Ahuja, me and the CSR

After the incorporation in the Company’s Act as a requirement, Corporate Social Responsibility (CSR) has become a large business in India. There have been several CSR Summits, Conferences & Seminars and Roundtables over past three years, held practically every month in the metro cities such as New Delhi, Mumbai, Bangalore, Hyderabad and Chennai.

Organizations like the Confederation of Indian Industry (CII), Federation of Indian Chamber of Commerce and Industry (FICCI) have been busy in organizing these events with Indian Institute of Corporate Affairs (IICA) taking a lead. IICA has been canvasing training programs of 3 months and 9 months’ durations for CSR managers and implementing NGOs with certification. This “training business” hasn’t been very successful because of the high fees and poor delivery capacities. Finally, there has been a surge of newsletters and magazines as well and launch of CSR dedicated websites with a lot of content that is recycled. Thankfully the momentum seems to be damping down a bit and most involved are in a kind of “CSR fatigue”.

But honestly, CSR has opened a big canvas of new business to several. These include consultants who know how to write and present well (specially to convert something basic into a form that has a halo), report designers and video-graphers (i.e. the “communications people”), researchers who are fond of conducting surveys and of course the, environmental and social NGOs who help organizations to implement their CSR mandates with “community engagements” and conduct “independent assessments” of impacts. We also see consultants who help in management of funds to get the best “tax advantage” and provide IT based solutions.

A friend of mine walked in my office and asked “Dr Modak, does your company work in the CSR domain?”. When I said I really don’t work “exactly” in this arena, he was surprised. “Well, every environmental and social consulting organization in India is into CSR game tapping the business. You are already late”. I offered him a well brewed coffee. He left.

Another well-wisher friend dropped in. “You have a section 8 not for profit company as well and so a combination of” for profit” and “not for profit” is perfect to meet the “business requirements” and sponge the monies. You must use your network now and talk to the Heads of the CSR of some of the large corporations and make offerings. In some companies, the Chief Sustainability Officers (CSOs) look at the CSRs and in some companies CSR is handled by the Corporate Responsibility Units (CRUs)”.

I decided to venture in the CSR business. A friend advised me to prepare an attractive brochure and hire a team – one from Tata Institute of Social Sciences (TISS), Mumbai, someone from Miranda House in Delhi and a third person from a family of ex-IAS bureaucrat, retired recently from Ministry of Corporate Affairs. I decided to follow his advice.

I contacted few conference organizers of CSR events, and got hold of contacts of the participants and speakers. When I put together the list, I realized that more than 50% of these attendees were common and seem to be attending and speaking at every other event!

I couldn’t really find however any familiar faces from the environmental fraternity. When asked in the “market”, I was told that CSR head is altogether a new breed. The “conventional” environmental experts are asked to manage Environment, Health and Safety (EHS) and do “liasoning” with the State Pollution Control Boards to ensure compliance. The new breed that runs the CSR show in companies are essentially those who are shunted or promoted from the Public Relations (PR) or Human Resources (HR) departments. Position of CSR head is sometimes more for a temporary transfer before the person is moved to more important or more relevant position in the organization. But their biggest qualification is that they don’t know much about the subject of environmental management and sustainability. They are however smart enough to hide their ignorance and a complete lack of the perspective by throwing jargon that they pick up from the CII/FICCI conferences.

I approached one of the large corporates and sought an appointment of the CSR Head. “Idea is to give you presentation and let you know our interest, commitment and capability in CSR” My colleague from Miranda House explained to the secretary of the CSR head – in the right voice and the pitch. The secretary was rather experienced and unmoved. She said “Mr. Ahuja gets at least 3 such requests every day and is really tired of such presentations. He is travelling to the United States this week for a 2-week mission. On his way back, he will attend a CSR roundtable in Amsterdam organized by the Global Reporting Initiative (GRI)”.

We were given an appointment after 3 weeks for a half hour slot in the afternoon. ” Check with me once again’ the Secretary said “Mr. Ahuja’s schedule is always packed and unpredictable”

I told my Professor Friend about meeting with Ahuja. He laughed. “You are wasting your time Dr Modak. I know Ahuja. A pretty drab person. He was brought as Head, CSR because of his poor performance in the company. Idea was to limit him to messing only 2% of the profits”. Professor lit his cigar.

“Ahuja’s wife is a friend of MD’s wife in a book reading club and that connection seems to have worked for him”

“Wow you seem to know everything Professor” I said

We went to Ahuja’s office in time. The TISS girl had prepared a dossier for me using all the right words – like 360 degrees’ approach, smart sustainability, social rate of return and pictures like “before” and “after”.

We were asked to wait. The secretary told us that Ahuja is swarmed with meetings after his international tour and may possibly give only 20 minutes. “Keep to only 5 slides”, the secretary said in a rather terse tone.

We were taken to a conference room after a wait for an hour. In this period, my colleague, daughter of ex-bureaucrat of MCA, told me about her dad’s transfers and how in this process she travelled and studied across India “Oh, this is like a 360-degree exposure -we should talk about this” I said. She smiled.

Mr. Ahuja entered the conference room.

“Who is Modak here?” He beamed. I raised my hand as done by a kid in the school when asked by the Teacher.

“Modak, I don’t know much about you and your organizations – but let me be clear”

“I get at least 2 such presentations every day and every presenter tells me a story that they are the best in CSR”

“I am not here to write a cheque. To us CSR is a culture. And we are very selective and sensitive when it comes to associating with CSR implementers

(I remembered this as a bi-line in Ahuja’s sustainability report)

These opening remarks were said in an icy tone. Ahuja was wearing half rimmed spectacles with thinnest lenses – that made his face look critical and intelligent.

I started my 5-slide presentation. As I was on 3rd slide, Ahuja stopped me

“Please come to the point, I really don’t like beating around the bush”

I was not comfortable with this snappy interception. I wanted to introduce the concept of Strategic CSR, weave in “business and sustainability”, highlight the process, illustrate case studies of relevance to Ahuja’s company and come up with an action plan.

