Auditing Ecology, Ecologising AuditEnv. Audit Reports by CAG of India:

The Way Ahead

Himanshu Upadhyaya

Faculty, Azim Premji University, Bangalore

Background on INTOSAI

The International Organization of Supreme Audit Institutions

(INTOSAI) is the professional organization of supreme audit

institutions (SAI) in countries that belong to the United Nations

or its specialized agencies. INTOSAI was founded in 1953 and

has grown from the original 34 countries to a membership of

over 180 SAIs. As the internationally recognized leader in public

sector auditing, INTOSAI issues international guidelines for

financial management and other areas, develops related

methodologies, provides training, and promotes the exchange

of information among members. One way by which INTOSAI

promotes the exchange of ideas and experiences between SAIs

around the world is through its triennial congress called the

International Congress of Supreme Audit Institutions (INCOSAI).

Background of INTOSAI’s WGEA

During the 14th INCOSAI meeting held in Washington, D.C. in October 1992 the INTOSAI membership indicated a strong interest in the roles and activities of Supreme Audit Institutions in issues of environmental auditing. The formation of a Working Group on Environmental Auditing (WGEA) was initiated and approved by the Congress.

The Working Group aims to improve the use of audit mandate and audit instruments in the field of environmental protection policies, by both members of the Working Group and non-member Supreme Audit Institutions (SAIs).

The WGEA started out with 12 countries and has since grown to a membership of over 60, making it the largest INTOSAI working group.

India’s SAI is a WGEA member, and hence it is extremely relevant for us to see what CAG has done far to audit environmental governance and how has MOEF responded to CAG’s audit findings.

‘Environmental Audits’ so far…

Environmental Audits by Issues http://www.wgea.org/Default.aspx?tabid=125

and here is India http://www.wgea.org/Default.aspx?tabid=126&CountryId=290

Since 1993, WGEA has carried out five surveys. It hascarried out these surveys on environmental audit at aninterval of every three years. Surveys are sent to heads ofall Supreme Audit Institutions. Surveys are instrumental inthe development of each WGEA work plan and serve theneeds of INTOSAI members.

However, when one examines the results, one finds thatIndia didn't respond to first three surveys. It responded tothe fourth survey in 2003 and fifth survey in 2006, and hadsent in the much-delayed response to the questionnaire ofthe first survey while responding to the fourth survey.

CAG’s Mandate on ‘Environmental Audit

Guidance on Conducting Audits of Activities with anEnvironmental Perspective' provided by the InternationalWorking Group on Environment Audit classifiesEnvironmental Auditing into the following five categories:

1. Audits of government monitoring of compliance withenvironmental laws;

2. Audits of the performance of government environmentalprogrammes;

3. Audits of environmental impact of other governmentprogrammes;

4. Audit of environmental management systems; and

5. Evaluations of proposed environmental policies andprogrammes.

Env Audit: First Steps

In the year 2002, when CAG of India brought out Manual on Standing Orders (Audit) its chapter 19 dealt with various facets of Environmental Auditing.

In the same year, CAG of India designated Regional Training Institute, Mumbai as a nodal institute and centre for excellence for Environmental Auditing.

In December 2003, RTI Mumbai organised the first five days training programme on Env Audit, followed by designing a Structured Training Module in 2004, and 3 days training for trainers based on STM in June 2004.

Till end 2005, RTI Mumbai had trained 566 officers in Environmental Audit.

Env Audit: First Steps

In February 2006, RTI Mumbai organised a workshop on

Natural Resources Accounting in collaboration with Central

Statistical Organisation, followed by another similar one on

November 2006 for PDs, Principals of RTIs/ RTCs and group

officers of the Audit department.

During the tenure of V N Kaul, the office of PD (Scientific

Department) was designated as the nodal office for

undertaking environmental audits.

Vijay Kumar states that there was now a shift from ‘EA

report being a rarity in SAI India’s non-civil reports’ to

‘environmental concerns being increasingly reflected in

recent reports’.

Environment Audit: Still in future tense?

