COMMENTS ON THE
  DRAFT ENVIRONMENT POLICY OF THE GOVERNMENT OF KERALA, 2006
   
   
  Dr. P. R. Sreemahadevan Pillai, Principal, Sree Chitra Thirunal College of 
Engineering, Thiruvananathapuram – 695018. Phone: 9447490572 E-mail: [EMAIL 
PROTECTED]
   
  (Presented at the seminar organized by CISSA at Thiruvananthpuram on 6th 
January 2006)
   
              The State Government in October 2006 has circulated to the 
members of the Kerala Legislative Assembly, the draft Environment Policy for 
the State and it is time now for the civil society organizations and policy 
analysts to come up with their comments. The policy document was approved in 
February 2006 by the United Democratic Front regime, but has been brought out 
without much change by the Left Democratic Front Government now. An environment 
policy for the state has been long awaited and the present one is supposed to 
be comprehensive enough to alleviate the apprehensions of all the stake holders 
and activists.
   
              Kerala is a state having active environmentalist groups and the 
absence of a comprehensive policy has always led to legal disputes and mass 
movements in almost all the parts of the state. Be it the exploitation of 
water, discharge of waste water, mining of river sand, blasting of rock, 
emission of pollutants – it all causes concerns in the state because of its low 
per capita availability of land, high population density, high literacy rate 
and awareness on health and hygiene.             As the first statement of the 
draft policy states, “there has been progressive pressure on the environment 
and the natural resources of Kerala over the years”
   
              The 38 page draft policy has 7 parts: introduction, the 
environmental scenario of Kerala, environmental management initiatives, agenda 
for action, priorities and strategies for action, policy implementation 
structures and linkages and at last, the conclusion.
   
              The purpose of the environment policy can be contained in a nut 
shell by the concluding statement, “the initiatives highlighted in the 
preceding paragraphs are expected to resolve the conflicts that often arise 
between the environmental concerns and developmental pursuits that have a 
direct bearing on the very fabric of our society and life styles”. The policy 
is prepared in line with the National Conservation Strategy and Policy 
Statement on Environment and Development adopted by the Union Government in 
1992.  The specific local conditions of the state of Kerala and the State’s 
economy are supposed to be taken care of by the policy.
   
              The specific environmental scenario of the state – the low per 
capita land area, the 3 tier terrain of the topography, the impact of the long 
coast and high rainfall, indiscriminate use of resources, the cultivation 
pattern, the uncontrolled dumping of wastes – are addressed properly in the 
document. Most of the national level Acts/ Rules / Notifications with regard to 
environment are mentioned in the 3rd part of the document. The initiatives 
taken so far by the Centre and State are highlighted thereafter. The fourth 
part lists the actions to be taken, mainly from the Government side. The fifth 
part lists the priorities for action in the areas of conservation and 
sustainable utilization of natural resources (land  and water resources, 
agricultural practices, forests and wildlife, land use in hill ecosystem, 
animals and wildlife, mining and quarrying, human settlements, waste land 
development), water resources (drinking water, coastal and marine resources,
 irrigation, wetland reclamation), air and noise pollution, biodiversity, 
energy, industrial development & tourism and transportation. The sixth part on 
policy implementation structures and linkages deals with strengthening of 
institutions and legislation, state environment department, state and district 
advisory councils, environmental audit statement, natural resources accounting, 
promoting environmental education, training and awareness, R&D and promotion of 
Technologies, rehabilitation of affected people in projects, role of 
non-governmental organizations and general strategies.
   
              A good number of items in the draft policy require serious 
consideration. Clause 6.2 stipulates the formation of a state Environment 
Department. Though a Department of Environment has been formed in the State, it 
is yet to have the necessary manpower support and budget allocation, sufficient 
to run the show. There is a Kerala State Council on Science Technology and 
Environment at present and it is advisable that the Environment related 
activities be separated and attached exclusively to the newly formed Department 
of Environment. The effective implementation of the policy is hampered by the 
separation of the Forest Ministry and the Environment Ministry by the present 
government. As in the Union Government, it is advisable to have a single 
Ministry of Environment and Forest, for convenience of policy implementation 
and administration.  
   
