Environment Effect
Environment Effect
Environment Effect
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The effect of environmental decentralization on
polluting industries in India.
Stefania Lovo
Grantham Research Institute for Climate Change and the Environment, London
School of Economics
January 7, 2014
Abstract
This paper examines the unintended effects of the 2006 reform of
the Environmental Impact Assessment (EIA) process in India using
firm-level data for the period 1998-2012. The reform favored a de-
centralization process by delegating the responsibility over environ-
mental clearance of certain activities to state-level authorities. The
results show that variations in the strength of environmental enforce-
ment across states has resulted in an increase of births for polluting
industries affected by the reform in states with lower level of enforce-
ment.
1 Introduction
This paper examines the impact of the 2006 Environmental Impact Assess-
ment (EIA) reform on firm decisions concerning births and locations. The
reform delegates the responsibility over environmental clearance of certain
activities, previously under the control of the central government, to newly
This research is part of the green growth programme at the Grantham Research In-
stitute on Climate Change and the Environment, which is funded by the Global Green
Growth Institute, as well as the Grantham Foundation for the Protection of the Envi-
ronment, and the Economic and Social Research Council through the Centre for Climate
Change Economics and Policy. I would like to thank the participants of the GGGI seminar
and GRI Green Growth Workshop at LSE for their useful comments and suggestions.
3
established state-level authorities. While environmental standards are de-
cided by the central government, most of the environmental compliance
monitoring and enforcement in India was already a responsibility of state-
level Pollution Control Boards (SPCB). The 2006 EIA reform has expanded
this decentralized model by assigning additional tasks to state-level author-
ities. Though this could potentially lead to a more transparent and efficient
environmental clearance process, it could also have unintended effects on
firms’ decisions.
Environmental enforcement varies notably across Indian states. Differ-
ences arise possibly due to variations in socio-economic and political con-
ditions across states but also due to state-specific technical and financial
constraints. This paper examines whether differences in environmental en-
forcement influence firm births across states through the EIA process strin-
gency. The key findings are derived from the fact that the reform of the EIA
has affected only certain polluting activities, while for others the process has
remained almost unchanged, and that pre-reform differences in environmen-
tal enforcement across states are likely to be indicative of differences in the
stringency of the EIA process across states. The empirical approach is based
on a firm-level latent-startup model where the number of births is a function
of time-varying state and sector level characteristics.
The estimations compare pre- and post-reform births, conditional on the
strength of environmental enforcement in each state. Environmental enforce-
ment is measured using a composite index obtained by aggregating various
state-level indicators of institutional quality, civic participation and institu-
tional capacity. The identification strategy relies on the presumption that,
while firm births in sectors affected by the reform should respond to vari-
ations in environmental enforcement after the implementation of the 2006
EIA reform, no effects are expected on non-polluting firms and on polluting
industries not affected by the decentralization process. The estimations are
based on the population of registered firms born during the period 1998-
2012. Although the formal sector contributes to only a small fraction of
total Indian output, large firms are the only ones subject to environmental
clearance, since smaller informal firms tend to operate outside the control
of pollution control authorities.
The results show a significant increase in births of polluting firms in
states with lower enforcement levels relative to states with higher enforce-
ment levels. This relocation effect has ambiguous consequences for the In-
dian economy. The relocation of firms across the territory may negatively
impact the Indian economy if it implies that firms choose inferior locations
that increase operational costs and decrease efficiency (Becker and Hender-
4
son, 2000). On the other hand, firm relocation may be socially beneficial
since firms might locate in less populated areas where either pollution dam-
ages are lower or economic growth benefits are higher and offset the envi-
ronmental costs. It is, however, not in the scope of this paper to quantify
all the welfare effects resulting from polluting firms locating in states with
lower enforcement.
The remainder of the paper is organized as follows. Section 2 describes
the policy background and the reform of the EIA process introduced in 2006.
Section 3 provides a brief overview of the relevant literature. The empirical
model is described in section 4 while the data are presented in section 5.
The empirical results are discussed in section 6 and section 7 concludes.
