Reflections

NABET
Abbreviations
Sl. No. Abbreviation
Full form
1
2
3
4
ACO
AO
CEO
CII
Accredited Consultant Organisation

Applicant Organization
Chief Executive Officer
Confederation of Indian Industries
CMPDIL
Central Mine Planning and Design India Limited
CPCB
Central Pollution Control Board
CSIR, NIIST
EAC
Council of Scientific and Industrial Research, National Institute of

Interdisciplinary Science and Technology
Expert Appraisal Committee
ECA
Environment Consultant Association
10
EC
EIA Coordinator
11
EIA
Environment Impact Assessment
12
FA
Functional Area
13
FAA
Functional Area Associate
14
FAE
Functional Area Expert
15
FAQ
Frequently asked questions
16
IA
Initial Accreditation
17
ISM
Indian School of Mines
18
JNU
Jawaharlal Nehru University
19
L&T
Larsen & Tubro
20
MoEF & CC
Ministry of Environment, Forest and Climate Change
21
NAAQ
National Ambient Air Quality
22
NABET
National Accreditation Board for Education and Training
23
NEERI
National Environment Engineering Research Institute
24
NGO
Non-Government Organization
25
NOC
No Objection Certificate
26
OM
Office Memorandum
27
QCI
Quality Council of India
28
RA
Re-accreditation
29
SA
Surveillance Assessment
30
SEAC
State Environment Appraisal Committee
31
TM
Team Member
32
TOR
Terms of Reference
33
WII
Wildlife Institute of India
Scheme for Accreditation of EIA Consultant Organizations Reflections.
NABET
Scheme for Accreditation of EIA Consultant Organizations

Reflections .
1. Background
The requirement of Environment Impact Assessment (EIA) report for environmental

clearance was brought in for the first time in India through the EIA Notification, 1994. The
Environmental Clearance process was further re-engineered through the EIA Notification,
2006.
EIA is a multi-disciplinary activity requiring inputs from a team of experts having

exposure and knowledge about the proposed project and in the various specialized
fields namely air pollution, water pollution, solid waste, ecology & environment, social
issues, land use, risk assessment, geology, soil, noise and vibration etc., backed by reliable
laboratory arrangement to capture the baseline environment status. It was a new field of
specialization in the country and not many competent agencies were available after the
1st Notification to take up such studies. In fact many consultants and even individuals
were preparing the EIA reports without having the requisite expertise, competence and
resources.
To address this shortfall, then Ministry of Environment & Forests (MoEF) was looking for a
methodology to identify and register consultants in the country capable of preparing such
multi-disciplinary reports. Realizing the need of improvement in this sector, the National
Accreditation Board for Education & Training (NABET), a constituent Board of Quality
Council of India (QCI), the National Accreditation Body, jointly set up by the Govt and
Industry, initiated work in 2005 to develop a Scheme for Accreditation of EIA Consultant
Organizations. After extensive consultation with stakeholders across the country a draft
Scheme was developed which specified the requirements for EIA Consultant Organizations
in terms of competence of human resource, laboratory arrangements, system based
approach and commitment to prepare quality EIAs.
The Scheme was launched on voluntary basis in Aug 2007 after it was thoroughly vetted
by MoEF and uploaded on QCI and MoEF websites. About 20 EIA Consultant Organizations
in the country had approached QCI/NABET for accreditation. Of these, 8 were accredited
and the balance were under process. Subsequently, looking at the merit of the Scheme,
MoEF in 2009 revisited the same and desired some fine tuning and incorporation of the
learnings from the voluntary Scheme. After these were addressed by QCI/NABET, the
Scheme was reviewed by MoEF in a meeting held with QCI/NABET on Sept 18, 2009.
MoEF then made the Scheme mandatory on Dec 2, 2009 through an Office Memorandum
F.No.J -2004/77/11013-IA ll (l) from Dr. P. B. Rastogi, Director, which required that no EIA/
EMP reports prepared by such consultants who are not registered with NABET/QCI shall
be considered by the Ministry after 30th June 2010. Since then, 380 applications have
NABET
been received, of which 170 have been accredited. List of accredited consultants with the
Sectors accredited for is posted on the QCI/NABET website and is updated on the 5th day
of every month.

Eminent people have been involved during the process of development and
implementation of the Scheme. Some of them are

Dr. Prodipto Ghosh, Ex Secretary, MoEF & CC
Ms. Meena Gupta, Ex Secretary, MoEF & CC
Sh. J. M. Mauskar, Ex Sp Secretary, MoEF & CC
Prof. C. K.Varshney, Prof Emeritus JNU and eminent Ecologist
Prof. S. P. Banerjee, Ex Director, ISM and an eminent Mining Engineer
Dr. Sukumar Devotta, Ex Director, NEERI
Dr. S. R. Wate, Director NEERI
Sh. Chandra Bhushan, Dy Director General, Centre for Science & Environment
Sh. Paritosh C Tyagi, Ex-Chairman CPCB
Sh. K. P. Nyati, Ex Head, EMD, CII
Prof. A. K. Maitra, Ex Director, School of Planning & Architecture
Sh. N. S. Tiwana, Ex-Chairman, CPCB
Dr. V. B. Mathur, Director, Wildlife Institute of India, Dehradun
Prof. B. B. Dhar, Ex Prof & Head, Mining, Banaras Hindu University
Dr. B. Sengupta, Ex Member Secretary, CPCB
Dr. G. V. Subrahmanyam, Advisor, MoEF & CC
Dr. Asha Rajvanshi, Scientist G and Head-WII, Dehradun
Dr. Nalini Bhat, Ex Advisor, MoEF & CC
Dr. A. N. Jha, Ex. C.E.O. & Sr. President, Essar Group
QCI/NABET is guided by a Technical Committee headed by Prof. S. P. Banerjee in developing

and updating the Scheme and by an Accreditation Committee chaired by Sh. Paritosh C Tyagi in
implementation of the same.
2.
Accreditation as per Scheme and achievements so far
MoEF OM date Dec. 2, 2009 focused on enhancement of quality of EIA reports through
improvements in requisite expertise, supporting facilities, laboratories for testing with
qualified staff. QCI/ NABET Scheme for Accreditation of EIA Consultant Organizations is
based on detailed assessment of following aspects:
i.
Human Resource (experts to be involved in preparation of EIAs meeting the

