TGM for Tanneries PDF 2010

FOR Prepared for Government of India  Project Coordination Dr. Nalini Bhat Ministry of Environment & Forests Advisor, Ministry of Environment and Forests Dr. T. Chandni Director, Ministry of Environment...

FOR Prepared for Government of India  Project Coordination Dr. Nalini Bhat Ministry of Environment & Forests Advisor, Ministry of Environment and Forests Dr. T. Chandni Director, Ministry of Environment and Forests Core Project Coordination Team Mr. Mahesh Babu IL&FS Environment CEO Mr. N. Sateesh Babu Vice President & Project Director Mr. B.S.V. Pavan Gopal Manager –Technical Ms. Tamil Ezhil.G Environmental Planner Ms. Suman Benedicta Thomas Technical Writer Resource Person Dr. S. Rajamani Former Director, Central Leather Research Institute Expert Core & Peer Committee Chairman Dr. V. Rajagopalan, IAS Additional Secretary Ministry of Chemicals & Fertilizers Core Members Dr. R. K. Garg Former Chairman, EIA Committee, Ministry of Environment and Forests Mr. Paritosh C. Tyagi Former Chairman, Central Pollution Control Board Prof. S.P. Gautam Chairman, Central Pollution Control Board Dr. Tapan Chakraborti Director, National Environmental Engineering Research Institute Mr. K. P. Nyati Former Head, Environmental Policy, Confederation of Indian Industry Dr. G.K. Pandey Former Advisor, Ministry of Environment and Forests Dr. Nalini Bhat Advisor, Ministry of Environment and Forests Dr. G.V. Subramaniam Advisor, Ministry of Environment and Forests Dr. B. Sengupta Former Member Secretary, Central Pollution Control Board Dr. R. C. Trivedi Former Scientist, Central Pollution Control Board Peer Member Prof. N.J.Rao Director, JAYPEE Institute of Engineering and Technology Prof. B. Subba Rao President, Environmental Protection Research Foundation and International School of Environmental Management Studies Member Convener Mr. N. Sateesh Babu Project Director  Table of Contents TABLE OF CONTENTS 1. INTRODUCTION TO THE TECHNICAL EIA GUIDANCE MANUALS PROJECT 1-1 1.1 Purpose................................................................................................................................ 1-2 1.2 Project Implementation....................................................................................................... 1-3 1.3 Additional Information........................................................................................................ 1-4 2. CONCEPTUAL FACETS OF EIA 2-1 2.1 Environment in EIA Context............................................................................................... 2-1 2.2 Pollution Control Strategies................................................................................................ 2-2 2.3 Tools for Preventive Environmental Management.............................................................. 2-2 2.3.1 Tools for assessment and analysis......................................................................... 2-3 2.3.2 Tools for action...................................................................................................... 2-5 2.3.3 Tools for communication..................................................................................... 2-10 2.4 Objectives of EIA.............................................................................................................. 2-11 2.5 Types of EIA..................................................................................................................... 2-11 2.6 Basic EIA Principles......................................................................................................... 2-12 2.7 Project Cycle..................................................................................................................... 2-13 2.8 Environmental Impacts..................................................................................................... 2-14 2.8.1 Direct impacts...................................................................................................... 2-15 2.8.2 Indirect impacts................................................................................................... 2-15 2.8.3 Cumulative impacts............................................................................................. 2-15 2.8.4 Induced impact.................................................................................................... 2-15 2.9 Significance of Impacts..................................................................................................... 2-16 2.9.1 Criteria/methodology to determine the significance of the identified impacts.... 2-17 3. ABOUT LEATHER / SKIN / HIDE PROCESSING INDUSTRY INCLUDING PROCESS AND POLLUTION CONTROL TECHNOLOGIES 3-1 3.1 Introduction......................................................................................................................... 3-1 3.2 Leather Manufacturing Process........................................................................................... 3-2 3.2.1 Process of tanning.................................................................................................. 3-3 3.2.2 Input Vs output in the tannery process.................................................................. 3-6 3.3 Qualitative and Quantitative Analysis of Rejects................................................................ 3-7 3.3.1 Wastewater............................................................................................................ 3-7 3.3.2 Air emissions....................................................................................................... 3-12 3.3.3 Solid waste........................................................................................................... 3-13 3.3.4 Hazardous materials............................................................................................ 3-13 3.4 Cleaner Technologies, Minimization, and Recycling / Reuse Options............................. 3-13 3.4.1 Cleaner technologies in leather processing.......................................................... 3-13 3.4.2 Waste minimisation options................................................................................ 3-20 3.4.3 Reduction/Recycling/Recovery/Reuse................................................................ 3-22 3.5 Summary of Applicable National Regulations.................................................................. 3-27 3.5.1 General standards for discharge of environmental pollutants............................. 3-27 TGM for Tanneries August 2010 i  Table of Contents 3.5.2 Tannery effluent standards as provided by CPCB............................................... 3-27 3.5.3 Pending and proposed regulatory requirements.................................................. 3-28 4. OPERATIONAL ASPECTS OF EIA 4-1 4.1 Coverage of Tanneries under the Purview of Notification.................................................. 4-1 4.2 Screening............................................................................................................................. 4-5 4.2.1 Applicable conditions for Category B projects..................................................... 4-5 4.2.2 Criteria for classification of Category B1 and B2 projects.................................... 4-6 4.2.3 Application for prior environmental clearance...................................................... 4-6 4.2.4 Siting guidelines.................................................................................................... 4-7 4.3 Scoping for EIA Studies...................................................................................................... 4-8 4.3.1 Pre-feasibility report............................................................................................ 4-10 4.3.2 Guidance for Filling Information in Form 1........................................................ 4-10 4.3.3 Identification of appropriate valued environmental components........................ 4-10 4.3.4 Methods for identification of impacts.................................................................. 4-11 4.3.5 Testing the Significance of impacts..................................................................... 4-16 4.3.6 Terms of reference for EIA studies..................................................................... 4-16 4.4 Environmental Impact Assessment................................................................................... 4-20 4.4.1 EIA team.............................................................................................................. 4-21 4.4.2 Baseline quality of the environment.................................................................... 4-22 4.4.3 Impact prediction................................................................................................. 4-25 4.4.4 Significance of the impacts.................................................................................. 4-25 4.5 Social Impact Assessment................................................................................................. 