I felt like a mouse sitting in front of lion Ahuja

At this very moment, the telephone rang. Ahuja picked up the phone “Rita (secretary’s name), I told you not to disturb me”. He cleared looked aggravated.

But there must be someone important or higher up on the phone as Ahuja said “Yes Sir” and he said this four times before ending the conversation.

“Modak, why didn’t you tell me that you are a friend of Professor who is an adviser to the PMO. Can you please stay a bit longer and explain your plan for us? I have all the time and interest to listen to new ideas. We are always open to innovation. And I am sure we will find a way to work together” He sounded now friendly. He removed his spectacles. Rita got us some coffee.

I met Professor in the evening in our usual Coffee shop.

“Professor, why did you intervene? I could see a transformation in Ahuja. He was simply shattered after the phone call”

“Well Dr Modak, knowing how you work, I knew that your meeting with Ahuja was going to be a waste of time.  So, when I met the MD at the Chembur golf club in the morning, I briefed him about you and stressed that your involvement in the CSR will be very useful for the company. And so, the MD called Ahuja” He said this with a smile. “That is how the CSR business works, my friend”

“All your proposals will be accepted now” He winked.

I returned home thinking whether it was worth to get associated with companies of “Ahuja kind”

I decided to write to Ahuja stating that I will not submit a proposal. I thought I will also say that I am very selective and sensitive when it comes to associating with CSR implementers” (essentially giving him back his own words!)

I had learnt my lesson.

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Cover image sourced from http://mallenbaker.net/article/clear-reflection/definitions-of-corporate-social-responsibility-what-is-csr


Something Fishy About 500


I was on the campus of IIT Bombay last week. I saw my Professor Friend rushing out of the Central Library.

“What are you researching on Professor?” I asked

“Well Dr. Modak, I have been quite intrigued with the use of number 500.  Many seem to have taken quite a fancy for this number” Professor lit his cigar as we started walking to the IIT Canteen.

“Oh, I don’t think anything deep in the number 500 Professor. Number 500 is an HTTP status code for Internal Server Error. Number 500 also shows up as an SMTP status code meaning a syntax error has occurred due to unrecognized command. There is no other significance”

“Oh, don’t trivialize the importance and mystery of 500”. I could sense that Professor did not like my simple explanation.

So I thought of a better explanation. I said

“Number 500 is a blend of the vibrations of number 5 and the energies of the powerful number 0, appearing twice. Number 5 resonates with making major life changes, spontaneity, life lessons learned through experience, making important choices, personal freedom, auspicious opportunities and being true to yourself” I reeled out this explanation like you read in the Wikipedia.

“Oh Dr. Modak, what kind of world are you living in? Think in the environmental context” Professor said this in a rather disappointed tone while descending down the staircase leading to the Canteen.

We took our seats on the metal chairs around a table with uneven legs. We purchased coupons for two plates of bread and omelet (You may not know but IIT Bombay staff canteen boasts to serve one of the thinnest omelets in the world). We also got some chai.

Professor then explained to me the real implication of Number 500 from an environmental perspective.

“Dr. Modak, you are aware that 500 meters are specified in India’s Coastal Regulation Zone (CRZ) notification. It states that the land area from High Tide Line to 500mts on the landward side along the sea front is in the CRZ. There are development restrictions stipulated accordingly. The number 500 therefore matters to all the builders, developers, government officials. To some Chief Ministers, relaxation in 500 m can mean a land bank that can make money more than Putin and Trump put together ”

I added “Yes, I know, but don’t forget the fishermen”. Professor did not seem to be much bothered about my reminder.

Indian Ministry of Environment and Forests passed the CRZ related regulation in 1991 and defined various zones such as CRZ-I, CRZ-II, CRZ-III and CRZ-IV. Each zone lists what is permissible and what is not with opportunities for interpretation.

The CRZ regulation has become contentious because of growing conflicts between the fishermen and those who want to develop hotels and projects near the coast. Balancing these interests has always been a tough call. The 1991 regulation was amended 25 times before it got comprehensively revised in 2011.

“So how was this 500-m number arrived at?” I asked

“Nobody knows Dr. Modak and nobody questions whether this number ever had any scientific basis” Professor sounded rather exasperated. “Rationally, the distance should be arrived at based the impact potential of the shoreline activities. Ideally the distance should be site specific as vulnerabilities in coastal areas will be different at different locations. Putting a blanket “buffer” of 500 m is like trying to fit one size for all”

“Well, you are right Professor” I couldn’t disagree. I thought it will be worth to develop a Vulnerability Index (VI), using information on our biodiversity hotspots, considering currents and depths, likely sea level rise and satellite imageries with thermal band. This VI may help in setting guidelines for the distance on a more objective and rational basis. I thought of offering this as a Masters dissertation to students at IIT Bombay.

Professor continued

“Dr Modak, the supremacy of number 500 does not stop there. Its now creeping into other spheres intruding our lives”

Last December, the Supreme Court of India ordered closure of all liquor shops along national and state highways if they were within a range of 500m from the edge of such highways, and directed governments to “cease and desist” from issuing excise licenses after March 31, 2017. A bench led by Chief Justice of India J S Khehar reduced the limit from 500m to 200m for “municipal corporation, city, town or local authority” provided the population was 20,000 or less after noting that the entire township might fall within the 500m-range. States of Sikkim and Meghalaya have been exempted from this directive where almost 90 per cent of liquor shops were to be closed because their relocation was not possible due to topographical constraints. These shops have been completely exempt from this directive by the court.

“Oh, number 200m also seems familiar – its stipulated in CRZ-III” I recalled

“Well Dr. Modak, The CRZ notification is so much discussed in the Indian courts that I was expecting schema of DRZs I, II and III on lines of CRZ-I, II and III” Professor said.

“What is DRZ? “I could not resist to ask

“Oh, its Drinking Regulatory Zone” Professor winked.

“This is terrible – why this restriction Professor” – After a long drive, stopping by a dhaba for a glass of chilled beer with egg bhurji was always so heavenly – that I was surely going to miss.

The Supreme court has noted that nearly 150,000 people die due to road accidents resulting from drunk driving. This is a matter of great concern and hence a basis for this ban.