5
polluting projects/firms are classified into two categories based on the po-
tential impacts on human health and natural resources. Projects classified
as category A have to undertake the EIA at the national level, as per the
1994 notification, while category B projects are referred to the State Envi-
ronmental Impact Assessment Authority (SEIAA) of the state in which the
project is located. The classification of projects into these two categories
is based on three main criteria. The first criterion defines those projects
that are of exclusive competence of either state or national authorities. Any
project within the petroleum refining industry, for instance, should under-
take the EIA at the central level, while projects in the integrated paint indus-
try are the exclusive responsibility of state authorities. A second criterion
distinguishes projects in terms of capacity. Large coke oven plants (above
150,000 tonnes per year), for example, are under the authority of the cen-
tral government, small ones are referred to the SEIAA in which the project
is located. A third criterion categorizes projects on the basis of whether
they are located within or outside a notified industrial area. Projects in the
leather/skin/hide processing industry, for example, are subject to state level
EIA only if located within an industrial estate/area. Table 1 summarizes the
five different groups of activities defined in accordance to the three criteria
mentioned above. The detailed list of projects and activities, as reported in
the official 2006 EIA notification, is provided in table 8 of the Appendix.
6
SSEIAAs were constituted in each state at different points in time and
all projects were treated as category A in absence of a notified state au-
thority. Table 9 of the Appendix reports the date of establishment of each
SSEIAA. The 2006 notification initiated a process of decentralization of the
EIA procedure which could reduce the burden on the central government
and accelerate the approval process. However, the decentralized powers
could either be misused if state governments intend to actively pursue in-
dustrialisation for their respective state, or be ineffective if state authorities
lack technical and financial powers.
The EIA process is subdivided into four stages. The first stage (Screen-
ing) affects only category B projects and is aimed at determining whether
a project requires an environmental impact assessment report. Projects re-
quiring EIA are categorized as B1 while the others are termed B2 and submit
a much shorter application form. Although guidelines for the screening pro-
cess are provided by the MOEF, there is still lack of clarity on this stage
of the process. The second stage (Scoping) involves either the central or
state authority in determining the terms of references covering all relevant
environmental concerns for the preparation of the EIA. The third stage re-
quires a public consultation through both a public hearing in the proximity
of the site and invitations of written responses from the concerned stakehold-
ers. The final stage (Appraisal) involves the scrutiny of the EIA application
which can result in either approval or rejection of the project. Each EIA
contains the environmental management plan, which becomes part of the
business permit and is binding upon the company that is carrying out the
activities. Therefore, it sets the point of departure for future supervision
and enforcement as it determines what can be enforced.
7
volved in the decentralization of the decision making process (Besley and
Coate (2003); Oates (2002)) fewer studies have empirically investigated its
consequences. Brunnermeier and Levinson (2004) review the empirical lit-
erature and find that while earlier cross section studies tend to find no sig-
nificant effect of environmental regulation on firms’ decisions, more recent
studies that use panel data estimations find evidence of firms responding to
variations in regulation within a country. Many empirical studies focus on
variations in regulation across counties and states of the United States (List
et al., 2003). Becker and Henderson (2000), for example, study variations in
air quality regulation across counties and find that there has been a signifi-
cant relocation of polluting firms from more to less polluted areas. Sigman
(2005) shows that the decentralization of environmental authorities in the
United States has led to a 4% increase in water degradation downstream of
states that had the authority to issue and enforce permits for point source
polluters.
This literature is related to that on the pollution-heaven hypothesis. Sev-
eral studies have analysed the impact of cross-country differences in environ-
mental regulation on the location of foreign direct investment. The results
are mixed. Javorcik and Shang-Jin (2003), for example, analyze investment
flows to 25 economies in Eastern Europe and the former Soviet Union and
find no evidence that FDI from polluting industries is more likely to go to
countries with weaker environmental regulations. On the other hand, Dean
et al. (2009) find evidence of pollution heaven behavior in China for invest-
ment in highly polluting industries from ethnically Chinese countries, while
no effect was found for investment from other sources.
Fewer studies have focused on firm’s location decisions in developing
countries. Duvivier and Xiong (2013), for example, studies trans-boundary
pollution in China where environmental policy is decentralized. Similarly to
India, while the central government sets the standards, local governments are
in charge of monitoring and sanctioning. The authors analyze the location
choice of polluting firms in one of the most polluted province in China and
find that polluting firms tend to locate in counties that share a border with
another province. Similarly, Lipscomb and Mobarak (2007) analyze rivers
water quality across jurisdictions in Brazil and find a significant strategic
polluting behavior around borders.
