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Public involvement in environmental impact
assessment: a case study of hydro development in
Kullu District, Himachal Pradesh, India
a
a
A. John. Sinclair PhD & Alan P. Diduck LLB, MNRM
a
Natural Resources Institute, University of Manitoba , 200 Dysart Road, Winnipeg , MB
R3T 2N2 , USA Phone: +1 204 474 8374 Fax: +1 204 474 8374 E-mail:
b
Department of Geography , University of Waterloo
Published online: 20 Feb 2012.
To cite this article: A. John. Sinclair PhD & Alan P. Diduck LLB, MNRM (2000) Public involvement in environmental impact
assessment: a case study of hydro development in Kullu District, Himachal Pradesh, India, Impact Assessment and Project
Appraisal, 18:1, 63-75, DOI: 10.3152/147154600781767637
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Impact Assessment and Project Appraisal, volume 18, number 1, March 2000, pages 63–75, Beech Tree Publishing, 10 Watford Close, Guildford, Surrey GU1 2EP, UK.
Public involvement
Public involvement in environmental impact
assessment: a case study of hydro development
in Kullu District, Himachal Pradesh, India
A John Sinclair and Alan P Diduck
The Governments of India and the Indian state
of Himachal Pradesh (HP) recently adopted
policy changes intended to expedite develop-
ment approvals for power projects. This paper
focuses on the 1997 changes to the Environ-
mental Protection Act that establish procedures
for public hearings as a component of EIA.
Three hydro project public hearings in the
Kullu District (HP) in 1998 show that public
involvement and public hearing processes are in
their nascent stages despite the rapid pace of
development. Many constraints, such as inac-
cessibility of information, lack of familiarity
with EIA, and lack of institutional capacity,
hinder serious public involvement. Public
concerns focused on safety issues (blasting),
new road construction and jobs, with little
consideration of environmental impact.
UMEROUS AUTHORS have highlighted the
important role of public involvement (PI) in
environmental impact assessment (EIA) (for
N
instance, Grima 1985; Gibson 1993; Sinclair and
Diduck 1995). Most EIA legislation recognizes this
roleandcalls onproject proponents toengagethepub-
lic in meaningful participation programs. Typically,
EIA legislation also establishes detailed public
hearings processes as the main vehicle of formal
involvement within EIA.
The Government of India passed EIA legislation in
994 to assist in the “conservation, protection and
1
preservation of the environment … cornerstones of
the Indian ethos, culture and traditions” (Singh et al,
1994, page 1). In 1997, the process enacted in this
legislation was amended to include provisions for
mandatory public hearings. This paper assesses the
application of the new public hearing provisions in
three EIA cases in the Kullu Valley, a rapidly devel-
oping mountain region in the state of Himachal
Pradesh, northern India. This research continues our
exploration of public involvement in EIA including
issues related to access to information, informal edu-
cation and social learning (Sinclair and Diduck, 1995;
Diduck and Sinclair, 1997a; 1997b; Diduck, 1999).
In terms of research design, the approach taken for
this study was qualitative, interactive and adaptive.
The primary data collection methods were qualitative
interviews, document reviews and participant obser-
vation. The interviews were scheduled and non-
structured in nature, and included members of the
general public in the area of the hydro projects in
question as well as those living in others areas of the
Keywords: public involvement; hydro development; India
A John Sinclair PhD, to whom correspondence should be
addressed, is at the Natural Resources Institute, University of
Manitoba, 200 Dysart Road, Winnipeg MB R3T 2N2, USA;
Tel: +1 204 474 8374; Fax: +1 204 261 0038; E-mail:
jsincla@Ms.UManitoba.CA. Alan P Diduck LLB, MNRM is in
the Department of Geography, University of Waterloo.
This research was funded by the Partnership Program of the
Shastri Indo–Canadian Institute. It is part of a two-year joint
project partnered by the Natural Resources Institute, University of
Manitoba and the Department of Geography, University of Delhi.
The authors gratefully acknowledge the support of the Shastri
Institute.
Impact Assessment and Project Appraisal March 2000
1461-5517/00/010063-13 US$08.00 © IAIA 2000
63

Public involvement in EIA in India
Kullu District, individual citizens who participated in
EIA cases, officials representing government EIA
agencies, and project proponents.
approach called for in some quarters and found in
some countries (Gibson, 1993; Wood, 1995).
In addition, reviews of the implementation of the
Notification are somewhat mixed. Banham and Brew
(1996) indicated in their assessment that there is rea-
son to be optimistic about the use of EIA in India. Oth-
ers, such as Dwivedi (1997) and Thakur (1997),
suggested that the process is still in its early stages of
development and that India lacks many of the insti-
tutions and knowledgeable government officials
necessary to make the process work properly.
Data sources of the document review were primar-
ily public records such as statutes, regulations, poli-
cies, proceedings from public hearings, court orders,
maps and government reports. Participant observa-
tion occurred through attending EIA hearings and
other public meetings in the study region. Analysis of
the data occurred both in the field and after the field
season.
In terms of scope, the research focuses on public in-
volvement as part of the EIA process in India. Thus, it
accepts the relatively limited role that public involve-
ment plays in comprehensive, rational planning,
which is the model for most EIA processes. That be-
ing said, it is recognized that alternative models exist
in which the public has a more active role at all levels
of planning including the normative stage in which
decisions about what should be done are made (for
instance, Nelson and Serafin, 1996; Chambers,
Public involvement in EIA
Detailed descriptions of the 1994 EIA Notification
can be found in the literature (Singh et al, 1994;
Valappil et al, 1994; Banham and Brew 1996;
Dwivedi 1997) and therefore, the ensuing discussion
does not attempt a comprehensive review of the pro-
cess. Rather, it focuses on those parts of the process
that provide opportunities for public involvement. In
addition, it concentrates on the public hearing provi-
sions, which were enacted in 1997 and have not re-
ceived considerable attention in the literature.
1
997; Cardinall and Day, 1998).
EIA in India
EIA Notification
India is a federal union of states in which the central
and state governments have concurrent jurisdiction
over resource and environmental management
The process enacted by the EIA Notification is initi-
ated by the submission of an application by the project
proponent to the Impact Assessment Division (IAD)
of the Ministry of Environment and Forests (MOEF).
The application must include, among other things:
(
Rosencranz and Rustomjee, 1995; Bakshi, 1998).
