Category: Op-ed

India’s Arctic policy must push Western countries to give up double standards

Posted on by Chandra Bhushan

‘We need to act for the Amazon and act for our planet,’ said Canadian Prime Minister Justin Trudeau when fires ravaged the Amazon rainforest in August 2019. He was joined by many Western countries in preaching the virtues of protecting the ‘global common’ for combating climate change.

But the Western world’s concern for the global commons seems to limit itself, so far, to the sensitive ecosystems in the southern hemisphere. Thus, there is an international treaty to protect the Antarctic, which puts an indefinite ban on mining and hydrocarbon extraction. Furthermore, there is a long-standing demand, pushed by the G7 countries, for an international treaty to protect the tropical forests because they are the most biodiverse regions and ‘Lungs of Earth’.

However, when it comes to the northern hemisphere ecosystems, the same countries reject any international intervention. The Arctic is a classic case of this double standard. In 2008, the five coastal states of the Arctic Ocean (United States, Russia, Canada, Norway and Denmark) vowed to block any “new comprehensive international legal regime to govern the Arctic Ocean” in the Ilulissat Declaration.

The Arctic is essential for the stability of the earth’s climate, arguably even more than the Antarctic. Its sea ice helps moderate the global climate. In turn, it is also very sensitive to changes in climate. Consequently, the Arctic is warming more rapidly than the global average, and its sea ice has decreased dramatically since the late 1970s.

The warming of the Arctic is also speeding the melting of the Greenland ice sheet. Recent studies indicate that Greenland’s ice is melting on average seven times faster today than in the 1990s. Therefore, the changes in the Arctic have massive ramifications on sea level rise, aquatic ecosystems, and weather patterns across the world, including the monsoon.

But the sea ice melting has also opened up the fabled Northwest Passage, significantly shortening the route between the Atlantic and Pacific Oceans. In addition, Arctic seabed is now accessible for oil and gas extraction and deep-sea mining. As an estimated 40% of current global oil and gas reserves are in this region, there is a scramble over shipping lanes and resources, especially between the Arctic states. But other countries are also staking claim over the region’s resources, especially China.

India is an observer at the Arctic Council and has recently released a draft Arctic policy. Regrettably, the draft policy lacks objectivity. It is an ‘all-of-the-above’ policy with contradictory goals. On the one hand, the policy envisions India’s role in exploring and exploiting hydrocarbon and encourages investments by Indian companies. On the other hand, it also expresses deep concerns regarding the impacts on the country due to the changes in the Arctic, including on the monsoon, and proposes a slew of research activities. In conclusion, the draft terms the Arctic as ‘the common heritage of mankind’ and calls for ‘sustainable, responsible and transparent’ human activity.

But ‘sustainable, responsible and transparent’ exploitation of the Arctic is an oxymoron. It is impossible to take out oil and gas, burn them, and still keep global warming under check, or open the international shipping lane and expect the ocean to remain pristine. The irony is that the world’s wealthiest people, living in the already wealthy Arctic states, will gain the most by exploiting the resources. However, the costs will be borne by the world’s poorest, living in the coastal areas of the global South.

If India wants to be a serious player in the Arctic, then its policy must address this irony and the double standards of the Arctic states. It is important to realise that we made a mistake by becoming an observer in the Arctic Council, thereby accepting the Arctic states’ sovereign right over the Arctic ocean. We will repeat the error if we join them in exploiting the Arctic.

The bottom line is that India will not gain economically but is likely to lose massively due to coastal flooding, monsoon disruptions and changes in the ocean systems. Therefore, India’s Arctic policy should push for an international legal mechanism, similar to the Antarctic treaty, and save the Arctic’s pristine ecosystem and earth’s climate. In this endeavour, it might find allies in the Biden administration, which has just cancelled the Arctic Refuge oil programme and Keystone pipeline.

Paris agreement isn’t enough: Climate crisis is too important to be left to governments alone. Private sector too must pitch in

Posted on by Chandra Bhushan

The world is not only suffering because of Covid and economic distress. It’s also reeling due to climate disasters. The year 2020 is likely to be one of the three warmest years on record, and 2011-20 will be the warmest decade on record. 2020 has witnessed increasing wildfires, new extreme temperatures on land, sea and especially in the Arctic, a record number of hurricanes in the Atlantic.

But these extremes have not deterred countries from investing in fossil fuels. In 2020, G20 countries have committed over $230 billion in fossil fuel industry to revive the economy, compared to $150 billion in clean energy. The US, UK, Canada, Russia and India are pursuing major expansions in fossil fuel supply.

Therefore, despite a 7% decline in CO2 emissions due to the economic slowdown in 2020, the current policies of the countries have put the planet on a 3.2°C temperature increase trajectory. The ‘Emission Gap Report 2020’, recently released by the UN Environment Programme, finds that the G20 nations, who account for 80% of global greenhouse gas (GHG) emissions, are collectively not on track to meet their modest Paris Agreement commitments and countries like Australia, the US and Canada are falling short of their targets.