4-26 4.6 Mitigation Measures.......................................................................................................... 4-28 4.6.1 Important considerations for mitigation methods................................................ 4-29 4.6.2 Hierarchy of elements of mitigation plan............................................................ 4-30 4.6.3 Typical mitigation measures................................................................................ 4-31 4.7 Environmental Management Plan..................................................................................... 4-33 4.8 Reporting........................................................................................................................... 4-34 4.9 Public Consultation........................................................................................................... 4-36 4.10 Appraisal........................................................................................................................... 4-39 4.11 Decision-making............................................................................................................... 4-40 4.12 Post-clearance Monitoring Protocol.................................................................................. 4-42 5. STAKEHOLDERS’ ROLES AND RESPONSIBILITIES 5-1 5.1 SEIAA................................................................................................................................. 5-4 5.2 EAC and SEAC................................................................................................................... 5-6 TGM for Tanneries August 2010 ii  Table of Contents LIST OF TABLES Table 3-1: Characteristics of Wastewater............................................................................................ 3-8 Table 3-2: Pollution Load per tonne of Hides/Skins Processed........................................................... 3-8 Table 3-3: Characteristics of Tannery Effluent.................................................................................... 3-9 Table 3-4: Sources of Air Emissions and Preventive Methods.......................................................... 3-12 Table 3-5: Odour Emissions to Air.................................................................................................... 3-12 Table 3-6: Tannery Effluent Standard (After Primary Treatment): Disposal Channel/Conduit Carrying Wastewater to Secondary Treatment Plant...................................................................... 3-27 Table 3-7: Tanneries – Effluent Standards........................................................................................ 3-27 Table 4-1: Advantages and Disadvantages of Impact Identification Methods.................................. 4-11 Table 4-2: Matrix of Impacts............................................................................................................. 4-13 Table 4-3: List of Important Physical Environment Components and Indicators of EBM............... 4-23 Table 4-4: Typical Mitigation Measures............................................................................................ 4-32 Table 4-5: Structure of EIA Report.................................................................................................... 4-34 Table 5-1: Roles and Responsibilities of Stakeholders Involved in Prior Environmental Clearance. 5-1 Table 5-2: Organization-Specific Functions........................................................................................ 5-2 Table 5-3: SEIAA: Eligibility Criteria for Chairperson / Members / Secretary.................................. 5-5 Table 5-4: EAC/SEAC: Eligibility Criteria for Chairperson / Members / Secretary........................... 5-9 TGM for Tanneries August 2010 iii  Table of Contents LIST OF FIGURES Figure 2-1: Inclusive Components of Sustainable Development......................................................... 2-1 Figure 2-2: Types of Impacts............................................................................................................. 2-14 Figure 2-3: Cumulative Impact.......................................................................................................... 2-15 Figure 3-1: Location of Tanneries in India.......................................................................................... 3-2 Figure 3-2: Tanning Process................................................................................................................ 3-3 Figure 3-3: Input vs. Output in the Tanneries...................................................................................... 3-7 Figure 3-4: Tannery Effluent Treatment System............................................................................... 3-11 Figure 4-1: Prior Environmental Clearance Process for Activities Falling Under Category A........... 4-3 Figure 4-2: Prior Environmental Clearance Process for Activities Falling Under Category B........... 4-4 Figure 4-3: Approach for EIA Study................................................................................................. 4-21 Figure 4-4: Elements of Mitigation Plan............................................................................................ 4-30 TGM for Tanneries August 2010 iv  Table of Contents LIST OF ANNEXURES Annexure I General Standards for Discharge of Environmental Pollutants as per CBCP Annexure II Form 1 (Application Form for Obtaining EIA Clearance) Annexure III Critically Polluted Industrial Areas and Clusters/Potential Impact Zone Annexure IV Types of Monitoring and Network Design Considerations Annexure V Guidance for Assessment of Baseline Components and Attributes Annexure VI Sources of Secondary Data Annexure VII Form through which the State Government/Administration of the Union Territories Submit Nominations for SEIAA and SEAC for the Consideration and Notification by the Central Government. Annexure VIII Composition of EAC/SEAC Annexure IX Best Practices & Latest Technologies available and reference TGM for Tanneries v August 2010  Table of Contents ACRONYMS AAQ Ambient Air Quality BAT Best Available Technology BOD Biological oxygen demand BOO Build-Operate-Own BOT Build-Operate-Transfer °C degree Celsius CCA Conventional Cost Accounting CETP Common Effluent Treatment Plant CFE Consent for Establishment CO2 Carbon dioxide COD Chemical Oxygen Demand Cr Chromium Cr2O3 Chromium Oxide Cr2(SO4)3 Chromium Sulphate CRZ Coastal Regulatory Zone DS Dissolved Solids EAC Expert Appraisal Committee EBM Environmental Baseline Monitoring EcE Economic-cum-Environmental EcE Economic-cum-Environmental ECI Environmental Condition Indicators EIA Environmental Impact Assessment EIS Environmental Information system EPI Environmental performance Indicators EMS Environmental Management System EMP Environmental Management Plan FCA Full Cost Assessment FSS Fixed Suspended Solids GC General Conditions g/l grams per litre H2S Hydrogen Sulfide HAPs Hazardous Air Pollutants HTL High Tide Line HVLP High Volume Low Pressure IL&FS Infrastructure Leasing and Financial Services IMD India Meteorological Department TGM for Tanneries August 2010 vi  Acronyms IUE International Union of Environment kg kilograms l litre LDAR Leak Detection and Repair LCA Life Cycle Assessment LTL Low Tide Level 2 m square meter mg/m³ milligrams per cubic meters mg/l milligrams per litre MoEF Ministry of Environment & Forests MSDS Material Safety Data Sheets O&M Operation and Maintenance PAP Project Affected people QA/QC Quality Assurance/Quality Control QRA Quantitative Risk Assessment RSPM Respirable Suspended Particulate Matter SEAC State Level Expert Appraisal Committee SEIAA State Level Environment Impact Assessment Authority SPCB State Pollution Control Board SPM Suspended Particulate Matter SS Suspended Solids TA Technology assessment TCA Total Cost Assessment TDS Total Dissolved Solids TEQM Total Environmental Quality Movement TGM Technical EIA guidance manuals TSDF Treatment Storage Disposal Facility TS Total Solids TSS Total Suspended Solids USEPA United States Environment Protection Agency UT Union Territory UTEIAA Union Territory Level Environment Impact Assessment Authority UTPCC Union Territory Pollution Control Committee VEC Valued Environmental Components VOC Volatile Organic Compound VSS Volatile Suspended Solids WBCSD World Business Council on Sustainable Development TGM for Tanneries August 2010 vii  ur{Rlifr TffEI ?rq df (sEtiaqerru) JAIRAM RAMESH rrql+rq u.i o-a a{rtaTsz$|J ag frrd-r r oooe {* MINISTEROF STATE(INDEPENDENT CHARGE) ENVIRONMENT & FORESTS GOVERNMENTOF INDIA N E WD E L H I. 1 I O O O 3 22"dDecember 2010 FOREWORD The Ministry of Environment & Forests (MOEF) introduced the Environmental Impact Assessment(EIA) Notification 2006 on 14tnSeptember2006,which not only reengineeredthe entire environment clearance(EC) processspecified under the EIA Notification 1994,bfi also introduced a number of new developmental sectorswhich would require prior environmental clearance.The EIA NotiJication 2006has notiJied a list of 