The first study to analyse firms’ location decisions in response to envi-
ronmental regulation in India was conducted by Mani et al. (1997). The
study finds that the number of new plants is not affected by the stringency
of environmental regulation at the state level. A positive correlation be-
tween a measure of enforcement and the number of new plants, however,
8
suggests that the variable might be capturing the quality of state govern-
ment rather than environmental enforcement. Moreover, the data date back
to 1994 when there was very little enforcement of environmental regula-
tion across all states since prosecution could only occur through the judicial
system (Lipscomb, 2008). There is, however, evidence of Indian firms ad-
justing their behavior in response to changes in environmental regulation
over time. Lipscomb (2008), for example, analyses the response of multi-
product firms to changes in enforcement at state level1 . The author finds
that firms react to increase stringency by increasing the share of product
portfolio allocated to clean products. High productivity firms invest in new
and cleaner products and gain from an increase in enforcement. Kathuria
(2007) finds that an increase in informal regulation, measured by local news
coverage of pollution-related events and the number of public interest litiga-
tions filed, has reduced industrial pollution in the state of Gujarat. On the
other hand, however, formal regulation, measured by the number of staff
allocated to a region, was found not to affect polluting behavior.
Finally, this paper relates to the broader literature on firms’ location
choices. This is a vast literature that covers various aspects such as ag-
glomeration economies (Brülhart et al., 2012), variations in corporate taxes
(Barrios et al., 2012) and infrastructure (Holl, 2004). In India, Lall and
Chakravorty (2005) estimate a cost function at the plant level where eco-
nomic and geographic factors are included to explain firms agglomeration.
The authors find that only local economy diversity matters as a cost-reducing
factor for medium and large industries. The empirical model presented be-
low builds upon this well established literature and takes advantage of the
institutional setting of the 2006 EIA reform to analyze the impact of differ-
ences in environmental enforcement on firms’ location decisions.
4 Empirical model
This section adapts the so called latent-startup model (Becker and Hender-
son, 2000) to represent the possible responses of Indian polluting firms to
the policy changes introduced with the 2006 EIA notification. While envi-
ronmental clearance is required also for the expansion or modernization of
existing polluting firms, this paper considers only the effects on the birth
of new polluting firms. The model assumes that potential entrepreneurs
are spatially immobile and decide whether to set up a firm in a particular
1
Enforcement is measured by the percentage of polluting firms which as been closed
by state and year.
9
sector and location. The alternative model, the footloose-startup model, in-
stead, considers the decision about which location to select once investors
have already decided to set-up a company. Empirically, the two models are
equivalent (Brülhart et al., 2012). At each point in time, an entrepreneur
acts as maximizing its net expected present value and compares the sunk
cost of entry with the expected profits in a particular sector and location.
The expected profits, πf ijt , of firm f in sector i state j at time t depends
on the characteristics of the sector and location of the firm at the time of
establishment, xijt , and on the expected relative compliance costs, cj , which
refers to expected future monitoring, reporting and punishment costs which
varies according to the location. Sunk costs are, for simplicity, only repre-
sented by the cost of complying with the EIA application, sijt . Assuming
a linear approximation of profits, the expected net present value can be
written as follows:
npvf ijt = πf ijt − Sjit + f ijt = α00 xijt + α1 cj + β1 sjt + f ijt , (1)
where f ijt is a random disturbance. Expected compliance costs depend on
the relative level of enforcement at state level, cj = f (Ej ), and are assumed
to be constant, in relative terms, over time, i.e. enforcement is allowed to
increase or decrease over time but the ranking across countries in terms
of environmental stringency is expected to be unaffected. Set-up costs are
instead expected to change over time, but only for category B firms. The
introduction of the 2006 EIA notification has decentralized the process of
environmental clearance for category B firms introducing a new source of
variation across states. The model assumes that before 2006, set-up costs
were identical across states because the EIA was conducted at the central
level for all firms. After 2006, environmental clearance costs depend on Ej
only for firms in category B.
Set-up costs after the implementation of the reform can, therefore, be
re-written as a function of the enforcement capacity in each state:
npvf ijt = α0 xijt + β0 f (Ej ) + β1 (DT × Ej )) + f ijt , (2)
where DT is a dummy variable indicating the years following the implemen-
tation of the EIA notification at time T . After T , set-up costs can be higher
or lower than pre-reform costs. States with low levels of enforcement are
expected to impose lower environmental clearance costs. For some firms,
start-up costs could drop to zero if the screening process conducted by the
SEIAA indicates that the project is exempted from the EIA process.
