Despite the obvious damage it would cause to Bengaluru’s environment and ecology, the elevated corridors project had got Environment Clearance (EC) in no time. As citizen groups have appealed to the National Green Tribunal (NGT) to scrap the project, in this series, we look at how the project had got EC even as it avoided a rigorous environment impact assessment.

EC is issued based on an Environmental Impact Assessment (EIA) report that the project proposers submit. In the case of elevated corridors, the project consultant AECOM ( on behalf of the proposer Karnataka Road Development Corporation Ltd) had submitted a 345-page EIA on February 14th.

It took authorities all of two weeks to study and approve this document. On March 2nd, EC was issued for the project.

Here is a FAQ on the process by which the EC was issued.

Which authority issued the EC?

The SEIAA (State Environment Impact Assessment Authority) is responsible for issuing ECs. SEIAA, a three-member committee, is constituted by the centre’s Ministry of Environment and Forests (MoEF). The members are recommended by the state government.

However, the EIA of the project is first assessed by the SEAC (State Expert Appraisal Committee). SEAC members too are appointed by the centre in consultation with state government. After studying the EIA, SEAC submits its recommendations to the SEIAA, and the latter generally acts according to these recommendations. Here are the details of the current SEAC and SEIAA members in Karnataka.

What is the process for obtaining EC?

The process begins with the proposer submitting their proposal online. SEAC then recommends the Terms of Reference (TOR), that is, the criteria based on which the proposer has to prepare the EIA. This TOR has to be approved by the SEIAA. After this, based on the approved TOR, the proposer prepares and submits the EIA report.

Once the proposer submits the EIA, SEAC scrutinises it and submits a report to the SEIAA. SEIAA meets once a month to decide on issuing EC to all such proposals forwarded by the SEAC.

How long does the process for issuing an EC take?

This depends on the size, complexity and impact of the project, the time taken by the proposer to prepare the EIA, and so on. It could take several months.

What is the chronology of the approval process in case of elevated corridors?

As per the EC issued:

• The proposer KRDCL (Karnataka Road Development Corporation Ltd) submitted the online application for EC through its consultant AECOM Asia Co Ltd on 6th September, 2018
• SEAC considered the application at its meeting on September 28th
• SEIAA decided to issue the TOR as recommended by the SEAC, in its meeting on 12th October
• TOR is issued on 23th October
• This February 14th, within four months of the issual of the TOR, AECOM submits the EIA. The EIA report is 345-pages long
• Two weeks later, SEAC meets on 1st March and recommends issue of EC after considering the submitted documents
• SEIAA meets on 2nd March, considers the SEAC recommendation, and decides to issue the EC
• EC is issued on 2nd March. EC is a 12-page document that refers extensively to statutory compliances

What does the EIA cover?

The EIA answers point-by-point to the TOR, and indicates compliance to all requirements. It covers data related to the project, its legal framework and environmental impacts. It covers a broad range of topics, from carbon emissions to water requirement during construction.

The EIA has 85 tables of data and 42 figures (graphical representation of data). It also has five annexures and three appendices.

Did SEAC and SEIAA give adequate time and attention to the process?

This is a subjective question, and cannot be directly answered from publicly-available documents.

But as per SEAC’s minutes of meeting for March 1st, 13 members were present. They discussed 11 projects overall, of which elevated corridors was the last. SEAC decided to recommend to the SEIAA to issue EC for the project, with eight conditions to the proposer. These conditions included using only treated sewage water for construction, installing air purifiers, ensuring smooth traffic flow during construction etc.

The SEIAA meeting that followed on 2nd March, had over 40 agenda items. This included 18 projects that the SEAC had recommended for EC issual, eight for issuance of TORs and the rest miscellaneous. In the list of 18 projects, elevated corridors figured last.

Of the 18 projects, SEIAA referred back three to the SEAC, and issued clearances to the remaining 15 which included elevated corridors. It’s unclear if the SEAC had support stuff including scientists to assist it in analysing the project’s EIA, and the extent of preparatory work that went into approving it, given that several projects are discussed in each SEAC meeting.

Glaring issues in the EIA process

Various court orders have pointed to the deficiencies in the EIA approval process in India. In fact, in its order in the 2014 case T N Godavarman Thirumulpad vs Union of India, the Supreme Court noted that EIA clearances relied mainly on data given by the project proposers themselves. Lack of reliable data in EIA reports, and lack of a mechanism to validate this data, could lead to inconsistency and inferior quality of the reports.

The court also pointed out that once the approval was given to a project based on certain conditions, there was poor monitoring and enforcement to ensure that the proposer did follow these conditions. Hence the court ordered setting up a separate independent regulatory authority to deal with these concerns.

There are also many cases pending in the Supreme Court and NGT, questioning the EC granted to several mega projects. The National Environment Appellate Authority – the precursor to NGT – had quashed ECs for many such projects on grounds that crucial impacts of the project were not considered, information submitted was false or inadequate, public consultation was not properly conducted, and so on.

In case of the elevated corridors project too, data in the EIA seems inadequate. EIA says that the project would reduce traffic congestion, but it does not quantify this outcome properly. Also, the TORs refer to carbon emissions and urban heat island effect, but the consultant is not required to study these effects in detail.

Also, as per the EIA, over 3000 trees have to be felled for the project, but the local ecological impact of losing so many trees is not quantified. Rather, the EC simply directs compensatory plantation, without considering whether compensatory plantations for previous projects were successful.

That is, the EIA avoids quantifying many environmental impacts as well as measures to mitigate impacts. These aspects are fundamental in the scrutiny before issuing EC. In the next part of this series, we look at these issues.