39 developmental sectorswhich have been further categorisedas A or B based on their capacity and likely environmental impacts. Category B projects have been further categorisedas B1 and 82. The EIA Notification 2006has further introduced a system of screening, scoping and appraisal and for the setting up of Environment Impact Assessment Authority (EIAA) at the Central level and State Level Environment Impact AssessmentAuthorities (SEIAAs)to gaantenvironmental clearancesat the Central and State level respectively. The Ministry of Environment & Forests is the Environment Impact Assessment Authority at the Central level and 25 State Level Environment hnpact AssessmentAuthorities (SEIAAS) have been set up in the various States/UTs. The EIA Notification 2006 also stipulates the constitution of a multi-disciplinary Expert Appraisal Committee (EAC) at the Centre and state level Expert Appraisal Comrnittees (sEACs) at State/UT Level for appraisal of Category A or B projects respectively and to recomrnend grant/rejection of environmental clearanceto each project/ activities falling under the various sectorsto the EIAA/SEIAAs respectively. Although the process of obtaining environrnental clearance consisting of Screening, scoping and Appraisal and for undertaking public consultation including the process of conduct of Public Hearing has been elaboratedunder the EIA Notification 2006,the Notification itself provides for bringing out guidelines from tirne to time on the EIA Notification 2005and the EC processwith a view to bringing clarity on the EC processfor expediting environmental clearance.This need was further rebJorced after the constitution of SEiAAs and SEACs in various States,who were assignedthe task for the first time and for addressingthe concernsof standardization of the quality of appraisal and in reducing inconsistencies between SEACs/SEIAAsin granting ECs for similar projectsin diJferentStates. The TechnicalGuidance Manual of "Tannery- Leathey'Skiny'tlideProcessingIndustry" sectordescribestypes of processand pollution control technologies,operational aspectsof EIA with model TOR of that Sector, technological options with cleaner production and waste minirnization techniques, monitodng of environmental quality, post clearance monitodng protocol/ related regulations/ and procedure of obtaining EC if linked to other clearancesfor e.g.,CM, etc. For each tannery plant the project team may research scientific and technical issues, fit methods to small and larger operating units in Indian conditions, demonstrate the methods in particular regions,establishthe economicand other benefits of TDS reductioru ensurethat hides and skins can be processed into suitable quality leathers and establish an educational and technology transfer program. India's industrial competitiveness and environmental future depends on Industries such as Tannery- Leather/Skin/Hide Processing Industry adopting energy and resourceefficient technologies.Recyclingand reuseof matelials is critical. To keep pace with changing technologiesand needs of sustainable developmen! the manual would require regular updating in the future. The manual will be available on the MoEF website and we would appreciate receiving responsesfrom stakeholders for further lmprovements. I congratulate the entire team of IL&FS Ecosmart Ltd., experts from the sector who were involved in the preparation of the Manuals, Chairrnan and members of the Core and Peer Committees of various sectors and various Resource Persons whose inouts were indeed valuable in the preparation and finalization of the Manuals.  1. INTRODUCTION TO THE TECHNICAL EIA GUIDANCE MANUALS PROJECT Environmental Impact Assessment (EIA) is a process of identifying, predicting, evaluating and mitigating the biophysical, social, and other relevant effects of development proposals prior to major decisions being taken and commitments made. These studies integrate the environmental concerns of developmental activities in to the process of decision-making. EIA has emerged as one of the successful policy innovations of the 20th Century to ensure sustained development. Today, EIA is formalized as a regulatory tool in more than 100 countries for effectively integrating environmental concerns in economic development process. The EIA process in India was made mandatory and was also given a legislative status through a Notification issued by the Ministry of Environment and Forests (MoEF) in January 1994. The Notification, however, covered only a few selected industrial developmental activities. While there are subsequent amendments, the Notification issued on September 14, 2006 supersedes all the earlier Notifications, and has brought out structural changes in the clearance mechanism. The basic tenets of this EIA Notification could be summarized into following: ̇ Pollution potential as the basis for prior environmental clearance based on pollution potential instead of investment criteria; and ̇ Decentralization of clearing powers to the State level/Union Territory (UT) level Authorities for certain developmental activities to make the prior environmental clearance process quicker, transparent and effective. Devolution of the power to grant clearances at the state level for certain category of the developmental activities / projects is a step forward to fulfill the basic tenets of the re- engineering i.e., quicker, transparent and effective process but many issues impede/hinder its functional efficiency. These issues could be in technical and operational as listed below: Technical issues ̇ Ensuring level playing ground to avoid arbitrariness in the decision-making process ̇ Classification of projects which do not require public hearing and detailed EIA (Category B2) ̇ Variations in drawing the Terms of Reference (ToR) for EIA studies for a given developmental activity across the States/UTs ̇ Varying developmental-activity-specific expertise requirement for EIA studies and their appraisal ̇ Availability of adequate sectoral experts and variations in competency levels ̇ Inadequate data verification, cross checking tools and supporting institutional framework ̇ Meeting time targets without compromising with the quality of assessments/ reviews ̇ Varying knowledge and skill levels of regulators, consultants and experts ̇ Newly added developmental activities for prior environmental clearance, etc., TGM for Tanneries August 2010 1-1  Introduction Operational issues ̇ State level /UT level EIA Authorities (SEIAA/UTEIAA) are formulated for the first time and many are functioning ̇ Varying roles and responsibilities of involved organizations ̇ Varying supporting institutional strengths across the States/UTs ̇ Varying manpower availability, etc., 1.1 Purpose The purpose of developing these sector-specific technical EIA guidance manuals (TGM) is to provide clear and concise information on EIA to all the stakeholders i.e., the project proponent, the consultant, the reviewer, and the public. The TGMs are organized to cover following: Chapter 1 (Introduction): This chapter provides a brief introduction on the EIA, basic tenets of EIA Notification, technical & operational issues in the process of clearance, purpose of the TGMs, project implementation process and additional information. Chapter 2 (Conceptual facets of an EIA): Provides an overall understanding to the conceptual aspects of control of pollution and EIA for the developmental projects. This basic understanding would set the readers at same level of understanding for proper interpretations and boundaries for identifying the environmental interactions of the developmental projects and their significance for taking mitigative measures. This chapter covers the discussion on environment in EIA context i.e., sustainable development, pollution control strategies, preventive environmental management tools, Objectives of EIA, types and basic principles of EIA, project cycle for Leather/skin/hide processing industry, understanding on type of environmental impacts and the criteria for the significance analysis. Chapter 3 (Leather/skin/hide processing industry): The purpose of this chapter is to provide the reader precise information on all the relevant aspects of the industry, which is essential to realize the likely interaction of such developmental activities on the receiving environment. Besides, this Chapter gives a holistic understanding on the sources of pollution and the opportunities of the source control. The specific coverage which provides precise information on the industry include (i) Introduction, (ii) Leather Manufacturing Process -Process of tanning, Input Vs output in the tannery process, (iii) Qualitative and Quantitative Analysis of Rejects-Wastewater, Air emissions, Solid waste, Hazardous materials, (iv) Cleaner Technologies, Minimization, and Recycling / Reuse Options-Cleaner technologies in leather processing, Waste minimization options, Reduction/Recycling/Recovery/Reuse, and (v) Summary of Applicable National Regulations-Tannery effluent standards as provided by CPCB, Pending and