Pollution control is not a priority

The Times of India report, “Order industries to bear cost, CPCB requsts NGT” (Aug 26, 2016), illustrates the bureaucratic setup by the state and central governments for pretending to be doing something about the Periyar pollution, without producing actual results.

The report says, “The Central Pollution Control Board (CPCB) has pleaded to the National Green Tribunal (NGT) to direct polluting industries to bear the remediation cost to save Periyar in Eloor area.” [2, 3, 4]

“The treated effluents should not be discharged through Kuzhikandom canal as it may continue to wash the sediments further down the creeks. The flow has to be contained to facilitate remediation activity. Therefore, the industries should be directed to submit a time-bound action plan to stop discharging treated effluents to the canal, the board submitted.”

“It said that multiple contaminants including DDT, endosulphan, chlorobenzenes and metals such as manganese, vanadium, zinc and chromium have been found in soil, groundwater, sediment and surface water and immediate steps need to be initiated to rejuvenate the river body.”

Apparently, the Central Pollution Control Board (CPCB) and the Kerala State Pollution Control Board (KSPB) do not have any real authority. KSPB appeals to the CPCB, and CPCB in turn appeals to the National Green Tribunal (NGT). If governments were serious about solving pollution problems, KSPB would have had real authority. (And provided an appeal process regarding its decisions.). An empowered KSPB would have been able to take action on its own. For example, shutdown a polluting plant. Instead, it has to go through laborious legalistic procedures, while the pollution problems continue to deteriorate. Even though it was determined that Eloor region is one of the most polluted places in the world in 2006, no real action to control pollution has been taken so far.

The CPCB pleading to the NGT is also meaningless. Most of the polluting companies are running at a loss. So even if the NGT rules that the companies to bear the remediation costs of the pollution, it won’t produce any tangible results. The current situation is the result of bad industrialization policies in the 1930s. And time has shown that chemical industries are a disaster for kerala.

So the logical course of action is to close down the loss making chemical factories, and the Kerala Government to assume the cleanup costs. In addition, implement an Eloor-Edayar Redevelopment Program. Anything else will be prolonging the misery of the people in the Eloor area, and further collapse of the Periyar ecosystem.

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Redevelopment of Eloor-Edayar region

The Times of India report, “CPCB report shows need for urgent action” (Aug 24, 2016), illustrates another instance of decentralized responsibilities resulting in gridlock, health hazards, and government agencies lacking purpose.

“A report submitted by the Central Pollution Control Board (CPCB) before the NGT (National Green Tribunal) on action to be undertaken in the Eloor-Edayar contaminated area, says remediation measures are to be given utmost priority.”

In addition, “It says that multiple contaminants including DDT, endosulphan chlorobenzenes and metals such as manganese, vanadium, zinc and chromium have been found in soil, groundwater, sediments and surface water and that immediate remediation measures must be taken to rejuvenate the water body.”

Kerala State Pollution Control Board (KSPCB) had informed CPCB that “the four main industries identified (causing the pollution) were Hindustan Insecticides Ltd (HIL), Fertilizers and Chemicals Travancore Ltd (FACT), Merchem and Indian Rare Earths (IRE).”

The report adds, “A preliminary investigation of the Eloor area [2] was carried out in 2006 wherein it was found that the soil and sediments in Kuzhikandom Thodu (creek) and the adjoining paddy fields are contaminated (pdf) with DDT (dichloro-diphenyl-trichloroethane) [2, 3, 4], BHC (Benzene hexachloride) [2, 3] and endosulphan [2, 3, 4],” and more.

Besides, “The NGT is hearing a petition filed by local residents demanding zero-discharge by industries into the Periyar. Periyar Maleenikarana Virudhha Samithi (PMVS), an NGO which is in the forefront of protests against the pollution of the river has a Clean Periyar Green Periyar action plan on the lines of the Ganges Action Plan.”