The expected effect of this decentralization process for category B firms
is twofold. Some states might impose more stringent conditions than those
10
imposed previously by the central government resulting in a reduction of
births in high enforcing states (deterrence). On the other hand, some states
might conduct a laxer EIA in order to promote industrialization, or due to
technical and financial constraints, facilitating the birth of new polluting
firms (attraction). Both forces lead to relative higher birth rates in lower-
enforcing states compared to higher-enforcing states.
Following Becker and Henderson (2000), the model can be represented
as a reduced form equation where the total number of firms born in each
sector, state and year, nijt , is a function of the above mentioned variables
and a set of state (gj ), sector (di ), and time (wt ) fixed effects:
The above equation can be estimated separately for each group of sectors
reported in table 1. We expect the coefficient β1 to be negative only for firms
affected by the decentralization process (Category B: group 5) while being
insignificant for non-polluting firms (i.e. not included in the reform, group
1) and those undertaking the EIA at central level (Category A: group 2).
For groups 3 and 4 the effect is ambiguous as they contain a mixture of
category A and B firms.
In practice, the model is estimated by pooling the five groups of sectors
and interacting all variables by group dummies. In doing so the results
are equivalent to those obtained by estimating the model separately but
have the advantage of allowing for a statistical comparison of the coefficients
across groups. Moreover, the pooled model can be related to a heterogeneous
treatment effect model where the treated sectors are those included in group
3, 4 and 5 and the control group includes non-polluting sectors and sectors
subject to central-level EIA (group 1 and 2). The treatment effect is allowed
to be heterogeneous depending on the level of enforcement in each state prior
to the implementation of the 2006 reform.
Because the model includes state, year and sector fixed effects it is not
possible to identify the effects of pure location, time and sector-specific vari-
ables. All specifications will control for the average share of firms in each
year and location to control for state-level growth patterns. Additional
controls will be discussed in the next sections. Although the EIA notifica-
tion was introduced in September 2006, the decentralization process could
not actually take place unless a SEIAA was created. Because most of the
SEIAAs were established between 2007 and 2008 (table 9 in the appendix),
the variable DT will take values one for 2008 and subsequent years. This
11
approach, de facto, compares the average number of new firms born before
and after the implementation of the EIA notification, conditioned on the
level of enforcement in each state.
The model is estimated using a Poisson pseudo-maximum-likelihood es-
timator with robust standard errors (Wooldridge, 1991), which allows for the
discreteness of the dependent variable and the large number of zeros. The
estimator produces consistent estimates under relatively weaker assump-
tions than a standard Poisson model, i.e. only the conditional mean need
to be correctly specified2 . The model is also estimated using a standard lin-
ear model (OLS) after log-transforming the dependent variable. While the
log-transformation does not alter the multiplicative relationship between
the explanatory variables and allows for double clustering, it has the dis-
advantage of dropping all cells with zero births. In this specification, the
dependent variable is the ratio of new firms in each sector and location over
the total number of new firms in the sector as it better deals with differences
in growth rates across sectors. The number of births is, however, also used
in an alternative specification.
12
unobservables, unobserved heterogeneity could still be a concern. Neverthe-
less, the regressor of central interest in the estimations reported below is a
three-way interaction term, between state-level enforcement, a dummy vari-
able indicating the post-implementation period and a group dummy that
is less subject to endogeneity problems. Moreover, the results are tested
for robustness to the inclusion of additional control variables that should
capture other sources of unobserved variation over time, such as changes in
average real wages and in the number of special economic zones.
In cross-section studies it is often argued that failing to control for cor-
ruption creates a problem of omitted variable bias (Dean et al., 2009). High
corruption often implies lower environmental stringency but may also act
as a deterrent for new investments. This is not a concern in this study.
Corruption is included as a measure of environmental stringency since it is
the best available measure of the quality of state-level institutions and there
are no reasons to expect that its deterrence effect should vary before and
after the implementation of the EIA notification.
13
Table 2: Measures of environmental enforcement by state
14
raised awareness of governments and the general public (UNESCAP, 2000)3 .
