Tag: environmental impact assessment

An EIA process just for the Himalaya?

In The Hindu today, lawyers Archana Vaidya and Vikram Hegde have written an article asking for a separate environment impact assessment (EIA) process for the Indian Himalayan region. The article begins with a brief history of the EIA, its origins in 1976 in the need to assess river-valley power projects from an “environmental point of view”, the environment ministry’s first EIA notification in 1994, the second notification that followed after 11 years and 12 amendments, and finally the 2020 notification that shifted the burden of proof of impact from industry to the environment. So far so good, especially to indicate that the Indian Himalayan region wasn’t ever on the ministry’s mind as it shaped and reshaped EIA protocols.

Unfortunately, the threshold limits beyond which EIA is warranted for all these projects [mining, extraction of natural resources, power generation, physical infrastructure] is the same across the country. Despite all levels of government being acutely aware of the special needs of the Indian Himalayan Region (IHR), the region’s vulnerabilities and fragility have not been considered separately.

Then begins a section called “Flaws in the graded approach”, followed by the authors’ contention that the EIA’s graded approach – to change the stringency of the project requirements based on the value of the habitat that the project will affect – is unmindful of the special needs of the Indian Himalayan region.

Despite its special needs and as an area of immense ecological importance to the entire country (it serves as a water tower and the provider of ecosystem services), this region is treated like any other part of the country. … Despite [an] understanding of the fragility and vulnerability of the Himalayas, there is no mention of a different set of environmental standards needed if the project is located in the IHR.

This is strange. The article was written in the aftermath of the Sikkim floods (rather, the Sikkim dam-failure) and against the broader backdrop of the Indian government’s dam-building spree over Himalayan and sub-Himalayan rivers rivers as well as work on the Char Dham highway and other road-transport projects. But such systematic degradation isn’t happening only in the Himalaya: across India, both the national and state governments have embarked on projects that will see large tracts of forests, wetlands, and shoreline lose their environmental features, if they haven’t lost them already. Why single out the Himalayan region for special treatment? In fact, it’s trivially easy to argue that every geologic province in the country is different, endangered, and in need of more effective environmental government. So it might be better to modify the EIA to introduce different thresholds for projects situated in different ecosystems – in effect extending the protection the authors are asking for the Indian Himalaya to all the various environmental provinces in the country.

(This is only on paper, of course. Just yesterday, for example, the environment ministry, the Rayagada district administration, and the Odisha State Pollution Control Board organised a public hearing for the Vedanta bauxite-mining project in Rayagada and Kalahandi – a crucial step before the company receives its environmental clearance. But before the meeting, according to social activists and members of tribal communities in the area, the police physically assaulted people in the area and arrested several. District and ministry officials later stated that the public hearing – or a mockery of it? – went smoothly.)

Second, despite the section title, the authors don’t spell out any specific flaws in the EIA’s graded approach that pertains to the Indian Himalaya. So again, it should be easy to see that the Indian Himalayan region doesn’t pose particularly unique problems to the EIA process that other domains don’t; instead, they all pose the same single problem to the process: the EIA overlooks their diversity. The authors write that the Indian Himalayan region “serves as a water tower and [is] the provider of ecosystem services”. The latter can be retained as is and the first feature can be changed to, say, drainage for wetlands, carbon storage for old forests, sustenance for bird and insect species for younger ones, protection against erosion and salinity for coasts, etc. and we’d still be speaking the truth.

That said, the triviality of the alternatives to the authors’ suggestion highlights an important problem with the article’s thrust: that there ought to be a new EIA process for the Indian Himalaya when in fact the existing process has been so diluted, is routinely misapplied, and often has the environment ministry rushing to make excuses for industry actors. In other words, the authors have contended that the existing EIA fails the Indian Himalayan region. This is not true: it fails all Indian regions. And we need to admit that. The reason for failure also matters – that the national government simply isn’t interested in letting an EIA’s requirements get in the way of industrial expansion and ‘development’. If we don’t address this rot, any ‘new EIA’ created to address the needs of a specific region will suffer the same political capture and become worthless.

Backfiring biofuels in the EU

A version of this article as written by me appeared in The Hindu on November 8, 2012.

—

The European Union (EU) announced on October 17 that the amount of biofuels that will be required to make up the transportation energy mix by 2020 has been halved from 10 per cent to 5 per cent. The rollback mostly affects first-generation biofuels, which are produced from food crops such as corn, sugarcane, and potato.

The new policy is in place to mitigate the backfiring of switching from less-clean fossil fuels to first-generation biofuels. An impact assessment study conducted in 2009-2012 by the EU found that greenhouse gas emissions were on the rise because of conversion of agricultural land to land for planting first-generation biofuel crops. In the process, authorities found that large quantities of carbon stock had been released into the atmosphere because of forest clearance and peatland-draining.

