Performance Audit on Conservation of Coastal Ecosystems, Ministry of Environment, Forest and Climate Change

Findings

1. The National Coastal Zone Management Authority was never notified as a permanent body with defined membership; it is reconstituted every few years and was functioning as an ad hoc body, with no continuity of approach.

   “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. Further, the composition of NCZMA has not been uniform over these years, indicating a lack of continuity of approach towards coastal conservation issues.”Executive Summary

2. Expert appraisal committees granted clearances with no domain expert present at the deliberations, and in some cases with fewer than half their members, because no quorum was fixed.

   “Instances were observed where Expert Appraisal Committees (EAC) granted clearances, though domain experts were not present during the project deliberations. Also, cases were noted where the members of EAC were less than half of the total strength during the deliberations as there was no fixed quorum for EAC members.”Executive Summary

3. The state coastal zone management authority was not reconstituted at all in Karnataka and late in Goa, Odisha and West Bengal; authorities met without quorum, and six states' authorities lacked the manpower to do their job.

   “SCZMA was not reconstituted in the state of Karnataka and there was delayed reconstitution in the states of Goa, Odisha and West Bengal. SCZMAs held meetings without fulfilling the quorum requirements and lacked representation from relevant stakeholder bodies. SCZMAs in the states of Andhra Pradesh, Karnataka, Goa, Tamil Nadu, Odisha and West Bengal did not have sufficient manpower to perform their mandate.”Executive Summary

4. Projects were approved on environmental impact assessments prepared by unaccredited consultants, using outdated baseline data, without evaluating environmental impacts or the disasters the site was prone to.

   “Projects were approved despite inadequacies in the EIA Reports which included non-accreditation of the consultant involved with the preparation of the EIA Report, usage of outdated baseline data, non- evaluation of environmental impacts of the project, non-addressal of disasters which the project area was prone to.”Executive Summary

5. The ministry made no independent effort to verify what private consultants said about a project's ecological risks, relying on the project proponent's own submission; and mitigation measures such as mangrove replantation were left out of environment management plans for the proponent to carry out.

   “Activities forming a part of the mitigation plans like mangrove conservation/ replantation, biodiversity conservation plan, rain water harvesting plan failed to be included in the Environment Management Plan as the same was left to the project proponent (PP) to be carried out… Projects were approved where MoEF&CC 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 with respect to potential ecological risks due to the project activities.”Executive Summary

6. State authorities took over powers that belonged to clearance-granting bodies and cleared projects themselves, and recommended projects without the mandatory documents; coastal regulation notifications were modified to approve specific projects.

   “Instances were observed where the SCZMA usurped the powers of clearance granting authorities and granted clearance to the projects. Further, there were cases of project approvals where the SCZMAs recommended the projects without the submission of mandatory documents. Modification of CRZ notifications for approval of specific projects defeated the efforts to conserve the coastal ecosystems.”Executive Summary

7. After clearance, proponents did not comply with conditions or file the mandatory half-yearly compliance reports, and some projects began without any consent to establish or operate from the state pollution control board; state and district committees failed to act on or even identify violations.

   “Instances were observed where the Project Proponent failed to comply with conditions mentioned in the Clearance and did not submit the mandatory half yearly compliance reports to the Regional Offices of MoEF&CC. There were cases where the projects commenced without obtaining any CTE or CTO from the concerned State Pollution Control Board… The enforcement of CRZ provisions by SCZMAs and DLCs were reviewed and instances were observed where SCZMAs failed to take action against CRZ violations and the DLCs too failed to identify violations and report the same to SCZMAs.”Executive Summary

8. Hazard line mapping was finished in August 2018 but never demarcated on the ground, and the integrated management plans for critically vulnerable coastal areas had still not been prepared by the states.

   “Although the entire work of mapping of Hazard Line was completed in August 2018, the ground demarcation of the Hazard Line was yet to be done by MoEF&CC. The Integrated Management Plans (IMPs) for Critically Vulnerable Coastal Areas (CVCAs) were yet to be prepared by the coastal states.”Executive Summary

9. Of 40 instruments installed at the marine field stations at Mandvi and Jamnagar in Gujarat, 33 were only ever switched on for checking and calibration and never used to study the Gulf of Kutch's intertidal soil and water.

   “In the marine field stations at Mandvi and Jamnagar in Gujarat, it was observed that 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 i.e., to study the physiochemical parameters of soil and water of the intertidal area of the Gulf of Kutch.”Executive Summary

10. In the Gulf of Mannar, live coral cover was seriously reduced and degraded with no strategy against the invasive species spreading through it, no monitoring system for the reefs, and no management plans for turtle nesting sites in Goa.

    “Despite serious reduction and degradation of the live coral cover in the Gulf of Mannar Islands, no viable strategy to mitigate the propagation of the invasive species had been devised by the Department of Forest, Tamil Nadu. Issues such as absence of a monitoring system for coral reefs, and non- preparation of management plans for turtle nesting sites in Goa were observed.”Executive Summary

Fact-checks citing this report

• ✕Not supported by auditThe 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.