EIA legislation at the central level was enacted in
994 by a regulation (or notification) passed under
1
The Environment (Protection) Act, 1986. The EIA
legislation is entitled the Notification on Environ-
mental Impact Assessment of Development Projects
· a proforma prescribed by regulation;
· an EIA report (or an environmental management
plan);
(
the EIA Notification) (GOI, 1994). Individual states
are compelled to adopt the EIA Notification as a mini-
mum, but may adopt their own more stringent legisla-
tion. During this study, and at the time of writing, the
state of Himachal Pradesh had not enacted its own
EIA legislation.
· a risk analysis report; and
· an executive summary containing the project de-
tails and the findings of environmental assessment
studies that were conducted (GOI, 1994).
Responsibility for the EIA Notification lies with
the Ministry of Environment and Forests, which is
based in Delhi but has six regional offices, the
Chandigarh office being the closest to the study area.
Responsibility for pollution control lies with the State
Pollution Control Boards (SPCB), coordinated by the
Central Pollution Control Board, also in Delhi. As the
ensuing discussion reveals, the SPCBs play an im-
portant role in the EIA process, particularly in regard
to public involvement.
The literature reveals that the EIA Notification
contains many of the key elements found in most pro-
cesses throughout the world, including screening,
scoping, comprehensive study, progress reports, re-
view, decision and follow-up (Valappil et al, 1994;
Banham and Brew, 1996; Dwivedi, 1997). However,
from the lack of reference to project need, purposes
and alternatives, a reasonable inference is that the pro-
cess reflects a narrowly focused, technical approach,
rather than the more broad, open and anticipatory
Under the 1994 law, the IAD had discretion over
whether to hold public hearings to solicit comments
about the project application. Typically, public hear-
ings were called for in projects involving a large dis-
placement of residents or severe environmental
impacts. The decision to hold hearings had to be made
within 30 days of receipt of the proposal. If the IAD
decided to hold hearings, it was required to provide
notice in at least two newspapers at least 30 days prior
to the hearing. This procedure was changed by the two
notifications on public hearings enacted in 1997, dis-
cussed further below (GOI 1994; 1997a; 1997b).
Upon receipt of the project application, the IAD is
required to prepare recommendations regarding ap-
proval based on a technical assessment of the docu-
ments and data submitted by the project proponent.
The IAD may also supplement this information with
data that it collects itself. If necessary, it may also
gather information through consultations with envi-
ronmental groups and concerned parties, which are
6
4
Impact Assessment and Project Appraisal March 2000

Public involvement in EIA in India
around the project … mentioning the date, time and
place of public hearings”. “Suggestions, views, com-
ments and objections of the public shall be invited
within thirty days from the date of publication.” Local
residents, environmental groups and others located at
the project site likely to be affected can participate in
the hearings or submit oral or written briefs to the
SPCB.
The new hearing process also contains require-
ments regarding the composition of hearing panels.
Panels must include a representative of the SPCB, the
District Collector, a state government representative
for the relevant sector under investigation, a represent-
ative of the central Ministry of the Environment and
Forests, not more than three representatives of local
bodies such as municipalities or panchayats, and not
more than three senior citizens nominated by the Dis-
trict Collector.
The gist of the public hearing
notifications in India is that hearings
are now mandatory for all projects to
which the EIA Notification applies: in
support of this new requirement, the
process includes provisions for public
access to information
defined as “bonafide residents located at or around the
project site or site of displacement or site of alleged
adverse environmental impact” (GOI, 1994; Singh et
al, 1994).
The EIA Notification also states that summaries of
the application documents, the IAD recommenda-
tions, and any conditions of approval placed on the
project must be made available to environmental
groups and concerned parties upon request. Further, it
states that public access to these documents must be
provided (subject to the public interest) at IAD head-
quarters (GOI, 1994).
Applications in Kullu District
Study area
This study focused on the Kullu District in the Upper
Beas River Watershed, Pir Panjal Range of the West-
ern Himalaya, Himachal Pradesh (literally “land of
the snowy mountains”), India (Figure 1). The Beas
River is the central axis and focus of the Kullu Valley,
which extends some 70 kilometers from Bajaura in
the south to the Manali area in the north. The area is a
typical high mountain environment with valley bot-
tom elevation in the Manali area of about 2,000 meters
with valley side slopes rising another 2,500 meters in
elevation. Set back from these slopes are the major
summits of the region that rise to 6,500 meters.
In the District as a whole, unofficial estimates cited
by the Overseas Development Administration (1994)
suggest that cultivated land is 10% of the total area,
forest land 40%, grazing land 30% and rocky inacces-
sible slopes 20%. Each village has a rich resource area
which usually includes a series of zones: mixed-use
land near the village, including orchards and some
grazing land; protected forest on the upper slopes of
the mountains; and forest meadows and alpine graz-
ing land.
For the purposes of monitoring the implementation
of IAD recommendations and conditions, proponents
are required to submit a semi-annual compliance re-
port to the IAD. These reports are available for public
review, subject to the public interest (GOI 1994).
Public hearings notifications
As noted earlier, the public hearing provisions of the
EIA Notification were changed by two regulations en-
acted in 1997: Public Hearing Notification, S.O.
318(E); and Public Hearing Notification, S.O. 319(E)
(the public hearing notifications) (GOI 1997a;
1997b).
The gist of the public hearing notifications is that
hearings are now mandatory for all projects to which
the EIA Notification applies. In support of this new re-
quirement, the process includes provisions for public
access to information. Project proponents are required
to provide the SPCB with an executive summary of
the project “containing the salient features of the pro-
ject both in English and local languages”. They must
also provide copies of all application forms relating to
the project that were submitted pursuant to other
environmental approval processes and “any other
document necessary for the Board to dispense with
the application”. Twenty copies of each of these docu-
ments must be provided to the SPCB. Public access to
executive summaries is available at District Collec-
tors’ offices, District Industry Centers, the office of
the Zila Parishad or Commissioner of the municipal
corporation/local body, and SPCB state and regional
offices.
Development pressures in the Kullu Valley
Natural resources and the environment are currently
under intense pressures in the Kullu District, espe-
cially in the upper reaches of the Beas River Valley.
