Journal of Environmental Protection, 2014, 5, 29-34
Published Online January 2014 (http://www.scirp.org/journal/jep)
http://dx.doi.org/10.4236/jep.2014.51004
Potential Benefits and Challenges in Applying Regional
EIA: A Case Study of Special Investment Regions in India
Masoom Mallick1, A ditya Singh2
1Gujarat Industrial Development Corporation, Gandhinagar, India; 2University of Portsmouth, Portsmouth, UK.
Received November 6th, 2013; revised December 5th, 2013; accepted J anuary 2nd , 2014
Copyright © 2014 Masoom Mallick, Aditya Singh. This is an open access article distributed under the Creative Commons Attribu-
tion License, which permits unrestricted use, distribution, and reproduction in any medium, provided the original work is properly
cited. In accordance o f the Creative Commons Attribution License all Copyrights © 2014 are reserved for SCIRP and the owner of
the intellectual property Masoo m Mallick, Aditya Singh. All Copyright © 2014 are guarded by law and by SCIRP as a guardian.
ABSTRACT
Development is an ever growing process and its impact is often detrimental to environment which in turn may
lead to adverse co nsequences for hu man life . Environme nt Impact Asse ssment (EIA) is an anticipa tory and pa r-
ticipatory environment management tool which helps in the decision-making process for different upcoming de-
velopment projects by analyzing the environmental consequences of the action. The large scale projects like set-
ting up of Special Investment Regions (SIR), Special Economic Zones (SEZ) and Industrial Estates (IE) have
cumulative impacts on the e nvironmental conditio n of the regio n. This paper inte nds to describe differe nt prac-
tices of impact a ssessment and seeks to direc t this debat e towar ds t he potential bene fits of applying R e gional EIA
over the project specific EIA to capture the cumulative impact of large development projects like SIRs and IE on
the environmental condition of the region and underline the challenges often faced during the study. Regional
EIA is a new concept in India and the process of development of an SIR is different from the other industrial
projec ts such as SE Z or IE. Unli ke SEZ whic h compri ses of only indust rial act ivity , SIR also includes re sidentia l
commercial and other amenities over an area of more than 100 square kilometers. Further, the implementation
of Reg ional EIA in Indian conte xt is also co nstrained by proble m in baseline da ta collection and la ck of exhaus-
tive ecological and socioeconomic indicators for impact assessment and restricted use of stat e of art technologies
such as Geographical Information System due to many factors such as cost involved and lack of awareness
among consultants. The whole proc e ss of Regional EIA should be made r apid a nd more participatory.
KEYWORDS
Regional Environmental Impact Assessment (REIA); Special Investment Region ( SIR); Spe cial Economic Zone
(SEZ); Cumulative Effects
1. Introduction
In 1960’s, economic development was given more
weightage over the environment. It was generally ac-
cepted that the benefits of economic development would
be more than enough to compensate for any deterio-
ration in environmental quality associated with these
developments. During this period, the project review was
mainl y based on the technical/engineering and economic
analysis. Environmental degradation and depletion of
natural resources induced by the human activities later
attracted steadily growing concerns and came into the
picture in the United Nations conference held at Stock-
holm in June 1972. This conference is widely recognized
as the beginning of modern political and public aware-
ness of global environmental problems wherein the focus
was to provide a framework for the comprehensive con-
sideration of the problems of human environment. In
parallel with and following the Stockholm conference,
there was a s urge of p olicy m aking a nd instit ution b uild-
ing in the developed world.
The National Environment Policy Act (NEPA) 1969,
which became effective on January 1, 1970, of the Unit-
ed States, was the first piece o f legislation that dea lt wit h
cross-sectoral issues and launched the word Environment
Impact Assessment (EIA) into the worldwide use. The
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Potential Benefits and Ch allenges in Applying Regional EI A: A Case Study of Special Investment Regions in India
30
act has been referred as the “Magna Carta for the Envi-
ronment” in the United States [1]. During this period,
basic principles, guidelines and procedures including the
public participation were instituted. It has since then
evolved considerably as it has been used increasingly in
many countries around the world in the decision-making
process. However, EIA, as it is practiced today, is being
used as a dec isio n -aiding tool rather than a decision-
making tool.