I kept shut. You may know that millions of people in India die due to Non-Communicable Diseases (NCDs) especially due to the rampantly growing diabetes. I was worried that that one day the Supreme Court will simply ban shops selling sweats within 500 meters’ distance from the schools and hospitals.

“The Honorable Judge should have thought of other options. Like limiting to sale of only low alcohol drinks (e.g. less than 2% alcohol content)”. I suggested.

“Well, enforcement of such recommendations is impossible. You are talking like a typical IIT intellectual who makes impractical suggestions” Professor pooh poohed my idea.

“Note that there is an ambiguity in the definition of 500 m distance as well. It is not clear whether 500 m refers to the direct distance (on the map) or distance travelled by road. Some hoteliers are asking for the latter definition based on road or travel distance”

This ambiguity in the DRZ sounded to me similar to the controversies in the calculation of distances in the CRZ.

Professor continued

“I expect that this imposition is going to Increase the national fuel consumption and hence the GHG emissions making tough for us to meet our pledge in the INDC released in COP21. People will now drive more than 500 m, circle around and search for a liquor bar now. They will eventually drink and so the death toll may not actually reduce”

“You have a point Professor”. I said this while walking towards the car outside the Main Building.

As I was getting into my car, Professor looked at me and spoke in a deep voice – “Dr. Modak – On number 500 again. Remember PM demonetized Rs 500 notes and not 100 Rs”

He was right once again. Indeed, there was something mystic about the number 500 – both to the politicians and judiciary.

Professor turned back and said “Let me get back to the Central Library therefore to research on why 500?

I drove back home wishing him all the best.

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The Noisy Indian

Sound is what we hear. Noise is a sound that we don’t want to hear. The difference between sound and noise depends upon the listener and the circumstances. Rock music can be a pleasurable sound to one person and an annoying “noise” to another.

We are all subjected to some form of loud noises for a considerable amount of time, during the day and night. We bear with the noise created by blowing of horns on the roads, noise created by the loudspeakers, tolerate noise during festive-times and during processions carried through the street. It seems like people consider noise as an expression of happiness, especially the Indians.

Noise pollution is one of the major environmental concerns in India today. Sadly, many are unaware of the hazards it can cause.

Noise pollution is linked to many ailments – from irreversible hearing loss to anxiety attacks to hypertension and heart disease. The situation is so bad in Indian cities that ENT specialists now say a 20 dB loss in hearing among urbanites is “normal”. Changes in the immune system and birth defects have been also attributed to noise exposure

To measure noise, the average pressure level of the sound is used over time by a weighting scale. The noise level is generally expressed in decibels.

Indian Ministry of Environment & Forests issued Noise Pollution (Regulation and Control) Rules in 2000. These rules were last amended in January 2010.  The rules prescribe noise standards in decibels based on area and time.  For residential areas, the standard is 55 dB (Leq) in the day time and 45 dB (Leq) at night.

Day time means time from 6.00 a.m. to 10.00 p.m and night time means time from 10.00 p.m. to 6.00 a.m. dB(A) Leq denotes the time weighted average of the level of sound in decibels on “scale A” which relates  to human hearing.

The Noise rules are meant for the following:

  • Implementation of noise standards in different zones or areas.
  • Restrict the use of loud-speakers.
  • Restrict the over-usage of horns, sound creating equipments for construction and fire-crackers.
  • Allott responsibility to State Pollution Control Boards (SPCBs) or Committees and the Central Pollution Control Board, for collecting, processing and providing the statistical data about the noise pollution, so that adequate measures may be taken to prevent and control.

On violation of these rules, the person is liable for penalty. The government is now working on devising new noise pollution standards.

In March 2011, the central government set up the National Ambient Noise Monitoring Network (NANMN) of 70 stations, through Central Pollution Control Board (CPCB) and the SPCBs, to monitor noise on a 24×7 basis in India’s seven largest cities. These cities include Delhi, Bengaluru, Kolkata, Chennai, Hyderabad, Lucknow and Mumbai (and Navi Mumbai). It is expected that the number of locations to be monitored will be increased to 160 cities in two phases.

A four-year study (2011-2014) on Noise pollution based on NANMN showed that Mumbai is the noisiest city, just ahead of Lucknow and Hyderabad while Delhi stood fourth and Chennai fifth. The busy ITO junction in Delhi registers around 74 decibel (dB) of sound on a typical day, almost 10 db over the limit for the commercial areas. The level near Acworth Hospital in Mumbai’s Wadala is usually 70 dB, almost 20 dB more than what’s permitted in such a zone. Even the “silence zones” – (areas within 100 metres around hospitals, educational institutions and courts) -do not meet the noise standard.

Several studies have been conducted to learn about the noise levels during Diwali festival. As per the study conducted on noise levels due to Diwali firecrackers by Awaaz Foundation along with the Maharashtra Pollution Control Board  the noise pollution reached to over 125dB between 2008 and 2013.

CPCB released a report in 2016 “Status of Ambient Noise Level in India” that provides access to the noise data. It’s an excellent report to read and understand the problem of noise pollution in Indian cities.

I was speaking to my Professor Friend after reading this report. We met in a bar where the audio system was under renovation and hence we could have a conversation. We asked for some draught beer and took seats next to the bar.

“Well, I am just returning from Delhi after a meeting with the High Command” Professor said.

“Now that the State elections are over, we have decided to take the issue of noise pollution very seriously”. He lit his cigar.

“With effect from April 1, 2017, we will enforce that all sports events held in India will observe complete silence. You will now watch cricket matches where no one will be allowed to shout or even speak. People will only observe and watch the game as that is what they are supposed to do”

“Are you crazy?” I (almost) screamed. “Game like Cricket works only on  screaming and shouting – it’s the noise that creates the pressure and the push and hence the unpredictable”.

“Well, we will now focus on the health impact of the audience in the stadium as well as impact on the neighborhood” – Professor said this rather solemnly.

He continued.

“There will not be any announcements made at the Railway Stations as well as Airports on arrivals and departures. Everybody will look at the signboards that will provide latest information – right or wrong.”