The pressures arise from development in three main
sectors: tourism, agriculture, and hydroelectricity. In
1998, for example, The Tribune newspaper of
Chandigarh published a series of full page “Saturday
Plus” articles with banners such as “Tourism Tram-
ples Manali Environment” and “Mountain Tops Turn-
ing into Garbage Dumps”. These articles, and others
like them, highlighted environmental damage, and
exposed some of its underlying causes, such as “the
The hearing process also contains provisions for
public notice. SPCBs are required to give notice “in at
least two newspapers widely circulated in the region
Impact Assessment and Project Appraisal March 2000
65

Public involvement in EIA in India
Figure 1. Manali and the study site in the Upper Kullu Valley
failure of government to ensure planned expansion of
the tourism industry” (Lohumi, 1998).
other major power developments are proposed for the
district including the:
Government officials have also made public com-
mentsinthe past year. At theopeningofthenewKullu
campus of the G B Pant Institute of Himalayan Envi-
ronment and Development, R H Khwaja, Joint Secre-
tary, Ministry of Environment and Forests,
commented that the “development activities that have
taken place along the road between Kullu (town) and
Manali are an ecological disaster ... the damage is
shocking”.
· Beas Satluj Link, which involves a diversion of the
Beas River;
· three stages of the Parbati project, which has 2,051
MW potential in total;
· three stages of the Larji project (1,200 MW in
total), which involves a 6 km tunnel to an under-
ground power plant; and
· 86 MW Malana project.
Focusing on the hydroelectric sector, the Kullu
District, along with much of Himachal Pradesh, has
vast potential for hydroelectric development. Steep
sloped valleys that rise above 4,500 meters result in
fast moving glacial-fed rivers and nallahs (streams).
In spite of the potential, there has been little
hydropower development in the district. However, in
recent years the demand for power in India has ex-
ceeded supply, especially in the northern region. This
has resulted in the “rapid exploitation of the hydro
power potential of Himachal Pradesh” (Himachal
Pradesh State Electricity Board, 1998a). The Beas
River is currently dammed near the border of Kullu
and Mandi Districts by the Pandoh dam and several
In addition to these larger projects, there are a number
of micro-scale hydro projects ranging in size from 200
to 1,000 KW that are either under construction or pro-
posed for the Kullu District. It is estimated that there
are 319 small-scale hydro sites proposed for develop-
ment in Himachal Pradesh (Government of Himachal
Pradesh, 1998). There is currently no such estimate
for the Kullu District, but the Himachal government is
reported to be “modifying its power policy in order to
speed up the process of development of micro power
projects” (The Tribune, 1998b).
Despite the level of development activity in the
Kullu District, document reviews and interviews
6
6
Impact Assessment and Project Appraisal March 2000

Public involvement in EIA in India
revealed that only three EIAs have been conducted in
the region to January 1, 1999. All three involved hy-
droelectric projects: Parbati Stages II and III and the
Malana project. To assess the public involvement in
each of these cases, public documents were consid-
ered and interviews were conducted with government
officials. In the case of Parbati Stage II, hearings were
held during the field season allowing for participant
observations and interviews with the panel members
and public in attendance. It should be noted in relation
to the discussion of these cases, however, that the
available literature varied considerably in both con-
tent and quality, to the extent that in one case a clear
project description was barely discernible.
As with Stage II, a detailed description
of the potential impacts of Parbati
Stage III is not available to the public:
moreover, the summary report for
Stage III is nearly identical to that of
Stage II, including the mitigation
measures
III is envisioned as a run-of-the-river development
comprising a concrete gravity dam 75 meters high.
The powerhouse will be further downstream and will
be combined with a powerhouse from a separate hy-
dro project, namely the Larji development. Reports
indicate that the peak labor force for Parbati Stage III
will be 14,000 workers.
As with Stage II, a detailed description of the po-
tential impacts of Parbati Stage III is not available to
the public. Moreover, the summary project report for
Stage III is nearly identical to that of Stage II, includ-
ing the mitigation measures listed above (Himachal
Pradesh State Electricity Board, 1998a). It is difficult,
therefore, to get an accurate and trustworthy descrip-
tion of the potential impacts of Parbati Stage III. One
distinction between the two projects that is evident is
that in Stage III a small area of cultivated land (5 hect-
ares) will be submerged, rather than forestland.
Parbati Hydroelectric Project Stage II (800 MW)
The Parbati River is a main tributary of the Beas
River. The Parbati Hydroelectric Project proposes to
harness the river in three stages: Stage I 750 MW;
Stage II 800 MW; and Stage III 501 MW. The
Himachal Pradesh State Electricity Board (SEB), a
statutory public utility responsible for the develop-
ment of power potential in the state, is the project pro-
ponent (Himachal Pradesh State Electricity Board
1996; 1997). During the research and at the time of
writing, only plans for stages II and III had been com-
pleted. Plans for Stage I had still not been subject to
environmental approval.
Stage II is envisioned as a run-of-the-river project
comprising a 91-meter concrete gravity dam on the
Parbati. The summary project report indicates that
“
the project area is sparsely populated and there is lit-
Malana Hydroelectric Project (2X43 MW)
tle habitation at the diversion site and the power
house” (Himachal Pradesh State Electricity Board
The Malana Hydroelectric Project is a private-sector
development, proposed by Rajasthan Spinning and
Weaving Mills Limited. The project is proposed for
the Malana Nallah, which is a tributary of the Parbati
River. The proposed site is approximately 33 kilome-
ters from the town of Kullu. By one account, the pro-
posed project is to provide 86 MW of electricity “to
meet the power shortages in Himachal Pradesh/
Northern Region” (Rajasthan Spinning and Weaving
Mills Limited, 1996). According to the site manager,
however, the power is to be used by the proponent at
its factories in Rajasthan. This disparity is interesting,
given that the Central and HP governments are pro-
moting hydro projects in the Kullu District based on
the power shortages in the north.
1998b, page 4). It is noted further that the area of the
storage reservoir is small “and as such there will be no
rehabilitation problem, as no family is affected by
submergence”.
A detailed description of the potential impacts of
the project is not publicly available but the summary
report indicates that only a small area of forestland
(
8.1861 hectares) will be submerged. The report fur-
ther notes that the following steps will be taken to
maintain the environmental and ecological balance
of the project area”:
“
·
adequate fuel arrangements for workers to prevent
felling of trees for fuel;
·
·
no grazingaroundreservoirtoprevent soilerosion;
enforcement of anti-poaching laws to protect wild-
life attracted to reservoir;
development of pisciculture in the reservoir;
proper slope stabilization; and
afforestation activities in the catchment area.
