Submissions-Other Issues

This section contains Submissions made by Manthan to different Public Authorities under the Other Issues theme.

Comments submitted to the Ministry of Power constituted Expert Committee on the Draft National Electricity Policy 2021

The Ministry of Power has published a Draft National Electricity Policy (NEP) 2021 on 27th April 2021, prepared and recommended by a MoP constituted Expert Committee. The Expert Committee has solicited suggestions and comments on the same. Ashwini Chitnis, an independent researcher and policy analyst, and Manthan Adhyayan Kendra have analysed the draft document and prepared a detailed set of comments with their main focus on hydropower sections, and some environmental issues. These comments submitted to the Committee argue that the proposed Draft National Electricity Policy’s push for hydropower as part of India’s optimal generation mix is lacking both economic and environmental rationale.

Read the Detailed Comments Here

Comments submitted to the Central Empowered Committee on the Goa transmission line project

The State Government of Goa has planned three infrastructure projects which will pass through the Mollem National Park (NP) and the Bhagwan Mahaveer Wildlife Sanctuary (WLS), apart from other sensitive areas. All three projects, though so-called “linear” projects will have serious environmental impacts, including on the protected areas through which they are to pass. The projects are being justified on account of several benefits that they will bring to the state, as well as the sometimes explicit, sometime implied argument that they are inevitable, and that there are no options to these projects.

This note here particularly focuses on one of the project planned which is, the Additional 400 kV High Tension Power Transmission Line from Narendra (Dharwad) to Xeldem (south Goa), and analyses the Justifications given by the State Government to push this project forward.

Submission sent on 22nd February 2021

Read Full Comments here

Comments submitted to the MoEF&CC on the Draft EIA Notification 2020

The Ministry of Environment, Forest and Climate Change (MoEF&CC) published the draft Environment Impact Assessment (EIA) Notification, 2020 on its website for public comments on 12th March 2020.   The new draft weakens an already weak environmental assessment and clearance regime i.e. EIA Notification 2006. To push this through when the whole country is under lock down and there is little chance of public consultation on the new draft especially among communities who are not connected on internet or do not follow English is totally unacceptable. We join the call given by many others to MoEFCC to withdraw the draft.

However, in the likely event that this does not happen, Manthan Adhyayan Kendra has reviewed the draft and prepared comments, objections and recommendations in three parts, namely:

Part 1

English: Comments specific to provisions related to Inland Waterways.

Hindi: पर्यावरणीय प्रभाव आकलन (EIA) अधिसूचना, 2020 के प्रारूप में अंतर्देशीय जलमार्ग संबंधी विशिष्‍ठ प्रावधानों पर टिप्‍पणियाँ

Part 2

English: Comments related to restructuring of the EIA/EC process and amendments needed in Draft 2020 Notification for the same.

Part 3

English: Additional comments on specific clauses / section of the Draft Notification 2020


To view the comments sent by us, please click on the respective titles above (Part-1, Part-2 & Part-3)

Date of Submission: Date of Submission: Part 1& 2 : 29th April 2020; Part 3: 29th June 2020


Comments on the Framework for Regulatory Control through Use of Continuous Real Time Effluent Quality & Air Emission Monitoring Data

Letter sent to Central Pollution Control Board of Government of India. This letter includes comments on the “Framework for Regulatory Control through Use of Continuous Real Time Effluent Quality & Air Emission Monitoring Data”.

Submission, sent on 2 Jan 2017.

Read full comments here.