A theme paper Auditing for Good Governance: FacilitatingForesight authored by A K Awasthi and Vani Sriram forbiennial Auditor Generals’ conference in October 2008reported "In the area of environment and climate change,we already have a nodal office (PDA SD) and a nodaltraining institution for environmental audit (RegionalTraining Institute, Mumbai)".

87th international training programme on Env Audit tookplace at iCISA, Noida in Jan 2009!http://www.icisa.cag.gov.in/images/87Schedule.htm

Similarly, on 15th and 16th March 2010, there was aninternational conference on Env Audit, which discussedconcerns around water pollution.

iCED: Env Audit and Sustainable Dev

Since 2008, the agenda of Env Audit started getting

prominence and in 2011, the global training facility was

created in the form of iCED, Jaipur.

iCED website now lists environmental audit reports carried

out by SAI India year wise in addition to the list that is

there on INTOSAI WGEA page.

iCED website also hosts publication of WGEA of INTOSAI,

WGEA of ASOSAI and SAI – India’s study reports as well as

guidelines on env audit issues.

iCED can play important role for better feedback between

Env audit and env policy, regulation and governance.

Audit Advisory Board and Ecologists?

http://www.cag.gov.in/html/advisory_board.htm

Prodipto Ghosh, Sunita Narain etc have been on board.

There is a 907 page document CAG of India: A thematic History 1990-2007. It has an appendix, Changes in the Policy, Law, rules etc at the instance of audit finding and did try to find [ctrl+f] the word ‘environment’ in vain!

We also need to see whether environmental audit report leads to strengthening environmental governance, i.e. strengthening environmental clearance process in wake of Env Management report on Mumbai Port Trust.

We also need to expand the knowledge base on environmental audits.

Quick Overview of Env Audits so far

In late 1970s, when SAI India started to carry out

Performance cum Effectiveness Audits, environmental

concerns emerged slowly as many of these highlighted that

neglecting env concerns led to shortfalls in benefits. e.g.

performance audit on Loktak and Baira Siul Hydroelectric

projects and on 15 major and medium irrigation projects.

These reports had brought to the attention of planners

command area ecological concerns and geological

investigations while undertaking Hydroelectric projects.

PA reports on Accelerated Irrigation Benefit Programme

and Command Area Development Authorities talked about

culture of non-compliance with env norms.

More focussed Env Audits in 1990s

In 1995, PA on Scientific bodies covered Ganga Action Plan

and Forest Survey of India and highlighted missing links.

In 1996, there was a performance review of preservation of

wildlife in Meghalaya and of Afforestation of Waste Land

and Agro Forestry in Haryana. There was a performance

review of Pollution Control Board in Maharashtra.

In 2000, SAI India revisited performance of Ganga Action

Plan and we need to ask if policy makers learnt lessons.

In 2000-’01, a compliance audit report looked at

implementation of env acts relating to Water Pollution. Did

MoEF during NDA regime (1998-2003) learnt lessons?

Env Audits (2000 onwards)

In 2002, CAG carried out performance audit of scientific

bodies and Zoological Survey of India under MoEF was also

one of those covered. The audit findings revealed “The

primary objective of survey and exploration work of ‘faunal’

resources in the selected areas was behind schedule for

periods ranging from five to 13 years.”

In 2004, an audit report on Gerusoppa Dam in Karnataka

talked about cost and time overruns, but this could have

indicted KPCL for having failed to comply with env norms.

In 2007, env audit reports were bringing env non-compliance.

Auditors were now carrying cameras during joint site visits,

e.g. PA on wildlife protection in Arunachal Pradesh.

Env. Audits (2007 onwards)

In 2007, environment management at Mumbai Port Trust

came under CAG’s scanner. The audit findings were

startling and could have launched an overhaul of env

clearance process. Alas, MoEF had worked overtime to

further dilute the EIA notification bringing amendments.

In 2009, there was a remarkable performance review

report on government’s flagship wildlife protection

scheme, National Tiger Conservation Programme. We need

to probe the impact of the audit findings on the policy

debates around Tiger Parks in India during 2009-’10.

