To
The Secretary,
Ministry of Environment, Forest and Climate Change,
Indira Paryavaran Bhawan,
Jor Bagh Road, Aliganj,
New Delhi-110 003,

Subject: Comments and observations on draft EIA Notification 2020 inviting comments from the public

Dear Secretary

We are writing to you as environmentally conscious tourists and travelers in response to the draft EIA notification 2020. Tourism has been seeing continuous growth for many years now, and in 2018, the growth rate of tourism was 11.9%. As you are aware, currently there are attempts to revive tourism after the slump due to COVID-19, and we believe that this is a good time to rethink how tourism is undertaken, and strengthen environmental sustainability of tourism practices. We believe that a strong and robust environmental scrutiny is a must for development of sustainable tourism.

For this, we ask that your Ministry withdraw the draft EIA notification 2020, conduct a detailed and broad public consultation, involving all stakeholders and the public, and draft a strong and robust Act for environmental impact assessment.

A few points are noted below on how the EIA can be strengthened for tourism -

1. Tourism should be included as a separate industry within the Schedule. Tourism has several negative impacts on the ‘destination’, including generation of waste, depleting water resources, changes in biodiversity and changes in social structures. Therefore, it is important to recognize it as a separate industry, especially in ecologically fragile areas and above a certain investment threshold.. Such an assessment should also include a ‘Tourism Carrying Capacity’ analysis.  

2. A comprehensive Tourism Carrying Capacity (TCC) should be included within the EIA. This should include different dimensions - physical-ecological (like ecology, natural heritage, climate, water and such); socio-demographic (such as relationship between communities and tourists, cultural identities and other characteristics); political-economic (such as linkages to local economy, policies and so on). As TCC is also a process for management and planning of the area, it is imperative that local participation is sought at all stages.
 
3. Strengthen process of consultation and consent within EIA - The current framework on EIA is a technocratic process where there is limited scope for affected persons, other stakeholders and the general public to engage with the projects. For tourism, the role of Panchayats in regulating land usage, building construction, waste management and others has been recognized under several state-level Panchayat Raj Acts. The EIA process must recognize the critical role of Panchayats and other local elected bodies in managing tourism development in the area, and ensure the full participation and consent of the Panchayat from the Scoping stage itself.

4. Small infrastructure projects, which are tourism related, may have severe ecological impacts that are either left out of the EIA framework or have been insufficiently covered. Infrastructural projects in ecologically fragile areas, including mountains and coasts, should be included in the EIA as Category A or B1, without size thresholds. A few specific examples are given below. For example, tarring of roads, even when they are small (1km or more) should require clearance if they are located in ecologically sensitive areas, coastal zones, and in mountains. Aerial ropeways should also be included in the EIA, and if they are in Ecologically Sensitive Areas, they should go through high scrutiny.

The dilution of the scrutiny for aerial ropeways between the 2006 and 2020 notifications is bound to have negative impacts on the ecology of the site. The original categorization of ropeway under the 2006 notification should be retained so that the impacts can be effectively assessed and mitigation measures undertaken.

5. One of the biggest loopholes in the current structure of assessing tourism impacts is that  it is done at an individual project level and not at a landscape level. Under the current framework of EIA there is no way to assess impacts of tourism at a landscape level. Haphazard, unplanned tourism can wreak ecological havoc, and also threaten lives, as seen in the case of the 2013 Uttarakhand floods. In tourism hotspots like Shimla and Goa, tourism has significantly contributed to acute water shortages and has deprived local communities of essential resources. In places like Mahabaleswar and Kodaikanal, tourism has changed the demographic structure of the place, and we now see that there are more tourists than the local population.

Hence, in tourism hotspots like these and many other destinations across India, we need a cumulative impact assessment from the perspective of tourism - a tourism impact assessment.

Yours sincerely