The project consists of a diversion barrage, diver-
sion channel, reservoir, underground tunnel and
pressure shaft, powerhouse and tailrace channel. This
design will redirect the flow of the nallah to two tun-
nels where the water will drop to a powerhouse and
eventually through the tailrace channel to the Parbati
River.
·
·
·
Parbati Hydroelectric Project Stage III (501 MW)
According to the Environmental Clearance Plan
developed by the proponent, the negative impacts of
the project include loss of forest, loss of land soil ero-
sion at the construction site, pollution by construction
spoils, health risks, cultural hazards, water-borne
The Parbati Stage III hydroelectric project is proposed
for the Sainj River, a tributary of the Beas that will re-
ceive water from the tailrace of Parbati Stage II. Stage
Impact Assessment and Project Appraisal March 2000
67

Public involvement in EIA in India
diseases, and vector-borne diseases. The positive
impacts include power generation, employment
potential, recreation and tourism potential, and addi-
tional habitat for aquatic wildlife.
· timely compensation for land damaged by blasting
or expropriated for construction of roads and colo-
nies for workers (the public requested land for land
compensation);
·
employment opportunities, especially for youth
from the local area, and training for those who
might require it;
Public hearings
·
·
conflicts between local people and migrant
workers;
compensation for damage to link roads caused by
construction machinery; and
Parbati Stage II
Public hearings into the Parbati Stage II project were
held on December 21 and 22, 1998, and were con-
vened by The Himachal Pradesh State Pollution Con-
trol Board (SPCB) in the villages of Barshaini and
Sainj. The hearings were officiated by 12 panel mem-
bers: four from the SEB; two from the SPCB; two
from local government revenue departments; and four
from local district administrations, for example, the
Kullu Block development officer and the Pradhan of
the Gram Panchayat Barshaini. (The Gram Panchayat
is the lowest of the three-tier Panchayat Raj local gov-
ernment institutions in India.)
The December 21, 1998 hearing was to be held ini-
tially in the village of Pulga. However, because of eas-
ier accessibility by bus, it was shifted to the village
Rashkat. On the day of the hearing, the venue was
changed again to the village of Barshaini at the insis-
tence of the Pradhan, Gram Panchayat Barshaini. To
get to the hearing it was necessary to travel by bus
from Kullu to Malana (46 km) switching buses to
Unch Dhar (6 km) followed by a 15 km walk to
Barshaini.
· investment in local infrastructure projects, such as
hospitals, schools, telephones, and new link roads
to currently inaccessible villages.
The panel attempted to respond to the issues raised by
the public but there was an obvious emphasis on es-
tablishing the economic development potential of the
project. Panel members made assurances to the public
of economic prosperity through employment (both di-
rect and indirect), development of basic infrastruc-
ture-like roads, schools and hospitals and increased
opportunities for trade and commerce. The public
at the Sainj meeting presented a memorandum of
demands to the panel at the end of the hearing.
Parbati Stage III
Public hearings into Parbati Stage III were held on
August 27, 1998. They were convened by the SPCB in
the villages of Largi and Sainj in the Kullu District.
The hearings were officiated by 11 panel members:
three from the SEB; three from the SPCB; and five
from local district administrations, for example, the
Assistant District Commissioner of Kullu and the
Pradhan of the Gram Panchayat Kanon. Approxi-
mately 75 people attended.
At the outset, representatives of the SPCB ex-
pressed the board’s objectives for the hearings. This
was followed by a presentation by the proponent
(SEB) regarding the main technical features of the
project. After this, the floor was open to questions and
comments from members of the public.
At the outset of both the hearings, members of the
public were apprised of the proponent’s objectives for
the hearings, which were to:
·
·
·
·
respond to questions from the public related to
environment and pollution;
learn the reaction of the local people to the project,
including any objections;
understand problems related to development of the
area; and
consider complaints and suggestions about how to
minimize inconvenience and costs and maximize
benefits to local people.
The proceedings of the Parbati Stage III public
hearings reveal that members of the public raised
eight broad issues:
The proponent then made a presentation of the main
features of the project indicating that it “finally ex-
pected to get approval and that the work may start in
the very near future”. The public was told that there
might be some pollution from blasting and the move-
ment of heavy machinery. As well, it was noted that as
a result of the “construction of the dam, and subse-
quent diversion of the water through a surge tunnel,
there would be no water left in the river”. After the
introductory comments, the floor was open to
discussions.
· preservation of the Lakshmi Narayan Temple in
the village Raila;
· prompt assessment and disbursement of compen-
sation for land and property expropriated for the
project;
· the type and number of local opportunities for
employment;
· road alignments and maintenance;
· compensation for downstream watermill operators;
· safety of the public during blasting operations;
· proper management of construction debris to avoid
damage to land and adverse impacts on water qual-
ity; and
Approximately 40 people in Barshaini, and 80 peo-
ple in Sainj, attended the meetings. The hearing
procedure was informal. Collectively, the public at
the two meetings raised the following issues:
· local access to new civic infrastructure, such as
6
8
Impact Assessment and Project Appraisal March 2000

Public involvement in EIA in India
roads, schools and hospitals constructed by the pro-
ject authorities (Himachal Pradesh State Pollution
Control Board, 1998b).
· the potential threat to the cultural heritage of
Malana village, which is known for its unique cul-
tural traditions and social systems; and
·
adequate provision for the proper disposal of debris
to prevent spillage into nallahs and rivers
(Himachal Pradesh State Pollution Control Board,
1998a).
The SEB panelists attempted to address the concerns
raised by the public during the course of the meeting.
In most cases, the SEB indicated it would do its best to
deal with the concerns raised without actually com-
mitting itself to specific action. For example, the pub-
lic was assured by the SEB that:
The issues raised by the public are similar to those
identified in the previous cases. Much of the informa-
tion about the Parbati III and Malana public hearings
was obtained from the proceedings of those events. It
is perhaps not a coincidence that the issues noted in
the panel reports are similar, as are the responses from
the panels. For example, both panels assured the pub-
lic that:
·
·
·
“in the course of implementation all efforts would
be made to ensure that the temple in village Raila
would not be disturbed”;
“local people will be afforded every possible
employment opportunity constant with their quali-
fication”; and
“all blasting operations including storage and use
of blasting materials shall be strictly carried out in
conformity with the norms prescribed by the Con-
troller of Explosives”.
