This post has been self-published on Youth Ki Awaaz by YLAC. Just like them, anyone can publish on Youth Ki Awaaz.

The Dilution Of Environmental Impact Assessments: Why Should You Care?

More from YLAC

Written by: Adarsh Srinivasan, Ananya Bansal, Anvitha Kollipara, Kriti Raheja and Navya Khurana

Disclaimer: The views expressed in this article are solely of the authors and do not represent the views of YLAC as an organisation. 

On the international front, Prime Minister Narendra Modi is keen to portray his government as a protector of the environment. At the 2019 United Nations Climate Action Summit in New York, he spoke of judicious use of resources and living within our means. However, India’s own domestic policy action is dismal. India ranked 168th out of 180 countries on the 2019 Environment Performance Index, slipping from 155th in 2014.

Over the last six years, there has been a systematic easing of environmental regulation, starting with the removal of the ban on opening factories in eight ‘critically-polluted’ industrial areas in June 2014. The latest assault comes in the form of the Draft Environmental Impact Assessment (EIA) notification 2020, which eases the process of obtaining environment clearance for new/expansion projects and facilitates the legitimisation of defaulting ones.

Despite all that is happening in the country at this moment, we cannot allow the government to dilute the environmental law. In a subcontinent with some of the foulest air on the planet, ever-increasing incidences of floods and droughts that destroy communities, and recent disasters such as gas leaks and fires, a dilution of EIA will only exacerbate the current issues it faces. Obviously, one cannot forget the longer-term issues of climate change and sustainability that continue to threaten every citizen, in the plains of Punjab, the coast of Mumbai or the valleys of Assam.

What Is An Environmental Impact Assessment?

Impact assessment is a part of the policy cycle wherein future consequences of a current/proposed action are analysed. Impact assessments include social impact assessments, health impact assessments and environment impact assessments (EIAs). Impact assessment is largely a theory-based activity that seeks to establish a ‘chain of causation’, which results from a specific intervention in a given context. The advantage of EIA is that it ensures adherence to relevant laws and regulations, reduces adverse environmental effects, and balances economic and environmental benefit.

The latest assault on the environment comes in the form of the Draft Environmental Impact Assessment (EIA) notification 2020, which eases the process of obtaining environment clearance for new/expansion projects and facilitates the legitimisation of defaulting ones. Image has been provided by the author.

EIA was first introduced in the US in 1969, in the wake of the publishing of Rachel Carson’s “Silent Spring”, which detailed the various unintended consequences of pesticide use. Today, over 100 countries around the world – from New Zealand to Ukraine – undertake EIAs in some form.

What Is The History Of EIA In India?

The history of EIA in India began in 1976-77, when the Planning Commission requested the Department of Science and Technology to consider environmental aspects when examining river-valley projects. However, it wasn’t until 1994 that EIA was put in place in its current form, when the Union Ministry of Environment and Forests made Environmental Clearance (EC) mandatory for a range of activities under the Environmental (Protection) Act 1986. A 2006 notification expanded the scope of EIA to include more types of projects and put the onus on the state government to clear several of them. Listed below are some salient features of EIA in India:

  • It requires a public hearing for most projects wherein locals are invited to express their grievances on the project
  • Projects are cleared by either the state or central government depending on the size of the project
  • Projects are assessed by committees that consist of experts/professionals and representatives from the state/national government

What Are The Changes In The New EIA Notification?

To improve the ‘Ease of Doing Business’, according to the Central government, the new notification will streamline the process of obtaining environmental clearance and avoids delays. A closer look at the notification reveals otherwise – it tampers with the very basic structure of EIA.

Most notably, the notification weakens the public consultation process, which is recognised by researchers as being good practice. A long list of projects to be exempted from public hearing is provided; this includes projects of “strategic consideration” to be determined by the Central government. Furthermore, no information about such projects will be released to the public. The vague phrasing in the notification places enormous discretionary power at the hands of the Central government.

Once a project is declared of “strategic consideration”, the government is free to act with no consideration towards the environment and the local populace. The same exemption is given to an area within 100 km (aerial distance) of an international border, which includes huge swathes of Northeast India.