In India, many of the development projects till as re-
cently as the 1980’s were implemented keeping in mind
very little or no environmental concerns. The environ-
mental issues came into the picture when a national
committee on the environmental planning and coordina-
tion was set up under the 4th five year plan (1969-1978).
When till 1980, the subjects of environment and forest
were the concern of Department of Science and Tech-
nology (DST) and Ministry of Agriculture (MOA), re-
spectively. Later, the issues were formally attended by
the Department of Environment (DoE) which was estab-
lished in 1980 which was later upgraded to the Ministry
of Environment and Forest (MoEF) in 1985.
The foundation of EIA in India was laid in (1976-77)
when the planning commission asked Department of
Science and Technology (DST) to examine the river-
valley projects from environmental angle. Later on, this
was subsequently extended to cover those projects which
required approvals from Public Investment Board. How-
ever, these were administrative decisions and lacked the
legislative support. To make it mandatory from the leg-
islative point of view, the Environment Protection Act
(EPA) was enacted by MoEF, Government of India on
23rd May 1986 which is known as Umbrella Act under
whic h EIA no ti ficati o n, 19 94 was e nacte d. The EIA no ti-
fication (1994) made Environmental Clearance (EC)
mandatory for expansion or modernization of any activity
or for setting up new projects listed in Schedule 1 of the
notification. Since then, there have been about twelve
amendments made in the EIA notification of 1994 [2-4].
The overall goal of EIA is to encourage the considera-
tion of enviro nmental is sues in the dec ision-making so to
“ultimately arrive at actions which are more environ-
mentally compatible”. Later on, EIA became so impor-
tant that e ven funding a gencies like the World Bank and
the Asian Development Bank (ADB) recognized the need
of EIA or IEE (Initial Environmental Examination) de-
pend i n g up o n t he t yp e o f the project before granting loans.
A number of bilateral agencies also have prescribed
guidelines for the environmental assessment of projects
for whic h they provide the financial assistance [5].
2. EIA Practice in Developed and
Developing Countries
In developed countries like United States and European,
there is a well framed EI A legislatio n to car ry out EC for
different projects whereas in developing countries there
is lack of formal EIA legislation. On the other hand, in
many African countries, EIA is not even mandatory. In
developed countries, there is active involvement of
people/competent authority/government agencies at ini-
tial as well as later stages of EIA whereas in developing
countries, there is limited involvement of public/gov-
ernment agencies during initial phases of EIA which re-
sults into poor prediction of impact. In developed coun-
tries, there is integrated approach to wherein social and
health aspects are taken into account whereas in devel-
oping countries, there is less stress on social and health
aspects. The screening process of EIA in developed
countries is decided by competent/authorized agencies
whereas in developing countries, the screening process is
decided as per the activity mentioned i n EIA notificatio n
without taking into account the threshold value of pollu-
tion load [6].
3. Different Paradigms of EIA
Tracing the environmental movement from its origin in
the 1960’s to the present day as it appears mainly three
main concepts has evolved.
3.1. EIA at the Project Level s
In many countries in the world where EIA is in place,
development projects undergo an environmental exami-
nation prior to being given clearance to establish and
operate. Present EIA practice in India is restricted to
project level, which recommends appropriate mitigation
measures or monitoring or management plans in the
project itse lf.
3.2. From Project to Regional EIA
The emphasis in environmental impact studies in the
early 1970’s was on the physical-chemical a nd biological
environ ments. Howeve r, ad d e d a tt enti o n was given t o t he
cultural and socioeconomic environments as the decade
progressed. In late 1970’s, the emergence of multidimen-
sional character in the project level EIA came into pic-
ture which involved inclusion of the social dimension
into the process. Social Impact Assessment (SIA) analy-
sis and risk analysis was incorporated into the process of
EIA [7]. T hi s turn i n t he co nc e p t o f EI A was t he r es ul t of
recognition of the fact that the different components of
the environment are interdependent. It was later on rea-
lized that the scope and level of EIA needs to be ex-
panded further where regional plans/master plans or de-
velopment plans are to be considered. An EIA, thus, can
be performed at various levels depending upon the scale
of the development activity. In a large industrial estate,
for example, while the individual industrial emission,
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Potential Benefits and Ch allenges in Applying Regional EI A: A Case Study of Special Investment Regions in India
31
effluent discharge etc. may be within the permissible
limit, the cumulative effect of the emission or effluent
discharge of different industrial units may lead to deteri-
oration of overall air/water q uality in the re gio n.