· “adequate security arrangements shall be made in
magazine and handling areas and the transit of
explosives”;
· “the SEB is committed to giving employment op-
portunities to locals commensurate with their
qualifications”;
· “locals will have unrestricted access to health,
roads, and other civic facilities developed through
compensation activities”; and
The hearing proceedings conclude by noting that “the
public endorsed early commencement of the works so
as to realize their aspirations in particular and the eco-
nomic betterment of the State in general”.
·
“the SEB would endeavor to develop natural fish
species”.
Malana
Public hearings in the Malana project were convened
by the SPCB in the village of Jari on March 18, 1998.
The hearing panel consisted of 15 members: two from
local district administrations; three from the SEB; six
members of the public; two from the proponent; and
two from the SPCB. Approximately 100 people
attended.
Similar to the Parbati II proceedings, the report ends
by indicating that “all people were in favour of early
clearance so socio-economic benefits could reach
people early and preventing cost over-runs”.
Patterns in the public’s concerns
The proceedings of the Malana hearings indicate
that the public raised nine broad issues:
As the foregoing discussion reveals, members of the
public at the Parbati II and III hearings were primarily
concerned with social and economic impacts. They
were concerned about both potential adverse impacts,
such as the loss of land and property, and potential
positive impacts, such as employment opportunities
and the development of local infrastructure. They also
raised public safety issues (reflecting a concern for
risks to community health) and the preservation of
cultural resources (the Laksmi Narayan Temple).
Other than potential adverse impacts from im-
proper disposal of construction debris, little attention
·
·
adequate safety provisions during blasting and in
storage of explosives;
adequate compensation for land, including provi-
sions to ensure that people are not rendered
landless;
·
·
·
adequacy of geological investigations with respect
to proposed structures;
compensatory afforestation to mitigate impacts
outside the catchment area;
development and propagation of suitable flora spe-
cies, including herbal species, in the catchment
area (it was noted that, besides controlling soil
erosion, due consideration must be given to soil
quality and landslides);
Other than potential adverse impacts
from improper disposal of
·
·
socio-economic benefits for local residents such as
employment, training and access to civic infra-
structure including the construction of a local
college;
impacts on wildlife and pisciculture and the miti-
gation of adverse impacts, especially in the
downstream diversion barrage where the water
flow would be drastically reduced;
construction debris, little attention
was given to environmental issues
such as loss of forest cover, social
erosion, ecosystem health and
conservation of biodiversity
Impact Assessment and Project Appraisal March 2000
69

Public involvement in EIA in India
was given to environmental issues. That is, nobody
raised questions reflecting concerns for loss of forest
cover, social erosion, ecosystem health, conservation
ofbiodiversity andotherbroad environmentalissues.
As in Parbati Stages II and III, the Malana hearings
devoted considerable attention to social and economic
impacts including loss of land and property, potential
employment opportunities, the development of local
infrastructure, public safety, and preservation of cul-
tural resources. In the Malana case, however, mem-
bers of the public expressed greater concern for
environmental issues. They discussed the potential
for adverse impacts from improper disposal of con-
struction debris, as in the Parbati III case, but they also
raised broader environmental concerns, including
loss of forest cover, socialerosion, andimpactsonfish
and wildlife. Moreover, they raised systemic concerns
reflecting awareness of linkages among issues such as
afforestation, soil erosion and landslide risk.
Overall, the comments and discussions at the pub-
lic hearings appear to have lacked both breadth and
depth. In the twoParbati cases, otherthanthepotential
negative impacts from improper disposal of construc-
tion debris, little attention was given to any other envi-
ronmental issues. The issues that demanded the most
attention related to social and economic benefits for
communities affected by the proposed projects. As
indicated by a SPCB official, these types of concerns
are increasingly being raised at public meetings:
problems or issues); and
· continuous exchange (mechanisms are required for
continuous exchange or interaction).
Relying on this framework, the first public involve-
ment activity in the three cases reviewed in this pro-
ject was a form of ‘information-out’. Two sources of
public information were available early in the
process: Handbook of Environmental Procedures and
Guidelines (Singh et al, 1994); and Guidelines For
Entrepreneurs (Himachal Pradesh State Pollution
Control Board, undated). The government did not pre-
pare these documents specifically for the Parbati or
Malana projects, but as generic sources of informa-
tion regarding environmental approvals.
The Handbook of Environmental Procedures and
Guidelines provides basic information on the indus-
trial licensing procedure, obtaining environmental
clearance, obtaining consent to operate an industrial
unit, and obtaining forest clearance. An Annexure to
the document outlines the EIA notification process
and includes a listing of projects and activities to
which the notification applies. Although this was a
useful document, the authors found it difficult to fol-
low in terms of gaining an understanding of the EIA
process and the relationships among the various ap-
proval procedures. Interviews with four different offi-
cials regarding the EIA procedures outlined in the
handbook improved our understanding but resulted in
a different interpretation of the EIA process from that
offered in the academic literature (for instance,
Banham and Brew, 1996).
Guidelines For Entrepreneurs describes the role of
the SPCB and briefly outlines the process for obtain-
ing a “no objection certificate” (NOC). This may
involve carrying out an “environmental impact as-
sessment” and presenting an “environmental manage-
ment plan (EMP)”. It is not clear from the document
when an EIA is necessary, which proformas must be
filled, or the content of the EIA/EMP, although some
details for EIA are provided. To be fair, it should be
noted that during the research and at the time of writ-
ing, the guidelines were under revision to make them
easier for ‘clients’ to understand.
“
Project proponents often agree to build things
for the local community like health facilities,
schools, cricket pitches, etc. People are starting
to realize that they can ask for such things.”
As well, in all cases, there was limited written, techni-
cal information available to the public in terms of the
socio-economic concerns raised at the hearings, such
as potential employment, compensation levels and
timelines, greatly limiting the depth of the
discussions.
Public involvement implications
These two documents constitute the publicly avail-
able information on the EIA process in Himachal
Pradesh. It can be argued that both are directed to the
proponent and as such, only help the ‘public’ to the
extent that they outline the EIA process. There is no
mention of public involvement in the process nor of
the possibility of public hearings. It is not surprising,
therefore, that interviews in the Kullu district revealed
scant awareness among the public and potential pro-
ponents of the EIA provisions:
Information-out prior to hearings
The review of the legislative framework presented
earlier in the paper revealed few opportunities for
public involvement in India’s EIA process. The case
studies confirm that, in practice, public involvement
opportunities remain quite limited.