So, why is it that five years after the “historic” Paris Agreement was signed, the global efforts to fight climate change are in tatters? And, how can we turn the tide and galvanise global action?

The Paris Agreement is a voluntary agreement in which countries are free to choose their climate targets, called nationally determined contributions (NDCs). Countries are also supposed to self-differentiate based on their responsibility for causing climate change and their capability to mitigate it. Hence, developed countries are expected to take up higher emission cuts than developing countries. But if a rich country doesn’t commit to a higher target, no one can question or demand a revision.

Besides, if a country fails to meet its NDCs, there is no penalty. The only obligation is to submit reports regarding the actions countries are taking to meet their commitments. The Paris Agreement is, therefore, based on goodwill and moral persuasion. The assumption is that goodwill will prevail, countries will enhance their targets, and collective action would meet climate goals.

But herein lies the mismatch. Since the beginning, countries have viewed climate negotiations as an economic and not as an environmental negotiation. So, instead of cooperation, competition is the foundation of these negotiations. Worse still, the negotiations are viewed as a zero sum game.

For instance, Donald Trump believes that reducing emissions will hurt the US economy and benefit China, so he walked out of the Paris Agreement; George Bush did the same with the Kyoto Protocol. China, too, believes in this viewpoint, and despite being the world’s largest polluter, its NDCs are woefully inadequate and compliant with 4°C warming.

The fact is every country is looking out for its own narrow interest. They, therefore, are committing to do as little as possible. This is the Achilles heel of the Paris Agreement. This is the reason why the Agreement will not be able to limit warming below 2°C.

Therefore, the world would make a big mistake by putting all its efforts into the Paris Agreement to meet the climate goals, as pushed by a large section of climate activists post the victory of Joe Biden in the US presidential elections. We need a radically different strategy to stimulate actions from the government, private sector and civil society to put the world on track to the 1.5°C goal.

Thirty years ago, when the UN Framework Convention on Climate Change  (UNFCCC) was being negotiated, we lived in a very different world – where economic growth was intrinsically linked to fossil fuel consumption and carbon emissions. Countries had to increase emissions to grow and, therefore, they had to compete to stake claim over the remaining carbon budget.

But this argument is slowly vanishing. In many sectors, including the most crucial energy sector, economic growth and emission reduction can go hand-in-hand. This is because the costs of renewable energy, batteries, super-efficient appliances, and smart grids are falling so rapidly that they are already cost-competitive or will become competitive very soon with fossil fuel technologies. So, the reason for countries to compete with each other for carbon space is becoming immaterial every passing day. If countries cooperate, the cost of cleaner technologies can be reduced faster, which will benefit everyone.

But this cooperation cannot happen only at one global platform and treaty – UNFCCC and the Paris Agreement. We will need multiple multilateral, regional, and sectoral platforms to drive transformation. In fact, climate action will have to be made part of every existing and new platform and treaty as a distributed global effort.

Similarly, the climate crisis is too important to be left to governments alone. We need concrete actions from citizens (especially the wealthiest 1% who account for more than twice the emissions of the poorest 50%) and the private sector to reduce emissions.

Today, more than two-thirds of the richest 100 entities on the planet are corporations, not governments. And, just 100 companies have been responsible for 71% of the global emissions since 1988, the year Intergovernmental Panel on Climate Change (IPCC) was established. Corporations, therefore, are the problem, but they are also the solution. They have the resources to decarbonise, and they must be held accountable if they fail to do so.

Five years since the Paris Agreement, we are at an inflection point. Delay and prevarication is not an option; the world needs a bold vision and leadership to turn the tide.

Energy transition and Just Transition must go hand in hand – as coal mines become rapidly unprofitable

Posted on by Chandra Bhushan

The writing is on the wall. A few days back, Coal India Limited (CIL), the world’s biggest coal producer and India’s largest CO2 emitter, announced its plans to become a ‘net-zero energy company’ by 2023-24. The company plans to install 3,000 MW of solar power to meet all its electricity demand, which will also reduce its power expenses. The foray into solar is part of CIL’s diversification plans to shift from a coal company to an energy company.

NTPC Limited, India’s largest coal-based power company, has won a bid this week to install 470 MW solar power at Rs 2.01/kWh. This tariff is 40% below the cost of existing coal power in India and less than half the price of new coal-fired power. NTPC has set up a separate renewable energy subsidiary – NTPC Renewable Energy – to build its green energy portfolio.

When the biggest coal mining and coal power companies see their future in renewable energy, it is time for the policy makers to start planning for coal phase-down and Just Transition of coal mining districts.

Just Transition was included in the Paris Climate Agreement in 2015 to ensure that the workers and communities dependent on fossil fuels like coal do not suffer due to the closing of mines and power plants to meet the climate change goals. India has so far not engaged nationally or internationally on coal phase-out and Just Transition because of the country’s high dependence on coal for energy security and industrial growth. But the situation is changing rapidly, and coal mines are being shut down in an unplanned fashion due to various factors, including unprofitability.

