With concerns over the increasing chances of human vulnerability due to climate related changes, the role of public participation in climate policy making has become more important. Incorporating public opinion has been a key feature of environmental decision making through the formalized environmental impact assessments (EIAs), meant to objectively evaluate developmental projects with environmental impacts. However, recent evidence has raised concerns that India’s EIA process is no more than a procedural puppet. This is of concern if India is serious about integrating equitable and effective climate policies which has been the rhetoric echoed by government officials.

EIAs in India
EIAs have become an integral part of environmental policy formulation and sustainable development dialogue in various countries. While they continue to be scrutinized for their subjectivity and tediousness, they remain an essential component of government regulations seeking interested in balancing development priorities with environmental conservation. In India, environmental impact statements were introduced and mandated for developmental projects in 1994. However, the formalized EIA process in India has had significant flaws since its 1994 inception despite multiple amendments to improve. The role of public participation in the EIA process and sustainable development goals has faced challenges in the Indian context due to population density, land pressures, and varied uses/users natural resources. The Chipko movement in 1980s protesting forest encroachment, Narmada coalition contesting Sardar Sarovar dam in the 1980s, the halt of Tata Nano factory in 2006  due to land disputes are just a few prominent events catalyzing the closer inspection and need for public participation inclusion in India’s EIA process.

The environment and local livelihoods take a back seat
In response to these events, the Government of India, since 1994 has amended the EIA process. In 2006 the EIA legislation was revamped to facilitate environmental clearances- streamlining criterion and bureaucratic processes to clear development projects faster! The environmental clearance notification has given way to poor quality documentation in the EIA process such as false accounting of flora and fauna, omitted endangered species, and fraudulent statements in impact statements that received clearance by the Ministry of Environment and Forests (MoEF).

In mid January 2009, the MoEF published a notification mandating that environmental clearances and associated terms be published in two local newspapers and on the state government website. Is this enough action to increase transparency and bolster the credibility of India’s EIA process? While this action can be viewed as welcoming, is it truly accessible to the communities and locales affected by such projects?

The outlook
Recent analysis over India’s climate policy suggest it is, in many ways, heavily centered on developing energy security and development agendas that are sustainable. With equally important concerns over issues such as energy and water security, environmentally-friendly alternative energy and developmental projects, such as dams and mining, are more likely to get the green light than face intense scrutiny over their environmental and social costs. Is this trend compatible with India’s climate policy principles- “Protecting the poor and vulnerable sections of society through an inclusive and sustainable development strategy, sensitive to climate change” (Page 2, National Action Plan on Climate Change)?

Upper Bhavani dam in Indian state of Tamilnadu

Talks at Poznan about a re-engineering of the Clean Development Mechanism, Kyoto Protocol’s righteous son, have been Bonn-ed. This does not come as a surprise for some observers, but disappointment is understandable. As a flagship of the Kyoto Protocol’s market-based approach to climate change, one could have hoped that delegates fixed at least the most visible holes perforating its surface.

What holes?

UNFCCC recently removed DNV’s CERs verification licence. The unease about project managers hiring the verification team then found, rightly or wrongly, an a posteriori justification. (DNV said it would win back its licence within a month).

Speaking of discomfort, the demonstration of additionality by the project promoters themselves also raised concerns throughout the short history of CDM. With acute information asymmetry between promoters and the Secretariat, the demonstration of additionality can potentially suffer credibility deficit.

Finally, the environmental impact assessment (EIA) of CDM projects is regarded as insufficient. A good EIA would make sure, for instance, that we don’t remove CO2 from the atmosphere ruining an entire ecosystem in the process of doing so.

What can be done? Some suggestions from delegates, bloggers and specialists.

• UNFCCC, not promoters, should hire and pay verification firms directly.
• UNFCCC, not promoters, should assess additionnality.
• Promoters should be required to conduct sound EIAs for CDM projects.

CDM being a rather complicated tool, its short history has given much weight to the procedural status quo. Project promoters, countries and Designated National Authorities (DNAs) have climbed up the learning curve of the actual CDM: they probably don’t want to start over again with new procedures.

In order to gather wide interest, an agenda for CDM should try to mix discussions on potential simplifications of project methodologies with discussions on the procedural modifications listed above.