In 2009, Several state audit reports carried review of air

pollution by thermal power plants. Panipat in Haryana etc.

Env Audits: 2007 Onwards

There were also performance reviews that talked in great

details about the env impacts of hydropower projects, e.g.

PA on hydropower projects in Uttarakhand (2008-’09) and in

Himachal (2012). Both reports did raise some pertinent

issues around non-compliance with env safeguards. We

need to find out how states and MoEF has responded.

In 2009-’10 and then again in 2012-’13, there was a

performance review of Hydropower projects in North East

and Eastern India. Even as the audit findings suggested the

culture of impunity and rampant non-compliance of env

norms, these reports suggested to ‘pay attention to

geological risks, but go faster on green clearance’?!

Ecologising Audit: Role of iCED

Since there have been more than 100 Env audits, there is a

lot that has already been accomplished. However, now

there is a need to focus of going beyond auditing ecology

and focus attention of ‘ecologising audit’.

This year there have been very indicting audit reports on

forest governance in West Bengal and Himachal Pradesh

and of functioning of Mining and Geology Dept in Andhra.

The question is that of follow up on these audit findings and

ensuring a dialogic feedback system between public audit

and env. policy makers. There is a need for a dialogic

engagement whereby auditors will listen to and learn from

ecologists, and definitely the other way round to.

Thanking you

Thanks a lot for providing me the opportunity for this

dialogue. You may like to read some of my writings

drawing from the env audit reports from CAG of India on

this link: www.indiatogether.org/c/environment

Would be grateful for your qualitative feedback

Contact Details:

himanshu.u@apu.edu.in/ himanshugreen@gmail.com

Auditing Ecology/ Auditing Environment?

Himanshu Upadhyaya, Faculty, Azim Premji University

What does it mean to audit ecology or environment or to dwell on the matter of natural resource capital

and how have governments managed the same? Even as there has been much that has been written

and published in academic circles on the discipline of Envionmental Economics and recently on

Ecological Economics, in this paper, I wish to focus on audit reports from the CAG of India over the years

which voiced environmental concerns. Allow me to start with an anecdote.

Sometime in 2003, I was doing a literature review along with a friend for our book that aimed to look at

the performance of Bhakra Nangal Project. I chanced upon a performance audit report by CAG of India

from the year 1979, which was on 15 of our major and medium irrigation projects. I vividly remember

the excitement, because here was something that auditors told the irrigation and water resource

establishment, based on what they could see in the command area. In 1979, environmental impacts of

irrigation in command area were not yet known in details, but the performance audit indicated the

command area development issues required to be paid attention to. Some of our hydropower projects

in 1970s were not without its prolonged saga of geological problems arising thanks to inadequate

geological assessment. An Advance Report of the CAG of India for the year 1976-’77 (Union Government

– Civil)contained 32 page long performance review of Loktak Hydroelectric project in Manipur.

Similar geological risks had plagued tunneling at Chamera Hydroelectric project, but none of the citizens

knew for years, except the news about a few accidents. When the information was kept under wraps by

project authority (NHPC), neither citizens not CAG of India had any hope to get a glimpse of the track

record of the project authority on the issue of geological risks. However, the project was financed by

Canadian Development Assistance Agency (CIDA), which was covered under Canadian Access to

Information Law and when an environmental organization filed those Access to Information

applications, a large set of documents entered public domain. In 1995, CAG carried out a performance

review of hydropower projects build by NHPC. In 2004, ten years from that moment, when I started to

research Hydropower issues in India, this was a very valuable reading, in addition to others.

Environmental Audit has thus evolved organically in Indian SAI through practice. Auditors would have

thought in 1960s why our irrigation sector still faced certain knotty problems and in late 1970s,

examined whether the investments were resulting in ‘development effectiveness’ or not, and if not

what other strategies were needed in command areas. They might have been concerned about whether

Small Farmers Development Agency worked at rural level and if it did, how effectively did it work; but

behind all these there were also issues of environmental impacts and ecological concerns.