The number of environmentally-oriented NGOs was also used in Javorcik
and Shang-Jin (2003) to measure variation in strength of environmental
enforcement across countries. Another measure of public concern over envi-
ronmental issues is represented by the number of newspaper articles covering
topics related to industrial pollution. The number of newspaper articles in
each state and year was obtained by conducting a search across all English-
language Indian newspapers contained in the database Factiva for the period
1998-2006. Each search included a set of common keywords, such as closure,
court, order, fine etc., and the name of the State Pollution Control Board,
e.g. Bihar State Pollution Control Board. The variable used to construct
the enforcement index was obtained by calculating the cumulative number
of articles referring to each State Pollution Control Board for the entire pre-
reform period. Finally, it was noted that Indian citizens can benefit from a
unique approach to enforce environmental law by exercising a constitutional
right before the Supreme Court and the High Courts in the form of Pub-
lic Interest Litigations (PIL). Unfortunately, it was not possible to obtain
the number of PILs filed in each state, but the number of judgments of the
Supreme and High courts offers a reasonable proxy. The list of judgments re-
lated to environmental issues was obtained from the Judgments information
system of the Supreme and High courts of India. Judgments were manually
assigned to each state based on the location of the firms or the pollution
control boards involved in the court case.
To measure institutional quality we used the corruption index at state-
level provided in a study by the Centre for Media Studies issued by Trans-
parency International India for the year 2005 (CMS, 2005). While this index
is our preferred measure of corruption, it is not available for the Union ter-
ritories of Chandigarh, Goa, Meghalaya, Puducherry and Uttarakhand that
are, therefore excluded from part of the analysis4 .
All enforcement measures are time-invariant and, when possible, refer
to the pre-reform period. They are aggregated into one unique measure of
state-level enforcement through principal component analysis. The use of
principal component analysis techniques is appealing because these multiple
3
The list of Indian NGOs was obtained from an online database: http://ngosindia.com/
accessed in June 2013.
4
We also tested an alternative measure of institutional quality constructed as the num-
ber of cases of persons arrested under the prevention of corruption act and related sections
that have obtained charges. The information was obtain from the India Bureau of Crime
and was available for all states. We also tested the robustness of the results to the exclusion
of corruption from the enforcement index.
15
Table 3: Environmental enforcement index: principal component analysis
variables are correlated and aim at capturing the same concept, i.e. the level
of environmental enforcement. Table 3 shows that, as expected, all measures
but the corruption index are positively related to the latent environmental
enforcement measure. The first principal component explains about 37% of
the total variance in the data. The eigenvalue of the first principal compo-
nent is close to two, thus we retain only the first component which will be
referred to as enforcement index. The index ranges between -1.9 and 2.2 and
takes higher values in states where environmental enforcement is stronger.
16
to obtain important information using the corporate identification number
(CIN) that the Ministry of Corporation assigns to each registered company
and that combines information on the year of establishment, state, 5 digit
industry code (National Industrial Classification, NIC), ownership type and
a registrar code. In 1998 the Indian Statistical office adopted a substan-
tially different sector classification which also affected the sector definition
contained in the CIN code. To avoid problems of misclassification of some
firms, the analysis only considers firms established after 1998. This does
not constitute a major drawback since prior to 1997 there was very little
enforcement of environmental regulation across all states (Lipscomb, 2008).
A birth is defined as the registration of a new company in the Registrar
of Companies of the Ministry of Corporation. Companies are assigned to
the five groups reported in table 1 based on the sector they operate in. Un-
fortunately, it is not always possible to assign a particular activity or project
listed in the 2006 EIA notification to a specific sector. Projects/activities
descriptions are sometimes too broad or too narrow to perfectly match a
sector as defined in standard industrial classifications. It was, however, pos-
sible to recover some useful information from a previous draft of the EIA
notification, which was circulated before the official approval of the reform
that provides a concordance table between sectors classification and activ-
ities using the National Industrial Classification (NIC). NIC is the main
classification used by the Indian Statistical Office and form part of the CIN
number. The concordance table was later removed from the official EIA
notification. The list provided in the draft notification was supplemented
by manually matching activities that did not report a corresponding sector
code. The detailed sector-activity concordance used in the analysis is re-
ported in table 8 in the Appendix while a summary is provided in table 1.
Sectors are considered at different digits based on the highest level of aggre-
gation that allowed a one-to-one matching between activities and sectors.
