This is with reference to the draft EIA notification, 2020 which has been uploaded on the environment ministry’s website on 12.3.2020 seeking public comments within sixty days of the issuance of the notification. We are deeply concerned that this draft notification has been put out in the midst of a national health crisis. As you are aware, most of the country is under lockdown and there are severe restrictions on movement in public places. Most offices are closed and the staff are working from home. These restrictions may be indefinite and it is not clear when public life and work can resume.
The long-term public health, social and economic impacts of this global pandemic are yet to be ascertained. The EIA notification is an important regulation through which the impacts of land-use change, water extraction, tree felling, pollution, waste and effluent management for industrial and infrastructure projects are to be studied and used in developmental decisionmaking. Any change in this law has a direct bearing on the living and working conditions of people and the ecology.
Therefore, it is critical that the government provides a suitable and adequate opportunity for those impacted or likely to be affected by the design and implementation of EIA notification. Opportunities to understand and discuss the implications of the proposed amendments may be severely hindered due to the present health emergency with restricted public movement, social distancing and challenges to everyday life activities. These restrictions also make it impossible to disseminate information about the notification to communities who deserve to know and influence the notification.
We, therefore, request the environment ministry to:
1. Immediately, withdraw the proposed amendments of the Draft EIA notification 2020.
2. Consider reissuing the draft only after health conditions related to Covid19 and civic life is normalized across the country.
3. Ensure that there are widespread and informed public discussions on the implication of these amendments.
4. A full disclosure of the nature of comments received and the reasons for acceptance and rejection of these comments, prior to the issuance of the final amendments.
We do hope that the environment ministry will uphold its obligations towards informed public participation like the commitment to Principle 10 of the Rio Declaration and also the Principles of Natural Justice, while taking a considered view on the proposed amendments to the EIA notification, 2020