A DDITIONAL  SOURCES  OF  INFORMATION

Coming to terms with the different meanings, contrasting knowledge systems and interventions attached to water quality also involved engaging with a diverse range of additional sources of information. The main additional sources that influenced this research included official documents accessed via the Right to Information (RTI) Act, 2005, government audit reports dealing with regulatory institutions, and participation in workshops and other fora as part of my affiliation with the STEPS Centre. Each of these sources is described briefly in this section.

Access to official documents from government departments operating at various executive levels (i.e. national, state and district) is often discouraged. This was a major setback when claims made by respondents during interviews needed to be further substantiated. It also hindered the research in getting to the bottom of the official rhetoric of senior civil servants and scientists and in examining the facts in more detail.

It is in this context that the use of the Right to Information Act, 2005 proved so important. Starting with small-scale sporadic initiatives, RTI has now become a nationwide people’s movement for exposing corrupt government practices by gaining access to government information. Specifically, the RTI empowers citizens, research NGOs and civil society groups to scrutinise government decisions and to ensure that they are consistent with the principles of public interest, probity and justice (Mander and Joshi, 2010). By using the RTI Act, 2005 this research was able to gain access to valuable sources of information that would have otherwise been unavailable, if the methodology had relied on fieldwork observations and interviews alone.

Not being an Indian national meant that I could not apply directly for access to official documentation. Sushil Raghav who was also helping me during my fieldwork in Ghaziabad district agreed to send the RTI requests in his name and with his authorisation. This became an effective partnership as on the one hand I benefited directly from answers received and on the other hand, Sushil also benefited by extending his knowledge and information sources to support his own environmental

activism in the district²⁵. Although the procedure seems simple, there are several points that require careful attention in order to ensure the quality of the information received through RTI. For example, questions posed to government departments have to be carefully worded in order to ensure that answers received from officials are not misleading. To some extent this requires some prior knowledge of the organisation to which an RTI application is filed. These are aspects of using the RTI that I had little prior knowledge of, but with Sushil’s prior experience I was able to submit effective applications which returned valuable official information.

Given the centrality of environmental regulatory institutions to the investigations carried out as part of this research, the majority of RTI requests were made to the Board and UPPCB regional office in Ghaziabad. Different questions were put to the departments concerned, on the basis of how my understanding of the key issues developed over the course of the fieldwork. In the case of the Board, questions were primarily focused on details of bureaucratic practice and organisational structure. The questions posed concerned public complaints received by the Board on issues related to pollution, minutes of meetings of Board members, inspection of industries carried out under specific pollution enforcement initiatives, and details regarding the annual allocation of the Board’s financial budget. In the case of the regional office, UPPCB, questions were primarily focused on details of pollution enforcement practice. These included details of the locations within Ghaziabad where water samples are collected, factories operating in the district which failed to comply with environmental norms, and the frequency with which pollution enforcement inspectors visited villages, residential colonies and other departments within the district. On the basis of the information received I was able to develop a better picture of the numbers of industrial units operating illegally in the district. I was also able to form better judgments about the water quality status of various water resources in the district.

25 An important area of Sushil’s involvement with the RTI process that overlaps with the interest of this study has been in exposing industries that operate either illegally in the district or without effluent treatment plants. He uses information received through the RTI to approach pollution control authorities and put pressure on regulators to take remedial action.

Nonetheless, it should be noted that there are several constraints to using the RTI Act.

The first relates to the time it takes to receive a response following an RTI request. This usually takes up to 30 days, depending on the nature of the request and the number of questions put to the department concerned. Given that my fieldwork proceeded in two relatively short visits of approximately three months each, I could not afford to rest entirely on the RTI process, and simply wait idly for the departments concerned to provide a response. Once I received the information I carefully examined it, but the fact that I could not predict when this would be meant that I had to treat information

provided using the RTI Act essentially as a secondary source of information, while interviews and fieldwork observations were the ‘primary’ source²⁶.

The second limitation relates to the quality of information received. Ultimately, the RTI Act has been mobilised by civil society in India to identify specific problems faced by people in their interface with the public authority (Mander and Joshi, 2010), and, more specifically, problems that relate to corruption, or the exercise of power in ways which adversely affect citizens. This means that officials are not always comfortable with answering questions put to their departments on the basis of the RTI Act. As a result, it is not always certain that documents received have not been altered, or that officials have not withheld specific information and documents. Another, simpler, strategy for officials to prevent the disclosure of sensitive information is to provide ‘short answers’

to questions that relate to contentious topics, such as in this case the topic of industrial pollution regulation. These issues meant that I was cautious in how I used RTI

information, and in many cases I observed that the ‘real problems’ and the respective causes of bureaucratic failure were identified much more easily during interviews and informal discussions than when I used the RTI Act. Generally, however, it must be said that the quality of information received using the RTI process depends largely on the questioner’s experience of making the information requests, and because officials are likely to be ‘defensive’ in the responses that they provide, usually a number of RTI requests have to be sent to the same agency in order to put pressure on officials, something which in turn requires more time than was available for the completion of this research project.

26 For an example of an official response to an RTI request refer to Appendix 4.

Another source for collecting additional information was a series of short visits to government institutions including Parliament House, the National Institute of Public Finance and Policy, the Indian Institute of Public Administration, and the Comptroller Audit General (CAG) of India. Specifically, the aim of these visits was to locate reports prepared by independent auditory bodies and committees of experts on the performance of environmental regulatory institutions, especially the Board and State Boards.

Examining these reports was important for understanding how the state mobilises its own evaluation of regulatory performance and implementation, but also for interpreting how these evaluations have evolved over time and especially since the establishment of the Board. Not all reports are referred to directly in the text. However, those that are referred to in this thesis include the Comptroller and Auditor General Review of the Board (CAG, 1992), as well as the more recent audit of the Board by the Parliament Standing Committee on Science & Technology, Environment & Forests (Parliament of India, 2008)

As already mentioned, during the course of the research I attended several fora that proved to be an invaluable source for the data collection process, and for participating in discussions related to this research, as well as gaining access to individual experts and documentation. As a member of the STEPS team²⁷, my study has benefited greatly from my attendance at a series of ‘peri-urban’ specific workshops, academic discussions, and access to research papers and documents related to the STEPS peri-urban project²⁸ . These sources of information have been invaluable for formulating ideas as well as for triangulating and substantiating information received during the fieldwork. Because the STEPS project’s focus was on exploring questions of water ‘supply and access’ as opposed to water ‘quality’, there are several points of intersection but also of departure between the STEPS project and this thesis. They differ in terms of their emphasis, with this thesis being more oriented to water quality and not just to issues of supply and access, while also adding another dimension to the discussion by introducing the Board’s role in the process, which is not accounted for in the STEPS project.

27 Funded by the Economic and Social Research Council (ESRC) to carry out DPhil research as part of the STEPS Centre.

28 ‘The Peri-Urban Interface and Sustainability of South Asian Cities’ is a STEPS project that seeks to bring together the social, technical and environmental dimensions of peri-urban areas. Water is used in this project as an entry point to ask questions of policy, science and engineering, with regard to supply, access and quality. For more information, see: http://www.periurbansustainability.org/.