Revisiting The EIA Report

The EIA reports are prepared for the prescribed projects, and legally approved to make the project environment-friendly and sustainable.Almost all countries have internalised the use of EIA tool for the environmentally sensitive projects and have enjoyed with the outcome of such a study to timely address project-specific environmental impacts

May 15, 2024, 8:41 a.m.

The Environmental Impact Assessment (EIA) report of any project is multi-stakeholder owned. The project proponent, local beneficiaries and interested people, and approving and other agencies are sufficiently engaged in the EIA process right from the preparation and approval of the environmental scoping and its EIA report, including in public hearing. Local people are also engaged in implementing the appropriate measures, when necessary.

The EIA reports are prepared for the prescribed projects, and legally approved to make the project environment-friendly and sustainable.Almost all countries have internalised the use of EIA tool for the environmentally sensitive projects and have enjoyed with the outcome of such a study to timely address project-specific environmental impacts. This process has a well-defined beginning and an end. Alternatively, it starts with environmental scoping and ends with auditing. The EIA is a predictive tool and uses science to identify, predict and evaluate the significance of the impacts. It addresses two types of impacts - 'will happen' and 'might happen'. Both identified and predicted impacts are evaluated based on existing policies, legislations or national and local priorities, practices and value of resources that will or might be impacted by the project activities. Each step of the EIA process has specific meaning and value. Misunderstanding or misinterpretation would lead to the preparation of under-quality report and will create additional problems during the implementation of the legally approved EIA report. To understand the existing situation, an EIA report of a hydro-project is reviewed.

The EIA report of the Bajhang Upper Seti Hydroelectricity Project was made public on 4 April 2024 to collectsuggestions within 7 days. This project has an installed capacity of 216 MWand will generate 163.6 gigawatts hour net energy during the dry season. This is a peaking-run-of-the-river project designed for 4.5 hours peaking capacity. It will store 0.835 million m3of water by damming the Seti Khola which has 34.1 m3/sec water discharge. This review flags few issues that are ignored or overlooked in the EIA report with a view to encourage the proponent and the government to carefully looksuch reports.

One of the objectives of this EIA study, as mentioned in the report,is to identify positive and negative impacts and recommend appropriate and practical mitigation and benefits enhancement measures.The objective ignores the need for predicting and evaluating the impacts, the fundamentals of the EIA tool.

The EIA report clearly mentions the record of tree species from the representative samples along the proposed road, adit portal and damsite of the direct impact zone. Representative samples represent over 1 percent of the potentially impacted total area of forests.Forcompensatory plantation (@ 1:10), enumerated data would be realistic.The sample-based estimation might create practical challenges in issuing forest area and number of trees that should be felled as a part of site clearance. The beauty of this EIA report lies on conformity on impacts on few aspects. For example, this report confirms no fish in the Seti kholabetween the proposed damsite and downstream of powerhouse site based on handset net used 6 times to know fish diversity. However, it proposes 10 percent release of water to maintain downstream ecosystem. It includes issues raised during the public hearing, and measures proposed to address people's concerns.

In 1990, the EIA Guideline drafting team considered the need for a review of policies and laws to timely inform the decision-makers whether the project can be implemented based on existing national policies and legislations. If not, review should clearly include the policy and legislative barrier(s) for project implementation. Guidelines were developed to help the EIA report preparer(s).In this EIA report, proponent has reviewednumber of policies and legislations without any inferences. It simply includes the provisions without linking with the project and its activities.

The EIA report rightly analyses the alternatives, and selects the alternative based on the length of the headrace tunnel, and area of forest to be used, including number of trees to be felled down for the construction of the project. It would have been more logical to identify, predict and evaluate the significance of the environmental impacts of both alternatives and select the best alternative on the environmental ground.

The EIA report has used the magnitude, extent, and duration to know the impact significance. Impacts are mentioned direct or indirect.Summary of impact is given in one sentence within bracket in italic form. The reporthas used 'shall, will, and may' to describe impacts.Unclarity on identified or predicted impacts indicate non-consideration of location and activity-specific impacts. For example, drying-up of water sources along the tunnel area is possible but the impact is considered insignificant due to non-use of water sources at the local level. Here, 'use' is the determining factor. The project will not be affected by glaciers as glacier is not reported at its watershed. Impact significance related to reduce climate risk is rated high with low magnitude, regional extent, and long-term duration. Similar prediction is made for earthquake risk (high magnitude, site-specific extent, and long-term duration). These impacts are here considered 'predicted'.