The report adds additional details: “The Eloor-Edayar industrial cluster is home to more than 280 industrial units, out of which 75 are in the red. The discreet discharge of trade effluents and waste in slurry form into Periyar has turned the river into an illegal “Treatment Storage and Disposal Facility (TSDF), the Supreme Court Monitoring Committee on hazardous waste has observed.”

Many state and central government agencies are involved in controlling or preventing the Periyar river pollution. But the net result, as the Supreme Court says, is “the river Periyar has has turned into an illegal ‘Treatment Storage and Disposal Facility.” Even with all these agencies, pollution control is practically non-existent, and “massive fish kill is a frequent phenomenon downstream of river Periyar.” (“75% of waste water released back into river”)

One thing striking about the situation is that in spite of the state and central government agencies (Central Pollution Control Board, Kerala State Pollution Control Board. National Green Tribunal) to protect the environment, it is the NGO, Periyar Maleenikarana Virudhha Samithi (PMVS), that is actually trying to do something about it through legal action.

Greenpeace India reports, “Eloor has become one of the most toxic parts of the country and figures on the list of most polluted areas put out by the Central Pollution Control Board in India. Poisoned land, waters and air, hreaten the health and very existence of people and the ecology of the area. Polluted rivers transport the toxins over much larger distances endangering more people and other living creatures.” [2]

In addition, the Status of Human Health report says, “Contrary to the expectations based on the initial literature survey about possible increases in particular types of diseases due to air and water pollution; this health assessment has discovered that there is an overwhelming increase in most types of systemic diseases across Eloor (target village) when compared to Pindimana (reference village). Broadly one can say that the cocktail of poisons in the air and water of Eloor affects all body-systems adversely. Potentially the immune system seems to be affected too.”

The Kerala State Pollution Control Board produced a “preliminary” report stating that there is a serious problem in 2006. The polluted Eloor-Edyaar site was selected as one of the priority sites in the country needing remediation under a National Clean Energy Fund (NCEF) project to be executed by CPCB. The Central Pollution Control Board produced a report and submitted to the National Green Tribunal, which is conducting a hearing on the issue. It looks the state and central governments are geared towards producing reports and conducting legal proceedings, but not taking action. Since nothing was been done even after the 2006 report, the NGO (PMVS) petitioned the Supreme Court, which concluded that the polluted site, which in reality should be nourishing river, has turned into a “illegal Treatment Storage and Disposal Facility” for highly toxic pollutants.

Finding a real solution means going into history to understand the causes of the current problems. The origin of the problems started in the 1930s with the decisions of the Travancore Administration to establish chemical industries for economic development. “A policy decision of the Travancore administration in the 1930 — to attract large-scale, chemicals-based industries to the State by the advertisement of cheap hydroelectricity as the basis for industrialization,” says Jayan Jose Thomas, an an Associate Professor at the Indian Institute of Technology Delhi. Unfortunately, it was an administrative policy decision lacking sound industrial development plan and follow-up actions.

Industrial scale chemical production, to be viable, need to act as a feeder to a strong supply chain manufacturing derivative products. Downstream industrial ecosystem failed to develop for the these chemical factories. Most of the industrial production, especially chemical industries, are centered around the MumbaiPune [2, 3] metro-regions in Maharashtra [2, 3, 4] and Gujarat [2, 3, 4]. With underdeveloped transportation systems, it was not feasible for Kerala based chemical industries to be viable suppliers to those distant regions. As a result these industries have been stagnating, except when India operated a centrally planned economy. Most of these industries now are not profitable, making it impossible to implement effective pollution control systems.