proposed regulatory requirements. Chapter 4 (Operational aspects): The purpose of this chapter is to facilitate the stakeholders to extend clear guidance on coverage of legislative requirements, sequence of procedures for obtaining the EIA clearance and each step-wise provisions and considerations. The coverage of the Chapter include provisions in the EIA Notification regarding leather/skin/hide processing industry, screening (criteria for categorization of B1 and B2, siting guidelines, etc.), scoping (pre-feasibility report, guidance for filling form 1, identification of valued environmental components, identification of impacts, etc.), TGM for Tanneries August 2010 1-2  Introduction arriving at terms of reference for EIA studies, impact assessment studies (EIA team, assessment of baseline quality of environment, impact prediction tools, significance of impacts), social impact assessment, risk assessment considerations, typical mitigation measures, designing considerations for environmental management plan, structure of EIA report for incorporation of study findings, process of public consultation, project appraisal, decision making process and post-clearance monitoring protocol. Chapter 5 (Roles and responsibilities of various organizations involved in the process of prior environmental clearance): The purpose of this Chapter is to brief the stakeholders on the institutional mechanism and roles & responsibilities of the stakeholders involved in the process of prior environmental clearance. The Coverage of the Chapter include (i) roles and responsibilities of the stakeholders, (ii) organization specific functions, (iii) constitution, composition and decision making process of SEIAA and (iv) EAC & SEAC and (v) other conditions which may be considered. For any given industry, each topic listed above could alone be the subject of a lengthy volume. However, in order to produce a manageable document, this project focuses on providing summary information for each topic. This format provides the reader with a synopsis of each issue. Text within each section was researched from many sources, and was condensed from more detailed sources pertaining to specific topics. The contents of the document are designed with a view to facilitate addressing of the relevant technical and operational issues as mentioned in the earlier section. Besides, facilitates various stakeholders involved in the EIA clearance process i.e., ̇ Project proponents will be fully aware of the procedures, common ToR for sector- specific EIA studies, timelines, required expertise, monitoring needs, etc., in order to plan the projects/studies appropriately. ̇ Consultants across India will have similar understanding about a given sector, and also the procedure for EIA studies, so that the quality of the EIA reports gets improved and streamlined ̇ Reviewers across the States/UTs will have the same understanding about an industrial sector and would able to draw a benchmark to establish the significant impacts for the purpose of prescribing the ToR for EIA studies and also in the process of review and appraisal. ̇ Public who are concerned about a new or expansion projects, use this manual to get a basic idea about the manufacturing/production details, rejects/wastes from the operations, choice of cleaner/ control technologies, regulatory requirements, likely environmental and social concerns, mitigation measures, etc., in order to seek clarifications appropriately in the process of public consultation. The procedural clarity in the document will further strengthen them to understand the stages involved in clearance and roles and responsibilities of various organizations. ̇ In addition, these manuals would substantially ease the pressure on reviewers at the scoping stage and would bring in functional efficiency at the central and state levels. 1.2 Project Implementation The Ministry of Environment & Forests (MoEF), Government of India took up the task of developing sector-specific TGMs for all the developmental activities listed in the re- engineered EIA Notification. The Infrastructure Leasing and Financial Services Ecosmart Limited (IL&FS Ecosmart), has been entrusted with the task of developing these manuals TGM for Tanneries August 2010 1-3  Introduction for 27 industrial and related sectors. Leather/skin/hide processing industry is one of these sectors, for which this manual is prepared. The ability to design comprehensive EIA studies for specific industries depends on knowledge of several interrelated topics. Therefore, it requires expert inputs from multiple dimensions i.e., administrative, project management, technical, scientific, social, economic, risk, etc., in order to comprehensively analyze the issues of concern and to draw logical interpretations. Thus, Ecosmart has designed a well-composed implementation framework to factor inputs of the experts and stakeholders in the process of finalization of these manuals. The process of manual preparation involved collection & collation of the secondary available information, technical review by sectoral resource persons and critical review and finalization by a competent Expert Committee composed of core and sectoral peer members. The MoEF appreciates the efforts of Ecosmart, Expert Core and Peer Committee, resource persons and all those who have directly and indirectly contributed to this manual. 1.3 Additional Information This TGM is brought out by the MoEF to provide clarity to all the stakeholders involved in the ‘prior environmental clearance’ process. As such, the contents and clarifications given in this document do not withstand in case of a conflict with the statutory provisions of the Notifications and Executive Orders issued by the MoEF from time-to-time. TGMs are not regulatory documents. Instead, these are the tools designed to assist in successful completion of an EIA. For the purposes of this project, the key elements considered under TGMs are: conceptual aspects of EIA; developmental activity-specific information; operational aspects; and roles and responsibilities of involved stakeholders. This manual is prepared considering the Notification issued on September 14, 2006 and latest amendment as on 1st December 2009. For recent updates, if any, may please refer the website of the MoEF, Government of India i.e., http://moef.nic.in/index.php. TGM for Tanneries August 2010 1-4  2. CONCEPTUAL FACETS OF EIA It is an imperative requirement to understand the basic concepts concerned to the pollution control and the environmental impact assessment in an overall objective of the sustainable development. This Chapter highlights the pollution control strategies and their tools besides the objectives, types & principles of EIA, type of impacts their significance analysis, in order to provide consistent understanding to the reader before assessing the development of activity-specific environmental concerns in Chapter 3 and identification & prediction of significant impacts in order to design mitigation measures as detailed in Chapter 4. 2.1 Environment in EIA Context “Environment” in EIA context mainly focuses, but is not limited to physical, chemical biological, geological, social, economical, and aesthetic dimensions along with their complex interactions, which affect individuals, communities and ultimately determines their forms, character, relationship, and survival. In EIA context, ‘effect’ and ‘impact’ can often be used interchangeably. However, ‘impact’ is considered as a value judgment of the significance of an effect. Sustainable development is built on three basic premises i.e., economic growth, ecological balance and social progress. Economic growth achieved in a way that does not consider the environmental concerns, will not be sustainable in the long run. Therefore, sustainable development needs careful integration of environmental, economic, and social needs in order to achieve both an increased standard of living in short term, and a net gain or equilibrium among human, natural, and economic resources to support future generations in the long term. “It is necessary to understand the links between environment and development in order to make choices for development that will be economically efficient, socially equitable and responsible, as well as environmentally sound.” Agenda 21 Figure 2-1: Inclusive Components of Sustainable Development TGM for Tanneries August 2010 2-1  Conceptual Facets of EIA 2.2 Pollution Control Strategies Pollution control strategies can be broadly categorized in to preventive and reactive. The reactive strategy refers to steps that may be applied once the wastes are generated or contamination of receiving environment takes place. The control technology or a combination of technologies to minimize the impact due to the process rejects/wastes varies with quantity and characteristics, desired control efficiency and economics. Many a number of combination of techniques could be adopted for treatment of a specific waste or the contaminated receiving environment, but are often judged based on techno- economic feasibility. Therefore, the best alternative is to take all possible steps to avoid pollution itself. This preventive approach refers to a hierarchy that involves i) prevention & reduction; ii) recycling and re-use; iii) treatment; and iv) disposal, respectively. Therefore, there is a need to shift the emphasis from the reactive to preventive strategy i.e., to promote preventive environmental management. Preventive environmental management tools may be grouped into management based tools, process based tools and product based tools. A few of them are given below : Management Based Tools Process Based Tools Product Based Tools Environmental Management Environmental Technology Assessment Industrial Ecology System (EMS) Toxic Use Reduction Extended Producers Environmental Performance Responsibility Best Operating Practices Evaluation Eco-labeling Environmentally Best Practice Environmental Audits Design for Best Available Technology (BAT) Environmental Reporting Environment And Communication Waste Minimization Life Cycle Assessment Total Cost Accounting Pollution Prevention (LCA) Law And Policy Cleaner Production Trade And Environment 4-R Concept Environmental Economics Cleaner Technology Eco-efficiency These tools are precisely discussed in next sections. 