Mitchell (1997) identified three basic components
of public involvement programs:
·
·
7
information-out (information must be shared with
those whose views are being sought so that they can
consider the nature of the problems or issues being
addressed);
information-in (opportunities must be provided for
the participants to express their views on the
· “there is not much interest in EA at the local, re-
gional or state level in this area. People in and
around Manali are not aware of such systems…”;
· “…people would be cooperative regarding EA ac-
tivity, but I am not aware of any current provisions
for EA”; and
0
Impact Assessment and Project Appraisal March 2000

Public involvement in EIA in India
·
“people in this region are not so aware of the word
of law in these matters”.
· “I do not expect early action on our demands”;
· “the hearing will bear no fruit — we have been de-
ceived by the government before”; and
· “memorandum of demands will just pile up with
other files”.
Nature of hearings
As indicated in the previous section, opportunities for
public involvement in India’s EIA process are quite
limited. The primary opportunity for involvement in
each of the three cases studied was found at the public
hearing stage of the process. Although hearings often
imply an adjudicative or quasi-judicial forum, the
hearings in the Indian process are more along the lines
of a consultation. Staying with Mitchell’s (1997)
framework described above, the hearings were a vehi-
cle for the proponent and government to provide ‘in-
formation-out’ and gather ‘information-in’. Two
senior SPCB officials noted that:
Of course, skepticism such as this is likely to be
caused by a myriad of factors, not the least of which is
a long, complex history of exploitative relations be-
tween government and local villagers. However, dis-
jointed expectations regarding the role of the hearings
in the EIA planning process could easily contribute to
a skeptical or cynical public sentiment.
Mismatched expectations regarding the role of the
hearings in the decision making process could also
contribute to negative feelings towards the govern-
ment, proponent and the public hearings. Most ob-
servers would expect that public hearings would be an
important element in the process and would occur
prior to a final decision being made with respect to en-
vironmental clearance. In fact, this is the process con-
templated in the EIA legislation. However, some
panel members in the Parbati II project expressed a
contrary perception: “hearings are a formality — the
actual purpose is to get a no objection certificate”. In
addition, government actions and some media reports
thereof implied that ultimate decisions in the Parbati
projects were made prior to completion of the public
hearings. Prior to the hearings it was reported that:
·
·
“The panel is there to listen”;
“The people on the panel do not decide … the Gov-
ernment of India decides”; and
·
“No decisions are made at the hearings, only a shar-
ing of information”.
Timing of hearings
There is no evidence that members of the public were
actively involved in the EIA process prior to the hear-
ing stage, such as at the scoping or environmental im-
pact study stages. Using Smith’s (1982) three-level
model of planning, it is evident that public involve-
ment was limited to the operational level of planning,
in which decisions are made to determine what will be
done. This contrasts with the normative level (in
which decisions are made as to what should be done)
and the strategic level (in which decisions are made to
determine what can be done). As Mitchell (1997) ob-
served, limiting involvement to operational levels of
planning could become problematic if affected
publics perceive their involvement as being tokenism,
borrowing Arnstein’s (1969) language from her clas-
sic ladder of citizen participation.
In fact, this may have occurred in the cases studied
in this project. It appears that at least some members
of the public came to the hearings expecting to deal
with broad normative or strategic issues (for instance,
questions relating to project need and how the need
should be met) but were faced with operational ques-
tions (for instance, where construction debris should
be stored). This prompted one participant to comment
that, “the hearing is the only opportunity for the public
to participate in the case, but the hearing itself offers
limited potential to participate”.
“The Union Government has decided to execute
the 2051 MW Parbati Power Project in
Himachal Pradesh in the central sector.” (The
Tribune, 1998a)
“The much-delayed 2051 MW Parbati Hydel
electric project in Kulu district is all set to take
off with the Himachal Pradesh Government and
the National Hydro-electric Power Corporation
(NHPC) signing an agreement here today to
commence work on the ambitious project. The
Prime Minister, Mr Atal Behari Vajpayee, is ex-
pected to lay the foundation stone of one of
North India’s largest power generation projects
sometime in the first week of December …”
(The Tribune, 1998c).
Process deficiencies of hearings
Although the hearings represented the primary oppor-
tunity for public involvement, the cases revealed seri-
ous deficiencies in the hearings process. As noted
earlier, information available on the EIA process that
could assist people in understanding the purpose and
objectives of EIA is scant and not user friendly.
In regard to the hearings themselves, there was no
indication prior to the hearings of what procedure was
going to be followed or how the hearing panel was
chosen. There was no assistance for members of the
public on how to participate, for instance, how to pre-
pare a brief or make a presentation. There was no
Disjointed expectations could have contributed
also to skepticism or cynicism towards the govern-
ment, proponent and the public hearing process,
reflected in comments such as:
·
“I have doubts about the implementation of various
assurances — it could be another political
gimmick”;
Impact Assessment and Project Appraisal March 2000
71

Public involvement in EIA in India
detailed EIS as late as 14 days prior to the hearings.
Although the public does not have access to detailed
EIA documents prior to the hearings, it does have ac-
cess to EIA project reports and environmental man-
agement plans for cases that have already received
their no-objection certificates. However, these docu-
ments cannot be removed from the SPCB office and
photocopying is not allowed. The study team found
that, in the cases of Parbati II and particularly Malana,
the EIA reports were very poorly written and difficult
to follow. In the case of Malana it was not even possi-
ble to discern a clear project description.
Although the hearings were the
primary oppportunity for public
involvement, there were serious
deficiencies in the process:
information available on the purpose
and objectives of EIA that could assist
public understanding is scant and not
user friendly
With respect to EIA documents generally, one gov-
ernment official indicated that:
background information provided on what an envi-
ronmental impact study should contain or how to cri-
tique such a document. Obtaining expert assistance
was not promoted in any way and funding was not
available to public participants. Members of the public
had to cover their own ‘traveling and incidental costs’,
which would have been a significant burden for most
villagers. Finally, there was no indication of how pub-
lic input provided at the hearings was going to be used
in the decision making process.
“there are about 60 hydro projects coming up
along the Beas. There will be lots of problems
with muck in the rivers. No teams of interdisci-
plinary experts have been set up for the EIA and
there will be no monitoring. In the mountain
areas there should be more focus on the com-
munity — they should decide what projects go
ahead. The public hearings are not working
right. The project is put in front of people and
they only see the project as development — tea
stalls, shops, roads, etc. They are not told that
their water is going to dry up or become pol-
luted, etc. People need more information to be
made aware of all aspects of the project. Profes-
sionals have to help to make people aware.”