              As mentioned in clause 3.2, Kerala is one of the first states to 
constitute a State Pollution Control Board. This Board has been under the 
Health Minister and only recently it was attached to the Department of 
Environment. So far Environment was only at the tail end of the Science, 
Technology and Environment Department and research on Environment was also 
getting this tail end consideration. The newly formed Department of Environment 
should have people with academic credentials and experience in the field of 
environment than the usual ‘administrative gurus’. 
   
              Of late, the output of the state level R&D organizations such as 
CESS, TBGRI, KFRI, CWRDM, RGCB and ANERT listed in clause 3.3 has been very 
minimal.  The policy needs a definite action plan to revive these organizations 
and to bring it under a common umbrella. Providing proper linkages between 
these organizations also needs consideration.
   
              Clause 3.5 mentions the relevance of non-governmental 
organizations in the field and it is worth mentioning that so far in Kerala, 
the environmental related studies and activities were done by these 
organizations beyond that by government.  In the draft policy, there is no 
clear cut frame work for pooling in the resources of these organizations. Some 
of these organizations have much more qualified human resources in the field 
than the concerned government department. If a separate wing is formed for 
coordinating the activities of these organizations, with nominal funding, it 
can bring-in good results.
   
              Some suggestions are given herewith for consideration in the 
finalization of the policy.
              The agenda for action mentioned in clause 4.5 may include the 
following also.
  ·                 Promote the establishment of self sustained eco-villages 
for the aboriginal inhabitants of the forest land
  ·                 Proposal for alternate livelihood activities for the 
population actively involved in environmental degradation as a means of 
subsistence
  ·                 There should be state preparedness for environmental and 
natural calamities and a separate wing formed under the government for the same.
  ·                 There is no  environment monitoring system and agency at 
present in the state and this should be met by the formation of an integral 
system
   
              In the section 5 under priorities and strategies for action, in 
clause 5.1.1, land and water resources, the following points may also be 
considered
  ·                 A total mapping of  the entire land and water resources 
available in the state should be made, using the available data as well as  
remote sensing tools.
  ·                 The legal controls for the encroachment of the water bodies 
is not effective and suitable legislation  with assigned agencies should be 
thought of. 
   
              In clause 5.1.2, under agricultural practices, the points to be 
noted are,
  ·                 Wetland cultivation is now an ignored area, mainly because 
paddy cultivation lost its charm in Kerala.  Profitable schemes and alternate  
models for wetland cultivation  should be sought
  ·                 Introduction of huge quantum of pesticides and fertilizers 
in to the ecosystem is a matter of concern and control of  the same should be 
of relevance. Substitute methods like biological fertilizers / pesticides needs 
promotion.  
   
        In clause 5.1.6, the additional point to be considered is 
  ·                 The construction industry is the biggest industry in 
Kerala, though in the disorganized sector. The extraction of construction 
materials, especially sand   is       causing concern for the water bodies. 
Action plan for alternative construction materials like manufactured sand  
should be taken up as major project.
   
              In clause 5.2.2, the addition required is
  ·                 The salinity intrusion of the coastal zone and rivers is 
alarmingly increasing and steps to curb it should be sought.
   
              In clause 6.1 on general strategies, the following also may be 
included
  ·                 There is no unified agency and centralized scheme for 
coastal protection works and hence it is now done by various agencies in a 
haphazard way. The coast protection works should be under the control of a 
single agency and repetition of mistakes should be avoided.
  ·                 The habitat development and sanitation should be taken up 
as a priority area by the local authorities, in the wake of the spreading of 
epidemics.
   
   
   
  
 
   

 
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