requirements of qualification, experience and competence)
NABET
ii.
Requirements of field investigation and laboratory arrangement (in-house or

external) to ensure integrity of baseline environmental, ecological and social data
iii.
System based approach towards EIA through Quality Management System to ensure
capacity building of the consultant organizations over time
iv.
Completeness/Quality of EIA Reports (addressing significant aspects of EIA)
v.
Organizational Commitment (facilities, resources, improvement etc.)
Accreditation is given based on a detailed process of assessment. The Scheme mentions the
parameters on which assessments are done and the complete findings of the assessment are
also shared with the applicant organization ensuring transparency in the process of assessment
and accreditation. The accreditation process follows the well accepted international approach
of an Initial Assessment (IA) followed by Surveillance Assessment (SA) and re-assessment at the
end of the accreditation period for granting Re-accreditation (RA). Accreditation period is for 3
years with a Surveillance assessment after 18 months. Achieving continual improvement is the
corner stone of the Scheme.
Potenal
Inial Accreditaon
18 months
Performance & Compliance
Surveillance Assessment
18 months
Improvement
Reaccreditaon
The weightages in the assessment process are such that these encourage the Consultant
Organizations to work towards improving the Quality of EIAs prepared by them. Weightage for
Quality of EIA increases from 10% in IA to 20% in SA and 30% in RA.
Sl.
Aspects
No.
1 Quality & performance of
personnel EIA Coordinators
FAEs
2 Quality Management System
3 Field investigations and
laboratory systems to ensure
data integrity
Marks Allotted
IA
SA
RA
20
15
10
20
10
10
15
25
15
25
15
20
Remarks
IA stage Potential of the AO is

the focus
NABET
4
5
6
Quality of EIAs
Organizational Evaluation/
commitment
Compliance to condition of
accreditation/improvements
achieved
Total
10
10
20
10
30
5
10
100
100
100
SA stage Compliance and

performance of the ACO are the
focus
RA stage Performance and
improvement of the ACO are
the focus
Since inception, the Scheme has been able to achieve following:

i.
For the first time in the country a list of capability verified EIA Consultant Organizations
is available in public domain with sectors of expertise, category, contact details etc.
ii.
The fly by night operators have been weeded out from the scene.
iii.
The crucial concept of team work by the EIA Coordinator and Functional Area
Experts for preparation of quality EIA was recognized.
iv.
The concept of system based approach for EIA preparation, instead of being person
specific, brought in the country. This will ultimately strengthen the EIA preparation
process in the country.
v.
Recognition given to human resource at all levels -
vi.
a.
Functional Area Associate
0-5 Years experience
b.
Functional Area Expert Cat B
>3 years experience
c.
Functional Area Experts Cat A
>5 years experience
d.
EIA Coordinator Cat. B
>5 years experience
e.
EIA Coordinator Cat. A
> 7 years experience
f.
Team Member
Provision to enter in new sector/area
g.
Mentor
Provision for experts with vast exp.
Self-realization by professionals of being an Expert of particular sectors/ functional

areas and a career progress path.
3.
Strengthening the assessment process -
Unbiased, objective and uniformity in assessment are the

cornerstones of a robust accreditation mechanism. QCI/NABET
leaves no efforts in moving towards these objectives. Qualification
and experience requirements of the assessors and their selection
process have been clearly defined. These have been posted
NABET
on the QCI/NABET website. Background and integrity aspects are ensured through
reliable references. A detailed Assessors Manual has been developed. The assessors are
given intensive training both on the technical and soft skill aspects of assessment. Four
workshops of 3 days were conducted for training of the assessors which were attended by
members of the Technical and the Accreditation committees where external experts were
also invited to deliberate on important aspects of EIAs

Hyderabad Jul 15-17, 2010
Dehradun Apr 7-9, 2011
Chandigarh Dec 1-3, 2011
AgraJan 3-5, 2014
Hyderabad 2010
Dehradun 2011
Chandigarh 2011
Agra 2014
Apart from the above, 6 One Day Training workshops have also been organized from time to
time for the Assessors. There is a panel of 21 assessors who are highly experienced and have
varied background such as academics, industry, regulator, consultancy, research etc. QCI/
NABET strictly ensures that there is no conflict of interest with the assessors or the members
of the Technical and the Accreditation committees and none of them is involved in any way in
preparation of EIA reports.
NABET
QCI Office 2013
Dehradun 2011
4.
Quality of EIA report

4.1 Issues involved
Improvement in quality of EIA reports was the main objective of MoEF & CC while
introducing the provision of accreditation of environmental consultant organizations.
In the process of implementation of the Scheme and discussions with various
stakeholders over the last 5 years, it emerges that there are 3 major components
which need to be addressed carefully to have perceptible improvement in quality of
EIA reports:
EIA
Project Proponent
ordering for EIA
Capability of
EIA Consultants
Appraisal of EIAs reports
Fig 1: Three essential enabling factors for quality EIA

a.
Capability of EIA Consultants

i.
The Accreditation Scheme aims to address this
ii.
The detailed process of assessment and accreditation ensures the capability

of a consultant organization to produce quality EIA reports. However, whether
the consultant still opts to prepare a quality EIA is its choice.
iii.
There does not seem to be enough incentive to prepare quality EIAs, since
most of the EIAs prepared do get approved ultimately.
NABET
b.
c.
Project Proponent ordering EIA

i.
As per the present system, the Project Proponent orders for preparation of an
EIA report through an Environmental Consultant. At times, the Consultants
feel constrained to come out with certain information if the Project Proponent
feels that the same is not helpful to him. This does adversely affect the quality
of EIA.
ii.
In many cases, an EIA report is prepared for the location already selected by
Project Proponent.
Appraisal of EIAs by Regulator

