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On June 16, 2025, India designated Chhari Dhand, a seasonal wetland in Gujarat’s Kachchh district, a Wetland of International Importance under the Ramsar Convention (Site No. 2588, 22,700 hectares). Its Ramsar Information Sheet recorded an average annual waterbird count of 1,11,449 individuals between 2017 and 2024, including 30,000 Common Cranes, 10,000 Great White Pelicans, 20,000 Lesser Flamingos, and 32,000 Greater Flamingos. The same sheet listed renewable energy as an actual high-impact threat in the surrounding area.

Eight months after that designation, NTPC Renewable Energy Limited’s foundation-drilling machines are on the ground nearby, testing soil bearing capacity for a proposed solar park covering approximately 4,500 acres across 16 Banni villages, around 1,400 acres of them in the eco-sensitive zone adjacent to the Chhari Dhand Conservation Reserve and Kiro Hill.

No environmental impact assessment has been conducted. None is required. The more important question is not simply why, but whether any other legal mechanism performs the function that an EIA would have served.

When EIAs stop, what takes their place?

In August 2017, the Ministry of Environment, Forest and Climate Change issued an office memorandum confirming that the EIA’s 2006 notification does not apply to solar photovoltaic projects, solar thermal projects or solar parks. While the ministry initially exempted individual solar projects from the EIA framework in 2011, the August 2017 office memorandum explicitly extended this exemption to include expansive solar parks.

The schedule to the 2006 EIA notification identifies the categories of projects that require prior environmental clearance. Conventional power projects are included: Coal and gas-fired plants above 500 megawatt (MW) require clearance from the Union government, while those between 5 and 500 MW  require clearance at the state level. Solar photovoltaic and solar thermal projects, however, do not appear anywhere in the schedule.

The schedule removes the one statutory mechanism that would have required baseline ecological data, public consultation and cumulative impact assessment before a project of this scale proceeds.

Other legal frameworks remain available in theory. The Wildlife (Protection) Act, 1972, covers protected areas but the Chhari Dhand Conservation Reserve’s protections apply within its gazetted boundary, not to the Banni commons surrounding it. Forest clearance is required if forest land is diverted, but grasslands are not forests in Indian law, and Banni has no protected forest notification.

Stoliczka’s bush chat, part of a vulnerable population, photographed December 9, 2016, in Banni grasslands, Kutch, Gujarat. Credit: UdayKiran28, CC BY-SA 4.0, via Wikimedia Commons

Coastal Regulation Zone rules do not apply this far inland. State pollution control consents attach to operational discharge, not to land acquisition or site preparation. None of these mechanisms requires an assessment of ecological impacts before the project........

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