Some sectors, however, were dropped because of ambiguous matching with
listed activities and are reported in table 11 of the appendix. The exclusion
of these sectors, however, does not significantly affect the results.
The information contained in the Orbis database does not allow for the
identification of production capacity or of whether a company is located
within an industrial estate. Therefore, it was not possible to distinguish
whether a company belonging to group 3 and 4 (defined as Capacity and
IE) had undertaken the EIA at the central or state level. One attempt,
however, will be made in the next sections to distinguish large from small
companies. The number of births in each group and year is reported in table
4. The same information is reported by state and year in table 12 in the
17
Table 4: Number of new firms by category and year of incorporation
Year 1 2 3 4 5
Year Without EIA Central-level Capacity IE State-level Total
1998 2346 160 1045 399 116 4066
1999 2438 208 1273 483 141 4543
2000 1780 154 1038 422 99 3493
2001 1497 115 1128 343 106 3189
2002 1747 154 1400 458 101 3860
2003 2284 207 2200 590 128 5409
2004 3133 225 3660 706 193 7917
2005 4097 335 5799 952 231 11414
2006 3966 351 6556 877 255 12005
2007 4944 337 7084 1020 250 13635
2008 4802 397 7984 833 230 14246
2009 5058 350 4653 699 194 10954
2010 6792 437 7297 980 311 15817
2011 7405 477 7045 1226 328 16481
2012 6534 404 5232 1007 209 13386
Total 58823 4311 63394 10995 2892 140415
18
applying a more stringent environmental clearance process may attempt
to mitigate its negative effects by offering fiscal incentives to new plants.
Considering the results reported in column 7, while no effect is found for
non-polluting firms and for new firms subject to central-level EIA (No EIA
and Central), the strength of environmental enforcement is shown to have
a larger negative effect after the implementation of the 2006 EIA reform
for firms in sectors of exclusive competence of the SEEIA authority (State)
and for those firms subject to state-level EIA if located within an industrial
estate (EI). The effects are not statistically different among these latter two
categories.
The results are consistent across all different individual measures of en-
forcement, although, in few instances, some coefficients are not significant.
The coefficient related to the third group of sectors (Capacity), those sub-
ject to state-level EIA only if of small capacity, is also negative but much
smaller and not statistically significant. It is likely that many of the compa-
nies included in this category are of large capacity, this issue, however, will
be further explored below. In order to interpret the magnitude of the effects
we can consider that the average gap between states in terms of the envi-
ronmental index score is 0.25. Therefore, an increase in enforcement that
would, on average, allow a state to catch up with the next higher ranked
state would lead to a decrease in the share of new polluting firms between
4% and 6% every year. This is a relevant effect considering that the overall
average annual change in births is about 9-10%.
19
Table 5: Base results: log-linear model
Dependent variable: log of new firms over total new firms in the sector
(1) (2) (3) (4) (5) (6) (7)
Index NGOs Judgments Corruption News Monitoring Indexa
Baseline: No EIA 0.051** 0.009*** 0.058*** 0.002 0.008 0.007*** 0.051
(0.023) (0.003) (0.016) (0.005) (0.010) (0.002) (0.043)
After x Aj x Central 0.030 0.001 0.027 -0.014*** -0.004 0.004 0.030
(0.044) (0.008) (0.039) (0.005) (0.028) (0.005) (0.055)
After x Aj x Capacity -0.019 -0.002 -0.020 -0.008 0.003 0.001 -0.019
(0.067) (0.008) (0.041) (0.011) (0.015) (0.007) (0.062)
After x Aj x IE -0.159*** -0.015*** -0.104** 0.030* -0.035** -0.011*** -0.159***
(0.054) (0.005) (0.041) (0.015) (0.016) (0.004) (0.054)
After x Aj x State -0.193*** -0.029*** -0.166*** 0.010 -0.013 -0.020*** -0.193***
(0.063) (0.006) (0.028) (0.007) (0.022) (0.003) (0.055)
20
State Yes Yes Yes Yes Yes Yes Yes
Year Yes Yes Yes Yes Yes Yes Yes
Sector Yes Yes Yes Yes Yes Yes Yes
Observations 11561 12590 12590 11561 12590 12590 11561
Standard errors clustered at sector level in parentheses. * p < 0.1, ** p < 0.05, *** p < 0.01
a
Double clustering at sector and state level. All regressions control for the average share of new firms
in the state (not reported).