This is the fairly latest extension of the impact assess-
ment which investigates the combined effects of the mul-
tiple activities instead of the effect of a specific devel-
opment project.
3.3. Policy Level Strategic EIA
The increasing scale of the global environmental prob-
lems was an indication that the environmental deteriora-
tion was accelerating and it is not restric ted to a specific
project or region. By late 1980’s and early 1990’s, the
experience of EIA over pro jects and re gional plans led to
the recognition that EIA of policies should be conducted
on a strategic level. Strategic Environmental Assessment
(SEA), basically inquires about the impact of an existing
plans, policies and programs on environment. It can be
applied both at the level of broad policy initiatives and to
more concrete programs and plans having physical and
spatial reference [8].
If policies at a generic level are evolved on an envi-
ronmentally sound basis then associated regional plans
and projects are expected to cause least conflict between
regional and local environmental pr iorities and issues.
4. Need of Regional EIA for SIRs
Regional EIA is more than expanding the boundaries of
EIA “up” to a higher tier or “out” to encompass a broader
geographic area, rather it represents a different way of
approaching the relationship between environment and
development decision making at a regional scale. A
project level impact assessment is limited to a specific
area and it does not ask whether the proposed undertak-
ing is the most appropriate form of development or
whether the cumulative effects of such development are
in conflict with broader environmental goals or desired
future conditions. It disregards the cumulative impacts i.e.
deforestation, depletion of the ozone layer, biodiversity
decline etc. No single project can be considered respon-
sible for the problems; however they do occur due to the
combination of several impact sources. When projects
are assessed individually, not much attention is paid to
other developments (existing or planned) affecting the
same area, consequently the decision makers are masked
the true nature of the problem under analysis and are
asked to assess the acceptability of individual impacts.
Such i mpacts oft en app ear negligible desp ite their poten-
tially harmful cumulative effect (e.g. loss of little wood-
land due to the construction o f an infrastructure) [9,10].
SIRs as compared to SEZ have larger spatial extent
and is not merely only export oriented. Instead, they offer
a range of other services and comprises of residential,
institutional etc. along with the industrial e states. Gujar at
is one of the first states to promote SIRs in India [11-13].
The concept of SIR came into the picture to control the
haphazard growth of industries outside existing notified
Industrial Estates (IE) for planned development. These
SIRs are having large spatial extent and includes residen-
tial, commercial and other amenities apart from existing
Industrial Estate. Thus, for such a large area containing
different land uses Regional EIA is needed for assessing
the cumulative impact of the proposed industries on the
region as a whole. These SIRs are undergoing regional
EIA study and approaching MoEF for EC under the cat-
egory 7(c)1.
5. Challenges Being Faced during the Study
5.1. SIR Being a New Concept as per the
EIA Notification
SIRs came into existence in 2009 with the advent of
Special Investment Region Act, 2009 [13]. As per the
EIA notification 2006 and 2009 under activity 7(c), only
terms like Industrial Estates/Export Processing Zones/
Special Economic Zones are mentioned. SIR is a new
concept which is nowhere mentioned in the notification.
Thus, the project proponent approaching MoEF for EC
under category 7(c) is required to give clear-cut picture
of difference between SEZ and SIR. Also MoEF is not
clear about the process of development of these SIRs as
they are being developed through Town Planning
Schemes (TPS) where there is no acquisition of land.
Thr ough thi s sche me, a smal l po rtion o f land i s ta ken fo r
developing trunk infrastructure and the rest major portion
is returned to owners as the final plot.