Operational deficiencies of hearings
The case studies revealed a number of deficiencies in
implementing the requirements mandated by the
legislation. In the three cases considered, the notice of
public hearing indicated that, “Interested per-
sons/groups/organizations may inspect the project ap-
plication and EIS proposed to be submitted by the
project proponents in the office of the Assistant Envi-
ronmental Engineer, SPCB, Kullu between 3 and 5
P.M.”. This opportunity was to be available for a
period of 30 days prior to the hearings. In fact, what
was made available to the public was an executive
summary of the EIS, as required by the legislation.
The summary could be reviewed in the Assistant
Engineer’s office but could not be removed, and
photocopying facilitates were not available at the
Kullu offices of the SPCB.
The summary documents were written in technical
language without providing a glossary of key terms.
There was no consideration of the potential environ-
mental implications of the project with the exception
that “safeguards for maintaining the environmental
balance” were noted, for instance, anti-poaching laws
will be enforced, kerosene will be provided to workers
and no grazing will be permitted. The summary docu-
ments were only available in English, despite the legal
requirement for translation into local dialects. There
was also no attempt to present the case information in
forms other than written prior to the public hearings,
despite the low rate of literacy in the District.
With respect to any of the information that is available
to the public, physical access could be a problem for
many villagers in the study area. In the case of Parbati
II, people local to the project area would have had to
travel 15 kms by foot, followed by over 50 kms on two
buses to get access to the executive summaries. If they
wanted access to the detailed EIS reports after a
no-objection certificate had been awarded, they
would have to travel to the state capital Shimla, at
least a day trip away.
Finally, some of the logistics of the hearings them-
selves may have been a deterrent to widespread public
involvement in the process. Changing the location of
one of the sessions of the Parbati II hearing twice,
once on the day of the hearing, is likely to have dis-
couraged participation and led some to question the
value of the process.
Contextual constraints
In addition to the problems associated with timing of
the hearings and the process and operational deficien-
cies reviewed in the foregoing discussion, larger con-
textual constraints also probably impinged on public
involvement in the EIA process. Some of these
constraints are reviewed in the ensuing discussion.
The public did not have access to the detailed EIS
Project Report prior to the public hearings. In fact, the
project proponents in the Malana case indicated to the
study team that the documentation was “secret”. In the
case of Parbati II, the proponent had not completed the
Economic development Other than Manali, economic
development has been slow to reach most areas of the
7
2
Impact Assessment and Project Appraisal March 2000

Public involvement in EIA in India
Kullu District. Poverty is still high, many areas lack
basic education, health and other services, and local
peoplehavea very strongdesiretoattract jobs through
local development activities. Many from outside of
Manali believe they are missing out on the opportuni-
ties economic development has brought Manali and
strive for the same. The president of a local non-
governmental organization indicated with regard to
a large hotel complex currently under construction
that:
“The culture here is very laid back. People don’t
want to get involved in others’ business.”
“It is a small community. I used to try to put my
foot down [regarding development] with the
District Commissioner but I made so many ene-
mies it was not worth it.”
“If he can build a hotel, why not me. We have a
democratic system so they just talk to friends in
government and get permission. We are proud
of breaking the rules.”
“
there was nothing — no meetings by the State
Government or builder. The environment
should be considered in these decisions but it is
difficult because the area needs jobs. People are
not so rich in this area and have to make business
in two or three months so new development is
positive.”
“There should be some environmental clearance
for hotels and hydro projects coming up but
these people have the money, power. There is
little local people can do.”
Education The low level of literacy in mountain re-
gions has already been mentioned. It is likely that
literacy is an important factor affecting public
involvement in the EIA process: “I saw some sort of
advertisement in the paper regarding hydro projects
— was thinking of writing. Most people of the area
will not come forward. Most are illiterate or are from
out of the Valley…”.
In addition, lack of awareness of local environmen-
tal conditions is probably a powerful constraint to ac-
tive public involvement. The evidence regarding
awareness of the environment on the part of local resi-
dents in the study area is actually mixed. It would be
easy to conclude that, in at least the Parbati cases, resi-
dents were unaware of the environment and poten-
tially related impacts of development, rendering the
environment a non-issue at the hearings. Indeed, some
local officials have come to that very conclusion. One
commented that, “People in this area are not aware of
the environmental problems caused by development”.
Another said, “One thing that is missing in the Valley,
people are not educated. They do not understand all of
the implications of development”.
Another commented that, “the environment should be
considered in [decision making] but it is difficult be-
cause the area needs jobs”.
Institutional capacity Institutional capacity intheDis-
trict and the State of Himachal Pradesh as a whole is
also an issue. Most of the large ENGOs (environment-
al non-governmental organizations) and NGOs in In-
dia are not active in the northern region of the country.
Despite the size of the Parbati project, no ENGOs or
NGOs made presentations at the public hearings. As
one local individual indicated, “Government plans
and programs like EA are bound to fail because there
are no institutions to implement them in the moun-
tains”. Another noted that “the government does not
have the infrastructure to do the work. That is why
they have formed NGOs. These groups have failed,
however, in regard to development in this area”. To be
fair though, the leader of one ENGO indicated that his
group deliberately refrained from participating in the
Parbatihearings soasnot todetract fromtheparticipa-
tion of local residents.
The Kullu District, and broader region, also has
difficulty getting and keeping permanent govern-
ment officials. Many local people complain that the
officials making decisions about development,
schools, forests, and other issues are from outside of
the region. They have no connection to the area and
However, contrary to the conclusions of the local
officials, considerable evidence suggests that vill-
agers in the Kullu Valley may be well aware of local
environmental issues, the problems caused by devel-
opment and potential solutions. First, through inter-
views with local villagers in an earlier study, Duffield
et al, (1998) were able to discern locally derived
sustainability indicators applicable to the Manali area.
Second, in this study, members of the public at the
Malana hearings not only raised concerns about spe-
cific environmental problems, they expressed con-
cerns about linkages among various ecosystem
components. Finally, further evidence from this study
indicates that residents of both Kullu (town) and
Manali are aware of the potential environmental im-
plications of development:
“
leave their posts too often”. One government offi-
cial noted that, “if a man indicates that there are prob-
lems with a project some higher-up will say you are
slowing the project and he will get transferred”.
These conditions make it difficult for effective
implementation of public policy, including public
involvement in EIA.