The logical solution is to disband results of the 1930s failed industrial policy and create a redevelopment plan for the region. However, it needs to be implemented after a careful review of the possibilities. Some parts of the chemical factories and businesses in the Eloor-Edyaar region are profitable and can be self-sustaining. A redevelopment plan need to be formulated consisting of these components:

  • Identify factories and businesses with current and long-term sustainability
  • Identify factories and businesses without current and long-term sustainability
  • Implement assistance programs to strengthen factories and businesses with long-term sustainability to incorporate strong pollution controls
  • Implement assistance programs to help factories and businesses that do not have a sustainable future to exit or migrate to other areas/ sectors
  • Develop and implement a cleanup plan for the Eloor-Edyaar region to remove accumulated pollution
  • Make Eloor-Edyaar redevelopment part of a Kerala Transformation Plan

Such a comprehensive approach is necessary to solve the pollution problems in the Eloor-Edyaar region. Bandage efforts like offering financial loans will not produce a permanent solution.

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Wishy-washy government programs

The Times of India feature, “Transforming traditional sectors” (Aug 14, 2016), reveals the wishy-washy thinking prevalent in the Kerala Government.

The report says, “The need of the hour is a comprehensive strategy that would lead to the region’s sustainable development.”

“Only 7-8 per cent of our coastline is ecologically stable.” But, “Kerala’s 590-km coastline is home to 20% of the state’s population.”

Promising immediate action to address the woes of the cashew industry under her portfolio, J Mercykutty Amma, minister for fisheries, and harbor engineering, remarked, “The industry is in chaos. It is now completely dependent on import for for raw material. 600 out of the 800 factories have shut down and intermediaries are stealing all the benefits. There will be strong intervention to restore some order in the sector in the next six months.”

T Peter raised the concern of plastic waste dumping and discharge of sewage into water bodies. “A fund of Rs 15,000 ($225) has been granted to each ward for the purpose. An intensive awareness and monitoring campaign and strict regulations have been initiated to bring about a change in coastal pollution,” she explained.

Rajmohan Pillai lamented that Kerala’s cashew industry which used to control 97% of the world market had now fallen to a measly 11% and called for measures to improve productivity. “An empowered committee has been appointed to suggest steps to rejuvenate the sector financially,” the minister replied. “My dreams are big and in the next five years, I plan to initiate a process that would engender a revolutionary transformation in these sectors,” she concluded.

“Local Self Governments Department is linked to the daily lives of people and giving power to the people is our priority,” said K T Jaleel, minister for local self governments, welfare of minorities, wakf and Haj pilgrimage. “A corruption-free Kerala is our aim and as the first step, we will start with the LSG department. A website named “For the people,” will be launched by October, through which common people can interact with the officials in the department. From peon to the minister, if anyone has a bitter experience from anyone in the department they can complain and immediate action will be taken,” he informed.

Shaji Joseph talked about the poor quality of the works done by LSG (local self government) Department. The minister said, “The Consumer Protection Forums were established to ensure quality of work but unfortunately it is not happening.”

For the cashew industry, the problem is “government intervention.” What is needed is for the government to create conditions for a thriving cashew industry by encouraging and supporting private businesses to grow cashews trees, process cashews, and create derivative products. A necessary first step will be to define a “Mission and Vision” for KSCDC (Kerala State Cashew Development Corporation Limited).

Granting Rs 15000 ($225) to each ward and focus on awareness campaign demonstrates utter lack of understanding of the waste/ garbage problem. Waste and garbage are intrinsic part of a consumer economy. The first step is for local governments to take responsibility for waste/ garbage clean up to implement systemic solutions.

“A corruption-free Kerala” is good aim. However, building a website will not achieve it. People are not interested in “interacting with officials in the department” and have “bitter experiences.” What they need is efficient processes that deliver the services the LSG department is responsible for. For example, Consumer Protection Forums are “Red tape paradises.”

If the ministers are genuinely interested in bringing about transformative changes in their respective ministries, they need to do more than make wishy-washy proclamations, platitudes and token actions. Since the proposed programs do not take into account the full scope of the problems, but propose token solutions, the problems continue to grow and fester.

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Waste and garbage are intrinsic part of consumer economy

The Times of India report, “Corp plans to privatize waste disposal” (Aug 1, 2016), exposes lack of basic understanding of the role of government by Kochi Corporation.