5.2. Delineation of the Boundary of an SIR
The concept of SIR came into existence to restrict the
haphazard growth of the industries beyond the existing
boundary of notified IE. The state of Gujarat is the first
state among Indian states to have passed SIR ordinance
[14]. These IE have been recognized as Industrial Nodes
along the Delhi-Mumbai Industrial Corridor. The SIRs
are generally spread over an area of more than 100
square kilometers. The boundary of an SIR includes not
only full-fledged existing industrial areas but also indus-
tries/IEs which are not yet established but have already
taken NOC and EC from the concerned authorities. Apart
from that, it al so includes areas (r esidential or industrial)
under development for which zonal plans has been made
under broader development plans. An EIA study being
1As per the EIA notification 2006 from MoEF category 7(c) is for
Industrial Estates/ P
ar ks/Complexes /
Areas, Export Processing Zones
(EPZs), Special Economic Zones (SEZs), Biotech Parks, Leather
Complexes.
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Potential Benefits and Ch allenges in Applying Regional EI A: A Case Study of Special Investment Regions in India
32
carried out for such area development projects comprises
of both situations (existing and proposed) within the SIR
boundary. The baseline data collection of existing indus-
trial units is easily ge nerated from primar y surve y as well
as secondary sources like audit reports of individual in-
dustries. However, the baseline data generation for the
proposed industries is a major challenge being faced by
consultants as it is entirely based on assumptions taking
into account d ifferent case studies from India or abroad.
5.3. Comprehensive Baseline Data Collection
Regional EIA study as compared to project level EIA
takes more time as it entails comprehensive data collec-
tion which req uires se tting up adequa te number of moni-
toring stations for a considerable period of time (for in-
stance, pre-monsoon, monsoon and post-monsoon pe-
riods) in order to assess the cumulative effects in the
whole region. Since the validity of the Terms of Refer-
ence (ToR) issued by MoEF for conducting the EIA
study is only for two years, it is often difficult to com-
plete the entire study within this given time period. The
delay in baseline data collection compels individual in-
dustries within proposed SIR to approach the ministry for
EC without taking into consideration the conditions of
EC of t he region a s a whole. On the other hand, the SIR,
at the same time, also undergoes EC from the Ministry
without taking in-principal approval from Individual
Units. This defeats the purpose of obtaining EC for the
SIR as a whole.
5.4. Insufficient Baseline Data for
Impact Prediction
Insufficient baseline data is a major challenge being
faced by consultants while preparing good quality EIA
reports. Lack of sampling networks and ill-defined sam-
pling a nd analysis procedures also add to the problem of
inconsistenc y. Althou gh all maj or industries s ubmit half -
yearly monitoring data to State Pollution Control Board
(SPCB), but the reliability of such data is doubtful.
Therefore, it is very hard to predict the pollution poten-
tial for proposed industries.
Additionally, the lack of proper guidelines on the use
of available modeling approaches put a question mark on
their application to the Indian conditions and on their
level of accuracy in predictions. Most of the mathemati-
cal models being used are not developed for Indian con-
ditions, so validation is necessary each time, thus the
accuracy of modeling depends on knowledge and exper-
tise o f t he a nal yst [15]. EIA practice in I ndia still c onsid-
ers impacts of individual activity/projects and the cumu-
lative impact o f the individual activity on the whole SIR
region is a major challenge before consultant as it re-
quires comprehensive baseline data collection.
5.5. Environment Management Plan (EMP)
EMP is one of the crucial parts of any EIA study wherein
detail descr iption is needed for proper implementation of
the same. However, for large projects, it is often difficult
to provide a detailed description. For example, the
greenbelt development is one of the mitigation measures
to reduce the adverse impact of pollution on the envi-
ronment but it is often quite challenging to mention in
the EIA report the type of plants to be planted consider-
ing the type of soil, agro climatic region and the type of
pollutant emitted by the industry. Also, the total cost for
implementing the mitigation plan is often hard to work
out.
5.6. Public Hearing Proceedings
Earlier, there was no accreditation of consultants for
sector specific projects, as a result of which the quality of
EIA reports deteriorated. At a later stage, the accredita-
tion of these consultants started through National Accre-
ditation Board for Education and Training (NABET).