i.
It is well appreciated that the approach of EAC/ SEAC is to bring the EIAs to
an acceptable level by plugging the shortcomings so that the environmental
clearance mechanism does not hinder developmental process. However,
during the assessment process NABET Assessors have come across many EIAs
which have been cleared in one go at EAC/SEAC level but these could only
score quite low marks in NABETs assessment process.
ii.
It is felt that the current appraisal process needs to be further professionalized

and the members be given adequate time for appraisal and consideration in
the committees.
iii.
Since an EIA report not meeting all quality standards does get ultimately
approved, there appears to be not much incentive for an EIA consultant
organization to prepare a good quality EIA which demands more effort and
cost.
4.2. Efforts of QCI/NABET for improving quality of EIA reports
a.
In-depth scrutiny of EIAs
QCI/NABET makes all efforts to make sure that the message is given strongly
to the accredited consultants that quality of EIAs prepared by them needs to
continually improve if they want to retain their accredited status. Minimum
two EIA reports prepared by an accredited consultant organization undergo
in-depth scrutiny by NABET Assessors during the assessment process. There is
a 9 point criteria for assessing the quality of EIAs by QCI/NABET as follows:
i.
Site & Project Description with photographs, layout maps, process

flow diagrams, environmentally sensitive receptors like water bodies,
wetlands, estuaries, human habitations, archaeological/historic
monuments, schools, hospitals, industries, croplands, forests, wild life
sanctuaries, national parks, biosphere reserves and the like.
ii.
Discussion on alternate sites, technology/processes.
iii.
Integrity of baseline data - methodology for collection of Scheme for Accreditation of EIA Consultant Organizations Reflections.
NABET
iv.
Primary base line data for physical environment (sampling

locations, preservation of samples, analysis)
Primary baseline data for ecology & socio-economy survey

methodology,
questionnaires
etc
Secondary data (reference, relevance, authenticity, period, ground

validation).
Interpretation of physical environment data, identification of impacts

and quantification, where applicable and mitigation measures.
v. Interpretation of ecological and social baseline conditions and

assessment of possible impact and mitigation measures.
vi.
Risks assessment and consequence analysis
vii. EMP with budget/timeframe and EMP monitoring Plan

viii. Signed statement by experts involved in EIA preparation.
ix.

Compliance to TOR and Public Hearing findings
Detailed feedback is given to the ACOs on the scrutiny of the EIA reports, for
them to appreciate the areas of improvement and work on them. These are
then checked in the next assessment. Out of 20 cases of large, medium and
small EIA Consultant Organizations analyzed, the quality of EIAs prepared
by them showed improvement for 17 from Surveillance Assessment
(18 months after accreditation) to Re-accreditation (36 months after
accreditation)-

Quality of EIA : %age Marks Scored
Fig 2: Quality of EIAs as assessed in Surveillance Assessment and Re-accreditation
NABET
Percentage
Quality of EIA : Change from SA to RA
Fig 3: Percentage change in Quality of EIAs from Surveillance Assessment to

Re-accreditation
b.
Commitment of accredited consultants to prepare quality EIAs
QCI/NABETs accreditation process also tries to address the commitment

of an accredited consultant organization to produce quality EIAs through
assessment of whether the consultant

Has programme of grooming and training its experts
Imbibes the learnings from EAC/SEAC meetings and public hearings
Brings in improvements in enabling factors like more qualified and

experienced human resource, investment in laboratory, facilities etc
after accreditation
4.3. Other challenges:

a.
It has been observed that the EIA profession is less paying compared to some
others. Thus, availability of quality professionals is hard to come by.
b. Study of EIA is generally not adequately addressed in curriculum of

many Universities even for Masters Courses of Environmental Science or
Environmental Engineering. To address this requirement and for capacity
building of consultant organizations, QCI/NABET has developed short term
Training Modules for EIA Coordinators and Functional Areas (Air Pollution,
Water Pollution, Ecology Biodiversity etc.). These training modules along with
Scheme for Accreditation of Training Provider Institutes/ Organizations are
also posted on QCI/NABET website.

10
Thus, accreditation of EIA Consultant Organizations needs to be supported with

suitable actions on above mentioned aspects (ordering process for EIA studies,
NABET
strengthening appraisal process and capacity building of consultants) to get the

desired result of improved quality of EIAs on a sustained basis.
Delhi Workshop Sep. 2011
Ahmedabad Workshop Jan. 2013
Delhi Workshop Jun. 2014
ACO Meet, QCI OfficeJan. 2015
5.
Feedback of Experts and Stakeholders
As mentioned above, the Scheme was developed based on extensive discussions with
the stakeholders including industry, consultant organizations, academics and civil society.
As there is no parallel Scheme to take cue from, continuous feedback of the stakeholders
is essential for evolving the Scheme to its logical conclusion. QCI/NABET has been
continually in touch with the stakeholders through 27 workshops and seminars held.
The 1st version of the Scheme came up in Jan. 2010, with the process to be followed for
Initial Accreditation. The Surveillance assessment process was incorporated in the 2nd
version of the Scheme which came up in Aug. 2011.
To ensure transparency and involvement of stakeholders the 3rd version of Scheme (Rev.
10) incorporating the Re-accreditation process is being finalized following the process as
under

The draft was posted on the QCI/NABET website for a month for stakeholders
comments
Stakeholders comments were compiled
The issues faced during the accreditation committee meetings while considering
the assessment findings were also compiled
11
NABET
All issues are discussed in a combined meeting of the Technical and the Accreditation
committees to finalize 3rd Version of the Scheme incorporating all three types of
assessments viz Initial Assessment, Surveillance Assessment and Re-accreditation
Assessment.
1st Version (Rev. 06)

NABET

2nd Version (Rev. 09)
3rd Version (Rev. 10)
Scheme for Accreditation of
EIA Consultant Organizations
NATIONAL ACCREDITATION BOARD FOR