“But wont people miss the flights and trains creating a chaos? Everybody is used to the announcements (although we know that most announcements are difficult to comprehend and create only noise!).  Besides what will happen to the jobs of the announcers. I am sure this will lead to a huge unemployment. Railway Minister Prabhu will know”

But, Professor did not seem to listen.

“The noise standards for fire crackers, loud speakers and horns in the car will be tightened. Manufactures will have to meet these new standards. The permissible noise levels will be mentioned on the packaging of these products and people will be told that these numbers are decibel levels and not the prices”

“But wont it affect the power of the political rallies and the fun (or sadistic pleasure) of annoying the neighborhood during festivals? We are used to honking loudly to vent out our frustrations when car is stuck in a traffic”. I protested.

“Regarding honking, we have asked Music Composer A Rahman to come up with a powerful audio clip on meditation that will be made available to download free. When played in the car, people will remain calm, will not honk and take traffic jam as their fate or way of new life.

“Oh, Rahman will sure do a good job”. I liked the idea of free meditation music in the car for calming down (and may be to fall asleep)

I thought of making a point

“Professor, you need to raise funds however to expand the NANMN and put more 24×7 monitoring stations, especially in States like Uttar Pradesh. Include large display boards as no one knows about them. Why don’t you increase the fines and the enforcement to generate required funds? In Delhi, the traffic police, challaned just 35 people for honking in 2015! They were fined Rs 1000 each. That’s no impact and no income”

“You made a good point” Professor said. “I will speak about this to Chief Minister of Uttar Pradesh. He is looking right now for new ideas”.

He continued

“There will not be any night time construction now in the 7 cities where noise monitoring has been done”

“I guess this does not happen anymore today – at least on paper” I said

“but if you insist on this imposition then the construction projects will get delayed that will lead to much more inconvenience to the citizens. A little bit of noise at the night time should be alright to meet the deadlines and get handsomely paid as a bonus”

Professor ignored what I said.

“We are revising the building standard too – We will insist installation of double or triple pane windows in the buildings falling in silence zones. These costs will be met by the Government from the election funds”

“Oh, that’s very kind of you Professor”. I said.

“But we are going even a step beyond”. Professor continued.

All major roads in the 7 cities will have noise barriers on both sides.

“That’s terrible Professor – these barriers will be sour spots of visual intrusion, blocking perhaps not noise but the flow of wind and affect the pedestrians” I was very concerned with this proposition.

Just as we were planning to have a last glass of beer for the road, we saw Nirajnan Hiranandani, a reputed builder of Mumbai, taking a stool next to us with few of his friends.

Niranjan said “Have you heard about a rumor that the Government is linking real estate price to the noise levels. The noise contours generated in cities will be used and data will be shared with public with information on the health impacts. “Reality data” in Europe and United States shows that real estate prices drop by 10 to 15% if the noise levels are high or exceed the standards. Apparently, some Professor is advising to the High Command in Delhi to set the framework. Crazy Professor he is. This is really worrisome to us. I am thinking of appointing a Noise Manager in the company or ensure that the noise monitoring instruments show lower results”

I thought linking real estate price with noise levels was a great idea – something more powerful than the mere enforcement of regulations.  I saw the Professor was smiling mischievously while extinguishing his cigar.

In Niranjan’s group there was “India CEO” of Sennheiser – one of the largest makers of headphones. The CEO said “if noise pollution is curbed, then I see impact on the sale of our flagship product –  the noise cancelling headphones. There will be only little to “cancel” if the noise stays in limits!”.

I thought he was right. But his fear looked much exaggerated.

And then there was someone in the group (who looked like a mix of Bhappi Lahiri and  R D Burman). He said.

“Well most people in India are accustomed to ambient noise over time. They cannot tolerate silence. They cannot sleep unless they hear the rumbling and rhythmic sound from the trains moving on the rail track at night. I plan to record this rail noise, make interesting audio clips and sell as a download on mobile phones. I am sure this clip will be downloaded and used by the millions living in Mumbai for a good night sleep “

I thought he was right too.

Indians indeed are happy and feel comfortable when there is noise.

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image courtesy rediff.com

Environmental Brokers


Public consultation is an important step in the environmental appraisal of projects. Many countries have instituted consultation as a part of the Environmental Impact Assessment (EIA) process. Ministry of Environment and Forests and Climate Change (MoEFCC) in India has provided guidelines for the conduct of the public hearing and for reporting the outcomes.

Public hearing is a complex process. It often has political overtones that are difficult to comprehend and manage. Public hearing is also influenced by corporate rivalries. Many believe that public hearing is the most crucial milestone of the EIA process. It can be a nightmare. Facing the technical committee in New Delhi for environmental clearance is comparatively less volatile and not so complex an ordeal.

Despite these challenges, public hearing is a step that is desirable. It provides an opportunity to the public to understand the project from both the perspectives i.e. development and environment. It’s a dialogue if conducted well can benefit everybody i.e. the project developer, environment, the affected public and of course the regulator. Unfortunately, the project developers often hide or provide incorrect information and environmental activists misinterpret and escalate the issues without much scientific basis to mislead the public. The public hearing then boils down to a negotiation between the project developers and the environmental activists to settle the matter.

My Professor Friend asked me to attend a public hearing on a Sunday. “Come dressed like a common man” he said.

“What is dressing like a common man?”, I asked the Professor

“Oh easy, look at the common man of the great cartoonist R K Laxman. You are already half bald like him and you were the coat just like he wears. You may wear some lose khaki trousers instead of the dhoti. But remember to make an ignorant and innocent face – that’s what the common man is about”

I agreed.

We reached the meeting place. It was a community hall that was not well maintained with paint peeling off from the wall. It had photos of stalwarts from both opposition and ruling parties hanging on the walls. Leaders of Congress were on the left and leaders from BJP on the right. A photo of Mahatma Gandhi was at the Center as if not sure where to be.

There was a long wooden table and chairs of different sizes stacked around. There were plastic chairs for people like us. The room was full. We took place in the last row. There was a wise looking man with a grey beard sitting next to me. He seemed to have experience of attending public hearing. He was wearing a pyjama and kurta – both not ironed.

