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Protecting Our Seas
Our large coastline demands of us to protect it in a pristine condition. At the very least, we must limit our environmental interaction to a level where nature can continuously heal itself. In a societal context this goes beyond good intentions and translates to how we govern ourselves. The canvas requires more detailing on framing regulations, protocols for permitting projects, compliance challenges, and many such factors.

EIA (Environment Impact Assessment), in simple English, is a process of making a case for a new project by proving that the project impact is acceptably small on the specific environment. In principle, the current protocol and methodology to approve a project is very sound, asking all the right questions and insisting on substantiated answers to relevant questions. This EIA is typically prepared by the project proponent who has all the final details of the project, the construction details, dredging and reclamation plans, plant capacities, effluent discharges and in short knows the complete contours of the proposed development. In recent years, EIA consultants are vetted and approved by NABET to control the quality of the consultants and thereby the reports.

Some of the important parts of such EIA are discussed below.

Baseline Environmental Status
Detailed marine ecological and environmental studies are carried out to establish the prevalent baseline status of the subject environment. This usually involves primary ecological sampling and analysis by approved laboratories. This is supplemented with extensive secondary research of the earlier studies, besides proximity of sensitive ecosystems. Combine this with the knowledge of project area bathymetry, currents and a host of parameters on the physical, chemical and meteorological characteristics that make up the unique environmental profile of the location.

An important part of the EIA is the study of all environmental interactions of the project with the specific environment. This interaction may be in the form of construction activities, reclamation, dumping the dredged material or effluent discharges. The dispersion pattern of this effluent is studied by numerical modeling of effluent trajectory to establish the project impact zone in various meteorological conditions. Nevertheless, there are established guidelines that must be followed to limit the effluent discharge levels i.e the temperature of the cooling water discharges of a coastal power plant must not exceed 7 deg C above the ambient waters.

Once the environmental interaction is detailed, its impact on this specific ecosystem is predicted over a short term and long term period. While this part is arguably a prediction by the EIA experts of the project proponent, it must stand scrutiny by a diverse team of highly qualified and experienced professionals deputed by the environmental department. It follows that if this impact is anything but insignificant, the project proponent has to show monitoring and mitigation plans, to the satisfaction of the authorities.

Shipping - Accidental Pollution
Pollution from shipping is an interesting sector, since it deals with pollution on your shores by vessel that are owned by foreign entities and not under your administrative control. Due to the nature of vessel ownership, registered in flags of convenience and owned by holding companies registered elsewhere, the ownership often cannot be traced easily. The country’s coastline suffers the consequences of pollution by vessels on ‘innocent passage’ on its coast, whose ownership thus lies elsewhere and no economic benefits accrues to the coastal state from bearing this risk. The large tankers passing by on the west Indian coast pose such huge risk from an accidental pollution without adding a single dollar to our economy. This risk is written unto our destiny by our geography. Perhaps we can compensate ourselves by commercially capitalising from this traffic like Singapore or Dubai has done, but that is another story for another day. Erica, Prestige, Braer or Exxon Valdez are all names of vessels that brought huge catastrophe to various coastlines, on their 'innocent passage'. They all came without warning.

The quality of tonnage and technology in navigation has continuously improved over the years, but 'improved' is a relative word. Traffic has increased multi-fold meanwhile. Major accidents have happened at regular intervals. The consequence score of a tanker breakup on the risk matrix is yet unacceptably high. To be fair, the world's tanker fleet is practically converted to double hull, raising the threshold of when an accident will turn into a polluting incident. Port state control as a weapon to control the quality of tonnage can be exercised in port, but there is little practical control on the quality of tonnage passing few miles off the country's coast. Stopping a passing vessel on the coast to inspect its pollution control equipment is fraught with the danger of becoming an 'international incident' unless there is obvious evidence. To undertake this, a mature system of surveillance is required, with all- weather remote monitoring of pollution, ability to promptly analyse forensic evidence, vessel traffic monitoring system and the state's will to prosecute.