EDUCATION AND TRAINING
National Accreditation Board For Education and Training
QUALITY COUNCIL OF INDIA
Jan 2010
12
QUALITY COUNCIL OF INDIA
Aug 2011
Scheduled-May2015
6.
Views shared by Accredited Consultant Organizations -
Some consultants who have benefitted from the Scheme as well as those with suggestions
shared their experience with us:
i.
MECON, Ranchi We would like put on record that we have been immensely
benefited by the QCI/NABET EIA scheme. The scheme ensures quality work,
encourages serious players like us and filters out casual business endeavours. With
implementation of the NABET scheme our country has graduated to a new level
Environmental Quality work
ii.
Kadam Environmental Consultants, Vadodra Increase in business due to exit of

non-accredited consultant organization from EIA business, receiving new business
in functional areas like EB, SE, HG and Geo, enforcement of Quality Management
System for areas outside EIA, increase in credibility of organization in environmental
consultancy in general, professional growth of individual in-House experts due to
accreditation
iii.
CSIR, NIIST, Trivandrum NABET/MOEF initiative of accreditation is highly

appreciated. This will help in bringing out quality impact assessment, prediction and
management plans
iv.
Indomer Coastal Hydraulics, Chennai QCI is really doing a commendable service

by evolving suitable mechanism to strengthen the Quality Control System and to
a great extent has achieved the intended objective with which it was created in
1996. The project proponents are now well aware of whom to select among the
consultants accredited by QCI in the desired sector of development
v.
Visontek Consultancy, Bhubaneshwar - The scheme for accreditation of EIA by

QCI-NABET has been quite useful in effective implementation of various activities
NABET
undertaken by us in the past. Implementation of some of the features of the scheme

in Non-EIA activities, has also been helping us in streamlining the functioning of the
organization, for enhancement of quantity and quality of output.
vi.
CMPDIL, Ranchi Rev 10 is an improvement & rationalization of functional areas a

good initiative
vii. TMS Consultancy - Should be more transparent in empanelment of Assessors

viii. Ultratech, Thane NABET assessors, AC/TC members should have EIA background.
7.
ix.
L&T Infrastructure Engg. Hyd Rationalization of FAEs do not mean much, if a

consultant has more Sectors,
x.
Asian Consulting, Delhi Weightage for Quality of EIAs to be increased to %50-40
xi.
KKB Enviro, Hyd Make EB & SE to be covered by empanelled experts for small
mines up to 5 Ha, for 25 Ha for minor minerals
xii.
Vardan EnviroNet, Gurgaon Monitoring and enforcement of EMP of Mining Plans

should be considered as EIA related experience
Some interesting facts about the Scheme Private
Public Sector
Public
Sector
22
Cat A
Cat B
Cat B
19
Private
148
Cat A
151
Fig 4: Accredited EIA Consultant Organizations (ACOs) 170-
Fig 5: ACOS-Number of Sectors accredited for

13
NABET
55
Townships and Area Development projects

Building and Large Construcon
CMSWMF
CETPS
Highways , Railways
Ports, Harbours
TSDFs
Industrial Estates
Oil and Gas transportaon pipeline
Dislleries
Synthec organic Chemicals
Petro chemical complex
Cement
Metallurgical Industry
Thermal Power Plant
River valley
Mining
18
40
17
26
29
47
36
No of Consultants
49
45
55
44
0
20
94
27
40
71
91
60
80
100
Fig. 6: ACOs for some of the major sectors
60
50
56
50
42
40
30
22
20
10
0
N
Fig 7: Geographical distribution of ACO

North J&K, Himachal Pradesh, Punjab, Haryana, Delhi, Uttar Pradesh and Uttarakhand.
South Kerala, Tamil Nadu,Karnataka and Andhra Pradesh (including Telengana)
West Goa, Maharashtra, Gujarat, Rajasthan and Madhya Pradesh
East Bihar, Jharkhand, Chhattisgarh ,Odisha, West Bengal and North East states
14
NABET
Fig 8: State wise distribution of ACOs

8.
Impediments to the Scheme
Some disgruntled consultant organizations who could not qualify for accreditation after
detailed assessment process, filed cases against MoEF & CC/QCI on the applicability of
Scheme through an Office Memorandum instead of Notification and obtained stay from
various High Courts. Of the 40 organizations who have filed cases, 19 were not approved by
QCI/NABET and 12 did not even apply for accreditation. One Consultant Organization from
Jaipur which was found not meeting the minimum requirements of the Scheme twice
and also made an unsuccessful attempt to bribe NABET Assessors, obtained a general
stay on QCI/NABET Scheme from Jaipur High Court. On being apprised of the background
during the hearing on July 15, 2014 the Honble court passed strong strictures against
the applicant and vacated the general stay on the QCI/NABET Scheme. These consultants
also formed an association (Environmental Consultant Association-ECA) and prepared a
document making various unsupported allegations against the Scheme. Background of
the office bearers of the ECA is given below:
15
NABET
a.
b.
c.
16
President, ECA

His organization could not be approved as it did not meet Schemes requirement
of covering minimum 3 functional areas out of 12 (the minimum requirement
for the Scheme) vide minutes of Accreditation Committee meeting dated Mar
15, 2011.
Requested for review of the decision. This was duly considered. The organization
could not produce any additional evidence than those assessed by NABET
Assessors during document review and the office assessment as required by
the Scheme. Hence, the Review Committee did not find any reason to modify
the decision, vide minutes of AC meeting dated Sep. 9, 2011.
Vice President, ECA

Submitted misleading and false documents in application w.r.t qualification,

experience, MoU and appointment letters of proposed candidates. The
organization was not approved by the Accreditation Committee for submission
of false and mis-leading documents as per the provisions of the Scheme vide
minutes of AC meeting dated Aug. 9, 2011.
Requested for review of the decision, which was duly considered by the AC
in its meeting dated Jan. 13, 2012. To be doubly sure the AC asked for further
detailed feedback from the Assessors. After reviewing the complete case,
documents and feedback of Assessors again, the AC found no reason to
change its decision.
Filed case in Delhi High Court against non-approval of his application by NABET.
During hearing the counsel of NABET brought out issues related to submission
of misleading and false documents amongst others. The organization then
preferred to opt out and the case was dismissed as withdrawn on Aug. ,30
2012
Despite many reminders, has not paid an amount of Rs. 0.85 lakh pending
towards assessments carried out by NABET.
Secretary, ECA