2.3 Tools for Preventive Environmental Management The tools for preventive environmental management can be broadly classified in to following three groups. ̇ Tools for assessment and analysis - risk assessment, life cycle assessment, total cost assessment, environmental audit / statement, environmental benchmarking, environmental indicators ̇ Tools for action - environmental policy, market based economic instruments, innovative funding mechanism, EMS and ISO certification, total environmental quality movement, eco-labeling, cleaner production, eco-efficiency, industrial ecosystem or metabolism, voluntary agreements ̇ Tools for communication - state of environment, corporate environmental reporting TGM for Tanneries August 2010 2-2  Conceptual Facets of EIA Specific tools under each group are discussed precisely in next sections. 2.3.1 Tools for assessment and analysis 2.3.1.1 Risk assessment Risk is associated with the frequency of failure and consequence effect. Predicting such situations and evaluation of risk is essential to take appropriate preventive measures. The major concern of the assessment is to identify the activities falling in a matrix of high & low frequencies at which the failures occur and the degree of its impact. The high frequency, low impact activities can be managed by regular maintenance i.e., LDAR (Leak detection and repair) programmes. Whereas, the low frequency, high impact activities (accidents) are of major concern in terms of risk assessment. As the frequency is low, often the required precautions are not realized or maintained. However, the risk assessment identifies the areas of major concerns which require additional preventive measures; likely consequence distances considering domino effects, which will give the possible casualties and ecological loss in case of accidents. These magnitudes demand the attention for preventive and disaster management plans (DMP). Thus is an essential tool to ensure safety of operations. 2.3.1.2 Life cycle assessment A broader approach followed to deal with environmental impacts during manufacturing is called LCA. This approach recognizes that environmental concerns are associated with every step of processing w.r.t manufacturing of products and also examines environmental impacts of the product at all stages of project life cycle. LCA includes the product design, development, manufacturing, packaging, distribution, usage and disposal. LCA is concerned with reducing environmental impacts at all stages and considering the total picture rather than just one stage of production process. Industries/firms may apply this concept to minimize the costs incurred on the environmental conservation throughout the project life cycle. 2.3.1.3 Total cost assessment Total Cost Assessment (TCA) is an enhanced financial analysis tool that is used to assess the profitability of alternative courses of action ex. raw material substitution to reduce the costs of managing the wastes generated by process; an energy retrofit to reduce the costs of energy consumption. This is particularly relevant for pollution prevention options. These options because of their nature, often produce financial savings that are overlooked in conventional financial analysis, either because they are misallocated, uncertain, hard to quantify, or occur more than three to five years after the initial investment. TCA includes all of relevant costs and savings associated with an option so that it can compete for scarce capital resources fairly, on a level playing field. The assessments are often beneficial w.r.t the following: ̇ Identification of costly resource inefficiencies ̇ Financial analysis of environmental activities/projects such as investment in cleaner technologies ̇ Prioritization of environmental activities/projects ̇ Evaluation of product mix and product pricing TGM for Tanneries August 2010 2-3  Conceptual Facets of EIA ̇ Bench marking against the performance of other processes or against the competitors A comparison of cost assessments is given below: ̇ Conventional cost accounting (CCA): Direct and indirect financial costs and Recognized contingent costs ̇ Total Cost Assessment (TCA): A broader range of direct, indirect, contingent and less quantifiable costs ̇ Full Cost assessment (FCA): TCA and External social costs borne by society 2.3.1.4 Environmental audit/statement Key objectives of an environmental audit include compliance verification, problem identification, environmental impact measurement, environmental performance measurement, conforming effectiveness of EMS, providing a database for corrective actions and future actions, developing companies environmental strategy, communication and formulating environmental policy. The MoEF, Government of India (GOI) issued Notification on ‘Environmental Statements’ (ES) in April, 1992 and further amended in April 1993. As per the Notification, the industries are required to submit environmental statements to the respective State Pollution Control Boards (SPCBs). ES is a pro-active tool for self- examination of the industry to reduce/minimize pollution by adopting process modifications, recycling and reusing of the resources. The regular submission of ES will indicate the systematic improvement in environmental pollution control being achieved by the industry. In other way, specific points in ES may be used as environmental performance indicators for relative comparison, implementation and to promote better practices. 2.3.1.5 Environmental benchmarking Environmental performance and operational indicators could be used to navigate, manage and communicate significant aspects and give enough evidence of good environmental house keeping. Besides the existing prescribed standards, an insight to identify the performance indicators and prescribing schedule for systematic improvement in performance of these indicators will yield better results. Relative indicators may be identified for different industrial sectors and be integrated in companies and organizations to monitor and manage the different environmental aspects of the company, to benchmark and compare two or more companies from the same sector. These could cover water consumption, wastewater generation, energy consumption, solid/hazardous waste generation, chemical consumption etc., per tonne of final product. Once these bench marks are developed, the industries which are below the benchmark may be guided and enforced to reach the level and those which are better than the benchmark may be encouraged further by giving incentives, etc. 2.3.1.6 Environmental indicators Indicators can be classified in to environmental performance indicators (EPI) and environmental condition indicators (ECI). The EPIs can be further divided into two categories i.e., operational performance indicators and management performance indicators. TGM for Tanneries August 2010 2-4  Conceptual Facets of EIA The operational performance indicators are related to the process and other operational activities of the organization. These would typically address the issue of raw material consumption, energy consumption, water consumption in the organization, the quantities of waste water generated, other solid wastes & emissions generated from the organization, etc. Management performance indicators are related to management efforts to influence environmental performance of organizational operations. The environmental condition indicators provide information about the environment. These indicators provide information about the local, regional, national or global condition of the environment. This information helps an organization to understand the environmental impacts of its activities and thus help in making decision to improve the environmental performance. Indicators basically used to evaluate environmental performance against the set standards and thus indicate the direction in which to proceed. Selection of type of indicators for a firm or project depends upon its relevance, clarity and realistic cost of collection and its development. 