One side of the long table was occupied by the environmental activists. I could recognize them because they had not shaved and were wearing spectacles of critical kind. Many were carrying cotton sling bags that did not seem to be washed on a regular basis. Few were smoking cigarettes and some were chewing paan (beetle leaves). Most had constipated and sad faces but a shine in the eyes that they were there to protect the world. The leader was wearing a bundee like Prime Minister Narendra Modi and a green band on the head. He looked impatient.

The other side of the Table was occupied by the project developers I guess. These people were wearing safari suits and were carrying some project documents. They had faces of most humble kind and were listening attentively to the environmental activists

And there were officials as well. I could recognize amongst these the collector as he had the best chair to sit with a towel placed at the back of the chair. Man from the Pollution Control Board (PCB) could be recognized as he was already walloping the cashew nuts placed in the plate.

We were perhaps late, as the project was already presented by the Developers. “Did we miss anything critical?” I asked the wise man sitting next to me. “Oh, nothing much” he said “It’s a thermal power plant based on coal. The usual stuff. Clean coal, Tall stacks, closed loop cooling water system, well protected ash pond, green belt etc.” He said this in a rather weary tone.

“So, then what’s the issue?” I could not hesitate asking.

I must be loud as the Professor asked me to focus on the conversations at the long table instead of “whispering” to the wise man.

One of the environmental activist was asking a question “Sir, are you aware that the emissions resulting from the stacks, coal yard and the ash ponds are going to severely impact the air quality in the surrounding villages. People will not able to breathe. Their lives will be shortened as they will keep falling sick – have you ever thought about the plight of children and old people?”

The lead project developer cleared his throat and attempted to defend “Sirs, we are within the emission limits of those stated by the Central Pollution Control Board (CPCB) and in fact lower. The coal yard has a wall with 15-meter height all around and in addition there are water curtains. The ash pond will hardly have any air emissions as the particles are large and in a slurry form”

The activist said “I don’t buy your story. All this will remain on the paper and you will be flouting the norms, especially in the night”.   The representative from the PCB nodded taking a bite of hot samosas. He was looking for the ketchup.

An activist who looked like someone from academia (probably not promoted for a long time) said “Apart from the threat of air emissions, I am really concerned about the thermal discharge that will lead to heating of the seawater. This is going to severely affect the biodiversity and the livelihoods of the fishermen”

There was silence.

A man with a laptop in the developer’s team responded (he must be a consultant). “Professor, we are using a closed-loop cooling that draws less water than open-cooling systems”

Professor activist was very angry with this response. He said in a raised voice “Mind you, I am talking about temperature and not quantity of water. If you really mean to minimize water consumption, then you should have considered dry cooling. These systems use little or no water; instead, they use air to cool steam.

“But Sir dry-cooling technology is much more expensive to build and is less efficient”. The Consultant tried to defend

“Oh, are you teaching me?” The Professor activist was now really upset as his voice started quivering and body trembling. “And by the way, your closed loop system will be using chemicals. The receiving sea water is surely going to be affected with these non-biodegradable compounds– the shrimp farming activities on the shore will simply be devastated”

The head of the activists who was wearing a green band on his head then spoke slowly, firmly and in all seriousness “Have you set aside a special compensation fund? This fund will have to operate for at least five years to ensure that alternate livelihoods are created for the fishermen”

I thought that the leader wasn’t much concerned about the dying shrimps.

The wise man sitting on my left whispered “See, this how the negotiation starts; listen carefully now. To me, all these activists are nothing but environmental brokers”

I was amused to hear this term – environmental broker.

And indeed, the wise man was right. Several issues were brought up subsequently that majorly included employment to the local people and demands were made that few contracts that must be awarded to the local businesses. The discussions that started with the environmental issues later turned towards the social and economic “opportunities”. Promises were being made and a frail looking man was jotting them down. The collector was on the mobile phone sending WhatsApp messages.

I decided to step out for a while to get some fresh air and visit the loo. I saw an old man waiting outside who probably couldn’t find a seat in the packed community hall.

“Sir, is the meeting over?” He asked me.

“Not yet” I said

“Well, I wanted to ask the company whether my grandson will get a job”

“What is his qualifications and experience? I am sure the company will find something – do get in and tell your expectation to the man wearing green band”

The old man decided to follow my advice

Before he was about to enter the community hall, I stopped him.

“Sir, are you aware that this power plant is going to worsen the air quality in the region over a period. People working and living here will face respiratory illness. One of the activists is questioning the company about this issue”

The old man said “Well, I don’t know how much of this will be true. May be this is an exaggeration”

And with some afterthought he said “A little bit respiratory discomfort against a job guaranteed for life is a better option, I guess”

I thought that the old man was wiser than the man sitting on my left

I re-joined the meeting to see how environmental brokers operate.


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Integrating Climate Change Considerations in Environmental Impact Assessment


Planners and regulators today are not addressing the impacts of Climate Change (CC) adequately in the future plans. This is not just the case with the developing countries but with the developed countries as well. There are very few examples available where you see CC is reflected in policies, plans and project designs. CC is more talked on the vulnerability.

The level of progress in integrating CC considerations in EIA varies considerably. Countries like Netherlands, Canada and Australia have been the pioneers in implementing incorporation of CC in EIA. While Netherlands includes CC through a Strategic Environmental Assessment (SEA), Canada and Australia have taken the route towards CC integration through project level EIAs. The European Commission, in its directive on the assessment of the effects of certain public and private projects on the environment, aims to reflect CC-related concerns.

When Indian Ministry of Environment & Forests added Climate Change to its title, I was hoping to see integration of Climate Change in EIA.  Unfortunately, I don’t get to see any traction in this direction. There is a need to address this issue by suitably modifying the existing EIA Notification.

Although CC related concerns and understanding are growing, incorporation of CC in the EIA process has not seen an acceptance as expected. Project developers in countries like Canada, a pioneer in this area, believe that not much climate related information is available to analyze the impacts of climate change on the projects. Besides, data availability and expertise on CC modeling is still an issue.