The report says, “The corporation’s garbage removal system in the Fort Kochi area is pathetic. Fort Kochi [2, 3, 4, 5] is a big part of the tourism industry. However, garbage is not effectively removed from the area. Moreover, the proposal to privatize garbage removal and treatment at Fort Kochi was presented in the budget,” said an official from the health department.

The official added that the proposal would soon be presented before the council. “The civic body is planning an open tender, in which private firms from across the country can participate. The firm that wins the bid would be asked to clean the entire area at least twice a day.”

It seems the Kochi Corporation official has lost common sense. Since garbage is an all India problem, why would any “private firms from across the country” would participate in the bidding. If viable opportunity exists, the private firms would process the garbage in their own backyard. Why would they be interested in coming to Kochi to process garbage?

The problem starts with misunderstandings or lack of understanding of a government’s role, One of the basic roles for a government is providing “public good.” Clean environment is a “public good.” There is no profit in garbage removal and waste management (except in some cases involving recyclable materials). A private business, on the other hand, is a profit-seeking organization. Hence, Kochi Coporation should not surprised if there are no bidders for their tender.

Garbage and waste are an intrinsic part of a consumer economy. Successful waste management systems in Nepal, Japan and Sweden are based on the local governments taking responsibility for garbage and waste cleanup.

If Kochi Corporation is serious about solving the garbage/ waste problem, it would stop looking for shortcuts and gimmicks. Instead, will take the initiative to implement an effective waste management system that other parts of the state and country want to emulate.

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A government lacking purpose

The Times of India report, “Energy plant: Corp exudes optimism” (Jul 16, 2016), provides an illustration for an “overdeveloped government for an undeveloped economy.”

Your report says, “Even though the minister for local administration K T Jaleel made it clear that the Rs 296-crore ($44.4m) waste-to-energy project to come up at Brahmapuram [2, 3] will be reviewed, the Kochi corporation authorities are hopeful of implementing it.”

The report adds, “The minister said that the technology to be used in the waste-to-energy project is gasification, a method that has never been tested and proven successful in our country. At the same time ruling front councilors said that the doubts raised by the Suchitwa Mission and Kerala State Electricity Board regarding the technology to be used for waste treatment and energy and viability have already been answered by the company (GJ Nauture and Energy Care Ltd).”

T J Vinod, deputy mayor, said, “We do not know on what basis the minister made such a remark on the project. We will respond to it only after receiving an official communication.”

It is heartening to learn that the local administration minister, K T Jaleel, plans to “review” the waste treatment project by the Kochi Corporation. However, Kochi Corporation seems not to be happy with oversight by the Kerala government. It seems Kochi Corporation would rather the Kerala government let it operate in its own “lackadaisical ways.” Here are some of the examples:

If Kochi Corporation were to operate true to its purpose, It would be able to identify the primary objective — waste management — and would not get distracted with energy generation. Or, it would let the KSEB, the electricity provider for the state, decide the viability of waste-to-energy scheme. Or, use some logical reasoning and accept the conclusion of experts that waste-to-energy method “reliability is far beneath the well-proven waste incineration.”

Instead, Kochi Corporation dreams up a “beautification” project for the waste disposal site.

What is even more striking is the lack of enthusiasm for the Japanese government offer to setup a pilot waste treatment plant for free [2, 3]. What is holding up moving forward with the Japanese offer?

It is high time Kochi Corporation understood the purpose for its existence.

The impact of the malfunctioning Kochi Corporation is not limited to Kochi city. Being the “commercial capital” of Kerala, a disproportionate amount of resources are being allocated to Kochi for potential development of Kochi as a regional metropolitan economic center for the whole of Kerala. By engaging in “lackadaisical practices,” Kochi Corporation is inhibiting and preventing the economic development of the whole state.

If Kochi Corporation were to take its proper role, it would set an example by implementing an effective waste management system that other parts of the state and country can emulate.