In Jharkhand, 50% of mines are closed, and half of the operational mines are unprofitable. Most of the mines have been shut down without proper mine closure and plans for the mining areas’ socio-economic transition. The situation at the district level is even more ominous. In Bokaro, 16 of the 25 mines are already closed, and six of the nine operational mines will exhaust their reserves in the next 10 years. In Jamtara (made famous by the Netflix series of the same name), all five mines are closed. In Ramgarh, a top coal-producing district, 50% of mines are shut, and two-thirds of the operational mines are unprofitable. The situation becomes alarming when one considers the economic dependence of these districts on coal.

Take the case of Ramgarh. Coal mining and coal-dependent industries contribute about 40% of the district’s GDP. Furthermore, one-fourth of the households depend directly on the coal industry for income, mostly informal workers. Therefore, the unplanned closing of mines has real implications on the lives and livelihoods of workers and local communities. The irony is these districts suffered ‘resource curse’ and environmental degradation due to coal mining and are now suffering economically because of its unplanned closure.

But this need not be the case. Experiences worldwide show that Just Transition can be a win-win for the environment and the economy if planned and managed well. A similar effort can be made in India to close coal mines over the next two-three decades and transition coal-dependent districts to a non-coal economy. The good news is that opportunities exist for such a transition planning to start immediately.

About 70% of CIL’s mines are loss-making. Many of these mines are losing more than Rs 1,000 per tonne of coal production (coal price in India is about Rs 3,000 per tonne). These mines (more than 170 in numbers) produce less than 10% of coal, employ about 40-45% of CIL’s workforce and incur an aggregate loss of Rs 16,000 crore per year – about the same as the annual profits of the company. CIL can close these unprofitable mines and use the additional profits to implement Just Transition in these mining areas. Coal cess, which collects about Rs 38,000 crore per year and is used for GST compensation till 2022, can also be used for the socio-economic transition of these mining areas.

All the above can only happen if we accept the inevitability of coal phase-out and put in place a Just Transition policy and planning framework. Just Transition is imperative for India. If we do not start planning for a post-coal future now, our coal-dependent regions and industries will face major disruptions in the coming years.

How to control air pollution from stubble burning

Posted on by Chandra Bhushan

This is a straightforward article to discuss the real issues concerning stubble burning, including its contribution to pollution in Delhi-NCR, and why the solutions promoted by the government are not working.

Let’s start with the contribution of stubble burning to air pollution in Delhi-NCR. While we can bicker over the numbers, stubble burning is a short duration, highly polluting activity that significantly impacts air quality in October and November. The equation is simple: The 15-20 million tonnes of paddy stubble burnt in Punjab, Haryana, and western Uttar Pradesh, emit PM2.5 that is 4-5 times the annual PM2.5 emissions from all vehicles plying on Delhi roads. Let me repeat: PM2.5 emitted from stubble burning in just 60 days is 4-5 times what all Delhi vehicles emit in the entire year.

The intensity of emissions from stubble burning, therefore, is so high that even if a small fraction of these reaches Delhi, it would cause the city’s air quality to deteriorate significantly. This is precisely what happens during the stubble burning season. Wind coming from the northwest picks up pollutants from Punjab and Haryana and brings them to Delhi, worsening its already polluted air.

The next question is, why do farmers burn paddy stubble? First of all, not all farmers burn it; only about 25% of the paddy residues are burnt in Haryana, and this number goes up to 50-60% in Punjab. So, why do some farmers put their fields to flames while others don’t? There are three primary factors, apart from a few minor ones, that are driving this practice.

The most important factor is the technology used for harvesting. Farmers using Combine Harvester (called Combine) are most likely to burn the stubble, whereas those practising manual harvesting don’t. Combines cut the grainy part of the paddy plant (called spike) and leave about 30 cm of stem intact in the field. The farmer either has to manually cut the stem, use some machine, practice in-situ management, or burn it. Among these, burning is the easiest and most cost effective option.

The next factor is the use of the straw. Farmers who are unable to use or sell straw are burning it. In Punjab and Haryana, basmati paddy is mostly harvested manually because its straw is highly valued as animal fodder. The incidence of burning in basmati fields is, therefore, very low.

On the other hand, non-basmati straw is not used as animal fodder and hence is burnt. But there is a growing demand for non-basmati fodder in Rajasthan and Gujarat, and industries are also buying it for energy and other uses. Farmers who can sell their non-basmati straw do not practise stubble burning. Lastly, small farmers and tenant farmers are more likely to burn the stubble than big farmers, as they have fewer resources and risk appetite for using alternative technologies.

Now, let’s come to solutions promoted by the government. It has adopted a carrot and stick approach. On the one hand, it has banned burning and is imposing fines on farmers; on the other, it provides 50-80% capital subsidy to acquire farm machinery to adopt in-situ crop residue management. Unfortunately, neither is working.