The notification also reduces the time period during which the public can submit responses during a public hearing from 30 days to 20 days, and cuts the overall duration of a public hearing from 45 days to 40 days. These reductions are insignificant compared to the average bureaucratic delay of 238 days in granting environmental clearance and serve only to take away power from Indian citizens should one want to oppose the displacement of a tribe or the destruction of the flora and fauna of their surroundings.

Environmental lawyer Ritwick Dutta calls the new EIA notification “a mockery of the law”. Image has been provided by the author.

Another dangerous aspect of the new notification is the introduction of post-facto approvals for projects that did not obtain Environmental Clearance or violated the terms of the clearance, upon the payment of a fine intended to recoup the cost of the negative externality. Environmental lawyer Ritwick Dutta calls this “a mockery of the law”.

The notification’s post-approval compliance mechanism is highly problematic – project proponents will only have to submit compliance reports every year, as opposed to each six-month period as stipulated in the 2006 notification. This would make locals more vulnerable to the environmental impact of a defaulting project. Additionally, the 2020 notification allows proponents to submit documents upon which compliance is to be assessed. This leaves room for the proponents to cherry-pick data which downplays the scale of ecological impact and removes critical neutrality from the EIA process.

In 2016, the Modi administration allowed construction projects measuring 20,000-150,000 m2 in area to proceed without environmental clearance, but the measure was soon quashed by the National Green Tribunal (NGT). Under the new notification, such projects are to be placed under ‘Category B2’, which exempts them from most aspects of the EIA process.

The notification largely excludes coal prospecting and solar park projects from the EIA mechanism. While one could argue that these measures are necessary to ensure India’s energy security, it is important to question the ethics behind leaving locals out of the picture when such projects could directly impact their health and well-being.

Coal mining is known to lead to chemical, air and dust pollution, and while coal prospecting only seeks to identify deposits of coal, a huge pro-coal lobby could develop in the case that coal is found in a particular area, and the local populace would barely be able to mount a resistance. The installation of solar panels requires the clearing and grading of a vast area, which leads to soil compaction and increased erosion.

Is There Anything Good About The Notification?

While there is general consensus among environment experts against the notification, there are some changes to EIA that can be viewed in positive light. The notification allows for many procedures under the EIA process to be conducted online, which could facilitate data collection and analysis. It further assimilates the many scattered amendments made by the Centre since 2006. Finally, the notification includes a new definitions clause that could help address the current ambiguity.

Was The Old Notification Useful?


It can be argued that the EIA had many structural issues to begin with and has been hollowed out over many years, suggesting that the current draft notification is only the final nail in the coffin. The 2006 notification also allowed for skipping public consultation if the situation is reportedly not conducive to consulting the public, a loophole that was abused time and again. The quality of Indian EIA reports has also been questioned, as reports are often found to be incomplete or containing forged data.

Loopholes were frequently exploited to escape the EIA process. For example, when the Centre initiated the Uttarakhand Char Dham highway project in 2016, it refused to obtain environmental clearance by arguing that the project was a combination of several highway-expansion schemes that each covered less than 100 km – only highway extensions of over 100 km require an EIA.

Although petitioners argued that the project did include extensions of over 100 km at a stretch, the government was ultimately able to get away with construction in an ecologically-sensitive zone with no oversight. It must be noted that the Char Dham project links key Hindu pilgrimage sites, and was therefore seen as appealing to a core voter base.

What Can You Do?

While the old EIA may have had its limitations, some of its best practices put India among an elite group of countries with similar legislation. It will be an uphill climb to make the EIA as effective as it was set out to be, but we cannot allow our country to fall backwards.

You have the ability to make your grievances with the new notification heard. Do your part in building a healthier, cleaner and sustainable India of tomorrow by raising your voice about these issues.

About the authors: The authors are students of the Young Researchers for Social Impact (YRSI) Program conducted by Young Leaders for Active Citizenship (YLAC). YRSI identifies promising high schoolers and builds their capacity as critical thinkers and problem solvers to produce thought-provoking solutions to pressing issues that affect our societies today. This article was written as part of the June 2020 edition of the programme.

You must be to comment.

More from YLAC

Similar Posts

By Badlaav Social Reform Foundation

By Subhransu Satpathy

By Hemlata Pandey

Wondering what to write about?