His organization could not be approved as it did not meet Schemes

requirement of having minimum 3 in-house employees covering minimum 3
functional areas vide Accreditation Committee meeting dated Jan. 10, 2012.
Filed case in Delhi High Court against non-approval of his application by

NABET. As per Delhi High Court decision dated Nov. 8, 2013, the organization
was given another opportunity to fulfill the shortfalls. However, even after 4
reminders from NABET, no information was submitted till date.
Despite many reminders, has not paid an amount of Rs. 1.34 lakh pending
towards assessment process
NABET
As mentioned above, the document prepared by the association contained several false
allegations. Detailed refusal of the document was submitted to MoEF & CC by NABET in
Jul. 17 and Dec. 30, 2014. Some of the major aspects mentioned in the document vis a vis
actual status is given below:
S. No
Issues Raised
1
NABET Scheme is biased,
unscientific, illogical, and
illegal and brought in a
short span of time. No
feedback from grassroots
level in developing the
S c h eme.
QCI/NABETs Response
Scheme has evolved over a period of 5 years. It was
initiated in 2005 with intensive interactions with
experts in the field including academics, consultants,
regulator, civil society etc and launched as a Voluntary
scheme in 2007. On being convinced of the merit of the
scheme, MoEF & CC made it mandatory in Dec 2009.
As many as 27 workshops were organised till Jun 2014
across the country for feedback from stakeholders.
For considering the feedback and appropriate
incorporation in the Scheme, technical committee of
very eminent professionals was formed which included
two representatives from Consultant Organizations.
Thus, allegations made are denied as these are not

backed up by facts and figures
Scheme developed to QCI/NABET is an autonomous not-for-profit organisation
make money for NABET under Department of Industrial Policy & Promotion,
& employment to retired Ministry of Commerce & Industry, Govt of India. It does
p e o p l e.
not get financial assistance from any quarters for the
accreditation services provided by it. As desired by MoEF
& CC, the fee structure for this scheme has been kept at
the lowest level to meet the expenses of operating and
keeping the scheme relevant by updating as required
from time to time.
This is a flagship Scheme of QCI. When it was started
no parallel scheme existed anywhere in the world. For
developing and operating Schemes, QCI depends on
wisdom and experience of experts who do not have
a conflict of interest with any party. These experts are
given remuneration as per QCI norms which are quite
nominal by Industry standards and cannot be termed as
major source of revenue for them.
17
NABET
18
Scheme
gives
more
emphasis on In House
people
rather
than
outsourcing to academically
qualified & experienced
people.
It is a total mis-representation of facts.

On the contrary, the scheme specifies that an
organisation need to have only 3 full time employees as
EIA Coordinator (EC) and Functional Area Experts (FAEs),
balance as required, could be empanelled from amongst
qualified people having experience in their chosen area
of expertise.
This is not borne out by facts. The experience
requirements for being an EAC/SEAC member is at
least 15 years of relevant experience in the field as per
Appendix VI of the EIA Notification dated Sep 14, 2006
from MoEF.
Scheme prescribes 7 years

experience of EC while
MoEF Notification specifies
4 years experience for EAC
members. Thereby, more
experience persons are The role of EC is such that it calls for maturity and
judged by less experience leadership along with the knowledge and experience
persons.
of the technical areas. After extensive discussions with
the experts in the field this requirement of 7 years was
arrived at. In fact, in the voluntary scheme in 2007, the
experience requirement for ECs was 15 years, which was
revised to 7 years in Jan. 2010 since it was becoming
difficult to get people with such long experience. Also,
in May 2013 the experience requirement of ECs have
been revised to 5 years for Category B projects.
How two (2) NABET This is a challenge. NABET has been trying its best to
Assessors can assess for address the issue.
all sectors and functional NABET assessors are highly experienced professionals
areas?
with exposure to various industries and understanding
of different functional areas. They are given periodic

training in the skill of assessment as well as on the
subject matter. Moreover, NABET takes care in selecting
the two assessors for the office assessment depending
on their background to suit the scope of accreditation
requested by the applicant.
Monopoly of QCI/NABET in QCI was created 1997 as a national accreditation body
accreditation.
jointly by the Government and the apex industry
associations under a cabinet note to provide accreditation
services in various sectors in the country. Over the
years QCI has developed expertise for accreditation in
various fields including health care, laboratory, schools,
management systems, environment, skill training etc.
NABET
QCI provides a time tested and credible accreditation

mechanism through 3rd party assessment process.
Apart from MoEF & CC, QCI is involved in providing
accreditation services for projects of various other
Ministries like Ministry of Small & Medium Enterprises,
Director General of Employment & Training of Ministry
of Labour & Employment, Ministry of Human Resource
Development, Ministry of Health and Welfare, Ministry
of Food Processing Industry, Department of Ayush and
Ministry of New & Renewable Energy
No scope for fresher to serve

under the Scheme.
Lack
of
transparency
in
assessment.
Only
organisations known to
NABET
are
favoured.
Ministry of Commerce is the nodal ministry for QCI.

Chairman of QCI is nominated by Prime Minister Office.
QCI is a not-profit organization registered under the
Societies Registration Act. World over, generally, there
is a single NSB (National Standards body BIS in India)
and a single NAB (National Accreditation Body QCI
in India). All developed countries have structured their
Quality Infrastructure in similar fashion. NAB, normally
is a public supported body, as in case of QCI which is
under DIPP.
On the contrary, the scheme provides opportunity to
the fresher with the requisite qualification in the form
of Associate FAAs who can work under guidance of an
experienced and approved FAE.
The criteria on which assessments are done are
mentioned in the Scheme itself. Results of assessment
are posted on QCI website which also mentions the areas
where an organization needs to improve. Moreover, the
entire assessment result including the marks scored
by the applicant in various aspects of assessment are
shared with the applicant. Thus, in fact, the assessment
process is highly transparent. No instance of favouring
by NABET of any particular organisation has been cited
hence no comments can be offered.
Till date, 170 consultant organizations have been
accredited, hence, the allegation that only favoured
applicants are approved is not at all justified. Since this
Scheme was created for MoEF & CC and NABET was
19
NABET
10
20
Corruption
NABET
Secretariat
/Assessors
are involved in various
corruption in assessment
process.
earlier not working in the environment domain, there is

