6. Evaluation Criteria for EIA/EMP reports
.
 One cool judgement is worth a thousand hasty counsels. The thing to do is to supply light and not heat.
- Woodrow Wilson

6.0 Introduction
The previous chapter has adequately revealed that no single methodology represents a panacea for all the objectives of EIA. EIA methodologies are generally descriptive and do not provide adequate evaluation of impacts. Some methodologies do not distinguish the impacts in terms of their significance. Many methodologies are project specific and none allow direct linkage to carrying capacity. It is therefore a daunting task to select a methodology and recast the same to make it a decision making tool to ensure environmental sustainability. The previous chapter has also underscored that while some methodologies are better for impact identification some others may be superior for impact evaluation.

A variety of methodologies are used in EIA and many of them have been adaptations of some well known planning methodologies. One such methodology in use, - the Goals Achievement Matrix, has been described by Westman (1985). But the complexities involved preclude their adoption as appropriate EIA methodology in the context of developing countries. A 1982 survey reported that, in the selected four US federal agencies, as many as 15 different EIA methodologies were in use (Caldwell et al. 1982). Out of 348 EIA reports analysed 106 (30%) did not use any of the 15 methodologies but rather relied on the methodology developed by the EIA practitioners involved. Needless to mention, such methodologies (developed by the EIA practitioner on a case to case basis) often lacked adequate theoretical considerations. Out of the 242 EIA reports in which at least one of the recognised methodologies were used about 10% (25) used the Leopold matrix. BEES was used in the assessment of seven cases only. Habitat Evaluation Procedure was used in as many as 30% (75) reports. Water Resources Assessment Methodology (WRAM) was used in only 15 reports.

The present situation in developing countries is somewhat similar. In spite of the existence of a number of theoretically sound methodologies few EMP reports are prepared based on these. According to Bisset (1988) 'little information exists on the actual operational performance of various methodologies' and the statement equally applies to all the developing countries including India. The author feels that the need for an in-depth study on the effectiveness of EIA practices in India can hardly be over-emphasised. However, that is far beyond the scope of this single-researcher study. Critical analysis of EIA reports may be expected to reveal the strengths and weaknesses of the methodologies in use. The author proposes to utilise the review criteria presented in this chapter for carrying out an in-depth evaluation of EIA/ EMP reports. The results would be published in a subsequent monograph to be published shortly.

6.1 EIA/EMP Reports Prepared in India
Procedural aspects of EIA study are reported in Chapter-4. Annual reports of MOEF provide statistics on environmental appraisal carried out in the respective calendar year. Choudhury (1995) estimates the number of EIA studies on mining projects completed between 1982 and 1995 to be between 200 to 300. As has already been pointed out in Chapter-4, prior to 1994 EIA of mining projects were conducted to comply with the administrative requirements and there was no legislative requirement for the same. Between September 1990 to October 1993 only 20 mining projects in the non-coal sector have been cleared by the environment ministry (IBM 1994). As per the requirements of EIA notification 1994 all proposed mining projects (for mining of non-minor minerals) with a mining lease of more than five hectares are to undertake EIA study. A two-stage environmental clearance procedure is followed for all site-specific projects, which are required to obtain site clearance before environmental clearance.

The trend in the number of mining EIAs carried out from 1990 to 1996 are presented in Table 6.1.
Table 6.1 Number of EIA reports on mining projects submitted to MOEF
Year
No. of EIA reports submitted
Site clearance application
1990
18
-
1991
11
-
1992
37
-
1993
37
-
1994
46
320
1995
57
117
1996
52
26

Table 6.2 Number of mining projects cleared from environmental angle
Year
Number of projects
Cleared
Rejected
Additional information sought
1990
20
20
35
1991
21
12
18
1992
20
2
33
1993
41
0
18
1994
13
5
57
1995
19
13
70
1996
39
48
35


It may be noted that imposition of legal requirement has resulted in an increase in the number of EIA reports prepared. In the year 1994 as many as 57 projects were denied environmental clearance because of inadequate information provided in the EIA report (Table 6.2). Predictably, this shows the impacts of reconstituting the environmental appraisal committee (experts committee) and making EIA a legal requirement. Out of 75 projects evaluated only 13 received clearance and five were rejected on merit. Similarly out of 320 applications received in 1994 only 24 mining project received site clearance. 210 projects were denied clearance while 86 proponents were asked to furnish additional details. From these data it can be inferred that many EIA reports of mining projects prepared in India fail to provide necessary information. The author has been informed that evaluation of EIA reports is intuitive. No specific evaluation criterion is prepared or followed.