It is vital to understand that the farm machinery the government is subsidising is not primarily designed to stop stubble burning. These machines are meant for zero tillage farming, in which stubble can be kept on the field and recycled in the soil. The zero tillage method has significant ecological benefits, including improvements in soil quality and lower water consumption; reduction in stubble burning is a co-benefit.

But zero tillage farming has two problems. First, it is an entirely new method of agriculture for Indian farmers. They have practised tillage agriculture for centuries, and therefore, moving them to zero tillage will not happen quickly. Second, it has a higher upfront cost. Despite subsidies, farmers incur an extra charge of about Rs 2,500 per acre to use these machines, which most can’t afford.

What, therefore, emerges from the above is that the use of Combines, weak market linkages for non-basmati stubbles and promotion of expensive technologies that require a long time for adoption, are sustaining the practice of stubble burning. What we need is a solution that is scientific, affordable, and culturally adaptable.

The easiest and affordable solution is to modify the Combine Harvester itself. We can redesign the Combine to cut the paddy straw from the plant’s base to remove the stem. The straw can either be sold or used as mulch in zero tillage agriculture. We can even incorporate a baling machine to the Combine to bale the straw, which can then be easily transported and sold.

The good news is that some newer versions of Combine already incorporate these features. I am not going to name companies, but I have seen foreign companies selling, in Haryana, precisely the kind of Combine I have explained above. The question is why Indian companies are not modifying their Combines and why the government is overlooking this simplest of solutions?

Ockham’s razor is a problem solving principle which states that the simplest solution is more likely to be correct than complex ones. This certainly is the case with stubble burning. By promoting complex solutions instead of a simpler one, we have botched up the stubble burning problem.

We have been barking up the wrong tree on air pollution

Posted on by Chandra Bhushan

On its 46th foundation day, the Central Pollution Control Board (CPCB) released two reports that should force us to re-examine our approach towards controlling air pollution.

The first report is the ‘National Ambient Air Quality Status & Trends 2019’, which contains air quality data for 344 cities/ towns from 28 states and 6 UTs. This is the only report that gives a snapshot of the status of air pollution in the country.

The second is a report on the ‘Impact of the Lockdown on Ambient Air Quality’. This report compares data for 12 cities from different parts of the country, including Delhi and NCR towns, during the lockdown phases with the corresponding periods in 2019. The report also estimates the various sources on air pollution in Delhi by chemically analysing PM2.5 (particles less than 2.5 microns in size or fine particles) in different phases of lockdown. Furthermore, it measured PM2.5 concentrations using satellite to estimate the air quality improvement over the entire country.

Read in isolation, these two reports do not give us much new information than which is known or expected. For instance, it is known that air quality is a pan-India problem. Similarly, we all experienced cleaner air during lockdowns, and therefore, a dip in the ambient air quality levels was expected. But once we put these two reports together, a completely new picture emerges that puts a question mark on our approach so far in controlling air pollution and the way National Clean Air Programme (NCAP) is being implemented. Here are the major findings of these two reports:

India has predominantly a PM10 problem: Most cities are exceeding the National Ambient Air Quality Standards (NAAQS) for PM10 (particles less than 10 microns in size or coarse particles). About 78% of the cities exceeded PM10 standards compared to 36% for PM2.5, 9% for NO2 and none for SO2.

We are not winning the air pollution battle: The data for the last few years show that while the SO2 concentration has decreased and NO2 concentration has remained stable, the PM2.5 levels have increased and PM10 levels have remained very high and are fluctuating. So, the two problem parameters – PM2.5 and PM10 – are not showing any sign of abating. In fact, PM2.5 levels have increased significantly in the last three years.

The CPCB report also lays to rest the controversy about air quality improvements in Delhi. PM2.5 levels in Delhi have consistently increased in the last 3 years and were 144 micrograms per cubic meters (μg/m3) in 2019 – more than three times the standard.

The baseline pollution level in India is high: During the peak lockdown (March 25-April 19), ground based monitoring stations in 12 cities recorded average PM2.5 levels of 25-50 μg/m3 and PM10 levels of 50-110 μg/m3. The satellite recorded PM2.5 levels in different parts of the country as 29-76 μg/m3, with an all-India average of 59 μg/m3. These levels are double the WHO standards and almost the same as NAAQS.

So, when transportation and industries were down by 80%, coal power plants were operating at 40% capacity, and people were largely indoors, even in relatively less polluting months of March-April, the country was barely meeting NAAQS. This indicates that pollution from cooking fuel, agriculture and natural sources are sufficient to breach air quality norms in large parts of the country.

An interesting fact the report captures is that during the lockdown in Delhi, the ratio of PM2.5 to PM10 was higher than in 2019. This is contrary to the general understanding; one would have expected lower ratio during the lockdown because factories and vehicles were not operating. The only plausible reason seems to be that we have been underestimating the contribution of PM2.5 from cooking fuel and natural sources.