no question of NABET knowing organisations working
in EIA field.
Completely denied. Disgruntled and rejected elements
use corruption allegation as a recourse to provide
sensational statements. No specific example has been
cited neither any documentary evidence submitted.
Only generic comments made. Hence, no comments
can be offered.
On the contrary, there has been cases of attempting to

bribe NABETs Assessors as mentioned above.
Limiting No of EIAs for ECs There is no limitation to the number of EIAs that an EC
to 15 is illogical.
can take up simultaneously. The EC being the central
figure in the EIA, his complete involvement is key to a
quality EIA. Accordingly, the Scheme envisages a very
involved role of the EC requiring adequate time to be
given for each EIA project. All the Scheme requires is that
if an EC carries out more than 15 EIAs of Category B in a
year, he should maintain a record of time spent for each
project so that during assessment his involvement in the
project can be judged. This has categorically helped in
identifying the cut & paste work which were prevalent
prior to such standards of quality prescribed and
audited carefully to provide credence to an EIA report.
Such consultants are given strong stricture by NABET
and assessed more closely in the next assessment.
9.
High Level Committee
Unfortunately, the report (Nov, 2014) of the High Level Committee to review various
Environmental Acts appears to be based on mis-information about actual situation. QCI/
NABET was not given an opportunity in spite of having requested for the same. The report
mentions that The present system of borrowing the list from Quality Council of India and
National Accreditation Board for Education and Training (NABET) is marred with multiple
controversies. Even exceptionally high quality research and education institutions often
do not qualify to be enlisted as consultants in the current process.
The only major controversy/issue with the Scheme till date pertains to stays obtained by
non-accredited consultants on administrative grounds viz making the Scheme mandatory
through an Office Memorandum (OM). While issuing the stays the Honble High Courts
have noted that action should have been taken through a Notification in place of an
NABET
OM. In fact, this is proving to be a disincentive for accredited consultants. As regards

second observation of the High Level Committee, all the major consultants and many
reputed Research Institutes including NEERI are accredited under the Scheme. Therefore,
a sweeping statement is made casually without valid background check, which does more
harm than good to the system.
10. Legal status

The MoEF & CC has filed a transfer petition to bring the 40 cases pending at various High
Courts to the Honble Supreme Court. This was registered in Nov. 2014 and first hearing
in the matter was held on Jan. 16, 2015. All respondents have been served notices as
per direction of the Honble Court for their response. While the case at Honble Supreme
Court takes its own course, the Asstt Solicitor General of Government attending the case
at the Supreme Court on behalf of the MoEF & CC had a very clear view that issuance of
Notification is the best approach to resolve all such matters in one go.
As a result of these stays by High Courts, some consultants who were actually not found
competent through a detailed assessment process, are carrying out EIAs for various
sectors thereby potentially endangering the projects as well as the environment and
people around. Additionally, some other consultant organizations, who have not even
applied for accreditation, are using this route to by-pass the entire process and doing
work at inexplicably low costs. This is a big disincentive for 170 consultant organizations
accredited across the country till date, who are willing to follow the process directed by
the Government and are making continuous efforts and investments to produce proper
EIAs. Seeing the fluid situation, some of these consultants are delaying submission of
various information to QCI on compliance to the accreditation requirements waiting for
clarity on the issue. This is making it difficult for QCI to operate the Scheme. Due to these
developments, the basic objective of MoEF & CC to have capable consultant organizations
to prepare proper EIAs thereby hastening the environmental clearance process, gets
defeated.
11. Cost of EIA

The cost of developing an EIA report cannot be defined in general or be given as a standard
figure. It depends on many factors like sector, size, site, surrounding and extent of baseline
data required to be collected. Broadly, cost of an EIA comprises two major heads:
i.
Baseline study for physical, social and ecological environment
ii.
Developing the report including interpretation of data, identification of impacts and

suggesting mitigations measures
In case a consultant organization is required to generate 3 month (1 season) physical

environment data based on NAAQ requirements for air and other relevant parameters for
water, soil, noise etc. in line with MoEF Notification dated July 21, 2008 its cost would come
to around Rs. 14-15 lakhs. Added to this the other costs (expertise inputs, travel, resources)
21
NABET
should be the proper cost of an EIA. However to the contrary, it has been observed that
EIAs are being prepared at the cost of Rs. 4-5 lakhs along with 3 months data. The quality
of EIA reports prepared at such inexplicably low cost can be imagined. In addition, many
Government agencies still follow the L1 approach which may not necessarily ensure
quality of the report.

An examination of TORs for various types of projects has shown that the extent of baseline
data required to be generated including the period are not always clearly defined. In case
the parameters to be measures and the period are properly defined in the TORs the cost
of EIAs being produced in our country can be rationalized to a considerable extent, suiting
the projects requirements.
12. Way Forward

QCI/ NABET is open to new ideas which may help improving the accreditation mechanism
further. However, to expect that accreditation of EIA Consultant Organizations alone would
bring improvement in the quality of EIA may not be fully justified. Following enabling
factors also need to be considered
a.
Issuance of Notification to resolve the legal cases.
b.
To deliberate on the issue of Project Proponents ordering for EIA and find a suitable
solution to the same
c.
To further professionalize the EIA appraisal process
d.
To form a Steering Committee to deliberate various issues and guide in making

the accreditation process including grievance redressal mechanism more inclusive,
responsive and robust.
Quality means doing it right when no one is looking
Henry Ford
22
NABET
FAQS
GENERAL
1
What is accreditation?
3
4
Accreditation is a process of verifying the capability