2.3.2 Tools for action 2.3.2.1 Environmental policy An environmental policy is a statement of an organization’s overall aim and principles of action w.r.t the environmental, including compliance with all relevant regulatory requirements. It is a key tool in communicating environmental priorities of the organization to all its employees. To ensure an organization's commitment towards a formulated environmental policy, it is essential that top management be involved in the process of formulating the policy and setting priorities. Therefore, the first step is to get the commitment from the high level of management. The organization should then conduct an initial environmental review and draft an environmental policy. This draft should be discussed and approved by the board of directors. The approved environmental policy statement should then be communicated internally among all its employees and should also be made available to the public. 2.3.2.2 Market-based economic instruments Market based instruments are regulations that encourage behavior through market signals rather than through explicit directives regarding pollution control levels. These policy instruments such as tradable permits, pollution charge, etc., are often described as harnessing market forces. Market-based instruments can be categorized into the following four major categories, which are discussed below: ̇ Pollution Charge: Charge system will assess a fee or tax on the amount of pollution a firm or source generates. It is worthwhile for the firm to reduce emissions to the point, where its marginal abatement cost are equal to the tax rate. Thus firms control pollution to different degrees i.e., High cost controllers – less; low-cost controllers – more. The charge system encourages the industries to reduce the pollutants further. The collected charges can form a fund for restoration of the environment. Another form of pollution charge is a deposit refund system, where consumers pay a surcharge when purchasing a potentially polluting product, and receive a refund on return of the TGM for Tanneries August 2010 2-5  Conceptual Facets of EIA product after useful life span at appropriate centers. The concept of extended producers’ responsibility brought in to avoid accumulation of dangerous products in the environment. ̇ Tradable Permits: Under this system, firms that achieve the emission levels below their allotted level may sell the surplus permits. Similarly the firms, which are required to spend more to attain the required degree of treatment/allotted levels, can purchase permits from others at lower costs and may be benefited. ̇ Market Barrier Reductions: Three known market barrier reduction types are as follows: − Market Creation: Measures that facilitate the voluntary exchange of water rights and thus promote more efficient allocation of scarce water supplies − Liability Concerns: Encourage firms to consider potential environmental damages of their decisions − Information Programmes: Ecolabeling and energy efficiency product labeling requirements ̇ Government Subsidy Reduction: Subsidies are the mirror images of taxes and, in theory, can provide incentive to address environmental problems. However, it has been reported that the subsidies encourage economically inefficient and environmentally unsound practices, and often lead to market distortions due to differences in area. However, these are important to sustain the expansion of production, in the national interests. In such cases, the subsidy may be comparable to the net social benefit. 2.3.2.3 Innovative funding mechanism There are many forums under which the fund is made available for the issues which are of global/regional concern (GEF, OECD, Deutch green fund etc.) i.e., climate change, Basal convention and further fund sources are being explored for the Persistent Organic Pollutants Convention. Besides these global funding mechanisms, there needs to be localized alternative mechanisms for boosting the investment in environmental pollution control. For example, in India the Government has established mechanism to fund the common effluent treatment plants, which are specifically serving the small and medium scale enterprises i.e., 25% share by the state Government, matching grants from the Central Government and surety for 25% soft loan. It means that the industries need to invest only 25% in first run, thus encouraging voluntary compliance. There are some more options i.e., if the pollution tax/charge is imposed on the residual pollution being caused by the industries, municipalities, etc., fund will automatically be generated, which in turn, can be utilized back for funding the environmental improvement programmes. The emerging concept of build-operate-transfer (BOT) and build-operate- own (BOO) are an encouraging development, where there is a possibility to generate revenue by application of advanced technologies. There are many opportunities which can be explored, however, what is required is the paradigm shift and focused efforts. 2.3.2.4 EMS and ISO certification EMS is that part of the overall management system, which includes organizational structure, responsibilities, practices, procedures, process and resources for determining and implementing the forms of overall aims, principles of action w.r.t. the environment. It encompasses the totality of organizational, administrative and policy provisions to be TGM for Tanneries August 2010 2-6  Conceptual Facets of EIA taken by a firm to control its environmental influences. Common elements of an EMS are the identification of the environmental impacts and legal obligations, the development of a plan for management & improvement, the assignment of the responsibilities and monitoring of the performance. 2.3.2.5 Total environmental quality movement (TEQM) Quality is regarded as ̇ A product attribute that had to be set at an acceptable level and balanced against the cost ̇ Something delivered by technical systems engineered by experts rather than the organization as a whole ̇ Assured primarily through the findings and correction of mistakes at the end of the production process One expression of the total environment quality movement (TEQM) is a system of control called Kaizen. The principles of Kaizen are ̇ Goal must be continuous improvement of quality instead of acceptable quality ̇ Responsibility of quality shall be shared by all members of an organization ̇ Efforts should be focused on improving the whole process and design of products With some modifications, the TQM approach can be applied in improvement of corporate environmental performance in both process and product areas. 2.3.2.6 Eco-labeling Eco-Labeling is the practice of supplying information on the environmental characteristics of a product or service to the general public. These labeling schemes can be grouped into three types: ̇ Type I: Multiple criteria base; third party (Govt. or non-commercial private organizations) programme claims overall environmental preferability ̇ Type II: Specific attribute of a product; often issued by a company/industrial association ̇ Type III: Agreed set of indices; provide quantified information; self declaration Among the above, Type I are more reliable because they are established by a third party and considers the environmental impacts of a product from cradle to grave. However, the labeling program will only be effective if linked with complementary program of consumer education and up on restriction of umbrella claims by the producers. 