If we join the dots, what emerges is that controlling PM10 emissions is key to solving the air pollution crisis. This would mean reducing the burning of solid fuels like biomass and coal and controlling emissions from land and agriculture. But by mainly focussing on cities and vehicles, we have lost the plot on air pollution. I will discuss this in detail in my next column.

Rebuilding a sustainable economy post Covid

Posted on by Chandra Bhushan
 

The global economy is in recession, and it is predicted to be more destructive than the Great Depression of 1929 and the Global Financial Crisis (GFC) of 2007. India too has been hit hard – tens of millions have lost their jobs, and the economy is projected to shrink by 4-9% in 2020-21. The last time the Indian economy contracted by more than 5% was in 1979 when the entire country was devastated by a once in a century drought (and some regions with floods).

Both Morarji Desai’s and Charan Singh’s governments fell, and we had mid-term elections which brought Indira Gandhi back into power. The fallout of this political upheaval was the founding of the Bharatiya Janata Party in early 1980, which successfully challenged the Congress and came to power within two decades. I believe that the India in which we live in today was in many ways created in 1979. The question is: What kind of India will the 2020 economic recession create? And, can we steer the ‘new’ India towards a more just, equitable and sustainable society?

A defining feature of the current economic crisis is the unprecedented fiscal and monetary stimulus packages being rolled out by the governments to provide relief and revive the economy. According to the International Monetary Fund, the total stimulus package for G20 countries averaged 12.1% of GDP – many times more than GFC. India too has announced a stimulus package worth 10% of GDP (though there are opposing views on this number). A quick analysis of the stimulus packages shows that they are primarily targeted to revive the current economy; hardly any country has thought about the long-term transition.

In India too, the focus is on the existing ‘brown economy’ and shovel-ready projects. The attention on the immediate crisis has also relegated climate and environmental concerns to the background. This is evident in the increasing plastic pollution and investments in the fossil fuel industry. Regulatory changes in the environment and labour sectors have also been proposed for the ‘ease of doing business’. While there is nothing wrong in short-term stimulus packages to keep the current economy alive, they must not be environmentally destructive. On the other hand, we also have to ensure that the long-term economic recovery takes into account the social and environmental crisis the world is facing today.

In other words, we must differentiate between a short-term stimulus to jumpstart an economy and a longer-term strategy to transition to a sustainable society. While the former mostly requires fiscal and monetary support, the latter requires long-term investments and serious pricing and policy reforms. The current economic crisis offers us a once in a lifetime opportunity to roll out a long-term strategy along with stimulus packages in core sectors:

  • Make agriculture sustainable: Agriculture accounts for 50% land, 85% water, uses a massive amount of chemicals and provides low-income livelihood to 50% of the population. Agriculture is central to building a sustainable society.
  • Transform the energy sector: We are at a cusp of change in the energy sector. With stimulus and R&D, we can build a new energy architecture based on renewable electricity, battery storage, smart grids and hydrogen fuel for industries.
  • Build resilient infrastructure: Massive amount of money will be spent by the government to build roads, airports, buildings etc as part of the stimulus package. We must make them ‘green’. Instead of roads, we should prioritise railways; instead of concrete jungles, we must build sustainable cities.
  • Invest in nature: Reversing deforestation and desertification and enhancing soil, wetlands and forests will build resilience against climate change and also provide massive livelihood opportunities.
  • Support local and small businesses: For jobs, sustainability and resilience of the supply chain, local small businesses are going to be the key. Government policies must support the development of efficient and green small businesses.
  • Invest in social capital and governance: None of the above would be possible without an educated and healthy society and good governance.

If we consider the experience of the past, then the economic recovery is going to be a long haul. The New Deal enacted by Franklin Roosevelt to respond to the Great Depression lasted for seven years (1933-39). Rebuilding in India will also need time and money. We must spend these rethinking about the type of economy and social system we need and want in the future.

India needs a new EIA law

Posted on by Chandra Bhushan

The Draft Environment Impact Assessment (EIA) notification 2020 has become a hot potato for the ministry of environment, forest & climate change (MoEF&CC). First, the Delhi high court overruled the ministry’s decision on the time limit for public comments and increased it till August 11. Then, in response to a formal complaint of the environment minister for spamming his email account, the cybercrime unit of the Delhi police invoked a terrorism-related law to shut down the website of young environmental campaigners, who were running an online campaign against the draft notification.

Though the police have now withdrawn the notice, the public uproar against the draft notification continues. Reportedly, lakhs of people have written to MoEF&CC to scrap the draft. So why is there such a hullabaloo around this subordinate legislation?

The draft EIA notification 2020 seeks to replace the existing law – the EIA notification 2006 – which grants Environment Clearance (EC) to projects. The major criticisms against the new draft are that it dilutes scope of public participation, legalises post-facto EC, removes the requirements of EIA study for several categories of projects, and weakens the provisions of reporting by companies. To understand the significance of these changes, let’s look at the 2006 law.