Local culture Local cultural variables could also have
had an impact on the level of public involvement in
the cases reviewed. The following quotations from in-
terview participants are diverse in their substance but
reflect a common reticence to become actively in-
volved in matters of development:
“development is out of control and we need en-
forcement of laws like SPCB and EA to bring
peopleundercontrolandprotecttheenvironment.”
Impact Assessment and Project Appraisal March 2000
73

Public involvement in EIA in India
“
buildings are coming up like mushrooms in the
be of most use to the proponent, difficult to access and
not user friendly.
valley but nobody is checking for their environ-
mental impact.”
In the present circumstances, the only vehicle for
public involvement is the public hearing. Yet it was
found that the ‘hearings’ were not hearings at all.
They would be better described as consultations,
since no adjudication or decision is made at their con-
clusion. The panel is just there to listen. Also, the
hearings occur at the operational level of planning
which limits the types of issue raised and considered
by the public that warrant the panel’s attention. More-
over, if a local person were to pick up a newspaper it
would probably seem evident to them that the deci-
sion to proceed with development had occurred prior
to public hearings taking place. At the least, these fac-
tors lead to public skepticism of the process.
As one person noted, “One can make their concerns
felt/known at public hearings but it is a black box after
that. It helps the government perhaps regarding the
politics of public relations for their plans”. The fact
that reports of proceedings from both the Manali and
Parbati III hearings ended with a general statement
like “all people were in favour of early clearance so
socio-economic benefits could reach people early and
preventcostover-runs”, stronglysupports thisclaim.
Many process and operational constraints, such as
inaccessibility of information, lack of familiarity with
EA, lack of financial assistance to participate, chang-
ing hearing locations and the use of technical lan-
guage all hinder serious public consideration of these
projects. These are not new issues in developed and
developing world EA processes. The World Bank
Environment Department (1993) recognized that
effective consultation in developing countries must
include wide dissemination of information, two-way
communication with a wide sampling of affected peo-
ple, and the provision of feedback on results of consult-
ation to avoid many of these constraints.
“
There is too much construction going on in
Manali and the Valley which is contributing to
deforestation. This has resulted in impacts on
the ecology which is responsible for flooding,
cloud bursts, etc.”
“
… over-cutting is occurring in the forests and
needs to be reduced. This is causing some of the
problems with cloud bursts.”
“
Exploitation of nature unscientifically is occur-
ring in the Valley. We want roads but we want
the fragility of the Valley considered in their
construction … now they just wash away and
take trees and soils away.”
“
just 15 years back the hills were green and river
banks protected. With population increases,
people from outside they move here for
work/hotels. This is increasing the burden on the
forest, especially in the winter for heat which in
turn is causing other problems.”
The same local officials who concluded that residents
were unaware of the environment and the impacts of
development also called for more and better education
in the region:
“government should introduce a subject in
schools about the environment.”
“
“
we need a good college in the area.”
college should be built up so that young people
can get a better education.”
Contextual issues were also revealed as being con-
straints to effective public involvement. The lack of
basic services, such as schools, hospitals, and phones,
all underscore the people’s desire for further eco-
nomic development in the area. In addition, there was
a general perception that the local people lacked the
capacity to engage fully in EIA because of their lack
of education and environmental awareness.
This last point was shown clearly not to be the case
and perhaps offers the best opportunity to improve
public involvement in EIA. Local people are environ-
mentally aware and are concerned about what is hap-
pening to ‘their environment’. The challenge is to
engage them in the decision making process more
effectively. A fruitful area of further research in this
regard would be to explore the application of informal
adult education as a strategic component of EIA.
The issues explored in this paper confirm the need
for policy makers to consider fully a diverse array of
constraints to the effective implementation of legisla-
tive initiatives. In developing countries, an effective
public participation strategy should not assume that
people have the time, willingness, organization and
Conclusions
Results show that, despite the rapid pace of develop-
ment in general, and for hydro development specifi-
cally (there are some 318 small hydro projects
underway or proposed in the state of HP alone), a criti-
cal element of the environmental approvals process,
namely environmental impact assessment, is in its
nascent stages in this area of the Indian Himalaya. As
one local individual suggested “there is a failed record
of EIA in the mountains. Development of roads, dams
etc. has followed a technocratic model that has failed
the environment and the people”.
Further, detailed consideration of the three EIA
cases that have been undertaken in the Kullu District
revealed few opportunities for public involvement
within EIA in India as it is applied in the mountains.
The involvement activities that occurred outside of
hearings were found to be in the form of ‘information
out’ only. The information available was also found to
7
4
Impact Assessment and Project Appraisal March 2000

Public involvement in EIA in India
Report 1996–97 (Himachal Pradesh State Electricity Board,
Shimla, India) page 89.
Himachal Pradesh State Electricity Board (1998a), Executive Sum-
mary: Environmental Impact Assessment Report, Parbati Hydro
Electric Project Stage-III (501 MW) (Himachal Pradesh State
Electricity Board, Shimla, India) page 14.
Himachal Pradesh State Electricity Board (1998b), Executive Sum-
mary: Environmental Impact Assessment Report, Parbati
Stage-II (800 MW) (Himachal Pradesh State Electricity Board,
Shimla, India) page 17.
resources to participate (World Bank Environment
Department, 1993). This may be possible in some
parts of India where the institutional capacity exists,
but is not the case in the high mountain rural areas of
the country. In these situations, extra steps must be
taken to facilitate public participation and make the
EIA process effective, efficient and fair.
Himachal Pradesh State Pollution Control Board (1998a), Proceed-
ings of the Environmental Public Hearing held in connection with
proposed Malana Hydroelectric Project on 18.03.1998
(Himachal Pradesh State Pollution Control Board, Shimla,
India) page 4.
References
S Arnstein (1969), “A ladder of citizen participation”, Journal of the
American Institute of Planners, July, pages 216–224.
P N Bakshi (1998), The Constitution of India (Law Publishers,
Allahabad, India).
W Banham and D Brew (1996), “A review of the development of en-
vironmental impact assessment in India”, Project Appraisal,
Himachal Pradesh State Pollution Control Board (1998b), Proceed-
ings of the Environmental Public Hearing Held on 27.08.98 in
Respect of 501 MW HEP-Parvati Stage-III in Larji and Sainj of
Distt. Kullu (Himachal Pradesh State Pollution Control Board,
Shimla, India) page 4.
Himachal Pradesh State Pollution Control Board (undated), Guide-
lines for Entrepreneurs (Himachal Pradesh State Pollution
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