of an organisation against a set of criteria to provide
a service or product through third party verification
Is Accreditation by NABET for Yes. Vide Office memorandum dated Dec 2, 2009
EIA Consultants mandatory? from Ministry of Environment, Forest and Climate
Change
What is the association NABET is a constituent Board of QCI
between NABET and QCI?
What is the purpose of EIA Study Report to be prepared by the EIA
accreditation
Consulting Organizations needs to be authentic,
reliable, and transparent which will enable the
stake holders to use it as dependable tool to take a
decision to go ahead with the project at the selected
site / alternatives or discard to avoid future liabilities.
The Accreditation of EIA Consulting Organization/s
is to ensure their capability in preparing a quality EIA
Report.
What are the benefits of Recognition of competence and capability of the
accreditation?
consultant, availability of a list of capability verified
consultants for different sectors on QCI and MoFE &
CC website for all stakeholders, growth in business
for the consultants, reduced risks on investments for
investors by choosing capable EIA Consultants.
Who can apply for NABET Only registered organizations, such as government,
accreditation
public, private, partnership, proprietary firms, bodies
registered under Society Act, Research Institutes
and the like engaged in EIA Consultancy service can
apply in the prescribed format as per NABET Scheme.
How can a consultant The organization needs to have people who have
organization not having adequate experience of EIA as defined in the Scheme,
earlier
experienced
of with other consultants
preparing EIAs under its name
enter the business and apply
for
accreditation?
23
NABET
9
10
How
the
Accreditation The Scheme was developed after extensive
Scheme has been developed? interaction with experts in the field including
academicians, consultants, regulators, industry,
EAC members etc. It is based on study of gaps and
reliability of information, impact predictions etc.in
EIA Reports prepared in the country, stakeholders
perception on the quality of EIA, public hearing
records etc.
Can we suggest changes in the

EIA Accreditation Scheme?
How can I empanel as
an assessor under the
Accreditation
Scheme?
11
What are the other schemes

available with NABET?
12
How can a complaint be

lodged against NABET?
The Scheme undergoes routine review and revisions

based on the feedback from the organizations,
assessment outcome, and expert advice in specific
fields.
Yes. There is provision of sending suggestions on the
Scheme on the QCI/NABET website
The qualification and experience requirements for
an assessor is mentioned on the QCI/NABET website.
One can apply to CEO, NABET, if meeting such
requirements
NABET also works on accreditation of ITIs, Skill
training, schools, management systems, business
management organisations etc
Complaints may be lodged by individual or
organisation to CEO, NABET
ACCREDITATION PROCESS
How to apply for accreditation? The application form is uploaded on the QCI/NABET
website. May download and send in soft format. No
hard copies to be sent.
The application along with requisite fee is to be
submitted to NABET with all necessary details as
asked for in the Application Form. Incomplete
Application is not processed by NABET.
What are the minimum An organisation should meet the following minimum
strength and facilities should requirements before applying
an organisation have to apply i. 3 in-house experts- one EC and two other FAEs,
for accreditation?
who together should cover the Core functional
areas (FAs)
ii. IH or empanelled experts for balance FAs
24
NABET
What are the minimum iii. NABL accredited/MoEF & CC recognised lab or
strength and facilities should
agreement with any such external lab
an organisation have to apply iv. A Quality Management System meeting the
for accreditation?
NABET Guidelines
v. Enabling office facilities for preparing an EIA
Is it necessary to have in- No. Please refer the answer above
house laboratory to apply for
accreditation?
How much time is required to If all information are provided in completeness in the
get accreditation?
application, the process can be completed within 3
months
Is there any Category of The NABET Accreditation of EIA Consulting
accreditation
Organizations is of two Categories,
namely,
Category A and Category B in conformity with the
Schedule of MoEF Gazette Notification No. S.O.1533
dated 14th September, 2006, and subsequent
amendments. An Organization scoring minimum
60% marks during Stage-III office assessment by the
NABET Assessors will be eligible for undertaking EIAs
for all types of projects both for A and B Category
of the Schedule. The Organizations scoring less
than 60% but above 40% will be of B Category and
eligible for undertaking EIA for B Category projects
only as listed in the Schedule.
What is the period of Accreditation is given for a period of 3 years with
accreditation?
the provision of a surveillance assessment after 18
months of accreditation
What are the eligibility criteria A candidate for EC should be a bachelor in a technical
(qualification and experience) subject or a Masters in science or humanities subject.
for an EIA Coordinator (EC) in S/he should have minimum EIA related experience
Category A & B and how many of 7 years for category A and 5 years for Category B
sectors can s/he apply for?
EC. A candidate may apply for maximum 5 sectors.
What are the eligibility criteria A candidate for FAE should be a bachelor in specific
(qualification and experience) technical subject or a masters in specific science
for a FAE in Category A & B or humanities subject, as applicable for the FA and
and how many FAs can s/he mentioned in the scheme. She should have minimum
apply for?
overall and EIA related experience in the FA of 5 & 3
years for category A and 3 & 1 year for Category B
FAE. A candidate may apply for maximum 4 FAs.
25
NABET
Who can be proposed as an Any person meeting the qualification and

empanelled expert and what experience requirements of the scheme and not a
are the criteria applicable?
full time employee in any company may apply to
be considered as an empanelled expert. A person
working with an academic institution or a NGO may
also apply, with NOC from authorities as specified in
the scheme
Criteria for approval of an empanelled expert are
the same as those for in-house experts. Additional
points arei. A person may be proposed by maximum 5
organisations
for
empanelment.
ii. However, those in an academic institution or a
NGO may apply from 3 organisations.
10
iii. An empanelled expert may be proposed for

maximum 5 sectors and 4 functional areas, all
organisations put together.
What is meant by IA, SA and IA - Initial Accreditation (when primarily the potential
RA?
of an applicant organisation is assessed)
SA Surveillance Assessment held after 18 months of
IA (when performance of the accredited organisation
and compliance to conditions of accreditation are
assessed)
26
11
What are NCs and Obs?
12
What is the provision for a

candidate/organisation to reapply once it is not approved
on qualification/experience/
knowledge/other grounds?
RA Re-accreditation held after 3 years of IA (when

