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ADVOCACY

Recommendations to the Government of India on the Basis of the National
Action Plan on Climate Change

The National Action Plan on Climate Change reiterated the need for stepping up action against irreversible Climate Change. Given the diverse nature and interlinkages with socio-economic and political nature, the climate change deserves a better deal. The NAPCC is a good attempt but it falls short. It fails to give clear direction and means to achieve a climate resilient society. In an attempt to mainstream these concerns few Civil Societies working on Climate Change under the CANSA Network met at Indian Social Institute, New Delhi and threshed out recommendations after consultation on the various opportunities for building up the regions resilience.

Civil Society Resolution

We, the civil societies, as active partners in Climate Change adhere to these tenets and suggestions:

I. Overarching Principles:

Reiterate the broad principle encapsulated in the National Action Plan and work towards

  • Shift in emphasis from a centralized production model to a decentralized/democratic production model.

  • Joint effort - not withstanding the obligation of developed countries, India alongwith its regional partners must deploy its own resources for both mitigation and adaptation, and both need to go hand in hand.

  • Protecting lives and livelihood of people in India and the regions through sustainable development and take cognizance that economic growth will not be just sufficient.

  • Synergy of market led investments alongwith employment of public resource to combat climate change.

  • Decoupling of Growth and Climate change for sustainable solution.

  • Differentiated responsibilities and cognizance of historical obligations in a equitable manner

  • Secure and safer technology use options. Apply the “Precautionary Principle” especially in situations where there are high risks of ecological/social costs, such as use of GMO technology in agriculture or big dams and big hydropower projects or Carbon, Capture and Storage for power plants, or large scale deployment of bio-fuels.

  • Strengthening and utilizing the traditional knowledge systems and practices in dealing with climate change alongside modern science and technologies.

II. Specific Demands on Mitigation and Adaptation

  • Paradigm shift in emphasis from “Centralised Energy systems” to de-centralised energy systems and a policy supporting the same. There are clear advantages from the decentralized system which is evident from:

    • Reduced Losses

    • Increased efficiency

    • Reduced infrastructure cost

    • Better quality

    • Rural development and livelihood generation

    • Inclusive growth and energy secure communities

    • Potentially more democratic systems with participation of the people at all levels

  • Enhanced Energy use Efficiency and energy modesty at domestic and commercial usage.

  • Introduction of Legislation and deterrence to promote innovations towards energy efficiency and phase out wasteful uses and practices. Specifically, the government should implement progressive and mandatory energy efficiency standards cutting across all energy applications in the country with clear time lines.

  • Incentivise energy use efficiency through broader approaches like

    • Reforms in the banking sector to ensure that energy efficiency projects are made bankable

    • Needs substantive government investment to promote efficiency, especially in enabling the small and medium enterprises sector to change over from energy inefficient production and products to efficient ones

    • Regulatory systems to implement and monitor efficiency

    • Trading of efficiency certificates

  • Substantial reduction in Transmission and Distribution Losses are reduced to a maximum of 10% by 2012

  • Improvement of plant load factor to at least 85-90%, which needs to be achieved not later than 2012.

  • Curbing of mis-use of electricity: Related to efficiency, is the current policy of unrealistic pricing system especially in the electricity sector. This is one of the causes for huge quantum of electricity being mis-used. Hence, it is imperative that we have in place, a dual pricing mechanism, which is based on the usage and consumption patterns and specially with regard to “free electricity”, it should be strictly on the basis of “farm sized based pricing policy”.

  • Increasing the energy mix: India has very high potentials for Renewable Energy, which currently forms only 4% of the energy mix in the country.

  • Instituting a National Portfolio Standard: While some states have in place renewable energy portfolio standards which specify a certain quantum of renewable energy uptake in the state, a number of them do not have and further more, there is no national portfolio standards either. (25% of total installed capacity by 2020).

  • Rationalise the reneweable energy caps: Further, only a few states have put in place a special tariff scheme for renewable energy (feed in tariff) and in the case of solar energy, the feed in tariff scheme sets a upper cap of 50 MW only

  • Repeal of Bio-Energy Policy and removal of blending commitments. On bio-energy, however, we would like state that, we support only very small scale, farm and community level tapping of bio-based energy sources for use within communities to facilitating their energy sovereignty and not for export outside the communities. Hence, we also demand the repeal of the national bio-fuel policy 2008, for the reason that it has targets for bio-fuel blending, which is unacceptable and must be dropped.

On Large Power Plants and Dams:

  • Follow International Guidelines for larget power and dam projects: We demand that the deployment of large scale projects of coal, hydro and nuclear power are made only after all viable alternatives of reduction of T&D losses, energy efficiency, demand side management (including peak hour demand management) and renewable energy have been explored, implemented and exhausted and after a comprehensive cost benefit analysis in full participation with the people. For large hydro power projects, the planning and decision making process should follow the guidelines of the World Commission on Dams (http://www.dams.org/report/).