International Association of Impact Assessment surveyed the Australian CC-EIA system from the point of view of EIA practitioners. In all, 63 respondents were drawn across the country. It was found that majority practitioners believed that CC is highly relevant in EIA and Strategic Environmental Assessment (SEA). In addition, the survey suggested that project EIAs cannot take lead in incorporating CC EIA. CC considerations must start or originate from SEAs.

Major barriers to project EIA being able to address CC were ranked as follows:

  1. Lack of government policy and incentives to address CC in EIA
  2. Lack of political and agency will to address climate change.
  3. EIA scoping does not address CC i.e. which projects need to address CC
  4. Lack of expertise and appropriate EIA tools

Let us understand the complexity of the issue.

CC considerations in EIA typically result into mitigation and adaptation plans. The adaptation plans need to be developed at regional level, often beyond the boundaries of an individual project. For designing and implementing adaptation related plans, a simultaneous consideration to multiple projects is required to assess the cumulative impacts over the region. Public consultations need to be used as an important milestone to link the SEA, REA and Project level EIAs.

Another point to remember is we need to bring in elements of risks by building scenarios.

The entry point for developing adaptation plan is thus at strategic level where tools such as Regional EIA (REIA), SEA and Cumulative Impact Assessment (CIA) need to be used.

Unfortunately, in India all these three extensions of Project EIA have not been legislated. If we want to address CC in Indian EIA, then we will require a major reform in the EIA system.

The mitigation plans on the other hand are generally project-limited and influence the project design and operations. Here aspects such as energy mix, water use and conservation, afforestation and erosion control need to be examined. Many of these aspects get addressed in the preparation of Project focused Environmental Management Plan (EMP).

To address abnormal and emergent situations however, the Project level EMPs need to be accompanied by the Disaster Management Plan (DMP). Once CC considerations are included, adaptation and mitigation elements get factored and the DMP assumes a form of a Disaster Risk Reduction Plan (DRRP). This DRRP needs to address both onsite and offsite risks.

Management of onsite risks become a part of the Project EIA while the management of offsite risks need to be integrated with regional DRRP. Both EMP and DRRP need to abide by the framework of the REA and SEA with clear institutional and cost sharing arrangements. Again, DRRP needs to be “synchronized” with the adaptation related plans at the regional level – especially on matters related to policy, plans and supporting commonly shared infrastructure. I have attempted to show the relationships between SEA/REA, Project level EIA, EMP and DRRP in the context of CC   integration. (See Figure 1)


Figure 1: Integration of CC consideration in EIA

Project EIAs are generally processed by State and Central level environmental authorities. Separate departments/ministries operate for management of disaster related risks.  Often, there are no linkages occur between these institutions. SEA with a focus on CC may be used to ensure mainstreaming of CC   in the project and regional EIAs and more critically to ensure coordination between key institutions and the project sponsor.

 Key stakeholders in the CC integration will be National/Regional Planning agencies, Environmental and Disaster Management Agencies and the Project Proponent. Table 1 lists roles and responsibilities of key stakeholder institutions in the conduct of SEA, Regional EIA and Project EIAs.

Table 1 Roles and Responsibilities of Key Stakeholder Institutions

Activity Planning Institutions engaged with Development and Development Controls Environmental and allied regulators involved in Environmental Clearance Project Proponent
Baseline data of climate parameters like rainfall, temperature, Hydrological maps, infrastructure mapping, natural resource maps
Future projections of climate at regional level
Probable CC related impacts/risks at regional level
Strategic/Regional Environmental assessment incorporating CC
Consultation with authorities and stakeholders
Development of Guiding Framework and Operational Principles for Integration of adaptation and mitigation in the development plans and policies


Prepare response mechanism plans for disaster risk reduction at regional   level
Monitoring effectiveness of the plan in terms of mitigation and adaptation
Project EIA
Impact of climate change on project/programme
Mitigation measures
EMP, DRRP Integration with outcomes of REA/SEA
Stakeholder consultation

 Many States in India have set up CC cells. These cells may undertake required coordination. These CC cells may be supported by a CC related research organization that has required databases and expertise on CC related modelling. This concept is shown in Figure 2.


Figure 2: Institutional Arrangements for Mainstreaming CC considerations in EIA

REA and SEA clearly assume an important role to ensure harmonization between Project level EMP and DRRP with the CC adaptation plans at the regional level. Cumulative Impact Assessment (CIA) will remain the key. Institutional coordination with cost sharing will be important in the implementation of the CC related recommendations. Involvement of the stakeholders is necessary to appreciate the concerns of the CC, especially its economic, social and environmental implications. Capacity building of the planners, regulators and professionals is also required. Finally, pilots should be implemented to demonstrate how CC in EIA could be mainstreamed. Based on the experience of the pilot, the EIA Notification may be suitably amended. We will need to develop another Schedule that will define which projects or regions will need CC considerations based on the vulnerability atlas, type and scale of projects development.

I presented my views to my Professor Friend.

He laughed “Don’t get so critical Dr Modak!” He said

“The Ministry likes you. The least MoEFCC will do is to constitute a “Committee on CC in EIA”. They are good at this and I am sure this Committee will be set up without much delay!! But remember, rest will follow as usual. Like the Climate is changing, MoEFCC may also change its mind!!!

This post draws from the paper I presented at the Impact Assessment the Next Generation 33rd Annual Meeting of the International Association for Impact Assessment 13 – 16 May 2013, Calgary Stampede BMO Centre | Calgary, Alberta, Canada. This paper was co-authored with Namrata Ginoya who worked with me at the Environmental Management Centre LLP

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Citizens Sense!


Until recently, measuring air pollution was a task that could be performed only by trained scientists using very sophisticated – expensive equipment. Environmental Sensors are now getting advanced, miniaturized and cheaper, opening up new methods of collecting environmental data.

Environmental data capture is no more left to the regulatory agencies today. Its now led by the citizens. Citizen can “sense” the environment using readily available sensor devices with smart phones, and share this information using existing cellular and internet communication infrastructure.