CAG of India have subsequently also carried out a performance audit on functioning of Command Area

Development Authorities in 2002-‘03. Similar to this was performance audit report on functioning of

centrally sponsored Accelerated Irrigation Benefit Programme (AIBP) in 2004. When CAG pointed out

that in number of projects included under AIBP forest/ environment clearance was not obtained till the

date of audit scrutinyi, the Ministry sought to argue in its reply dated March 2004 that “there were

delays in obtaining forest and environment clearance in respect of projects sanctioned before coming

into effect of Conservation/Protection Acts”. Having quoted this reply, CAG stated that the same was

“not tenable as the Acts had come into force when AIBP was launched and therefore, these clearances

should have been ensured before inclusion of such projects under AIBP”ii. Only in the cases of a couple

of irrigation project in Rajasthan, CAG auditors found that such violations had attracted imposition of

penalty!

The question that arises then is: why do Techno Economic and Investment clearances pre-date

environmental and forest clearances and why are they given irrespective of the fact that project

proponents deliberately hide environmental impacts of the projects, or at best apply for the same much

later after projects have attained some sort of fait accompli status?

More Pronounced Environmental Audits in 1990s

In 1995, a CAG audit reported performance reviews of scientific bodies and it had covered Ganga Action

Plan as well as Forest Survey of India. The audit findings on FSI stated, “the objective of creation of the

National Basic Forest Inventory System was not achieved”.

In 1996, CAG carried out performance audit of schemes for preservation of wildlife in Meghalaya. In the same year its audit report on Haryana had covered Afforestation of Waste Land and Agro Forestry.

In 1999, a CAG audit report looked critically at the Botanical Survey of India and indicted it for having failed to preserve 1990 species out of 2000 species of flowering plants, which are likely to become rare, threatened or extinct by the year 2000. It also reported that a research project for selecting, conserving, multiplying and distributing these species was sanctioned in March 1994, but the same had not been initiated as of June 1998. In June 1998, even as audit pointed out that the entire fund sanctioned [Rs 17.81 lakhs] had remained idle, BSI sought to reply that “the work was being carried out by traditional methods” and added that “many species of our country would be saved by different institutes of our country engaged in such projects.” And what was the reaction by MoEF to such CAG audit findings on BSI? “The matter was referred to the Ministry in October 1998; their reply was awaited as of December 1998.”

In the year 2002, when CAG of India brought out Manual on Standing Orders (Audit) its chapter 19 dealt

with various facets of Environmental Auditingiii. In the same year, CAG of India designated Regional

Training Institute, Mumbai as a nodal institute and centre for excellence for Environmental Auditing.

In 2002, CAG carried out performance audit of scientific bodies and Zoological Survey of India under

MoEF was also one of those covered. The audit findings revealed “The primary objective of survey and

exploration work of ‘faunal’ resources in the selected areas was behind schedule for periods ranging

from five to 13 years. There was slow progress in conducting status survey of endangered species.

Research results were not published expeditiously resulting in their non-dissemination. Non-

commissioning of Marine Aquarium Research Centre at Digha for about a decade adversely affected

marine research and equipment worth Rs 49.25 lakh remained idle. Ineffective monitoring and

evaluation resulted in delay in achievement of targets fixed by Ministry of Environment and Forests in

1987.”

Cracks in CAG’s Scanners: Gerusoppa Dam, Karnataka Power Corporation Limited (2004)

In its 2004 report, the Comptroller and Auditor General of India (CAG) criticised the Karnataka Power

Corporation Limited (KPCL) for huge cost and time overrun on its 240 MW Gerusoppa Dam power

project over river Sharvathy. The river Sharvathy is an important west flowing river in Karnataka, dotted

with a series of dams built in its valley for power generation. The Gerusoppa Dam, a 56 metre high and

545 metre long dam located near Gerusoppa village is the last in the series of dams built across the

river. This report had failed to integrate environmental concerns with financial accountability concerns.

The project involved the diversion of 700 hectares of forestland for which a clearance was obtained in

March 1987. In June 1988, environmentalists had challenged the clearance in High Court but KPCL

appeared unmoved and went ahead with tendering process. High Court stayed the forest clearance in

an order dated September 1989.