2.3.2.7 Cleaner production Cleaner production is one of the tools, which has lot of bearing on environmental pollution control. It is also seen that the approach is changing with time i.e., dumping-to- control-to-recycle-to-prevention. Promotion of cleaner production principles involves an insight into the production processes not only to get desired yield but also to optimize on raw material consumption i.e., resource conservation and implications of the waste treatment and disposal. TGM for Tanneries August 2010 2-7  Conceptual Facets of EIA 2.3.2.8 4-R concept The concept endorses utilization of wastes as by-products to the extent possible i.e., Re- cycle, Recover, Re-use, Recharge. Recycling refers to using wastes/by-products in the process again as a raw material to maximize production, etc., Recovery refers to engineering means such as solvent extraction, distillation, precipitation, etc., to separate useful constituents of wastes, so that these recovered materials can be used. Reuse refers to the utilization of waste from one process as a raw material to other. Recharging is an option in which natural systems are used for renovation of waste for further use. 2.3.2.9 Eco-efficiency The World Business Council on Sustainable Development (WBCSD) defines eco- efficiency as “the delivery of competitively priced goods and services that satisfy human needs and bring quality of life, while progressively reducing ecological impacts and resource intensity throughout the life cycle, to a level at least in line with earth’s carrying capacity”. The business implements the eco-efficiency on four levels i.e., optimized processes, recycling of wastes, eco-innovation and new services. Fussler (1995) defined six dimensions of eco-efficiency, which are given below to understand/examine the system: ̇ Mass: There is an opportunity to significantly reduce mass burdens (raw materials, fuels, utilities consumed during the life cycle) ̇ Reduce Energy Use: The opportunity is to redesign the product or its use to provide significant energy savings ̇ Reduce Environmental Toxins: This is a concern to the environmental quality and human health. The opportunity here is to significantly control the dispersion of toxic elements. ̇ Recycle when Practical: Designing for recyclability is important ̇ Working with Mother Nature: Materials are borrowed and returned to the nature without negatively affecting the balance of the ecosystem. ̇ Make it Last Longer: It relates to useful life and functions of products. Increasing the functionality of products also increases their eco efficiency. The competitiveness among the companies and long-term survival will continue and the successful implementation of eco-efficiency will contribute to their success. There is a need to shift towards responsible consumerism equal to the efficiency gains made by corporations – doing more with less. 2.3.2.10 Industrial ecosystem or metabolism Eco-industrial development is a new paradigm for achieving excellence in business and environmental performance. It opens up innovative new avenues for managing business and conducting economic development by creating linkages among local ‘resources’, including businesses, non-profit groups, governments, unions, educational institutions, and communities. They can creative fostering of dynamic and responsible growth. Antiquated business strategies based on isolated enterprises are no longer responsive enough to market, environmental and community requirements. TGM for Tanneries August 2010 2-8  Conceptual Facets of EIA Sustainable eco-industrial development looks systematically at development, business and environment, attempting to stretch the boundaries of current practice - on one level. It is as directly practical as making the right connections between the wastes and resources needed for production and at the other level, it is a whole new way of thinking about doing business and interacting with communities. At a most basic level, each organization seeks higher performance within it self. However, most eco-industrial activity is moving to a new level by increasing the inter connections between the companies. Strategic partnership, networked manufacturing and performed supplier arrangements are all the examples of ways used by the businesses to ensure growth, contain costs and to reach out for new opportunities. For most businesses, the two essentials for success are the responsive markets and access to cost-effective, quality resources for production or delivering services. In absence of these two factors, virtually every other incentive becomes a minor consideration. Transportation issues are important at two levels, the ability to get goods to market in an expeditious way is essential to success in this day of just in time inventories. The use of least impact transportation with due consideration of speed and cost supports business success and addresses the concerned in community. Eco-industrial development works because it consciously mixes a range of targeted strategies shaped to the contours of the local community,.Most importantly, it works because the communities wants nothing less than the best possible in or near their neighborhood. For companies it provides a path towards significantly higher operating results and positive market presence. For our environment, it provides great hope that the waste will be transformed into valued product and that the stewardship will be a joint pledge of both businesses and communities. 2.3.2.11 Eco-industrial park An eco-industrial park is a community of manufacturing and service businesses seeking enhanced environmental and economic performance through collaboration in managing environmental and resource issues including energy, water and materials. By working together, the community of businesses seeks a collective benefit that is greater than the some of the individual benefits, each company could realize it is an optimized its individual performance only. The goal of an eco industrial park is to improve economic performance of the participating companies by minimizing their environmental impacts. 2.3.2.12 Voluntary agreements Voluntary environmental agreements among the industries, government, public representatives, NGOs and other concerned towards attaining certain future demands of the environment are reported to be successful. Such agreements may be used as a tool where Government would like to make the standards stringent in future (phase-wise- stringent). These may be used when conditions are temporary and require timely replacements. Also, these may be used as supplementary/ complimentary in implementation of the regulation. The agreements may include: ̇ Target objectives (emission limit values/standards) ̇ Performance objectives (operating procedures) TGM for Tanneries August 2010 2-9  Conceptual Facets of EIA ̇ R&D activities – Government and industry may have agreement to establish better control technologies. ̇ Monitoring & reporting of the agreement conditions by other agents (NGOs, public participants, civil authority etc.) In India, the MoEF, has organized such programme, popularly known as the corporate responsibility for environment protection (CREP) considering identified 17 categories of high pollution potential industrial sectors.. Publication in this regard, is available with Central Pollution Control Board (CPCB). 2.3.3 Tools for communication 2.3.3.1 State of environment The Government of India has brought out the state of environment report for entire country and similar reports are available for many of the states. These reports are published at regular intervals to record trends and to identify the required interventions at various levels. These reports consider the internationally accepted DPSIR framework for the presentation of the information. DPSIR refers to Ü D – Driving forces – causes of concern i.e. industries, transportation etc. Ü P – Pressure – pollutants emanating from driving forces i.e. emission Ü S – State – quality of environment i.e. air, water & soil quality Ü I – Impact – Impact on health, ecosystem, materials, biodiversity, economic damage etc. Ü R – Responses – action for cleaner production, policies (including standards/ guidelines), targets etc. Environment reports including the above elements give a comprehensive picture of specific target area in order to take appropriate measures for improvement. Such reports capture the concerns which could be considered in EIAs. 2.3.3.2 Corporate environmental reporting Corporate environmental reports (CERs) are only one form of environmental reporting defined as publicly available, stand alone reports, issued voluntarily by the industries on their environmental activities (Borphy and Starkey-1996). CER is just are a means of environmental improvement and greater accountability, not an end in itself. Three categories of environmental disclosure are: ̇ Involuntary Disclosure: Without its permission and against its will (env. Campaign, press, etc.) ̇ Mandatory Disclosure: As required by law ̇ Voluntary Disclosure: The disclosure of information on a voluntary basis TGM for Tanneries August 2010 2-10  Conceptual Facets of EIA 2.4 Objectives of EIA Objectives of EIA include the following: Ü To ensure environmental considerations are explicitly addressed and incorporated into the development decision-making process; Ü To anticipate and avoid, minimize or offset the adverse significant biophysical, social and other relevant effects of development proposals; Ü To protect the productivity and capacity of natural systems and the ecological processes which maintain their functions; and Ü To promote development that is sustainable and optimizes resource use as well as management opportunities. 