TSR Subramaniam Report: Critical Analysis

TSR Subramaniam Report: Critical Analysis

Question: The TSR Subramaniam Committee Report has been rejected by the MoEF. What were the reasons for it to be debunked? Analyse.

- TSR Subramaniam report has been junked due to focus on expediting environmental clearances and limited public participation for promoting economic development

- The report has a bargaining approach to the environment whereby the administration as agents of citizens and environment accept development activity results in environmental damage and that the compensation for this would be given in utmost good faith. Report did not consider economic constants of utmost faith namely adverse selection and moral hazard

- Valuing the environment and conversion of the same into compensatory amount requires corroboration between ex ante and ex post damages

- Assessing environmental value and qualification of damages is not an exact science and there can be skewed value resulting from mismatch between projected and actual damages. For example, how can one assess the monetary worth of the extinction of a species?

- Report aimed to strengthen monitoring and compliance mechanisms while the NEMA and SEMA would subsume Pollution Control Boards and become technical organisations for processing environmental clearance apps in strict and timely manner

- Assessment, regardless of nature of institutional structure should ensure more compliance and greater monitoring

- If the new authorities would be more effective than PCBs is an important consideration

- In terms of the proposed Environment Law Management Act, special courts have to be set up for complainants . This curbs the power of the NGT and the report also makes its powers applicable for judicial review of administrative actions. This does not support the conservation of the environment

- Report was based no information management and though it recognised that the latter was poor, it did not consider that core issues of access and utility of information database would be affected by projects. Database would lack accessibility as the controlling organisation would charge for access and this would reduce the critical analysis by stakeholders

- Report also did not consider present weakness in environmental governance

- It limits the ability to evaluate the environment through monetary terms making the management exercise one of futility.

Facts and Stats

There are numerous schemes for environmental conservation such as the following:

- Integrated Forest Protection Scheme

- National River Conservation Plan

- Sanjhi Van Yojna in Himachal Pradesh

- Construction of Building Scheme

- Scheme to Protect Forest

- Orissa Bamboo Development Programme

- Economic Plantation Scheme

- Utkal Sabuja Gram Yojana