Magnitude of the location-specific felling of 2144 trees along the project direct impact areaswith two protected species (lauthsalla and Juglans), and 481 trees along the access road is rated medium. While submergence of plant species with medium magnitude, regional extent and long-term duration is ranked with high significance. Submergence seems site-specific impact, but its extent is considered regional. The report has specified no impact on fish species and magnitude of the impact on protected species is ranked minor. The EIA report categorically mentions that project construction will not affect water use right as Seti Khola is not used for drinking, irrigation, commercial fishing, or tourism but the significance of impact is categorised low. In some cases, impacts are rated in absence of baseline condition.

The EIA report mentions the importance of impact insignificant, related to the generation of employment at local level, but skill development has high importance like that of climate risk mitigation. It happened so as the scores allocated for magnitude, extent and duration of the impact are unclear.Score-based rating for significant or insignificant impacts confuse the reviewers and decision-makers. This requires proper interpretation, and if necessary, some explanation. Previously, importance value of a plant species was calculated using frequency, density, and dominance in relative terms. Message of the high importance value of a species that will or might be affected by the project activities should be clearly understood to select enhancement or mitigation measures.

Review indicates number of areas where improvement is required to make the EA report practical and implementable. Twenty-eight years of experience in Nepal in facilitating, preparing, approving, and implementing the EIA report of social and economic development, and infrastructure sectors seek for additional initiatives to improve the technical quality of the EIA report to make the development projects environment-friendly and sustainable.

Based on review of the EIA report of this project, and in view of unclarity on identified and predicted impacts, mitigation and enhancement measures proposed for insignificant impacts, and impact score seen in the report, the government is encouraged to be clear on what it needs for the approval of the EIA report(s) and timely inform the proponents to ensure technical quality of such report(s). The government may wish to consider the following for few issues noticed:

a.reasons of lower total score of site-specific impacts, and proposed mitigation measures for insignificant impacts, and/or dealing with impact-based mitigation and enhancement measures, even the score-based impact is ranked insignificant;

b.dealing with mitigation measures and auditing parameters mentioned without baseline; and

c. discontinuation to include the percentage of the total project cost for proposed environmental enhancement and mitigation measures started in 2006.

The EIA report mentions costs for mitigation measures to be included under the civil cost for some measures. The EIA report estimates nearly NRs. 2 crore and 96 lakhs for benefits enhancement and adverse impacts mitigation measures, including NRs 1 crore and 18 lakhs for compensatory plantation, and NRs 19 crores and 50 lakhs(0.5 percent of the total project cost) for community support programmes totalling to about NRs. 22 crores and 46 lakhs, excluding those which will be included in the civil cost. This is less than 0.6 percent of the total project cost.For this project, the need for environmental management cost might be sufficiently below 1 percent of the total project cost.

Interestingly, this EIA report does not specify the cost for environmental monitoring and auditing. It includes number of plans such as dam protection plan, solid waste management plan, disaster management plan etc. but lack the basic elements of the plan and budget required for their implementation.

The government is encouraged to take measures to make the EIA report project-specific, categorise impacts into identified and predicted, and evaluate the significance of those impacts. The government should strictly enforce the implementation of the approved EIA report to understand the state of compliance with the implementation of the enhancement and mitigation measures, and effectiveness of the measures in addressing the project-induced impacts. Environmental monitoring and auditing provide multiple opportunities to streamline realistic identification and prediction of environmental impacts, evaluation of their significance along with corresponding appropriate and location-specific benefits enhancement and adverse impacts mitigation measures, and clarify the environmental management plan, including monitoring and auditing requirements.

All countries have institutionalised and benefitted from the use of EIA tool to advance sustainable development. Over 3 decades of experience in internalising the EIA tool in Nepal would provide multiple opportunities to benefit from this tool. However, small effort is required with clarity of both proponents and the approving agencies.

batu uprety111.jpg

Batu Uprety

Former Joint-Secretary and Chief of Climate Change Management Division, Ministry of Environment (then), and former Team Leader, National Adaptation Plan (NAP) formulation process. E-mail: upretybk@gmail.com

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