“Democratization” of technology and Do-It-Yourself (DIY) hardware platforms, have the potential to enable citizens to sense. It is estimated that by 2019, “citizen environmentalists” will have more personal sensors, measuring air and water pollution, energy consumption, health parameters etc. than the governments.

US EPA is challenging communities across the country to collect data using hundreds of air quality sensors as part of the Smart City Air Challenge. The agency just offered up to $40,000 apiece to two communities to help them develop and implement plans for collecting and sharing data from air quality sensors. The award money only covers part of the program costs, so communities will need to partner with sensor manufacturers, data management companies or others to get resources and expertise to implement their plans.

The State Pollution Control Boards in India should think of taking up such initiatives.

I came across the Air Quality Egg.  This is a network of about 1,300 CO2 and NO2 sensors, which cost $240 each. Another popular device is the Smart Citizen Kit.   Here data is uploaded to the Smart Citizen Website which shows about 800 kits deployed across the world, with more than half deployed in Europe. The basic kits cost about $170, before tax and shipping. There are dozens of such sensor packs and gateways now available and the number is constantly growing.


Air Quality Egg Sensor

We don’t have such devices and networks established in India.


Forty Air Quality Eggs in Georgia

The Do-It-Yourself Mantra

EnviroDIY in the US is a community of enthusiasts sharing Do-It-Yourself Ideas for environmental monitoring. All EnviroDIY members can showcase their environmental sensing gadgets or describe their own homegrown approaches to monitoring, sensor calibration, installation hardware, radio communication, data management, training or any number of other topics. Members can pose and answer questions and can network within interest groups to collectively develop new devices, tutorials, or other useful products.

Empowering the Youth

The Kids Making Sense program empowers youth to drive positive change and improve public health by collecting credible air quality data around their neighborhoods. Students participate in hands-on science tasks, discuss their findings with an air quality scientist, and share their data with the global air quality community. They can even use their data to identify local sources of air pollution and take actions to be part of the solution. DIY is the strategy.


Students in Bangkok participating in Air Quality Sensing

Market forces and consumer convenience are driving the growth of DIY sensor market. Whatever the motivation, these sensors are being used now by many organizations, including concerned citizen advocacy groups, and to some extent by the regulatory community. Regulators are interested in the low cost sensor technologies because they can cheaply expand measurement capacity. But at the same time, they are cautious because of uncertainties about measurements that do not comply with narrowly prescribed measurement methods.

Many environmental sensors are still in an early stage of technology development, and many sensors have not yet been evaluated to determine the accuracy of their measurements. So there are important concerns about how well and how accurately these sensors work.

The latest version of EPA’s Air Sensor Toolbox provides a variety of resources on using air sensor technologies, including new sensor performance reference tables. One of the most popular resources is the Air Sensor Guidebook, a how-to for using of air sensors and what to consider before getting started with a citizen science project. In addition, the Toolbox includes scientific reports on air sensor monitors that undergo testing and evaluation by EPA. Technical documents on operating procedures also are available.

But low-cost air monitoring does have merits. It is not hard to build a $30 sensor to measure carbon monoxide, although such a device probably will not be able to measure concentrations less than, say, one part per million. In many advanced countries, where pollution levels are relatively low, such a device would not produce meaningful measurements. But on a busy street in New Delhi, or near a brick kiln in Patna, it could be quite useful because pollution levels are significantly higher that citizens would like to sense.

Sensors of Tomorrow

The team, led by Professor Giacinta Parish, has come up with a new kind of sensor. It’s made from gallium nitride, a material that can perform in extreme heat and at high power levels, unlike the materials silicon and gallium arsenide that are often used in sensor chips.

Parish’s team along with engineers from CSIRO, Australia have used the gallium nitride to build a single sensor chip that can detect many different ions without the need for a reference electrode that would add to its size and weight.

Plants have amazing and significant sensing capabilities. For instance, each single root apex can simultaneously and continuously monitor many chemical and physical parameters. A digital network and a powerful algorithm transforms each tree into an environmental informer. A group of Italian, British and Spanish researchers are working on developing a network of micro sensors that can be embedded in plants, sending us information on how plants respond to changes in temperature, humidity, air pollution, chemicals and many other changes in their environment. A project called PLEASED (PLants Employed As SEnsing Devices)  has been launched with €1.07 million ($1.46 million) funding by the EU.

I am a strong advocate of citizen monitoring. To encourage the citizens to sense our environment, engage into science based discussions and action, we should probably consider launching a nation-wide program on “citizen sensing”.

The Central Pollution Control Board (CPCB) should take the task of setting a Toolbox like US EPA did to ensure quality entry of the sensors, guide correct use and provide tips and training for the interpretation of this data.

Department of Science & Technology should sponsor research on low cost environmental sensors that can be indigenously manufactured and serviced and promote entrepreneurship in this area. Our venture capitalists should seriously consider investing and come up with innovative business models.

Some may say that involving citizens in “sensing” will increase the Public Interest Litigations (PILs) and appeals to the National Green Tribunal (NGT). But whether the regulators like or not, citizens and especially the youth – are going to get more involved – since the environment matters.

Citizens are now interested to know more about the state of environment they are living and not solely depend on the monitoring reports of the regulators. Don’t you think it makes a pretty good sense!

You may want to read my following previous posts

Participatory Air Quality Monitoring

Why Monitor Environmental Quality – Why not Generate Random Numbers?

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Environment Minister Looks for an Officer on Special Duty


During one of the Ministerial Get-togethers, held in the lawns of the Prime Ministers bungalow, the Environment Minister observed that few people were floating around Ministers of Energy, Agriculture etc.   These people looked a bit special. While they looked like “babus”, they were enthusiastic and efficient. That seemed odd.

When asked, the Environment Minister was told that these people were the Officers on Special Duty (OSD).

“Don’t you have one?” The Energy Minister asked the Minister of Environment. “If you want the impact or bring in a change, then you will need one – You can also use an OSD to checkmate the volley of secretaries in the Ministry – one of the greatest stumbling blocks to bring in any change”.

An OSD (Officer on Special Duty) is an officer in the Indian civil service considered of the status between a Secretary and an Under Secretary. The practice dates to the British colonial rule in India.