In table 6 we test the robustness of the above results considering alter-
native specifications. The first column, considers the log of new firms as
dependent variable and produces similar findings: the strength of environ-
mental enforcement has a larger negative effect after the reform for those
sectors affected by the decentralization process. The remaining columns
include additional control variables. The results reported in column 2 are
obtained after controlling for the average wage in each state and year. The
data are provided by the Ministry of Statistics and Programme Implementa-
tion (Government of India, 2012) and are calculated from the Annual Survey
of Industries that collects information on medium and large firms in India.
Wages are deflated using state-level price indexes (source: IndiaStat). The
inclusion of this variable does not significantly affect the results. On the
other hand, changes in average wages do not appear to significantly affect
the birth of new firms (coefficients not reported). While wages are usually
found to be an important determinant of firms’ location decisions, their poor
performance in these specifications is likely to be due to the limited variation
in real wages over time, as suggested also in Becker and Henderson (2000).
21
Column 3 controls for changes in minimum wages in polluting sectors
(source: IndiaStat), while column 4 includes an additional variable indicat-
ing the presence of sector-specific special economic zones (source: Ministry
of Commerce and Industry, Department of Commerce). It is important to
control for the creation of new special economic zones (SEZ) as they pro-
vide notable advantages, such as tax exemptions, to new firms. India is
one the first country to recognize the importance of SEZs and the first zone
was created in 1965. The Indian government passed the SEZ act in 2005 in
order to increase investors’ confidence. The bill was implemented in 2006
and brought about a simplification of the bureaucratic procedures. While
most of the SEZs involve only the information technology sectors (55%) it is
still important to consider those that affected polluting sectors (about 20%
including also general multi-product SEZs) as they could induce possible
confounding effects if omitted. The inclusion or exclusion of both variables
has no significant effect on our main results.
The results obtained so far have helped to deal with the concern that
variations in environmental enforcement across states could proxy for differ-
ences in other state level unobservable characteristics. It is, however, pos-
sible that some differences in the policy environment remain unmeasured.
The results reported in column 5 include state-specific time trends and iden-
tify the effect of a change in the EIA process deviating from the pre-existing
state-specific trends. The effect of the 2006 EIA reform is still apparent and
mostly unchanged.
Table 7 reports the results obtained using the Poisson model. Also these
results support our central hypothesis: firm births in sector affected by
the decentralization process are more negatively affected by the strength of
environmental enforcement after the implementation of the reform, while no
changes are observed for non-affected sectors. The results are robust to the
inclusion of the additional control variables considered previously in table 6
and reported in column 2, 3, 4 and 5.
The coefficient related to those firms subject to state-level EIA if of
small capacity (Capacity) is now negative and statistically significant in one
specification (column 4). It is possible to further disaggregate this group of
firms by considering the classification of companies provided in the Orbis
database. This classification allows to distinguish firms into small, medium
and large and is based on annual turnover, total assets or total number of
employees. Although this classification is not intended to measure capacity
it can provide a reasonable approximation. The results reported in table 13
of the Appendix show that the effect is indeed much larger for small firms,
i.e. those more likely to be subject to state-level EIA. In column 2 of table
22
Table 7: Poisson Pseudo-maximum likelihood model: base specification and
additional control variables
13 the results are obtained using the Poisson estimator and show that the
negative effect previously attributed to the category ”Capacity” is entirely
capture by small firms. This confirms once again that the observed negative
effects are attributable to the decentralization process that has affected only
some polluting firms (Category B) established after 2007.
As noted earlier, no changes are observed for firms belonging to non-
polluting sectors. While this finding supports the underlying hypothesis,
this control group includes a large number of sectors and, although on av-
erage the effect is close to zero, it could conceal significant individual sector
responses. To provide further evidence in support to our hypothesis, the
effect is estimated separately for each of the 18 non-polluting sectors at two-
digit level. The extended model was estimated using both the linear and
Poisson estimators. A negative and significant coefficient was found only
for the tobacco (-0.214) and the office, accounting and computing machin-
ery (-0.371) sectors. It is reasonable to expect these two sectors to not be
indirectly affected by the reform as their appear to be quite disconnected
from category A sectors. The negative effects could, instead, be associated
to pre-existing trajectories in birth rates that will be analyzed in the next
section.