Here are some topics to get you started

Share your details to download the report.

We promise not to spam or send irrelevant information.

Share your details to download the report.

We promise not to spam or send irrelevant information.

An ambassador and trained facilitator under Eco Femme (a social enterprise working towards menstrual health in south India), Sanjina is also an active member of the MHM Collective- India and Menstrual Health Alliance- India. She has conducted Menstrual Health sessions in multiple government schools adopted by Rotary District 3240 as part of their WinS project in rural Bengal. She has also delivered training of trainers on SRHR, gender, sexuality and Menstruation for Tomorrow’s Foundation, Vikramshila Education Resource Society, Nirdhan trust and Micro Finance, Tollygunj Women In Need, Paint It Red in Kolkata.

Now as an MH Fellow with YKA, she’s expanding her impressive scope of work further by launching a campaign to facilitate the process of ensuring better menstrual health and SRH services for women residing in correctional homes in West Bengal. The campaign will entail an independent study to take stalk of the present conditions of MHM in correctional homes across the state and use its findings to build public support and political will to take the necessary action.

Saurabh has been associated with YKA as a user and has consistently been writing on the issue MHM and its intersectionality with other issues in the society. Now as an MHM Fellow with YKA, he’s launched the Right to Period campaign, which aims to ensure proper execution of MHM guidelines in Delhi’s schools.

The long-term aim of the campaign is to develop an open culture where menstruation is not treated as a taboo. The campaign also seeks to hold the schools accountable for their responsibilities as an important component in the implementation of MHM policies by making adequate sanitation infrastructure and knowledge of MHM available in school premises.

Read more about his campaign.

Harshita is a psychologist and works to support people with mental health issues, particularly adolescents who are survivors of violence. Associated with the Azadi Foundation in UP, Harshita became an MHM Fellow with YKA, with the aim of promoting better menstrual health.

Her campaign #MeriMarzi aims to promote menstrual health and wellness, hygiene and facilities for female sex workers in UP. She says, “Knowledge about natural body processes is a very basic human right. And for individuals whose occupation is providing sexual services, it becomes even more important.”

Meri Marzi aims to ensure sensitised, non-discriminatory health workers for the needs of female sex workers in the Suraksha Clinics under the UPSACS (Uttar Pradesh State AIDS Control Society) program by creating more dialogues and garnering public support for the cause of sex workers’ menstrual rights. The campaign will also ensure interventions with sex workers to clear misconceptions around overall hygiene management to ensure that results flow both ways.

Read more about her campaign.

MH Fellow Sabna comes with significant experience working with a range of development issues. A co-founder of Project Sakhi Saheli, which aims to combat period poverty and break menstrual taboos, Sabna has, in the past, worked on the issue of menstruation in urban slums of Delhi with women and adolescent girls. She and her team also released MenstraBook, with menstrastories and organised Menstra Tlk in the Delhi School of Social Work to create more conversations on menstruation.

With YKA MHM Fellow Vineet, Sabna launched Menstratalk, a campaign that aims to put an end to period poverty and smash menstrual taboos in society. As a start, the campaign aims to begin conversations on menstrual health with five hundred adolescents and youth in Delhi through offline platforms, and through this community mobilise support to create Period Friendly Institutions out of educational institutes in the city.

Read more about her campaign. 

A student from Delhi School of Social work, Vineet is a part of Project Sakhi Saheli, an initiative by the students of Delhi school of Social Work to create awareness on Menstrual Health and combat Period Poverty. Along with MHM Action Fellow Sabna, Vineet launched Menstratalk, a campaign that aims to put an end to period poverty and smash menstrual taboos in society.

As a start, the campaign aims to begin conversations on menstrual health with five hundred adolescents and youth in Delhi through offline platforms, and through this community mobilise support to create Period Friendly Institutions out of educational institutes in the city.

Find out more about the campaign here.

A native of Bhagalpur district – Bihar, Shalini Jha believes in equal rights for all genders and wants to work for a gender-equal and just society. In the past she’s had a year-long association as a community leader with Haiyya: Organise for Action’s Health Over Stigma campaign. She’s pursuing a Master’s in Literature with Ambedkar University, Delhi and as an MHM Fellow with YKA, recently launched ‘Project अल्हड़ (Alharh)’.