Generally, for large scale projects, only sector specific
NABET accredited consultants can carry out EIA study.
These consultants are based anywhere in India and thus
language constrain is the main problem faced by these
consultants during public hearings proceeding as the ex-
ecutive summary and presentations are to be made
available in local language for the convenience of the
local people residing in the project area. Also, during the
proceedings, it is hard to convince people regarding the
project as they are very often ignorant about the concept.
What actually happens in such area development projects
is that the land is acquired from people and is developed
through town planning schemes wherein some percen-
tage of land is deducted for developing trunk infrastruc-
ture like road, street light, storm water drainage etcetera
and the remaini ng majo r portio n is given to the owner o f
land as a final plot of the land.
5.7. Lack of Exhaustive Ecological and
Socioeconomic Ind ica tors for
Impact Assessment
Ecological and socioeconomic assessments are often
marginalized within the impact study. One of the reasons
for such marginalization could be lack of a common
framework to support the impact assessment on ecologi-
cal and socioeconomic components. Only a few analyses
can be considered as standard and are found to have been
applied in most of the studies. In general, there does not
exist a common type of data, a common way of proc-
essing and organizing the information, of selecting the
evaluation criteria, of expressing the impacts and so on.
Contrary to this, air or noise pollution assessments ap-
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Potential Benefits and Ch allenges in Applying Regional EI A: A Case Study of Special Investment Regions in India
33
pear to be much more structured. They follow well- es-
tablished procedures that guide the entire assessment
right from data collection to discussion of the relevance
of the impacts.
5.8. Restricted Use of Geographic Information
Syste m (GI S) fo r Impact Prediction
GIS is a tool which can be applied for a project where the
spatial distribution of impact is relevant. The application
of this software is restricted to wider use mainly because
of cost associated with the development of GIS database.
However, the cost of the development of GIS database is
actually negligible when compared with the cost of im-
pact mitigation measures [16]. It is a significant tool
which can be used to make decision making process rap-
id and spatially accurate. Currently, even the MoEF de-
sires to have a satellite imagery based land use c la ssi fica-
tion for about three consecutive years for any project area.
By doing this, it want to ensure that the green areas and
drainage pattern are not adversely affected by the pro-
posed activity in the study region. However, the fact of
the matter is that not many EIA consultants are using
GIS during impact prediction probably because they are
not familiar wit h the utility of the software in this field.
6. Conclusions
Regional EIA came into the light to address the cumula-
tive impact of upco ming projects on the whole region. It
is significant especially for the projects having large spa-
tial extent which consists of industrial estates as well as
other areas such as residential, commercial and other like,
for example, SIR and large industrial estates which can
have irreversible impacts on the region as a whole.
Ho wever , the diffe rent up coming i ndustries i n the regio n
approach MoEF for EC as per the schedule of list of
projects or activities requiring prior EC mentioned in
EIA notification 2006 and 2009 and these projects are
not taking into consideration the terms and condition on
which the region as a whole is approaching for EC to
MoEF. Thus, to make Regional EIA more effective for
such large area projects like SIR, it is necessary to make
the process rapid so that different upcoming industries
can co me up with the pr ior ter ms and co ndition gi ven b y
MoEF for sustainable development.
The whole process of Regional EIA should be made
more participatory so that people can become aware of
the mechanism on which these area development pro-
jects/SIR are developing. Also, the application of the
new tools like GIS should be broaden for impact predic-
tion whic h is based o n the spa tial distrib ution o f impacts.
Efforts should also be targeted to include environmental
conservation concerns at policy and planning level so
that the environmental factors can be taken into consid-
eration well in advance at the policy level. As per the
new environment ministry policy for the national manu-
facturing and investment zone (NMIZs), the individual
units within the proposed NMIZs will be exempted from
public hearings, once a public hearing has been con-
ducted for the entire NMIZ, provided that these zones are
notified as industrial estates by the state governments
concerned. Thus, this will help in expediting the process
of EC of t he whole region which will faci litate to add ress
the environmental issues in advance for sustainable de-
velopment.
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