chapter4-Open Sesame

INFOCUS | INDIA-CHINA | ENVIRONMENT

ENVIRONMENTAL CONSULTANCY IN INDIA

Open Sesame

The scope for environment consultancy is opening up in India with more and more businesses realizing the importance of doing ecologically sound business.

Rajeev Betne

I

ndia’s Environment Protection Act 1986 is one of the most stringent Acts in India’s independent history that gives sweeping powers to the government(s) with regards to clearing business proposals as well as providing a composite framework within which these businesses must operate. The laws under this Act are coming fast, and along with lots of teeth. Processes such as the Corporate Social Responsibility (CSR), the Extended Producers Responsibility (EPR) and value contributions to end-of-life management of their products are progressively becoming the norm.

Thus increasingly, and rightly so, India is getting strict on allowing business here.

Additionally, the global environment and health regime is also moving towards creating a Globally Harmonized Policy and Institutional Framework that countries need to adhere to (this is inclusive of international charters and conventions on such issues).

Hence, not adhering to the global environment norms in the coming future would also mean losing huge market share and thus unviable.

However, the business conditions here are not the same as in the western world and a lot of dots need to be joined in this sphere beginning business and development is approached to resource-use minimization, waste minimization and conducting operations in environmentally sound man|20| India-China Chronicle  April 2012

ner. This provides scope for environment consultancy in a gainful and ethical manner. Situations in the rest of South Asia is not bright either providing supplementary or multiple options for improving business ambience in the region, including space for policy consultancy and advocacy.

The following areas present opportunities for green consultancy in India: A. Environment Clearance B. Environment Compliance C. Environment Consultancy for waste managing business/ certified recyclers D. End of life management (EPR modeling) E. Policy Engagements F. Third party audit/ certification G. Environment education, training and capacity building H. Advisory services for industrial financing houses A. Environment Clearance India’s Environment Ministry had issued the Environmental Impact Assessment Notification in the year 2006, which makes environmental clearance mandatory for development activities for industries listed in its schedule. Most of the sectors fall under this

schedule. The proponents need to prepare them in advance and in full details to get the environment clearance for their business activities. While some of the big players and proponents might not find it difficult to form a team to specifically look into such issues of environment clearance and compliance, many would like to outsource for various reasons, capital and working cost for such a professional team being the primary one. With the ‘environment clearance’ domain in India getting tougher by the day, and bridging gaps between business clients and regulatory enforcement agencies reaching critical levels, there is enormous opportunity for engaging in environment consultancy. In this domain a consultant would need to do the following:  Keep track of the latest environmental regulation and their clauses applicable to business. Through a certain mechanism (it could be a paid one) this information could be made available to prospective clients, especially new proponents. For example, if a small proponent likes to start a plastic recycling operation in region ‘x’, what are his/her environmental obligations to get started with, whom should s/he approach for clearance, what information would be needed for business clearance etc.

This can be sort of knowledge manage-

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INFOCUS | INDIA-CHINA | ENVIRONMENT

ment and extension service;  For the above purpose a simple and user-friendly model for environmental clearance could be built for preparing report/s needed to get business clearance. Such models could be made available on paid basis;  The third level could be consultancy for preparing required stages and documents/ reports, essential for environment clearance and getting the NOCs from the MoEF under various rules;  Designing sustainable longterm environmental plan and plan document for clients based on compliance requirements;  A consultant could also assist representing clients during clearance processes.

Here, the Environment Impact Assessment (EIA) needs a special mention. An environmental impact assessment is an assessment of the possible impacts (positive as well as negative) that a proposed project may have on the environment, the society and the livelihood, especially locals. As a thumb rule EIAs need to be conducted independently and in an open and transparent manner.

The EIAs require multiple skills based team and are considered one of the most prolific consulting areas.

Further, public hearing process for projects is a must; project proponents need assistance in which a consultant could provide help to get the projects going. This is part of the overall clearance process.

Interestingly, environment clearance is also a stage where long-term relations with clients could be built for future gainful engagement.

B. Environment Compliance Industrial facilities generally choose not to dedicate existing staff or hire new staff to manage environmental compliance activities. Reasons include substantial cost associated with having dedicated staff and its associated liabilities. Also, compliance is a specialized job.

Hence, the common trend is to |22| India-China Chronicle  April 2012

outsource compliance services. It is like companies outsourcing services such as financial audits, website development and maintenance, logistics, event management, housekeep etc.