She says, “Bihar is ranked the lowest in India’s SDG Index 2019 for India. Hygienic and comfortable menstruation is a basic human right and sustainable development cannot be ensured if menstruators are deprived of their basic rights.” Project अल्हड़ (Alharh) aims to create a robust sensitised community in Bhagalpur to collectively spread awareness, break the taboo, debunk myths and initiate fearless conversations around menstruation. The campaign aims to reach at least 6000 adolescent girls from government and private schools in Baghalpur district in 2020.

Read more about the campaign here.

A psychologist and co-founder of a mental health NGO called Customize Cognition, Ritika forayed into the space of menstrual health and hygiene, sexual and reproductive healthcare and rights and gender equality as an MHM Fellow with YKA. She says, “The experience of working on MHM/SRHR and gender equality has been an enriching and eye-opening experience. I have learned what’s beneath the surface of the issue, be it awareness, lack of resources or disregard for trans men, who also menstruate.”

The Transmen-ses campaign aims to tackle the issue of silence and disregard for trans men’s menstruation needs, by mobilising gender sensitive health professionals and gender neutral restrooms in Lucknow.

Read more about the campaign here.

A Computer Science engineer by education, Nitisha started her career in the corporate sector, before realising she wanted to work in the development and social justice space. Since then, she has worked with Teach For India and Care India and is from the founding batch of Indian School of Development Management (ISDM), a one of its kind organisation creating leaders for the development sector through its experiential learning post graduate program.

As a Youth Ki Awaaz Menstrual Health Fellow, Nitisha has started Let’s Talk Period, a campaign to mobilise young people to switch to sustainable period products. She says, “80 lakh women in Delhi use non-biodegradable sanitary products, generate 3000 tonnes of menstrual waste, that takes 500-800 years to decompose; which in turn contributes to the health issues of all menstruators, increased burden of waste management on the city and harmful living environment for all citizens.

Let’s Talk Period aims to change this by

Find out more about her campaign here.

Share your details to download the report.

We promise not to spam or send irrelevant information.

A former Assistant Secretary with the Ministry of Women and Child Development in West Bengal for three months, Lakshmi Bhavya has been championing the cause of menstrual hygiene in her district. By associating herself with the Lalana Campaign, a holistic menstrual hygiene awareness campaign which is conducted by the Anahat NGO, Lakshmi has been slowly breaking taboos when it comes to periods and menstrual hygiene.

A Gender Rights Activist working with the tribal and marginalized communities in india, Srilekha is a PhD scholar working on understanding body and sexuality among tribal girls, to fill the gaps in research around indigenous women and their stories. Srilekha has worked extensively at the grassroots level with community based organisations, through several advocacy initiatives around Gender, Mental Health, Menstrual Hygiene and Sexual and Reproductive Health Rights (SRHR) for the indigenous in Jharkhand, over the last 6 years.

Srilekha has also contributed to sustainable livelihood projects and legal aid programs for survivors of sex trafficking. She has been conducting research based programs on maternal health, mental health, gender based violence, sex and sexuality. Her interest lies in conducting workshops for young people on life skills, feminism, gender and sexuality, trauma, resilience and interpersonal relationships.

A Guwahati-based college student pursuing her Masters in Tata Institute of Social Sciences, Bidisha started the #BleedwithDignity campaign on the technology platform, demanding that the Government of Assam install
biodegradable sanitary pad vending machines in all government schools across the state. Her petition on has already gathered support from over 90000 people and continues to grow.

Bidisha was selected in’s flagship program ‘She Creates Change’ having run successful online advocacy
campaigns, which were widely recognised. Through the #BleedwithDignity campaign; she organised and celebrated World Menstrual Hygiene Day, 2019 in Guwahati, Assam by hosting a wall mural by collaborating with local organisations. The initiative was widely covered by national and local media, and the mural was later inaugurated by the event’s chief guest Commissioner of Guwahati Municipal Corporation (GMC) Debeswar Malakar, IAS.

Sign up for the Youth Ki Awaaz Prime Ministerial Brief below