  • Rigorous EIA on Power Projects: Historically, Cost Benefit Analysis (CBA) has proved inadequate to accurately measure social and environmental impacts of large conventional power projects (Coal, Hydro and Nuclear). Therefore, their deployment must be done only after a rigorous and proper assessment of all risks and costs. This would involve:

    • considerable strengthening of the Environment and Social Impact Assessment regulations that have remained largely on paper and the assessments are unaccountable and pathetic

    • Extensive stake-holder consultation right from the stage of beginning of project formulation.

    • The EIA and SIA should be formulated in full consultation with the local people. The EIA should include an assessment of the potential contribution of the project to the green ground gas emissions during its entire life cycle, right till the stage of decommissioning.

    • Full EIA and SIA should be available to the local people in the language and manner they can understand, at least two months before the public hearing date

    • The public hearings should be conducted by an independence panel, which would also certify to what extent the EIA and project proponent have addressed the issues raised at the public hearing and what next steps are required, including a new or improved EIA and fresh public hearings.

    • If the public hearing committee finds that EIA has been incomplete or doctored, or giving wrong, biased or tendentious information, the independent panel can order black listing of and stoppage of payments to such EIA consultants.

    • There should be a legally mandatory committee for each project in which at least 50% of members should be from the local area, for monitoring and ensuring that the EIA-SIA is implemented as required, pari passu with the project and when that is not the case, the committee has the power to order stoppage of construction till the EIA-SIA implementation catches up. Such committee should also continue to function during the project operation.

ADAPTATION ISSUES

Water

  • The approach towards water must not be a purely targeting an increase in the resource base, in any case not through more large projects. Equity and access to water for all through rights based regime must be a central plank for any plans that the government implements.

  • In this light, suitable changes must be made to the National Water Policy. For the formulation of a new NWP, a detailed participatory exercise should be started immediately. The NAPCC recommends such review only in consultation with states, but this process has to start from the people and would have to be aimed at a new NWP.

  • Stop the ongoing destruction and neglect of natural, local and traditional water harvesting systems (including tanks, wetlands, johads, flowing rivers) and rehabilitate the systems that have been already destroyed, create new systems were possible, as first priority when going for new developments

  • Emphasise on groundwater recharge and rainwater harvesting strategies. Groundwater is India’s water lifeline and that lifeline can be sustained only through direct recharge where appropriate and through protection, rejuvenation and creation of local water systems.

  • Make available adequate funds in the budget to maintain the existing water related infrastructure rather than spending money on new schemes. For example, there is a need to ensure that dams and canals do not get silted up quickly and therefore there is a need to make adequate investments for catchment area treatment of existing large, medium and small dams. Similarly maintenance of the canal infrastructure to ensure optimum use of created infrastructure should be given first allocation of available resources. To ensure that all this actually gets done in a transparent way and accountable way, the governance in water sector will have to be changed so that the local people have decisive say in planning, decision making, implementation and operation of the systems.

  • To ensure proper and optimum functioning of the existing and under construction reservoirs in the interest of the people, each reservoir should have a reservoir operation committee, in which at least 50% members should come from the local communities. As a first step in this direction, the reservoir operation rules and actual reservoir operation details (inflows, outflows, levels, capacities, anticipated inflows) should all be made public on daily basis for each large dam in India.

  • Similarly for embankments, canals, pipelines, and other related water infrastructure. Such committees should be formed right from planning stage of the projects and they should be statutory bodies with powers to make necessary mandatory orders with respect to the functioning of the projects.

  • While considering new storage requirements, the priorities should be in following order:

    • for ensuring sustainable use of created capacities, e.g. arresting siltation.

    • For ensuring optimum use of the created capacities, in large number of cases it has been found that huge quantities of water remain unused till the next monsoon arrives

    • For groundwater recharge

    • For creating local water systems through tanks, lakes, wetlands, watershed development and so on

Only after all this has been shown to be exhausted in a credible way, should a larger project in any basin be considered.

It has to be believed that the Climate change problem has been created by the over exploitation of the natural resources for the economic purposes. For this, the core of the plan of action should feature sustainability. The action plan should be developed in the paradigm of sustainable usage of the resources and this will create a future which will be equitable, fair and climate resilient.

October 2008

(These recommendations are part of the larger documents titled “Draft Recommendation to the Government for strengthening the National Action Plan on Climate Change”, held at New Delhi during September 25-26, 2008, in response to the National Action Plan on Climate Change)

Endorsed by the Trade and Climate Change Team, Centad.

 
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