The Northeastern states and our Island/coastal areas will be developed while being sensitive to conserving their ecological uniqueness… We will further encourage integrated development of coastal areas including coastal cities, coastal transport and coastal industrialization.

The 2019 Sankalp Patra makes two coastal commitments that pull in different directions, and it makes them a few pages apart. One is developmental: "We will further encourage integrated development of coastal areas including coastal cities, coastal transport and coastal industrialization." The other is a constraint on it: island and coastal areas "will be developed while being sensitive to conserving their ecological uniqueness."

The constraint is the checkable half, because India already has the machinery meant to enforce it — the Coastal Regulation Zone notifications, the national and state coastal zone management authorities, the expert appraisal committees, the district level committees. The CAG audited whether that machinery works, and tabled the result on 8 August 2022.

It begins with the body at the top. "MoEF&CC has not notified NCZMA as a permanent body with recommended members. NCZMA is reconstituted every few years and in the absence of defined membership, it was functioning as an ad-hoc body, devoid of permanent members." The audit reads the shifting composition as "a lack of continuity of approach towards coastal conservation issues", and notes the authority had no working website publishing its agendas or minutes.

Below it, the committees that actually decide on projects were deciding without the expertise or the numbers. Clearances were granted "though domain experts were not present during the project deliberations", and in some cases "the members of EAC were less than half of the total strength during the deliberations as there was no fixed quorum". At state level it was thinner still: the authority "was not reconstituted in the state of Karnataka", was late in Goa, Odisha and West Bengal, met "without fulfilling the quorum requirements", and in six states did "not have sufficient manpower to perform their mandate".

What those committees were reading was often not reliable. Projects were approved on impact assessments prepared by consultants who were not accredited, "usage of outdated baseline data, non-evaluation of environmental impacts of the project, non-addressal of disasters which the project area was prone to". And the ministry did not go behind them: it "failed to make independent efforts to verify the veracity of the information given by private consultants and merely relied on the information submitted by the Project Proponent". The mitigation that was supposed to offset the damage — mangrove replantation, biodiversity plans, rainwater harvesting — was left out of the binding environment management plan and left "to the project proponent to be carried out".

Two findings go directly to the word "sensitive". State authorities in some cases "usurped the powers of clearance granting authorities and granted clearance to the projects", and recommended projects without mandatory documents. And the rules themselves moved: "Modification of CRZ notifications for approval of specific projects defeated the efforts to conserve the coastal ecosystems." That last sentence is the audit's own, and it is a finding about the design of decisions, not their execution.

Enforcement after clearance was largely absent. Proponents did not meet conditions or file the mandatory half-yearly compliance reports; some projects "commenced without obtaining any CTE or CTO from the concerned State Pollution Control Board"; and the state and district committees "failed to take action against CRZ violations" and, at district level, "failed to identify violations" in the first place.

The ecological consequences the audit records are specific. Live coral cover in the Gulf of Mannar was seriously reduced and degrading, with no strategy against the invasive species spreading through it and no monitoring system for the reefs; Goa had no management plans for turtle nesting sites and infrastructure being built on coastal sand dunes, where it is prohibited; mangrove conservation had gaps in Goa and Gujarat; and sewage treatment plants were "either altogether absent or were functioning without any monitoring leading to discharge of harmful effluents into coastal waters."

Even the protective mapping stalled. The hazard line — the line that tells planners which coastal land is unsafe to build on — was fully mapped in August 2018, and as of this audit "the ground demarcation of the Hazard Line was yet to be done". The integrated management plans for critically vulnerable coastal areas had not been prepared by the states at all. And at the two marine field stations in Gujarat built to monitor the Gulf of Kutch, "out of 40 instruments installed under the project at these two places, 33 instruments were operated only for checking and calibration and were never used for the intended purpose".

Development of the coast proceeded. The promise's own qualifier — sensitivity to ecological uniqueness — depends on institutions that the audit found unconstituted, under-quorate, under-staffed and, where they did meet, working from documents nobody checked. Our verdict is not supported.