating low wastes/residues. So it should provide an advantage of less cost of inputs (water, energy, materials) and that of processing outputs (wastes/residues). All this should improve competiveness and provide an incentive to make more volumes.

Again, Green product, if truly green, must cost less, if accounted in a life cycle perspective. The problem is that life cycle costs and benefits are not generally computed and demonstrated to convince the buyer or the consumer. Price is often the driver for the decision. Life cycle costs and benefits are unevenly shared and are often hidden.

Some argue that green products are bound to cost more if they use frontier technologies and materials that are yet to be commercialized. If green products use recycled materials  then cost of recycling is sometimes more than cost of virgin materials because of disproportionate costs of reverse logistics and often due to perverse pricing of resources. Green products are expected to be compliant across the supply-chains that have informal segments. So you pay more for organic food ingredients as here manufacturer will ensure proper wage to the labor.

There are companies however who have set prices of their green products comparable to those conventional and in some cases kept the price of green product a wee lower! Examples of such companies are Sierra Nevada Brewing company, that uses fuel cells; Stonyfield Farm and Trader Joe’s yogurt, that have reduced packaging; General Mills, which reduced the shape of noodles in Hamburger Helper to reduce packaging volume by 20%, and Procter & Gamble and Unilever, in association with Wal-Mart, who changed liquid detergents to concentrated formulas to reduce consumption of water, plastic, and cardboard. So what works is the innovation in greening.

So when you next visit the Supermarket, look for companies, that maintain or lower the price of green product. These companies  will represent hallmarks of innovation and long term interests in influencing the markets  towards ensuring business with sustainability.

 (Blog based on article I published in Green Prospects Asia. You may like visit report prepared by Green Purchasing Network of India on Consumer Perception of Green Products. Visit

Sustainability – Make it Smart and Simple

Sustainability’ is a buzz word that has spawned industry-wide interest and led to the emergence of several corporate sustainability initiatives in the recent times. However, many enterprises struggle to achieve significant tangible outcomes from sustainability based initiatives. Sustainability is perceived to be more of a branding strategy and many skeptics look at sustainability as just a green wash.

While some say that sustainability pays, it is hard to find clear evidence that reports material or economic gains or advantages. Most ask – we understand importance of sustainability but how do we put sustainability into practice? And what is the advantage?

This question was asked to me by Chairman of one of the group of industries near Mumbai. He put this question more as a challenge. We met over a dinner then and went through a long conversation on how to make sustainability happen! This dinner conversation led to a road map. We were not fully clear whether we were on the right track but we decided to make a beginning and remain open for any changes.

The first thing we did was to develop a policy statement that enshrined sustainability. We did this by inviting a small group of top management, worker union representative, company lawyer and principal company investors. The policy statement was simple, not ambitious and it drew upon guiding principles such as do no harm, conservation of natural resources etc.

These guiding principles were then discussed with company’s operational teams to develop projects that best reflected the policy commitment. Conservation of natural resources principle for instance led to identification of projects on rainwater harvesting and vermi-composting. The  do not harm principle led to a mission on replacement of Ozone Depleting Substances (ODS) and promotion of renewable resources as a principle led to a project on solar water heating at canteen.

All these projects were designed and evaluated for cost-benefits where benefit calculation included both tangible and non-tangible returns; and on scales both local as well as global such as reduction of GHGs. Some projects on a standalone basis had a relatively long payback period but some projects did have high economic returns. On a “basket” basis, the projects were financially sustainable.

A project implementation plan was then prepared with financing arrangements. There was also a need to update company operating procedures, especially in the ISO 9000 documentation and impart associated training. This required a communiqué on the basket of projects to the third tier of the company team – giving them the genesis or the project finding process – and importantly its sustainability based policy root. The teams were accordingly sensitized and involved in implementation on a departmental basis. An element of competition was brought in.

The projects were implemented gradually with evaluations done to report project effectiveness and innovation e.g. water and energy saved, wastes avoided, wastes recycled, hazard reduced etc. The overall environmental performance of the company improved and moved closer to the industry benchmarks with economic gains. A catalogue of project sheets was developed, and shared through company newsletters and notice boards. This led to a comprehensive communiqué to the staff and the shop floor workers

I suggested the Chairman to take the sustainability story further ahead to the families of the employees and the neighbourhood.  We organized an outreach programme on a Sunday where children of company employees and neighbourhood visited the factory to see the projects implemented. Some children were excited to do a school project on vermi-composting using the data on vermi-pits and some college youth wanted to look at options for use of treated wastewater for gardening. All these engagements and interactions led to generation of more field data and better understanding of the technologies.

Some people in the neighbourhood decided to replicate solar water heaters. So the message on sustainability spread! A feedback session indicated that the stakeholders were convinced that sustainability is not just to be believed but to be put in practice with results and experience shared. I asked the Chairman to put aside funds that could help the entrepreneurs in the neighbourhood to set up businesses on solar water heaters. This fund was linked to Corporate Social Responsibility (CSR) and routed through a local commercial bank. There was an excellent response. The company put its seal/logo on the solar heaters that were supported and this led to co branding.

This is a story – some 15 years ago. Today, we use sophisticated management systems, reporting guidelines and mechanisms to express and demonstrate our commitment towards sustainability. In this maze however, simple approaches often get lost. The internal and external communications are poor or neglected. A kind of green-washing happens – though not intended!

Let us focus therefore on demonstration and practicing – and less on preaching on sustainability. Let us be smart and simple!