The EIA notification 2006 is possibly the most amended piece of environmental law. It has been amended 43 times, and at least 50 office memorandums (worth 350 pages) have been issued to tweak this law. Many of these changes have diluted the original version for some or other industry. The 2020 draft, in large part, brings together several of these revisions.

Therefore, effectively the 2020 version is a little worse than the existing one. So, while I appreciate the criticism of the proposed draft, keeping the 2006 version or even improving it is not going to solve the environmental problems in the country either. Let me explain why.

First, the approach of conducting EIA of individual projects is bad science. The environment is affected by the cumulative impacts of all activities, which project-specific EIAs fail to capture. Even if individual projects meet all benchmarks, their cumulative effects may still destroy the environment. This is evident in most mining and industrial areas of the country – from Singrauli to Korba and from Vapi to Patancheru.

Second, the EIA report, which forms the basis for EC decisions, is prepared by a consultant paid by the project proponent. This creates an apparent conflict of interest, and therefore most EIA reports are not worth the paper they are written on. I am yet to come across an EIA report that says that a project is likely to have significant ecological impacts.

Third, the process of the public hearing, which is mandated to take into account the concerns of the project-affected people, is a sham. Public hearing as practised in India is neither an informed consultation nor an informed consent. Most times, it is organised in the presence of police force, and physical violence is not uncommon.

Worse still, concerns of the community are most often dealt with in a cursory way by the expert appraisal committees (EACs). EACs typically ask companies to make some investments like building schools or providing drinking water to appease the community. MoEF&CC has even formalised this by calling these expenditures as ‘corporate environment responsibility’ (CER) and directing companies to earmark 0.125-2% of the capital investment on CER.

Finally, the environmental conditions imposed on the companies are rarely monitored by authorities. Monitoring is based on self-certified half-yearly reports submitted by companies; this has been reduced to yearly report in the 2020 draft.

The fact is that the current EIA and EC process in India is defunct. While it involves a lot of paperwork, there is little improvement on the ground. 99.9% of the projects are cleared, and non-compliance of the safeguards is rampant. The paperwork and transaction costs, on the other hand, gives legitimacy to industries to argue for watering down the process further.

It is, therefore, time that we demand a new EIA law based on sound science, and robust and transparent decision making processes to safeguard environment and community rights as well as to reduce investment risks of industries. This can be achieved by integrating three environmental concepts.

The first is the strategic environmental assessment (SEA). SEA will help to evaluate the ecological ramification of policies and plans and address concerns at the earliest stage of the decision making process. Many countries have adopted SEA to integrate environmental concerns in policy making.

The second is the regional planning approach. This involves conducting carrying capacity studies and developing regional plans based on them. This will allow us to take into account cumulative impacts and also provide information to project proponents to decide the location of the projects beforehand.

The third is project specific EIAs. In this, EIAs should be done for major projects and not for all. The focus here should be to improve environmental management plans and post-clearance monitoring. To ensure quality EIA reports, an environment information centre should be established to provide independent data to consultants and the EACs. In all the three processes, public participation should be ensured to improve assessment and scrutiny.

The EIA process is the most important piece of environmental law as it has the scope to decide the development trajectory of the country. But this powerful piece of legislation has never been discussed or legislated by the Parliament. Time to take the EIA discourse to the Parliament floor and develop a new law suitable for the 21st century.

Over regulation will not solve plastic waste problems

Posted on by Chandra Bhushan
 

An oft-repeated saying in India is that our environmental laws are good, but their implementation is poor. I have always disagreed with this simply because the primary reason for a law’s poor implementation lies in its flawed design. Most environmental laws in India are designed using a top-down approach, with an inadequate understanding of ground realities, leading to failed implementation. The recent draft guidelines published by the Ministry of Environment, Forest & Climate Change (MoEF&CC) on Extended Producers Responsibility (EPR) for plastic wastes is a classic example of this approach.

EPR is a ‘polluter pays’ principle under which producers and users of plastics, especially plastic packaging, have to take back plastic waste and recycle or dispose of them in an environmentally sound manner. The first regulation on EPR was enacted almost a decade back in the Plastic Waste (Management & Handling) Rules, 2011. The rules directed municipal authorities to set up plastic waste collection centres with financial support from the producers. The problem was that EPR was vaguely defined and the municipalities were not capacitated to implement the rules. This law was repealed within five years.

The Plastic Waste Management Rules, 2016 replaced the 2011 law. It introduced a slew of provisions for everyone in the plastics supply chain. Under EPR provisions, companies were directed to work out their own arrangements for collecting plastic waste and achieve 100% collection within two and a half years of enactment of the rules. Four years later, we are in 2020, and no company has fulfilled its EPR obligations. The new draft guidelines intend to amend this very situation.

It’s crucial to understand why companies have failed to meet their EPR obligations time and again. The main reason seems to be a combination of ambiguous laws, high regulatory burden, and inadequate time for implementation. For instance, under the 2016 rules, companies were asked to develop their modalities without any proper guidance. Some companies hired third party organisations called Producers Responsibility Organisations (PROs) to collect and dispose of wastes on their behalf. But, this was a colossal failure due to lack of formal coordination between PROs and municipalities.

