little, since nobody bothered to specify exactly which part of the 'Environment Management Plan' was to be pari passu with which part of the 'engineering and other works'.
To complete the illusion of firmness, the Ministry went on to insist that the proposed body "should possess the authority to stop the engineering and other works by all means including withholding of sanctions, approvals, tenders, contracts and funds to ensure that the Environmental Management Plan gets implemented as per the approved plans and time schedules. The powers to withhold funds should be applicable to the funds made available from the State, the Centre and the foreign agencies."
Even the MoEFs highly critical assessments of the environmental implications of SSP were severely limited, leaving out vital aspects such as the impacts on the command area and the downstream ecosystems. In private, MoEF officials dealing with the subject have always maintained that SSP (and NSP) should not have been cleared. The complete failure of the "pari passu approach" has recently been highlighted in a paper on the SSP by a senior MoEF official who has been involved in assessing river valley projects since the inception of such assessments (Maudgal 1993). He has suggested that this approach should be abandoned since it allows project authorities to completely subsume environmental concerns to the exigencies of construction schedules, and results in a failure to adequately safeguard the environment.
The environmental implications of the SSP were so serious, that when the MoEF finally capitulated in 1987, it still gave only conditional clearance to the project (MoEF 1987a). It is well known that the conditionalities were put in only due to the insistence of a few courageous officials of MoEF, who refused to give up even when the pressure became well-nigh unbearable. It was a brave but ultimately fruitless gesture. What was supposed to mean `we will let you build the dam, but only if the following conditions are met' was effectively interpreted as `the dam is environmentally sound, because the MoEF has cleared it (and never mind the conditionalities)'. This was the case with both the clearance given on environmental grounds in 1987, as also the clearance given under the Forest Conservation Act later that year. Over subsequent years, project authorities have conveniently blanked out the conditional nature of their 'license', and the Ministry of Environment and Forests has remained powerless to revoke this 'license'.
What does "conditional clearance" mean ? As far as we am concerned, the very act of setting time-bound conditions implies that if the conditions are not met within that time frame, clearance would automatically lapse, and thus all further work would be in violation of the law . Conditional clearance is irrelevant if it doesn't mean this.
And now we come to the conditions themselves. In the case of the environmental clearance, the most important conditions were about the acquisition of data (surveys and studies) within a stipulated time frame. This was done to allow an accurate assessment of the environmental problems to be made and necessary ameliorative and mitigatory measures to be taken. In addition, the complete Catchment Area Treatment Programme and the Rehabilitation Plans were required to ensure that these were completed before the reservoir