Because of the High Court stay order on the use of forest land, work slowed down. The progress of work

was "interrupted/ retarded" - as the CAG puts it - "due to availability of only 60 hectares of land, non-

availability of designated quarry, agitations by environmentalists and stay order of the court". The status

worsened and works had come to a complete standstill on August 1992, this time due to the withdrawal

of forest clearance by the Central Government. Things remained in this state for a year.

Wildlife Protection in Arunachal Pradesh (2007)

However, three years later in 2007, an audit report on Arunachal Pradesh carried a long paragraph that

looked at performance of Forest and Wildlife department and brought non-compliance with

environmental regulations under scanner. Auditors were now carrying the digital camera and images of

environmentally destructive activities within protected areas had stared to make it to final reports.

Beyond reporting the grim picture of 12 protected areas in Arunachal, the audit report presented a

telling comment not merely on state’s commitment to wildlife, but also on the MoEF when it presented

on page 60, three photographs of adverse impacts on ecology of protected areas due to construction

activities of Kameng Hydro Electric Project by North Eastern Electric Power Corporation (NEEPCO).

In the year 2009, we witnessed lot of media coverage on the issue of dwindling tiger count in national

parks and sanctuaries, but stories based on CAG’s performance audit of MoEF’s flagship programme

were very few.

Mumbai Port Trust (2007): A Tip of the Iceberg

In 2007, CAG of India report on Autonomous Bodies reported a long paragraph on the Environmental

Management at Mumbai Port Trust. Audit findings and nearly contemptuous response by MPT as well as

MPCB and MoEF as well as the Ministry of Surface Transport had made me wonder if the government

was responding to CAG auditors addressing environmental issues with increased sincerity with a stony

silence. During the year 2007, certain amendments were being proposed by Ministry of Environment

and Forests on the coastal zone environmental regulations and some of us environmental researchers

met in New Delhi to discuss the ramifications. When I talked about the audit findings from performance

review of environment management at Mumbai Port Trust, Prof B C Chaudhary from the Wildlife

Institute of India responded saying how he has been trying to convince Tuticorin Port Trust located

along the Gulf of Mannar coast to develop an appropriate EMP, but to no avail!

The report had also shown in details how there was a need to strengthen the environmental clearance

process emanating from EIA notification 1994. On the contrary, MoEF went ahead with its moves to

amend the EIA Notification, which has further weakened the environmental clearance process.

Panipat Thermal Power Pollution (2009): Anonymous Reader highlights air pollution issues at IOCL

refinery, Mathura

An audit report on Haryana had covered Panipat thermal power plant and when my article based on the

audit findings got published, an anonymous reader posted comment. We were a bit concerned as the

comment voiced very serious charges and so far our comments policy had not allowed any anonymous

comments. I went searching through the old CAG audit reports on IOCL at Mathura and did come across

very indicting comments on NEERI in a report.

Similarly, in the year 2005, there was a performance review of thermal power plants of Bihar State

Electricity Board that revealed ineffective air pollution control. In the same year, environmental

safeguards measures in Themral Power Plants in Gujarat and Andhra Pradesh were audited.

Environmental impacts of Hydropower Projects in Uttarakhand (2008-’09)/ Himachal (2012)

One amidst brilliantly planned and executed audit report was this and when I read this, it was

heartening to see that chapter 3 on the environmental impacts did draw upon the knowledge presented

in publications by organisations such as South Asia Network on Dams, Rivers and People.

Similarly, there has also been an audit report that takes a close look at environmental impacts of

hydropower projects in Himachal (2012). Both these reports did raise some pertinent issues around non-

compliance with environmental safeguards parameters built within the policy. However, both auditors

and environmental researchers need to find out how have state government departments and the union

level MoEF has responded to these audit findings. Do we have any indication that certain corrective

measures have been put forth in the wake of these audit reports?

Performance Review of Hydropower Projects in North East and East (No 27 of 2009-’10/ 2012-‘13):

Pay attention to Geological Risks but Go Fast on Environmental Clearances?