The Environment Minister called my Professor Friend for help and suggestions. As usual, Professor asked me to tag along and I gladly obliged.

Do you have any special duties at all Minister? Professor asked a question so basic and fundamental.

“Good question – “The Environment Minister said. He looked outside the window.

It was a Friday evening and Delhi was under a thick smog and it appeared as if the streetlights were in tears and blinking. The traffic was crawling with emissions oozing out like a slow poison. Solving the puzzle of Delhi’s air pollution could be a special duty that could be assigned. The Minister muttered to himself.

I knew that this task was far beyond any OSD or the Prime Minister for that matter and a herculean task even if the Nations were United.

So, I decided to make a practical suggestion. I said ““Well Minister” – I see several special duties that could be performed by an OSD at your Ministry”

For a change, the Professor allowed me to speak.

I said “Environment Ministry has 40 odd divisions listed on its website. Do we really need 40 divisions? Can we ask the OSD to come up with just 10 divisions and stay focused? He could take up reorganization and streamlining of the Ministry as a special duty. This will lead to a higher efficiency and a considerable impact besides getting out of the redundancy “

“Well Dr Modak, don’t forget that these divisions were created to accommodate interests of the individuals and not because of any reasons genuine. If we apply rationality and collapse these divisions, then we will be confronted by protests & political inquiries” Professor said this with some caution. The Minister agreed.

I was disappointed. I thought that the Ministry required a thorough restructuring rather than the present amoeboid format.  But I didn’t want to give up.

I said “I have another idea. The Ministry has signed up more than 10 International MoUs with various bi-laterals (see http://www.moef.nic.in/division/bilaterals)  We will ask the OSD to find out what’s really happening on these MoUs and check whether they are still active – then revisit/restructure MoUs and follow up to our benefit”

Professor did not like this idea either. “Minister – This task is no big deal or worthy of putting time of an OSD as we already know that nothing happens after the MoUs get signed. The case is just like MoUs signed during Vibrant Gujarat. Most MoUs use the broad term “cooperation” and make a “laundry list of topics for collaboration”. You should be firing those who drafted such inconsequential MoUs”.

I kept shut. I thought that Professor was right. Most such MoUs of the Ministry were drafted by retired Secretaries and Ex-Professors from JNU.

The Environment Minister suggested. “What if we attach the OSD to Ministry’s Economic Cell?”

“Well, Minister Sir, Are you aware about the functions of the Economic Cell? ” Professor asked.

(I did not even know that such a cell existed in the Ministry).

According to S R Maheshwari (S.R., Maheshwari (2003). Indian Administration (6th ed.). New Delhi: Orient Longman Private Limited. ISBN 812501988X), there are two principal criteria in appointing an OSD in the civil services. –

  1. When an officer by his appointment brings far greater economic benefit to the government than that spent in his appointment
  1. When there is an obligation on the government to take a certain action for the benefit of the larger good..

In the above “economic” perspective, I thought – attaching the OSD to the so called Economic Cell will be a good idea.

The Professor continued

“Let me list a few functions of the Economic Cell”

  • All matters having bearing on internal and external economic management in the Ministry and reform in the environment and forest sectors.
  • Providing material for Economic Survey of M/o Finance, Finance Minister’s Budget Speech, etc.
  • Nodal Division for handling and coordinating all matters referred by the Ministry of Finance.
  • Secretariat for the Sectoral Committee to Review the Release and Utilization of the Grants-in-Aid for State Specific Needs recommended by the Thirteenth Finance Commission.
  • Compliance under the Fiscal Responsibility and Budget Management Act, 2003.
  • Parliament Questions on policy matters

He ended reading out this list and quipped. “Do you think we should waste career of a bright OSD on such terribly and ambiguously worded functions?”

I couldn’t disagree.

We discussed several other possible special duties for the next hour with the Minister but each suggestion made was ruled out by the Professor saying that it was hardly any special duty. All duties seemed either routine or inconsequential. Nothing seemed special.

After such a frustrating discussion, Professor got up from his chair and said “Minister Sir, let us work other way round “. I knew that Professor had a different thought.

“Sir, do you have anyone particular in mind?” Professor put this rather probing question.

An OSD is chosen by the Minister based on personal preference or based on the recommendation of the people well known to the Minister. OSD is among the personal staff of the Minister and his term is co-terminus with the tenure of Minister. There is no notification for the selection of OSD.

“I was thinking of one Mr Hardik Shah –  present Member Secretary of Gujarat Pollution Control Board” The Minister said sheepishly

Well, then Professor said. “I have now two questions to ask. Firstly, are you aware that you are choosing a Gujarati – you are perhaps a Gujarati and the Prime Minister is also Gujarati. So, this nexus should not be looked at as a conspiracy. Secondly, I do hope Mr Shah is not related to you in any way as there have been cases filed if Minister choses even a distant relative as OSD”

The Environment Minister said no.

“Oh, are you talking about Mr Hardik Shah who was Member Secretary of the High-Level Committee under the chairmanship of T.S.R. Subramanian?” I exclaimed.


Mr Hardik Shah

The Environment Minister nodded.

(Many of you know that the TSR Committee made reformistic recommendations to beef up India’s environmental governance. But some of the recommendations were radical. The TSR Committee report was not accepted)

“Sir, then the problem is solved. Mr Hardik Shah is the right person as the OSD to you. His special duty will be to implement the T.S.R. Subramanian committee report. This will keep him (and you) sufficiently busy till the next election” Professor said this in a firm voice

But I had another suggestion.

“How about appointing Mr Shah as your Personal Secretary (PS) instead of an OSD”. I said “In this capacity and under your support, Mr Shah will be able to help you in bringing the desired change in the Ministry”.

The Environment Minister liked my idea.

And this is how I was told that Mr Hardik Shah got appointed as a PS to the Environment Minister. I guess the Ministry had to follow the appropriate procedures.  Apparently, his appointment took place just in the last week.

I now hope to see some action at the Ministry of Environment especially on the T.S.R. Subramanian Committee report.

My best wishes to you Mr Shah and count all my support.

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