Shri C.K. Mishra

The Hon’ble Secretary Ministry of Environment Government of India New Delhi

Dear Sir,

Subject: Seeking withdrawal of Draft EIA 2020 in the interest of protection of environment and public welfare

This has reference to the Draft EIA Notification 2020 published on 23rd March of this year.

We would like to submit the following views and suggestions with regard to the notification:-

  • First of all, the amendments proposed in the notification are in contravention to the scope and spirit of Section 3 of the Environmental Protections Act (1986) itself.
  • The notification has totally ignored the devastating impact on the ecosystem and environment, if the amendments are implemented, though the notification states that it seeks to make the EIA process more transparent and expedient.
  • Sufficient time was not given to the stakeholders to submit their feedback. This is violation of the Principle 10 of the Rio Declaration, and the principle of Natural Justice. It is the court interventions that have made it possible for the public to register their opinions.
  • There are a lot of sound scientific researches emerging that link the present pandemic to the vast destruction of natural habitats and among numerous other ecosystem services, that also greatly buffer zoonotic diseases like COVID19.
  • The amendments will aggravate the already severe global climatic breakdown that results in devastating super-cyclone Amphan in the east and the cyclone Nisarga in the west in our country.
  • Relaxation of many strict norms will definitely lead to the exploitation of the nature by large corporates and business houses.
  • Provision for post-facto clearance and non-requirement of EIA for B2 projects including potentially harmful ones like river valley projects, tanneries, many chemical manufacturing units, petrochemical industries, expansion of national highways, etc. Will only help the greedy entrepreneurs and it will open the doors for heavy corruption.
  • The proposals that the companies no longer need to have a compulsory public hearing; companies need not submit compliance reports every six months, but annually, reduction of time provided for submission of public response from 30 to 20 days during public hearings and the public hearing process has to be completed in 40 days instead of 45 days will undoubtedly undermine the very spirit and objectives of the Environment Laws and the EIA.
  • The proposal enables the companies to implement projects without the approval from the people or environmental organisations. This shall definitely end up in mass displacement of people along with irreversible environmental damage. The government gets empowered to take decisions without the involvement of people affected. The companies that would enjoy this exemption include chemical industries that produce acids, paints, fertilisers, etc. which push out toxic wastes that are detrimental to the surrounding areas. These wastes cause contamination of water resources, air quality and soil quality.
  • The proposed amendment that relaxes the frequency of submitting compliance report help companies to cover up their lapses and non-compliance with ease. It would further debilitate the hold, if any, of the Environment Ministry on the companies on exploiting the natural resources.
  • The proposal that denies sufficient time to the people who would be affected by the project to prepare and present their views, comments and suggestions; turns such public hearings a mockery. The time reduction would be affecting those people in areas where information is not easily accessible, the most.

Unfortunately, there is nothing in the notification which is for the protection and conservation of the environment or for public welfare and the proposed amendments in the draft will cause irreparable damage to the ecosystem, humanity and the globe.

The haste to implement the amendments will lead to grave ecological damage and so in this circumstance, we would like to request you that the amendments be put on hold till a close study of the proposals by subject-experts is conducted after gathering the public and stakeholders’ opinion.


Adv. Sharafuddin Ahmed National Vice President

Social Democratic Party of India

New Delhi

09th August 2020