CAG Of India 's Most-Missed Responsibilities On Environmental-Concern
By Anurag Modi
22 September, 2012
Countercurrents.org
While, Comptroller Auditor General's of India (CAG) has been able to raise the financial-standard, which was much needed in a country reeling under rampant corruption, it has left the much required environmental-standards, continued to be viewed as mere procedural-burden. A corruption free government, with clean financial management aimed to improve human life, will prove pointless without equally sound environmental condition. Since its first conference in 1972, it has been repeatedly established by the United Nation. The United Nation Environment Program, in recently held conference, has coined a new term, “green economy”: “that recognizes the properties of healthy ecosystems as the backbone of economic and social well-being and as a precondition for poverty reduction.” With this background, the (CAG) in its report on coal-block, was required to be equally vocal and stricter on environmental standards as he was on financial management.
Coal has serious impacts on the environment and people in its entire cycle, from mining to power. Open cast mining or strip mining destroys the landscape, silts water bodies, displaces and dispossess communities and has severe health impacts as well. It is now established that water required washing coal and running the thermal power plants will compete with irrigation. Last but certainly not the least is that coal power is the leading contributor to India's GHG emissions and as these emissions reach danger levels, India's future energy choices have an impact on what is being called the biggest threat to life as we know it.
The Planning Commission projects a 250% increase in domestic coal consumption by 2031-32. With coal imports costly, this demand would have to be met mainly from domestic production, which means a rapid expansion in mining. Over one million hectares of forest stand to be destroyed from coal mining in just 13 coalfields in Central India . International environmental groups like Greenpeace have begun to take up the issue of coal-miningin India . The recognition of the overlay of coal resources, forests and adivasi land has meant that the organisation has actively engaged themselves in organsisng the local community towards ensuring their right over the forest is recognized. Greenpeace is involved in an on ground struggle in Mahan, to fight the unjust allocation of the coal block without any ecological logic and in violation of the rights of the people of Mahan, the power capital of India , i.e., Singrauli in Madhya Pradesh.
But, on the contrary, CAG without realizing repercussion of its recommendations, and verifying Ministry of Environment & Forest's (MOEF) positive role in addressing some of the genuine environment concern, engaged in criticizing the delay in environment clearance to various coal-blocks. Its' recommendation on adoption of single-window mechanism to ensure early clearances to coal-blocks, will not only increase the pressure on MOEF for early clearance, but it will further dilute its' position. On the face of all the opposition by environmental groups and local communities to the allotment of coal-blocks, the push on the part of CAG will only provide coal ministry with required excuse, it has been looking for to maneuver upon MOEF -especially on the issue of environment clearance to coal-blocks falling in sensitive, “no-go" zone, like ‘Mahan' in Singrauli, M.P.
In fact the CAG has cited the delay in environment clearance, along with other clearance, as one of the main reason for failure of realsing the dream of, “Power for all by 2012. To overcome this, the CAG has recommended the idea of Single Window Mechanism on the line of Foreign Investment Board to ensure early clearance, including environment Clearance. In August 2012, Minister Jayanthi Natarajan refuted the charge that the Ministry of Environment and Forests is responsible for the power shortage facing the country, stating that the environmental clearances for coal mining and coal-fired power plants actually exceed the Indian government's own targets till 2017.
Despite this, the CAG seems to have supported formation of a High Powered Committee with coal secretary as its head with members of all the nodal ministries including MOEF. CAG without verifying that amalgamation of MOEF with set of other ministry will make him loose its prime position on forest clearance and this, ‘amalgamation', may prove detrimental to the environmental health of the country.
CAG should have born in mind that, under the mandate of, "International Organisation of Supreme Audit Institution (INTOSAI)”, the CAG should have enlarged its ambit of audit and, apart from conventional three E's of Economy, Efficiency and Effectiveness, should have adopted fourth E, that is Environment. Otherwise also, audit of the effective implementation of various laws, including Environment laws and Forest Right Act, 2006, has been the mandate of CAG.
As per the INTOSIA guidelines the CAG is supposed to audit the performance of any department/ministry on the following five points:
One, Audit of Government's Monitoring of Compliance with Environmental Laws, under which the CAG is expected to audit and offer a opinion on compliance of exiting environmental laws; second, Audit of Government's Monitoring of Compliance with Environmental Programs, where CAG is required to opine on performance of environmental programs/projects/strategy; third, Audit of Environment Impact of other Government Program, under this head CAG is to opine on the environmental impact of programs undertaken by other ministries; fourth, Audit of Environment Management System, in this the CAG is to opine on the implementation of Environment management System (EMI), the absence of EMI must have been part of audit comment; fifth, Evaluation of Environment policies and Programs, under this comment on lack of policy framework.