As against the Xth Plan revised outlay of Rs 6853 crore for implementation of 13 hydropower projects,

NHPC could utilize only Rs 3998 crore within plan period, whereas NEEPCO could utilize only Rs 692

crore against the outlay of Rs 2509 crore. The reasons that it cites for these shortfalls range from delays

in environment and forest clearances, delays in investment decisions, delays in signing MoUs/ MoAs

with state governments, natural calamities, geological surprises, law and order problems [read: fierce

resistance and protest from local communities].

Not only did planners set a high enough capacity addition target, they also overlooked the audit findings on NHPC reported in 1995 which showed in graphic details how the corporation had failed to pay adequate attention to geological risks. An earlier CAG audit report showed that way back in 1983, during the very first year of commissioning of Loktak Hydropower project, a portion of tunnel collapsed following heavy rains fall on July 25, 1983. An enquiry committee set up to investigate the tunnel collapse had observed, “a) Geologists had specifically brought out the necessity for taking surface protection measures in the slopes where tunnel was on low cover. Possibility of the over crown being washed away from overburden movements over the years was foreseen. This aspect did not appear to have been taken note of by the project designers till the accident. b) The Commissioning of the project in April 1983 was preceded by a Technical Advisory Committee’s meeting to finalise the filling schedule and other connected matters. There was however, no discussion among designers, geologists and the project team on the aspect of design and construction of tunnel lining in the low cover zone and no rock reaches.” PA on Disaster Preparedness Uttarahand (2009-’10): No Questions Asked on Weather Forecasting, Flood Forecasting and Operations of Hydropower Dams during a Flash Flood Disaster At a hindsight, one might have the luxury to raise this issue since in 2013, another national level Performance Audit on Disaster Management (where in Uttarakhand was again a sample state) did raise criticism of state not finding land to situate weather monitoring radars. 2009-’10, report remains hugely concerned about seismic issues in this hill state and even as the union level performance audit on Disaster Preparedness was tabled on April 23, 2013; i.e. some three year later than the previous audit, the state had still not learnt lessons from audit findings. Later that year, April 2013 audit report was taken out of cupboard in newsrooms and was heavily cited as Kedarnath landslide triggered flash floods remained in national news for about a fortnight. This month, we have yet again witnessed failure on the front of disaster preparedness in the form of massive flash floods in J&K. Central Water Commission didn’t take any proactive action to start flood forecasting in J&K, even as the 2013 performance audit finding indicating this shortfall! Not to speak about huge costs of neglecting to pay attention to environmental management of Dal lake that was audited in 2011!!! There is probably a fallacy that plagues many policy makers in India that economic growth is adversely affected if you listen to CAG auditors. The recent floods (and even earlier ones such as Surat 2006) shows us beyond doubts that economic growth comes crashing down, when audit findings are paid scant attention to. Compensatory Afforestation: A Hoax in Madhya Pradesh (2008)

In the year 2008, the CAG carried out a comprehensive performance audit for instances of forestland

diverted for non-forest purposes during 1996-2007. The result: it has highlighted several significant

cases of violations and absence of execution of compensatory afforestation measures in most of the

cases.

Performance Audit of Flood Control in Bihar (2013): When will Auditors learn from Ecologists?

An audit report on Bihar in 2013 contained a performance review of flood control measures in this flood

prone state. On reading this performance review, one gets an idea of how CAG audit teams’ knowledge

base on flood issue in Bihar relied heavily on Ganga Flood Control Commission (set up by Government of

India in April 1972) recommendations, Bihar Flood Management Rules of 2003, Guide on Flood

Management Programmes issued by Govt of India etc. However, the performance audit fails to draw

upon the numerous writings by Dinesh Mishra of Barh Mukti Abhiyan (Freedom from Floods campaigns)

and others. The performance audit also fails to draw upon the recommendations in the civil society fact

finding mission following the massive floods due to Kosi embankment breach at Kusaha in Nepal, Kosi

Deluge: the Worst is Still to Come.

