A Six monthly compliance report is a self-declaration made by the proponent on a six-monthly basis on certain aspects of their project. It includes a compilation of the status of different general and specific Compliance Environmental Clearance (EC) conditions. As per EIA Notification 2006 proponent needs to submit half-yearly compliance reports in respect of the stipulated EC conditions in hard and soft copies to the ROs/SPCBs concerned on 1st June and 1st December of each calendar year. Fulfilling EC post-compliance conditions is crucial in maintaining the validity of the EC. The Standard EC conditions are considered by the Expert Appraisal Committee at the time of Appraisal. EAC, after due diligence, can modify, delete and add conditions on project-specific requirements. The recommended condition by the EAC will be brought in the minutes of the meeting of the Expert Appraisal Committee. This legal responsibility of post-compliance starts immediately after the grant of EC, and so the implementation of the EC conditions must be done as soon as the proponent is provided with conditions of environmental clearance. In this article, you will find all about the six monthly compliance reports ranging from the report submission process to the role of comprehensive reporting for the seamless functioning of your project.
Conditions of Six Monthly Compliance Reporting
A six-monthly compliance report has to be submitted throughout the validity of the EC as a part of compliance with environment-related conditions. The proponent’s declaration is monitored by the Regional Offices of the MoEF&CC to ensure the adequacy of the suggested safeguards and undertake mid-course corrections required, if any. In the event of non-submission of six monthly compliance reports by PPs, MoEF&CC could take action as deemed fit under the provisions of the Environment Protection Act, 1986.
The Six monthly compliance reporting conditions include the applicable statutory compliance, along with monitoring and preservation conditions to safeguard the surrounding environment, and the project proponent must comply with all of them. If, for whatsoever reason, there is difficulty in fulfilling the compliance, the valid reason and the present status of the compliance must be indicated.
General Conditions of EC Post-Compliance
- For category ‘A’ project, it is mandatory for the project proponent to make public the EC granted along with the conditions and safeguards that they are required to observe and implement. This includes advertising it at least in two local newspapers of the region/district/ state where the project is located at their own expense and permanently displaying it on their website.
- For Category ‘B’ projects, irrespective of its clearance by MoEF / SEIAA, the proponent needs to advertise in the newspapers indicating that the project has been accorded environment clearance and the details of the MoEF website where it is displayed.
- Copies of the EC must be submitted to the Heads of local bodies, Panchayats and Municipal Bodies in addition to the relevant offices of the Government, such as MoEF/ SEIAA, who have the authority to display it in the public domain on the Governmental portal.
- Along with it, the proponent must also adhere to energy conservation and waste management measures.
Submission of Six Monthly Compliance Reporting
The proponent has to Fill out the form for uploading six monthly Compliance Reports on the Parivesh portal after generating their ID and Password and then submitting the Compliance Report.
An E-KYC has to be done by the proponent before uploading the self-compliance. Proponent can upload supporting document that contains information related to the self-declaration. The documents needed at this stage will include
- Details of Production and Project Area
- Date of Commencement of Project/Activity
- Project Area as Per EC Granted (In case of mine lease)
- Actual project area (in case of mine lease)
- Production capacity
- Last site visit report (pdf/jpg/jpeg/png and as per the size limit specified)
- Last site visit report date
- Additional attachment (pdf/jpg/jpeg/png)
- Any additional Remarks
After that, the proponent can proceed with E-authentication and submission of a six-monthly compliance report. Before submission, the proponent also has the option of verifying their six-monthly compliance reporting.
How to Prepare an EC Compliance Report?
Proponent can directly upload the EC condition or click on the +Add button provided on the profile page of the portal to add the prior accorded EC if it is not available on the PARIVESH portal. The proponent can modify the existing EC proposal or fill in all required fields if details are not available. The proponent can give the details of the amendment EC granted details and upload the EC condition in provided format, either by means of an Excel Sheet or manually. After saving the details of EC, the proponent can finally upload their six monthly compliance report.
Note: Once the proponent has added the self-compliance, the page will be directed to the main form. The proponent needs to upload the self-declaration against each and every EC condition.
EC Compliance and Monitoring
The monitoring cell of MoEF&CC is responsible for the supervision and coordination of all the functions assigned to the ROs. MoEF&CC resolution of January 2014 regarding the mandate of the ROs for Environmental Management and Pollution Control functions, perform tasks such as implementing conditions and safeguards laid down for projects when environmental clearance was given and analyse the six monthly progress reports. This is required to maintain liaison and provide linkage with the State Governments and other stakeholders.
Importance of Six Monthly Compliance Reporting For The Proponent
In case of non-submission or violation of EC conditions, punitive action can be taken by the MoEF/ SEIAA, as per the Environment (Protection) Act 1986, for the breach of the EC conditions. The MoEF&CC has the power to:
- Direct closure of the project:
- Prohibit or regulate the industry operation or process; or
- Stop or regulate the supply of electricity or water or any other service.
EC compliance reports submitted by the proponent are public documents and accessible online. Six Monthly Compliance reporting is mandatory not only for new projects but also required whenever EC is accorded. This means that Six monthly compliance reporting will be required in case of modernisation or expansion of existing projects that have been notified under the EIA notification 2006. Therefore, the project proponent must ensure that the environmental mitigation measures described in EC compliance and Environmental Management Plan are being implemented without fail during the construction and operation phase. This requires due diligence from the end of the proponent as well as the assistance of environmental experts. The agency conducting EIA must be fully conscious of environmental management and have experience in handling any crisis.
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