Normally, the above points are undertaken while overall environment audit is undertaken under Compliance Audit and Performance Audit, conducted on different environment themes. But, considering power generation by coal, as one of the major source of Air-Pollution and its mining a major threat to the existence of forest, the coal-block allocation should have been, simultaneously, undergone audit under Environment-Audit performance, as both financial as well environmental health condition is required to be reflected together, otherwise the environmental concern always get sidelined and overruled by financial considerations; and its is more likely to happen when it concern power-generation.
Like, on examining the records of MOEF on the allotment of environment-clearance to ‘Mahan coal-bloc, the CAG would have realized the fact that this coal-block falls under the category of, ‘no-go' forest zone and biodiversity-rich area. The recommendation of the forest advisory committees' report of June 2011 would have further convinced them that , withholding the environment clearance was on the ground of quality of forest and non settling of community's right over forest under FRA, 2006, and for no other reasons. Rather, the CAG should have appreciated the role of MOEF for taking strong position, earlier, on the issue of environment clearance to Mahan and Chatrsal coal blocks in Singraulli district of M.P. And, the CAG should have pulled up the government for, later, forcing MOEF to dilute its position on, ‘no-go' forest zone, without ensuring compliance of concern raised by Forest Advisory Committee (FAC) in its report. The FAC committee opined that the ‘Mahan Coal-Block' area is part of critical wild life habitat mentioned in schedule I under Wild Life Protection Act, 1972 and, it falls under the catchment area of Rihand Dam. These are some of the very few environment concerns involving ‘Mahan coal-block', but coal-blocks in general are major threats to environment. On this very note, Greenpeace has called for the cancellation of all the coal-block allocations made in the period covered by the CAG audit and demanded a moratorium on any further allocations and forest clearances for coal mining, until a transparent public consultation process is held to arrive at the criteria for determining which forests should be permanently closed for mining.
As about the Environment Impact Assessment (EIA ), even the National Environmental Engineering Research Institute is termed as one of the “most notorious EIA consultants.” In another matter of different mining projects in five different villages of Rajasthan, they have identical Environment Impact Assessment (EIA) prepared by single EIA consultant— R.K. Consultants, Jodhpur . Centre for Science and Environment (CSE) carried out the technical analysis of the EIA-EMP report of Gare Pelma Block III coal mining and washery, on the request of a local NGO, for the project that is to come up in the Mand-Raigarh coalfields in Raigarh district of Chhattisgarh. The CSE has concluded that the EIA report fails to do a cumulative assessment of the project along with all the existing projects. Similarly, Greenpeace while evaluating the EIA of Dhama Port in Orissa has criticized it for its shortcomings and omission of impact assessment.
According to the CAG's own audit report on, “Audit of Environment Assessment” 2008, the MOEF has issued guidelines for 8 steps EIA. It includes assessment of resultant pollution and quality of pollution. With Singrauli considered to be power capital of India, it is 7th most pollutant in the country, had CAG had considered the EIA report of Mahan and other coal-block in Singrauli on this ground, it would have opined against its sanction on the Environment grounds, alone. The CAG's performance audit report of MP government on implementation of Forest Conservation Act, 1980 (FCA), for the period 1997 and 2007, is also cause to worry and, at the same time it reflects badly and shows that the government has never been serious on the issue of alternative plantation- infact it shows that the MP state did not carry out compensatory afforestation in 70 per cent of the projects, while in the rest 30 per cent plantations did not survive.
With the dismal situation of Environment Impact Assessment (EIA) report and implementation of FCA, CAG rather than pushing for early environment clearance should have suggested ways to strengthen the MOEF. It should have evaluated the EIA and EMP of atleast few of the coal-blocks, like ‘Mahan' which is falling in sensitive and ‘no-go' zone.
India 's environmental health has already been in ICU for past two decades and, has been getting worse with every environment-clearance given by MOEF. India has been having bad track record of its commitment and seriousness on the Environmental-Concern, at this juncture environmental-concern shown by CAG would have been quite an example and, provided MOEF with much needed regulatory-boost.
Anurag Modi
Shramik Adivasi Sangathan
References:
Comptroller and Auditor General of India 's report ,2012, Allocation of coal-blocks;
Rio +20 United Nation conference on Sustainable development, 2012, “Future We Want”;
Re-thinking Coal's Rule in India , 2007, World Wield Forum document
Greenpeace of India website;
Environment Audit report, by Comptroller and Auditor General of India 's, 2008 ;
Minister of Environment & Forest of India 's Letter on Mahan Coal-block, dated 8/6/2011 ;
Report of Site Inspection of Mahan coal-block undertaken by sub-committee of Forest Advisory Committee 4th to 6 th June 2011;
The Dhamra-Chandbali Port Expansion Project, Orissa , India Critique of the Environmental Impact Assessment, 2007 , by Greenpeace;
envcoal.blogspot.in- ENVIRONMENT AND COAL BASED POWER IN NEWS NEWS CLIPPINGS ON ENVIRONMENTAL IMPACT OF COAL BASED POWE;
Analysis of the Draft EIA/EMP Report for Durgapur II – Taraimar Coal Block, Centre for Science and Environment, Report, 2007
Comments are moderated