Likewise, the regulatory burden was very high. Companies selling their products in multiple states had to register themselves in each state and meet state-wise EPR obligations. This became a logistic and accounting nightmare as companies now had to account for every kilogramme of plastic packaging sold through dealers/ sub-dealers in different states and collect back the same amount. Alongside this, the timeframe of two and a half years was just too short a window for companies to enact an EPR-compliant system.

It seems that MoEF&CC hasn’t learned from past failures – the 2020 draft guideline is prescriptive, top-down, and onerous. It proposes to register every producer/ brand owner/ importer, even those using a small amount of plastic for packaging their products. Similarly, it hopes to trace and account for every kilogramme of waste, through a system of multiple certifications and third party audits, using blockchain technology.

To compensate for the vagueness in 2011 and 2016 rules, the draft guidelines have allowed all possible EPR models without deciding which one is best suited for Indian conditions. Additionally, it has proposed a maze of licensing procedures, authorities, and committees at the Centre and in states to implement the law. In a nutshell, the draft EPR guidelines, if enacted, will likely again fail in implementation because it has ignored ground realities and put a high regulatory burden on companies.

If 20 years of plastic waste legislation has taught us anything – the first law was enacted in 1999 to ban (the still widely available) thin polythene bags – it’s that regulations and penalties are not sufficient to manage plastic waste; we need to transform the market and municipal services to solve this problem. Without strengthening and improving city waste management, we cannot hope to manage plastics. Moreover, the best way to reduce plastic waste is to find an alternative to plastics. An EPR policy that doesn’t recognise the need to decrease the use of plastics or create a straightforward, accessible model to support municipalities is bound to fail.

India is too poor to afford coal

Posted on by Chandra Bhushan
 

As part of the stimulus package to revive the economy, the Union government has announced a slew of measures to boost production and reduce imports of coal. It has liberalised the sector, curtailed the monopoly of Coal India Limited (CIL), and has announced an investment of Rs 50,000 crore for coal transportation infrastructure. All this has been done to double coal production in the next four years – from 730 million tonnes in 2019-20 to 1.5 billion tonnes in 2023-24. The question is: Can India afford such a massive increase in coal consumption?

Till three years back, coal was the cheapest source of electricity. Then in May 2017, the solar power tariff nosedived to Rs 2.62/kWh – 20% lower than the coal based power tariff of NTPC – and changed the energy market forever. Since then the coal power prices have kept increasing because of the increase in coal mining and transportation costs, while the costs of renewable and energy storage systems have continued reducing on the back of global and local innovations.

Just three weeks back, the Solar Energy Corporation of India awarded a project to ReNew Power to supply 400 MW of renewable energy, round the clock, at a tariff of Rs 2.90/kWh. Very few, if any, new coal power plants can compete with this tariff. In fact, the business case to install a new coal power plant is fast vanishing with such steep reduction in the prices of renewables with storage.

The business case entirely erodes if one includes health and environmental costs. Coal is the single largest source of air pollution and CO2 emissions in India. About half of all the CO2 emissions come from burning coal, and coal power plants account for 60% of particulate and 50% of sulphur dioxide emissions of the entire industrial sector. Deaths and diseases due to air pollution cost India a GDP loss of more than 5% and coal-related pollution constitutes a significant proportion of this. If we add carbon price and pollution cost to coal, then we should be shutting down even the existing power plants.

The private sector understands these risks and has practically stopped investing in coal power. According to a report published jointly by Global Energy Monitor, Sierra Club and others, a staggering 47,400 MW worth of coal power projects, mainly of the private sector, was scrapped in India in 2019. The private sector, instead, is now investing in renewable energy. In 2019, more than two-thirds of all the new power plants constructed in India were based on renewables, with the bulk of investments coming from the private sector and FDIs. The question, therefore, is why in the face of an overwhelming case against coal, the government is still promoting it?

The reason seems to be twofold: One, coal is viewed as the foundation of energy security and self-reliance (Atmanirbhar Bharat); and two, it is considered as a shovel-ready venture to revive the economy in parts of central and eastern India (about 25 districts) that are primarily dependent on coal for growth and employment. While these reasons can be justified as short-term expediency, they would become a liability very soon.

We need to understand that the investments made today will lock our economy to expensive coal for the next 20-30 years. This will limit our scope of innovation and reduce the pace of transition to clean and cheap renewable energy. We will, therefore, be paying a high cost of energy even when much more affordable options would be available. Can India, which already has one of the highest costs of energy in the world, afford this?

As far as coal mining areas are concerned, they have been suffering from ‘resource curse’ for decades. Most coal districts are polluted and poor with some of the worst human development indicators.

More coal mining will perpetuate the status quo. The need, therefore, is of economic diversification and a ‘just transition’ plan for these districts to reduce their dependence on coal.