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Kerala model’s mutation over the years

By K V Joseph – The pattern of development, which ushered in Kerala during the third quarter of the 20th century, attracted worldwide attention.

It was eulogized as an ideal form of development as Kerala could achieve impressive level of improvement in various social indicators without a corresponding development of the economy.

The growth of consumerism has paved the way for the emergence of various kinds of undesirable consequences. One of them relates to the attitude of Keralites towards work. A mentality for hard work, essential for economic development sadly, seems to have vanished from the bulk of Keralites. A fall in agricultural production, particularly of paddy, is a clear manifestation of such a mentality.

Though overall prosperity is discernible, the quality of life has also deteriorated beyond recognition. The state is facing new problems like shortage of clean drinking water and the menace of waste management with no clear solution in sight. Heaps of plastic bags containing household wastes are a regular sight from one end of the state to the other.

How to retrieve the model poses a major issue calling for serious attention. more> http://goo.gl/PVlghe

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A framework for clean environment

The Times of India report, “As you burn, so shall you reap” (June 12, 2016), highlights the health hazards, incompetence and counter-productive actions by authorities regarding waste management in Kerala.

The report says, “People continue to burn plastic waste in the open because the local authorities have not put in place a system to clear it. Waste burning can controlled if people are made aware of the ill effects. Before pushing ahead with disciplinary actions, local self government bodies should ensure setting up collection points for recycling agents, says experts.”

Unfortunately, awareness building and punitive measures alone will not take care of waste and garbage disposal. Effective waste management consists of integrated and sustainable waste systems, processes and strategies.

Learning and adapting from the experience of other successful countries can help finding a solution. Nepal [2, 3, 4], Japan [2, 3, 4] and Sweden [2, 3, 4] have successfully developed and implemented effective waste management solutions.

Best Practices on Solid Waste Management of Nepalese Cities” by Practical Action Nepal describes successful best practices and help understand the roles of various organizations in effective waste management. This study focuses only on examples of best practices that worked, and does not cover schemes that failed, or theoretical cases never implemented.

Solid Waste Management and Recycling Technology of Japan” by the Ministry of the Environment provides a comprehensive overview of waste management methods and technologies used in Japan for management and disposal of waste. With limited landfill disposal sites, Japan has developed a system to collect and transport waste, process it through intermediary treatment by incineration and other methods, and then dispose it in landfills in a sanitary manner to prevent environmental pollution, especially in areas surrounding densely populated cities. Japan is a leader in waste incineration technology for safely disposing waste, while generating electricity efficiently.

A Strategy for Sustainable Waste Management (Sweden’s Waste Plan)” by Swedish Environmental Protection Agency discusses the scope and depth of waste management in Sweden. Sweden’s sustainable waste management is based of the country’s sustainable development goals. “Sustainable development means that all political decisions are to be formulated taking account of their long-term economic, social and environmental implications.” Also, “when it comes to waste, Sweden is very much at the forefront, and there is thus great potential for commercial export of technologies and know-how, even to rich countries.” In fact, Swedish waste management is so effective that there is shortage of waste and the country is importing garbage.

Using this background, here is a framework for solving waste management problems in Kerala:

Starting point for effective waste management is understanding people, systems and technologies.

Here are the operating principles to be adopted:

  1. Simple, efficient and clear stakeholder responsibilities.
  2. Promote awareness, understanding and a vision about waste management in the Kerala context.
  3. Local government entities are responsible for collecting, intermediate processing and disposing of household and similar waste, except for the product categories covered by producer responsibility.
  4. Sorting of waste at source.
  5. Sorting of waste must be simple.
  6. Treat waste management as a basic infrastructure need similar to water, power or roads.