Following are the areas of profitable consultancy one could think of in the Indian context:  Providing advisory services on compliance and regulatory requirements – for example production ambience, product specification and content, labelling and product information, information compliance, waste management, production efficiency etc;  Assisting companies to reduce compliance costs by prioritizing and streamlining compliance requirements;  Preparing compliance reports, environment audit reports for clients;  Develop internal environment reporting and self tracking mechanism for clients;  Environment data management for clients (this can be a huge business in future for consultants);  Remediation consultancy,

specialty and emerging technology services could be thought of as a profitable model;  Referral services based on expertise of different consulting firms in India.

There is huge opportunity with clients in the chemical industry, healthcare sector and waste-generating sector such as tourism (hotels etc), electrical and electronics, big malls, construction etc.

C. Environment Consultancy for waste managers/ certified recyclers The global waste market is estimated to be approximately USD 410 billion annually. This is a conservative estimate of what the worldwide waste is worth as many nations still do not have proper inventory in place. However, even this conservative estimate provides for a ripe opportunity for waste-business in developing countries, including India. Nonetheless, this business due to its very nature of handling potentially (and ecologically as well) unsafe materials (Table1) would require even more rigorous mechanism for clearance and operation and is ultimately an open field for prospective consultants.

D. End of life management (EPR modeling) A lot of firms struggle to find solutions for end of life management of their products. Till date many have not even thought of integrating this in their business model. However, the new environment and health regulation norms progressively talk of Extended Producers Responsibility and other kinds of contribution towards end of life management of consumer products which ultimately enter into the waste stream.

A lot of opportunities lie in designing cost effective and eco-friendly models for such entities (electrical manufacturers such as CFL and batteries, healthcare facilities generating bio-medical waste, hotels generating food waste, electronic manufacturers etc.)

Table1: The OECD Environment Outlook 2030 for Waste Management

[Yellow Light]

[Green Light]

Waste & hazardous chemicals

 Waste management in OECD countries  OECD country emissions of CFCs

E. Policy Engagements A consultancy establishment could think of the following service for ministries and government bodies:  Consultancy on best policies  Consultancy on institutional reforms for better compliance rate  Implementation of existing policies is a bottleneck in India because the infrastructure, financial mechanism and monitoring mechanism are not in place. Here is the opportunity for policy level engagements with the governments to design suitable plan for implementing regulations  Regulators training and capacity building (at central and state level) in improving compliance  Compliance reports preparation on different sectors for ministries/ government agencies.  Research advisory services for frontier areas such as nanotechnology F. Third party audit/ certification This is going to be one of the mandates for industries in the future. The state of Gujarat for example has already initiated this and the industries need to submit third party audit to the Pollution Control Board within prescribed time schedule. Further, in this age of globalization, most firms like to go for international certifications such as ISO certifications. These are very specialized and high-end jobs requiring dedication and specialized skills.

One could develop the required capacity to render third party audit/ certification services.

 Municipal waste generation  Developing country emissions of CFCs

THE GLOBAL WASTE MARKET IS ESTIMATED TO BE APPROXIMATELY USD 410 BILLION ANNUALLY. THIS IS A CONSERVATIVE ESTIMATE OF WHAT THE WORLDWIDE WASTE IS WORTH AS MANY NATIONS STILL DO NOT HAVE PROPER INVENTORY IN PLACE G. Environment education, training and capacity building This is needed along the complete business chain including major stakeholders such as governments, industries, recyclers and even educational bodies. This opportunity could be harnessed by consultancies by designing tailored training manuals and modules including workshops, presentations, talks, technical guidance, visits etc.

H. Advisory services for industrial financing houses In the coming days India would see surge of green financing and the donor/ financial houses would stick to putting money in ventures that are environment compliant. Because, putting money elsewhere would mean both, (a) loss of worth of money financed in case of the proponent getting blacklisted on ecological grounds and / or (b)

[Red Light]  Hazardous waste management and transportation  Waste management in developing countries  Chemicals in the environment and in products

the financial house getting a bad name in the market for financing ecologically irresponsible business proponent.

Here a consultant could assist the financers/donors for ecologically responsible financing.

With the looming global environmental crisis, the world is progressively moving towards enforcing green modules of development. There is no second chosen path. India, aspiring to become a major global power, can’t afford to lag behind and thus has initiated steps to massively improve its business ambience and has taken relevant policy measures. From being a mere concern, ecological spillover of human endeavours (especially commercial ones) has become a critical thematic area of the development paradigm; with the constant lookout for better alternatives.

The situation calls for specialized intervention and hence unwrap a pack full of opportunity for green consultancy.

It is hoped that entrepreneurs would harness the maximum out of the given situation and contribute towards creating an ecologically just and globally competitive business ambience. 

Rajeev Betne is a development professional with over 15 years of experience. He has worked extensively in the field of environment research and advocacy. He heads the Chemicals and Health Programme at Toxics Link, a New Delhi based environment policy group.

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