If Covid-19 pandemic has taught us anything, it is that our current economic system is akin to ‘sawing-off the branch on which we are sitting’. By investing in coal, we will exacerbate climate change, increase air pollution and make energy more expensive in the future. We need an Atmanirbhar Bharat, but atmanirbharta (self-reliance) must also be affordable and sustainable.

The truth about air pollution in Delhi

Posted on by Chandra Bhushan

Contrary to the claims made by the Delhi government, air pollution in the city has deteriorated significantly since 2012.

There is an irony being played out in Delhi. While the national capital is reeling under one of its worst spells of air pollution, the Delhi government is bringing out a series of advertisements claiming that the pollution levels are down by 25%.

The advertisements mention that the levels of PM 2.5—particulate matter of size less than 2.5 microns—have reduced from 154 microgrammes per cubic meter (µg/m3) during 2012-2014 to 115 µg/m3 during 2016-2018. If this claim is valid, then we are on the right path, and we should continue with the current action plan to control air pollution. If it is not, then we should seriously change track and develop a new blueprint.

To understand the exact situation of pollution in the city, one has to understand the status of air pollution monitoring. Delhi has the largest number of air quality monitors in the country—47 monitoring stations, to be precise. Out of these, 10 are manual monitors, and 37 are continuous monitors. Four agencies own these monitors—the Central Pollution Control Board (CPCB) has 13 monitors, Delhi Pollution Control Committee (DPCC) has 24, India Meteorological Department (IMD) has 7 monitors, and the National Environmental Engineering Research Institute (NEERI) has 3.

Continuous monitors give pollution readings every 15 minutes, and these are used for calculating the Air Quality Index (AQI). CPCB has developed data validation criteria for these monitors. For example, continuous monitors must be operational for 16 hours in a day for estimating daily pollution levels. Similarly, they must be operational for 80% of the time in a year for determining the annual pollution levels.

In manual monitors, the monitoring is carried out for 24 hours, with a frequency of twice a week. There must be a minimum of 104 readings in a year for estimating annual pollution levels. In India, data from manual monitors are still used to make country-wide comparisons on the status of air pollution. The reason is simple: we have 573 manual stations in 240 cities/towns compared to just 202 continuous monitors in 112 cities/towns. Manual monitors, therefore, are sentinel monitors as they have comparable data for the longest time-frame.

As one can see in the accompanying graphic, continuous monitoring is a recent phenomenon in Delhi. Twenty continuous monitors were installed in 2018, and seven were introduced in 2017. We have data from only four monitors for 2012 onwards. But, there are significant data gaps from these four monitors. For instance, the Dilshad Garden monitoring station had correct data for only 32 days for 2013; the ITO station has data for less than 50% of the time for 2012, 2014, and 2016; and RK Puram has no data for 2013, and 2014. Most researchers have concluded that using data from the continuous monitors to estimate annual pollution levels for the years 2012 to 2016 is statistically wrong. Therefore, one has to rely on manual monitors to establish whether the pollution status has improved or deteriorated since 2012.

The data from manual monitors, published by CPCB, shows that the amount of PM 2.5 has almost doubled between 2012 and 2018—from 63 µg/m3 in 2012 to 121 µg/m3 in 2018. The average PM 2.5 level during 2012-2014 was 72 µg/m3, and during 2016-18, it was 115 µg/m3—an increase of 59%. So, air pollution levels in Delhi have increased significantly, and not reduced. From where, then, has the Delhi government put together data to show a reduction of 25%? Interestingly, there is another set of data put out by DPCC, which is less publicised. This DPCC data shows that the average level of PM 2.5 was 154 µg/m3 during 2012-14, which reduced to 131 µg/m3 during 2016-2018—a reduction of 15%. DPCC data, however, comes with a disclaimer. It clearly states that for the period 2012-2017, the data is based on four continuous monitors, and the 2018 information is based on 26 monitors. As explained above, the data from the four continuous monitors are incomplete. They cannot be the basis for estimating pollution levels during the 2012-2017 period. Even if we had complete data from the four continuous monitors, comparing data of four monitors with that from 26 monitors is highly spurious. It will not stand even the basic statistical scrutiny.

Nevertheless, let’s take the DPCC data with a pinch of salt, and put it together with the CPCB data. We can see, in the accompanying graphic, where the mistake has happened. The Delhi government has taken continuous monitoring data of DPCC for the period 2012-2014 and manual monitoring data of CPCB for the period 2016-2018 to claim that air pollution reduced by 25%. This is cherry-picking, and completely wrong. These types of analyses cannot be the basis for decision-making.

Let me end by saying that I support CM Arvind Kejriwal on stubble burning. He is absolutely right that the spike in pollution post-Diwali is because of stubble burning. One can smell biomass burning in the air, and we need to do something about this urgently. But, he is wrong to claim that his actions have led to a 25% reduction in pollution levels. Instead of putting out wrong information, it is important that his government goes back to the drawing board and develops a new blueprint for saving this historical city from Airpocalypse.

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