Marine accidental pollution has not found its way into the agenda of disaster management bodies. This is often debated by pollution control board (PCBs) analysing pollution risks from shipping. It will be good to differentiate the pre and post incident roles of these two organisations. PCBs control operational pollution of industries within their jurisdiction, perhaps even scrutinise the on-site and off-site emergency plans. A vessel accidentally polluting our coast does not lend itself to these controls.

The design of the vessel follows the very international Solas convention and operational pollution conforms to Marpol, again a very international convention. Design and condition are inspected by international third party inspection agencies, acceptable to their respective flag states. The coastal state’s power to inspect a vessel in port for its compliance with these conventions is well established and usually done by the coastguard or maritime authorities in many countries. The PCBs usually do not wear these hats.

However, a vessel flying a foreign flag does end up regularly on our shores in potentially polluting situations. While actual oil spill combat is done by specialist agencies and monitored by specialist regulators like coastguard, the resources for restoration of the coastline, the modalities for rehabilitation of communities, can do with some knowledge and competence. It is a fit case for the disaster management authority, which has expertise in post incident scenarios, to step in and shoulder some responsibility. This will be useful for many coastal district administrations, who may face such incidents.

Another beneficial move is setting up Tier III response resource in India. This level of response is for a major pollution incident, where local or national resources are considered insufficient. Currently such equipment, usually bulky, must come from hubs like Singapore or P.Gulf. The logistical challenges in moving such resources in an emergency are too many. The country's port sector and oil and gas sector have grown enough and now have a size to viably support placing such resource inventories in India.

Shipping - Operational Pollution
The tankers coming from the east to load in Persian Gulf wash their tanks, settle these washings during the voyage and get ready to decant their tanks. These vessels need to decant these washings before entering Persian Gulf, which is a special areas as per Marpol annex I. Decanting these washings is a perfectly legitimate activity as per Marpol and this frees up revenue earning space of the tankers. Due to the geography of our country, this decanting happens when these vessels are passing off our coast. If these vessels are exceeding the permissible discharge limits, or walking the thin line between compliance and violation, they are fully confident that prosecution is a remote possibility, given the issues of real time surveillance, collection of forensic evidence and jurisdiction in international waters.

Ballast water discharge is considered the most irreversible form of pollution. It transplants a completely foreign marine eco-system to be planted on the local marine environment. This is a major problem typical to ports where a lot of bulk exports happen and therefore most of the de-ballasting happens. Persian Gulf would see a lot of de-ballasting from loading tankers. The international shipping is grappling with ways to deal with this issue. Unlike fitting an additional GPS on a vessel, which is easier to retrofit, this issue requires fundamental changes in vessel’s ballast system design with little elbow room for retrofitting. It will take years to deal with the problem completely.

Pollution from Offshore Oil and Gas Facilities
This sector poses huge potential risks as noticed from the Gulf of Mexico pollution incident. The challenge is source control, of a source which has far larger crude in store that few VLCCs put together. The positive note is that this sector has its ownership interests within the country and this makes the accountability simpler. It must be acknowledged that this sector is also a well regulated sector. The technological solutions that develop over the years can be implemented faster unlike the shipping industry which must patiently await the meeting of mind of the world’s seafaring nations. Another benefit is the oil properties are known, reporting lines are tested, spill trajectory model is ready barring last minute details of wind, location and quantum of spill. These factors will hasten the response, unlike the case of a VLCC breaking up on the coast where information is not available, be it pour point of the oil or the owners actual co-ordinates. It is interesting we are in an age where media is bringing the pollution incidents to our drawing rooms, traffic is better controlled, information and incident reports are widely distributed and debated, company’s brand value is closely safeguarded, technology is continuously improving and accountability is increasing. All these will serve to offset the risks from the ever increasing trade volumes.