23
Among the 18 sectors mentioned above we consider also the automobile
industry. This sector was initially included in the draft EIA reform, officially
circulated in September 2005, but later removed from the final version of
the notification. Because all projects in the automobile sector were assigned
to state-level authorities, the fact that we do not find any effect of the
intervention suggests that there were no anticipatory effects of 2006 EIA
reform.
The results are summarized in figure 1 and are obtained using a linear
24
specification with a log-dependent variable applied separately to each group
of sectors. The graph reports the coefficients of the interaction terms for each
of the 5 groups of sectors. Statistical significance at a level lower than 10%
is indicated by a grey circle. Considering those sector of exclusive compe-
tence of state-level authorities (State), the results show that environmental
enforcement to have a significant negative effect from the end of 2007, while
for the period prior to the reform the effect is often close to zero or not
statistically significant. The drop after the implementation of the reform
is large and the coefficients remain negative and significant for the entire
post-reform period. Similarly, the coefficients related to those companies
subject to state-level EIA if located within an industrial estate (IE) show
a significant drop between 2006 and 2008. The coefficients remain negative
thereafter although not always significant. No significant differences are ob-
served for the group labeled ”Capacity”, probably for the reasons already
mentioned above, and for non-polluting firms.
Figure 2 reports the results of a similar analysis conducted for the sectors
tobacco and office, accounting and computing machinery that were found to
exhibit a significant drop in average births after the implementation of the
EIA reform. The graph reveals a negative trend in births beginning in 2003,
two years before the implementation of the reforms for the tobacco sector. In
25
the case of the machinery sector, in particular, the coefficients remain almost
stable before and after the implementation of the reform. This indicates that
the effects previously observed for these two sectors cannot be attributed to
the EIA reform and confirms our hypothesis that, while the decentralization
of the EIA process has affected firm births in polluting sectors subject to
state-level EIA, no unintended effects are observed on non-polluting sectors.
7 Conclusions
The decentralization of environmental regulation and enforcement has the
potential to lead to a more efficient and transparent system of pollution
control and management. On the other hand it carries the risk of inducing
a race-to-the bottom competition among local authorities and to suffer from
the consequences of heterogeneous financial and technical constraints across
the territory.
This paper has investigated whether the decentralization of the EIA
process in India initiated in 2006 has produced unintended effects on the lo-
cation decisions of polluting firms. The results have shown that the reform
has produced a significant change in the number of firm births in polluting
sectors leading to relatively higher birth rates in states with lower enforce-
ment levels. The results are robust to different specifications and are not
driven by other pre- or post- reform shocks.
These findings show that firms are responsive to variations in environ-
mental enforcement within India but are not intended to prove that states
actually use environmental stringency as a competitive instrument since in-
stitutional, technical and financial constraints also play an important role in
determining the effectiveness of environmental enforcement. Moreover, the
results neither suggest that a centralized approach (as the one in place before
the reform) would be optimal since no attempts were made to compare the
two enforcement models. The net social welfare effects of the 2006 reform
were not quantified and room is left for further research on the environmen-
tal and socio-economic consequences of the environmental decentralization
process in India.
26
Appendix
27
Table 8 – continued from previous page
28
Table 9: Date of constitution of State EIA Authority
29
Table 10: Results obtained employing a negative binomial model
Table 11: Sectors excluded from the analysis because of ambiguities in their
classification
30
Table 12: Number of new firms by category and state
31
Table 13: Small versus large companies in the ”Capacity” group
(1) (2)
OLS Poisson
Baseline: No EIA 0.038 0.001
(0.047) (0.038)
After x Aj x Central -0.001 -0.032
(0.072) (0.059)
After x Aj x Large 0.003 -0.001
(0.050) (0.049)
After x Aj x Small -0.058 -0.261∗
(0.095) (0.136)
After x Aj x IE -0.150∗∗∗ -0.126∗∗
(0.051) (0.055)
After x Aj x State -0.179∗∗∗ -0.110∗
(0.059) (0.058)
Observations 12596 30000
Average wage Yes Yes
Minimum wage Yes Yes
SEZ Yes Yes
State Yes Yes
Year Yes Yes
Sector Yes Yes
Clustered standard errors in parentheses.
∗
p < 0.1, ∗∗ p < 0.05, ∗∗∗ p < 0.01
32
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