2.5 Types of EIA Environmental assessments could be classified into four types i.e. strategic environmental assessment, regional EIA, sectoral EIA and project level EIA. These are precisely discussed below: Strategic environmental assessment Strategic Environmental Assessment (SEA) refers to systematic analysis of the environmental effects of development policies, plans, programmes and other proposed strategic actions. SEA represents a proactive approach to integrating environmental considerations into the higher levels of decision-making – beyond the project level, when major alternatives are still open. Regional EIA EIA in the context of regional planning integrates environmental concerns into development planning for a geographic region, normally at the sub-country level. Such an approach is referred to as the economic-cum-environmental (EcE) development planning. This approach facilitates adequate integration of economic development with management of renewable natural resources within the carrying capacity limitation to achieve sustainable development. It fulfils the need for macro-level environmental integration, which the project-oriented EIA is unable to address effectively. Regional EIA addresses the environmental impacts of regional development plans and thus, the context for project-level EIA of the subsequent projects, within the region. In addition, if environmental effects are considered at regional level, then cumulative environmental effects of all the projects within the region can be accounted. Sectoral EIA Instead of project-level-EIA, an EIA should take place in the context of regional and sectoral level planning. Once sectoral level development plans have the integrated sectoral environmental concerns addressed, the scope of project-level EIA will be quite minimal. Sectoral EIA helps in addressing specific environmental problems that may be encountered in planning and implementing sectoral development projects. TGM for Tanneries August 2010 2-11  Conceptual Facets of EIA Project level EIA Project level EIA refers to the developmental activity in isolation and the impacts that it exerts on the receiving environment. Thus, it may not effectively integrate the cumulative effects of the development in a region. From the above discussion, it is clear that EIA shall be integrated at all the levels i.e., strategic, regional, sectoral and the project level. Whereas, the strategic EIA is a structural change in the way the things are evaluated for decision-making, the regional EIA refers to substantial information processing and drawing complex inferences. The project-level EIA is relatively simple and reaches to meaningful conclusions. Therefore in India, project-level EIA studies take place as a large-scale and are being considered. However, in the re-engineered Notification, provisions have been incorporated for giving a single clearance for the entire industrial estate for e.g., Leather parks, pharma cities etc., which is a step towards the regional approach. As we progress and the resource planning concepts emerge in our decision-making process, the integration of overall regional issues will become part of the impact assessment studies. 2.6 Basic EIA Principles By integrating the environmental impacts of the development activities and their mitigation early in the project planning cycle, the benefits of EIA could be realized in all stages of a project, from exploration and planning, through construction, operations, decommissioning, and beyond site closure. A properly-conducted-EIA also lessens conflicts by promoting community participation, informing decision makers, and also helps in laying the base for environmentally sound projects. An EIA should meet at least three core values: ̇ Integrity: The EIA process should be fair, objective, unbiased and balanced ̇ Utility: The EIA process should provide balanced, credible information for decision- making ̇ Sustainability: The EIA process should result in environmental safeguards Ideally an EIA process should be: ̇ Purposive- should inform decision makers and result in appropriate levels of environmental protection and community well-being. ̇ Rigorous- should apply ‘best practicable’ science, employing methodologies and techniques appropriate to address the problems being investigated. ̇ Practical- should result in providing information and acceptable and implementable solutions for problems faced by proponents. ̇ Relevant- should provide sufficient, reliable and usable information for development planning and decision making. ̇ Cost-effective-. should impose minimum cost burdens in terms of time and finance on proponents and participants consistent with meeting accepted requirements and objectives of EIA TGM for Tanneries August 2010 2-12  Conceptual Facets of EIA ̇ Efficient- should achieve the objectives of EIA within the limits of available information, time, resources and methodology. ̇ Focused- should concentrate on significant environmental effects and key issues; i.e., the matters that need to be considered while making decisions. ̇ Adaptive- should be adjusted to the realities, issues and circumstances of the proposals under review without compromising the integrity of the process, and be iterative, incorporating lessons learnt throughout the project life cycle. ̇ Participative- should provide appropriate opportunities to inform and involve the interested and affected publics, and their inputs and concerns should be addressed explicitly in the documentation and decision making. ̇ Inter-disciplinary- should ensure that appropriate techniques and experts in relevant bio-physical and socio-economic disciplines are employed, including use of traditional knowledge as relevant. ̇ Credible- should be carried out with professionalism, rigor, fairness, objectivity, impartiality and balance, and be subject to independent checks and verification. ̇ Integrated- should address the interrelationships of social, economic and biophysical aspects. ̇ Transparent- should have clear, easily understood requirements for EIA content; ensure public access to information; identify the factors that are to be taken into account in decision making; and acknowledge limitations and difficulties. ̇ Systematic- should result in full consideration of all relevant information on the affected environment, of proposed alternatives and their impacts, and of the measures necessary to monitor and investigate residual effects. 2.7 Project Cycle The generic project cycle including that of leather/skin/hide processing industry has six main stages: 1. Project concept 2. Pre-feasibility 3. Feasibility 4. Design and engineering 5. Implementation 6. Monitoring and evaluation It is important to consider the environmental factors on an equal basis with technical and economic factors throughout the project planning, assessment and implementation phases. Environmental consideration should be introduced at the earliest in the project cycle and must be an integral part of the project pre-feasibility and feasibility stage. If the environmental considerations are given due respect in the site selection process by the project proponent, the subsequent stages of the environmental clearance process would get simplified and would also facilitate easy compliance to the mitigation measures throughout the project life cycle. A project’s feasibility study should include a detailed assessment of significant impacts, and the EIA include a detailed prediction and quantification of impacts and delineation of Environmental Management Plan (EMP). Findings of the EIA study should preferably be incorporated in the project design stage so that the project as well as the site alternatives is studied and necessary changes, if required, are incorporated in the project design stage. TGM for Tanneries August 2010 2-13  Conceptual Facets of EIA This practice will also help the management in assessing the negative impacts and in designing cost-effective remedial measures. In general, EIA enhances the project quality and improves the project planning process. 2.8 Environmental Impacts Environmental impacts resulting from proposed actions can be grouped into following categories: ̇ Beneficial or detrimental ̇ Naturally reversible or irreversible ̇ Repairable via management practices or irreparable ̇ Short term or long term ̇ Temporary or continuous ̇ Occurring during construction phase or operational phase ̇ Local, regional, national or global ̇ Accidental or planned (recognized before hand) ̇ Direct (primary) or Indirect (secondary) ̇ Cumulative or single The category of impact as stated above, and the significance will facilitate the Expert Appraisal Committee (EAC)/State Level EAC (SEAC) to take a look at the ToR for EIA studies, as well as, in decision making process about the developmental activity. The nature of impacts could fall within three broad classifications i.e., direct, indirect and cumulative, based on the characteristics of impacts. The assessment of direct, indirect and cumulative impacts should not be considered in isolation nor can be considered as separate stages in the EIA. Ideally, the assessment of such impacts should form an integral part of all stages of the EIA. The TGM does not recommend a single method to assess the types of impacts, but suggests a practical framework/approach that can be adapted and combined to suit a particular project and the nature of impacts. Figure 2-2: Types of Impacts TGM for Tanneries August 2010 2-14  Conceptual Facets of EIA 2.8.1 Direct impacts Direct impacts occur through direct interaction of an activity with an environmental, social, or economic component.