Performance reviews such as this one clearly points out the need for CAG auditors to equip themselves

better in the realm of understanding the ecological aspects around flood, flood plains and flood

management; rather than simply drawing up from the reports in official domain such as Ganga Flood

Control Commission etc.

Forest Governance in West Bengal (2014)

Performance review of state forest department in West Bengal points out an incident wherein despite

the revocation of forest clearance the land continues to be used by the project authority, West Bengal

Power Development Corporation! Perhaps the new powers-that-be should read this performance

review to understand that prudent environment and forest governance does not merely mean

encouraging fast track clearances.

Rampant Diversion, Tardy Afforestation in Himachal Pradesh (2014)

Similarly an audit report tabled in Himachal assembly in February this year narrates the sordid tale of

how compensatory afforestation remains a neglected cause in this hill state.

Ecologising Audit

As we revisited with the help of few instances from some recent and some not so recent audit reports

from the CAG of India, IAAD needs to go an extra mile to integrate the fourth E while carrying out

auditing task. This is best done when the emphasis shift from ‘auditing ecology’ to ‘ecologising audit’

and through this ‘ecologising governance’.

While the big ticket audit reports that have caught the attention of media in recent years have brought

the focus on governance, transparency and accountability issues, I believe that environmental

governance in our country is marred by continued impunity and the culture of non-compliance.

Environment and Forest clearance processes and the scope for affected community to voice their

concerns during the environmental decision making processes have been drafted since 1980s. The sum

total of forest and environmental clearances granted in a year could become a probable theme of a

performance audit to understand how robust is this decision making process is. However, the discourse

both amongst MoEF officials, project proponents and even certain sector specific performance audit

report focus overwhelmingly on issues such as ‘time overruns’ due to “delays” in clearances.

If sector specific performance reviews merely look at documents such as targets of hydropower capacity

addition during 10th five year plan, audit team might be missing a perspective. Instead, if performance

review tries to engage with how many meetings of expert committees debated the projects on merit

before granting clearance, we might start getting audit findings that would shock us into disbelief at the

professionalism. Even recent example of NBWL may show us that the expert committee in question at

times gets just couple of minutes to exercise ‘an application of mind’ on the question of whether the

project is ready for clearance or not!

Before, National Green Tribunal there was National Environmental Appellate Authority and you may

look up an audit report on this tribunal, where aggrieved affected community can go in appeal against

the grant of clearance. After reading the report, if we ask a collective question, shouldn’t performance

and environment audit mandate empower audit team to seek details on how many appeal did it hear,

how many of those appeal it merely rejected to hear on procedural grounds, how many appeal, it heard

on merit and so on and so forth.

What about performance review of National Ganga River Basin Authority? How has this institutional

mechanism functioned so far? Has it checked rampant construction of hydropower projects in the upper

reaches of several tributaries of Ganga in Uttarakhand, many of which are being accorded

environmental and forest/ wildlife clearances without robust impact assessment studies?

While the implementation of environmental safeguards policy and parameters has been identified as

priority for environmental audit, how about looking at some large dams that have aged. I have in mind

large dams such as, Mullaperiyar in Kerala or for example Jaikwadi in Maharashtra or Dumbur dam over

Gumti river in Tripura.

i Somsila and Cheyyeru Irrigation projects in Andhra Pradesh, Durgawati Irrigation project in Bihar, Hasdeo Bango Irrigation project in Chhatisgarh, Tillari Irrigation project in Goa, Surangi Irrigation project in Jharkhand, Kallada Irrigation project in Kerala, Rajghat Irrigation project in Madhya Pradesh, Surya and Waghur Irrigation projects in Maharashtra, Saryu Canal and Hindo Krishi Doab project in Uttar Pradesh and Jangal Mahal Main Canal under Damodar Valley Project in West Bengal were all such projects wherein forest/ environment clearance was not obtained. ii Performance Audit Report on Accelerated Irrigation Benefit Programme (Report No 15 of 2004), CAG of India,

New Delhi, iii See p. 645 in Kumar, Vijay (2008) History of Comptroller and Auditor General of India 1990-2007, CAG of India,

New Delhi.