And here are the implementation steps:

  1. Implement education programs to promote 3R (Reduce, Reuse, Recycle).
  2. Develop and popularize waste management desired outcomes.
  3. Waste management must be made part of initial construction: For any type of construction, either residential or commercial, the responsible local government entity should enforce basic requirements to reduce and segregate waste at source. For example, local self-government entities should consider making household composting and separate containers for recyclables mandatory, before approving construction proposals.
  4. Develop regional networks for waste collection and transportation. Maybe divide the state into 5 regions, centered around main cities in the state: Thiruvananthapuram [2, 3, 4], Kollam [2, 3, 4], Kochi [2, 3, 4], Thrissur [2, 3] and Kozhikode [2, 3, 4].
  5. Develop regional
    • composting centers,
    • intermediate waste processing centers for sorting, recycling and compacting for long distance transport,
    • incinerator plants with pollution controls,
    • hazardous waste processing disposal centers, and
    • landfills.
  6. Collect data necessary to measure the performance, efficiency and effectiveness of waste management activities. Evaluate collected data and implement improvements.
  7. Enforce compliance with waste management norms and standards.

Once a full-scale plan is developed, there is no need to get loans [2, 3] for implementing the plan, the “normal” project financing method in Kerala.

There is a huge amount of money on deposit in the banks in Kerala: “Bank deposits in Kerala up 53 per cent at Rs 407,000 cr ($61B)” [2], not including the gold holdings. The New York Times reports, “With only 3 percent of India population, Kerala gobbles up 20 percent of the country’s gold every year, and the World Gold Council estimates that India, the largest consumer of gold in the world, consumes 30 percent of the global supply.” [2, 3, 4, 5, 6] For comparison, Kerala GDP is $59B (2014). Kerala bank deposits is about 103.4 per cent of GDP.

If effective programs are implemented for channelizing the bank deposits, not to mention gold holdings, into systems for capital formation, Kerala can jumpstart economic development without relying on loans. That, unfortunately, will require a whole lot of changes for which the political will may not be available. For starters, people (depositors) may not trust the current political system to spend their money wisely.

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Sans industrial development, better to leave minerals in the ground

The Times of India feature, “Time for a resource rethink” (June 8, 2016), points out the problems of over-fishing and underutilization of the mineral resources in Kerala.

The report says, “There are about 44 rivers in Kerala and the river run-off associated with the rainfall brings fertility to the coastal waters leading to increase in phytoplankton. The abundant food servers as pasture for all age groups of sardine.”

Along with other causes, discharge of polluting effluents into rivers must be a reason for the drastic declines in fish catch along Kerala coast. According to the report, estimated Oil Sardine catch was 720,270 (2012) and 265,667 (2015) tonnes, a decline of 63 per cent. While estimated Penaeid Prawn catch was 252,300 (2012) and 199,195 (2015) tonnes, a decline of 15 per cent. And estimated catch of Ribbon fishes was 234,766 (2012) and 20,659 (2015), a decline of 91.4 per cent. Controlling river pollution will have the added benefit of improving fishery resources in the ocean.

The report says, “The state is yet to make even titanium sponge [2, 3, 4] which would have earned good profits,” said Dr. K Soman, former head of resource and analysis section, National Centre for Earth Science Studies.The value of the mineral resources is not in mining and exporting ore, but in post processing and manufacturing value added products. Therefore, natural resource mining plans must be complemented with industrial development. In addition, effective steps for preventing environmental degradation and pollution must also be taken.

Otherwise, it may be better to leave the mineral resources in the ground.

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A plan for economic development

A confluence of forces — increasing chronic budget deficits, declining agriculture, slowing tourism, reduced foreign remittance, among others — make it necessary to think about new ideas for developing Kerala economy.

It seems Kerala government gimmicks and shortcuts are catching up with the tourism industry, reports The Times of India (“God’s own destination, but heading nowhere,” Apr. 27, 2016).

“The problem is that what you see on the screen is very different from what a tourist experiences when they touch down,” says the report. Seems like the Kerala tourism department has been using the skills from the movie industry in the state to win awards, but lacks understanding of essentials for building a brand. Brand is about trust and promise. Marketing makes promises about future experience that must be fulfilled. Otherwise the trust is broken, and the brand withers. Apparently, Kerala tourism marketing was about “luring tourists,” and the methods are no longer working.