the performance and improvements achieved are
assessed)
NC is the Non Conformance with the Scheme
requirement, and Obs is the Observation as recorded
by the NABET Assessors during assessment process.
Applicant organization is required to respond to
the NC/s and Obs to the satisfaction of the Assessors
and closure by them to proceed to the subsequent
stages of assessment process.
An organisation or an expert is considered for reassessment after a gap of 3 months with necessary
application fee once the shortcomings have been
addressed
NABET
13
14
15
16
How can a fresh graduate A fresh graduate may enter the Scheme as a
enter the Scheme?
Functional Area Associate (FAA) if s/he meets the
relevant qualification requirements for the FA. A
candidate may be proposed as an FAA for maximum
two FAs, so that s/he can pick up the subject properly.
S/he will work under the guidance of a FAE in the
FA for 3 years then may be proposed as a FAE. Since
FAA option is to encourage young professionals, a
candidate is considered for FAA up to 5 years after
obtaining the requisite qualification. For more
experienced people provision of Team Member is
there (see below)
Who can be a Team Member A professional having work experience of more than
and/or Mentor?
5 years after obtaining the requisite qualification
but no EIA exposure may be proposed as a Team
Member (TM) to work with an approved expert. The
TM provision may also be used to expand the area
of association for an approved expert. NABET needs
to be informed PRIOR to putting a person as a TM. A
TMs work is assessed in the next assessment but no
formal approval is necessary. A TM may be proposed
after getting the requisite experience as an EC and/
or a FAE.
Some senior professionals who may not like to visit
site frequently as required by an EC or FAE, may serve
as a Mentor, to guide and train FAAs. A mentor is
met by the NABET assessors but no formal approval
is given.
What is procedure for up- For up-gradation from Category B to A, an ACO
gradation of organization needs to score 60% or more overall in SA.
from Cat. B to A after IA, SA &
In RA an ACO is assessed a new and need to score
RA
60% or more to get Category A.
What is procedure for up- Similar to those for an Organisation as above
gradation
an
individual
candidate from Cat. B to A
after IA, SA & RA?
27
NABET
17
18
Who are Assessors?
Assessors are professionals with minimum 12 years

overall experience of which 8 years should be EIA
related as defined in the Scheme. They are not
connected in any manner with preparation of EIA
reports by EIA Consultants.
What are accounts details of Bank details for RTGS
QCI/NABET for online money Name of bank AXIS BANK LTD
transfer?
Address of the bank
83/6, Padam Singh Road, WEA
Karol Bagh, New Delhi 110005

19
Account No - 223010100053020
IFSC Code - UTIB0000223

How can I appeal against the There is a 2 tier Complaint and Appeal mechanism
decision of QCI/NABET
i. Review of decision by the Accreditation
Committee
ii. Appeal to be heard by an independent Appeals
Committee formed by the NABET Board
All complaints to be addressed to the CEO, NABET
28

Reflections

Transféré par

Informations du document

Copyright

Formats disponibles

Partager ce document

Partager ou intégrer le document

Options de partage

Avez-vous trouvé ce document utile ?

Ce contenu est-il inapproprié ?

Droits d'auteur :

Formats disponibles

Reflections

Transféré par

Droits d'auteur :

Formats disponibles

NABET

Accredited Consultant Organisation

Central Mine Planning and Design India Limited

Central Pollution Control Board

Council of Scientific and Industrial Research, National Institute of

Environment Consultant Association

Environment Impact Assessment

Functional Area Associate

Functional Area Expert

Frequently asked questions

Indian School of Mines

Jawaharlal Nehru University

Larsen & Tubro

Ministry of Environment, Forest and Climate Change

National Ambient Air Quality

National Accreditation Board for Education and Training

National Environment Engineering Research Institute

Quality Council of India

State Environment Appraisal Committee

Wildlife Institute of India

Scheme for Accreditation of EIA Consultant Organizations Reflections.

Scheme for Accreditation of EIA Consultant Organizations

The requirement of Environment Impact Assessment (EIA) report for environmental

EIA is a multi-disciplinary activity requiring inputs from a team of experts having

Dr. Prodipto Ghosh, Ex Secretary, MoEF & CC

Ms. Meena Gupta, Ex Secretary, MoEF & CC

Sh. J. M. Mauskar, Ex Sp Secretary, MoEF & CC

Prof. C. K.Varshney, Prof Emeritus JNU and eminent Ecologist

Prof. S. P. Banerjee, Ex Director, ISM and an eminent Mining Engineer

Dr. Sukumar Devotta, Ex Director, NEERI

Dr. S. R. Wate, Director NEERI

Sh. Paritosh C Tyagi, Ex-Chairman CPCB

Sh. K. P. Nyati, Ex Head, EMD, CII

Prof. A. K. Maitra, Ex Director, School of Planning & Architecture

Sh. N. S. Tiwana, Ex-Chairman, CPCB

Dr. V. B. Mathur, Director, Wildlife Institute of India, Dehradun

Prof. B. B. Dhar, Ex Prof & Head, Mining, Banaras Hindu University

Dr. B. Sengupta, Ex Member Secretary, CPCB

Dr. G. V. Subrahmanyam, Advisor, MoEF & CC

Dr. Asha Rajvanshi, Scientist G and Head-WII, Dehradun

Dr. Nalini Bhat, Ex Advisor, MoEF & CC

Dr. A. N. Jha, Ex. C.E.O. & Sr. President, Essar Group

QCI/NABET is guided by a Technical Committee headed by Prof. S. P. Banerjee in developing

Accreditation as per Scheme and achievements so far

Human Resource (experts to be involved in preparation of EIAs meeting the

Scheme for Accreditation of EIA Consultant Organizations Reflections.

Requirements of field investigation and laboratory arrangement (in-house or

Completeness/Quality of EIA Reports (addressing significant aspects of EIA)

Organizational Commitment (facilities, resources, improvement etc.)

Performance & Compliance

IA stage Potential of the AO is

Scheme for Accreditation of EIA Consultant Organizations Reflections.

SA stage Compliance and

Since inception, the Scheme has been able to achieve following:

Recognition given to human resource at all levels -

Functional Area Associate

0-5 Years experience

Functional Area Expert Cat B

>3 years experience

Functional Area Experts Cat A

>5 years experience

EIA Coordinator Cat. B

>5 years experience

EIA Coordinator Cat. A