Moreover, because food-production has now been shifted to take place in another location, transportation and other logistic fuel costs will have been incurred, emissions due to which will also have to be factored in. These numbers fall under the causal ambit of indirect land-use change (ILUC), which also includes the conversion of previously untenable land to fertile land. On October 17, The Guardian published an article that called the EU’s proposals “watered down” because it had chosen not to penalize fuel suppliers involved in the ILUC.

This writer believes that’s only fair – that the EU not penalize the fuel suppliers – considering the “farming” of first-generation biofuels was enabled, rather incentivized by the EU, which would have well known that agricultural processes would be displaced and that agricultural output would drop in certain pockets. The backfiring happened only because the organization had underestimated the extent to which collateral emissions would outweigh the carbon-credits saved due to biofuel-use. (As for not enforcing legal consequences on those who manufacture only first-generation biofuels but go on to claim carbon credits arising from second-generation biofuel use as well: continue reading.)

Anyway, as a step toward achieving the new goals, the EU will impose an emissions threshold on the amount of carbon stock that can be released when some agricultural land is converted for the sake of biofuel crops. Essentially, this will exclude many biofuels from entering the market.

While this move reduces the acreage because “fuel-farming” eats it up, it is not without criticisms. As Tracy Carty, a spokeswoman for the poverty action group Oxfam, said over Twitter, “The cap is lower than the current levels of biofuels use and will do nothing to reduce high food prices.” Earlier, especially in the US, the recourse of first-generation biofuels such as biodiesel had been resorted to by farmers looking to cash in on their steady (and state-assured) demand as opposed to the volatility of food prices.

The October 17 announcement effectively revises the Renewable Energy Directive (RED), 2009, which first required that biofuels constitute 10 per cent of the alternate energy mix by 2020.

The EU is now incentivising second-generation biofuels, mostly in an implied manner, which are manufactured from crop residues such as organic waste, algae, and woody materials, and do not interfere with food-production. The RED also requires that biofuels that replace fossil fuels be at least 35 per cent more efficient. Now, the EU has revised that number to increase to 50 per cent in 2017, and to 60 per cent after 2020. This is a clear sign that first-generation biofuels, which enter the scene with a bagful of emissions, will be phased out while their second-generation counterparts will take their places – at least, this ought to happen considering the profitability of first-generation alternatives is set to go down.

However, the research concerning high-performance biofuels is still nascent. As of now, it has been aimed at extracting the maximum amount of fuel from available stock, not as much at improving their efficiency. This is especially observed with the extraction of ethanol from wood, high-efficiency microalgae for biodiesel production, production of butanol from biomass with help from acetobutylicum, etc. – where more is known about the extraction efficiency and process economics than the performance of the fuel itself. Perhaps the new proposals will siphon some research out of the biotech. community in the near future.

Like the EU, the USA also has a biofuel-consumption target set for 2022, by when it requires that 36 billion gallons of renewable fuel be mixed with transport fuel, up from the 9 billion gallons mandated by 2008. More specifically, under the Energy Independence and Security Act (EISA) of 2007,

  • RFS program to include diesel, in addition to gasoline;
  • Establish new categories of renewable fuel, and set separate volume requirements for each one.
  • EPA to apply lifecycle greenhouse gas performance threshold standards to ensure that each category of renewable fuel emits fewer greenhouse gases than the petroleum fuel it replaces.

(The underlined bit’s what the EU has now included in its policies.)

However, a US National Research Council report released on October 24 found that if algal biofuels, second-generation fluids whose energy capacity lies between petrol’s and diesel’s, have to constitute as much as 5 percent of the country’s alternate energy mix, “unsustainable demands” would be placed on “energy, water and nutrients”.

Anyway, two major energy blocs – the USA and the EU – are leading the way to phase out first-generation biofuels and replace them completely with their second-generation counterparts. In fact, two other large-scale producers of biofuels, Indonesia and Argentina, wherefrom the EU imports 22 per cent of its biofuels, could also be forced to ramp up investment and research inline with their buyer’s interests. As Gunther Oettinger, the EU Energy Commissioner, remarked, “This new proposal will give new incentives for best-performing biofuels.” The announcement also affirms that till 2020, no major changes will be effected in the biofuels sector, and post-2020, only second-generation biofuels will be supported, paving the way for sustained and focused development of high-efficiency, low-emission alternatives to fossil fuels.

(Note: The next progress report of the European Commission on the environmental impact of the production and consumption of biofuels in the EU is due on December 31, 2014.)