“The basic requirements are infrastructure development and capacity building. Government needs to ensure good quality roads, make tourist spots garbage-free, provide hassle-free inland navigation by mid-size boats from Kollam [2. 3] to Kottpuram, develop eco-tourism clusters to protect Kerala as a green destination, besides ensuring continuous quality audit of tourist facilities,” said E M Najeeb, president Confederation of Kerala Tourism Industry. Tourism cannot function in a bubble, but is enmeshed in the local economy. It is not viable or practical to develop good quality roads, make tourist spots garbage free, or provide hassle-free inland navigation for the sake of tourism. However, it would be feasible to achieve those goals as part of overhauling the Kerala economy for making it sustainable.

First step is to develop a plan for an optimum transportation network for whole of Kerala. Once different modes of transport suitable for different regions are identified and transportation networks are designed, they can be constructed as funds become available. It will not solve the problems immediately. But, over time, will provide adequate transportation — which will never be achieved with the current piecemeal, ad-hoc, fragmented approach. Here is an outline of the priority areas for transforming Kerala economy to be sustainable:

  1. Enhance quality of education
  2. Agriculture producing premium organic agro-products [2]
  3. Plan Kerala-wide optimum transportation networks for phased implementation
  4. Implement integrated wellness and heathcare solutions
  5. Implement integrated water distribution and management
  6. Implement integrated waste management and pollution control
  7. Develop electronics and ICT (information and communication technologies) industrial capabilities, beyond the current services focus

Building malls and apartments will not result in a sustainable economy. Neither will “exporting partially educated people.” As experience has shown, IT Parks, as currently implemented, will also not produce required results. So it is time for serious investment in core industrial capabilities. Electronics and ICT sectors can form core “market activities” for a comprehensive economic development plan, for example, using “Metropolitan business planning” methodology.

To sum up, trying to build the infrastructure needs of tourism in isolation is not viable. But it can be achieved by an integrated approach for transforming the Kerala economy to be sustainable.

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Kerala government structure is outdated

Over the past several decades many theories on management, organization and leadership have evolved and new ones have been developed. However, Kerala government is continuing with a patch work of organizational structures that evolved historically, without any coherent plan or strategy for effective governance.

The Times of India report, “Eco warriors are missing the wood for the trees” (Apr. 3, 2016) is an illustrative example of this problem. “During the last three decades, the state has lost over 41,000 hectares ( 100,000 acres) of its forest cover. The largest parcel of land allotted for non-forestry purposes was in 1995 — revenue department took 28,588 hectares for ‘realization’ (legitimization) of encroachment by sundry settlers that happened before January 1, 1977,” says the report.

This shows the Kerala government does not have any serious plans for nature preservation. In addition, Kerala government organizational structure [2] is outdated and illogical. Why is the “Revenue Dept.” responsible for forest land? It should logically belong to the Forest Dept. And, by the way, the “Revenue Dept.” could use some name change to reflect its true functions.

“KCZMA (Kerala Coastal Zone Management Authority) maintained that though they were aware of violations of CRZ (Coastal Regulation Zone) norms, they have not received any formal complaint in this regard. ‘We can act only if we receive a complaint regarding violations of CRZ norms,’ said senior scientist with ECZMA,” (The Times of India, “Rampant reclamation of wetlands, mangroves,” Apr. 3, 2016).

This means that KCZMA of Kerala government is a joke. What is the use of KCZMA being an “authority” if it cannot take action on illegal activities? Unless there is enforcement, laws are ineffective. Who are they waiting to receive the complaints from? Why should those people make a complaint in the first place? Do they even know that they are supposed to make complaints? How are they qualified to know that there is a problem to make complaints?

It seems the KCZMA setup is a farce aimed at creating an illusion of effort without any real intention to preserve and manage the environment.

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