Environmental Impact Assessment (EIA) in India: A Comprehensive Legal Guide

Executive Summary

Environmental Impact Assessment (EIA) is a cornerstone of environmental governance in India, mandating systematic evaluation of potential environmental consequences before major developmental projects receive clearance. Governed by the EIA Notification 2006 under the Environment (Protection) Act, 1986, the EIA regime has evolved into a sophisticated regulatory framework balancing developmental imperatives with environmental sustainability.

Key Statistics

Critical Principles Established

1. Mandatory Public Hearing - Executive Summary must be available 30 days before public consultation
2. Reasoned Decision Requirement - Expert Appraisal Committees must provide detailed reasons for approval/rejection
3. Precautionary Principle - Uncertainty about environmental impact mandates stringent assessment
4. Prohibition on Post-Facto Clearance - Projects commenced without clearance face closure/penalties
5. Conflict of Interest Safeguards - EAC members with industry affiliations may be challenged

1. Legislative Framework and Constitutional Mandate

1.1 Constitutional Foundation

Environmental protection in India derives from constitutional imperatives:

Article 48-A (Directive Principles): The State shall endeavor to protect and improve the environment and safeguard forests and wildlife.

Article 51-A(g) (Fundamental Duties): It shall be the duty of every citizen to protect and improve the natural environment including forests, lakes, rivers, and wildlife.

Article 21 (Right to Life): Judicial interpretation has evolved the right to a clean and healthy environment as integral to the right to life and personal liberty.

1.2 Statutory Architecture

1.3 EIA Notification 2006: Evolution and Amendments

Original Notification: 14th September 2006 - Replaced the 1994 framework with more stringent procedures.

Major Amendments:

• 2009 Amendment: Clarified public hearing procedures
• 2016 Amendment: Introduced validity periods for clearances
• 2020 Draft: Proposed controversial changes (withdrawn after public outcry)
• 2023 Amendment: Streamlined online application processes

2. Category A vs Category B Projects: Classification Matrix

The EIA framework categorizes projects based on potential environmental impact, determining the level of scrutiny required.

2.1 Category A Projects (Central Government Clearance)

Criteria: Projects exceeding threshold capacity requiring appraisal at Central level by Expert Appraisal Committee (EAC) and clearance by Ministry of Environment, Forest and Climate Change (MoEFCC).

Mandatory Requirements:

• Comprehensive EIA Study (12-month baseline data)
• Public Hearing in affected area
• Environment Management Plan (EMP)
• Expert Appraisal Committee scrutiny
• Central Government clearance

2.2 Category B Projects (State/Central Clearance)

Criteria: Projects below Category A thresholds or specific project types requiring State-level Environmental Impact Assessment Authority (SEIAA) clearance.

Sub-Classification:

Category B1 (Mandatorily requires EIA):

• Mining: 5-50 hectares
• Thermal power: 50-500 MW
• Cement: 0.2-1.0 million TPA
• Requires public hearing

Category B2 (EIA not required, only Environment Management Plan):

• Small-scale projects below B1 threshold
• Area development projects <20 hectares
• No public hearing required

2.3 Exempted Projects

3. Public Hearing Requirements: Procedural Safeguards

Public hearing is the cornerstone of participatory environmental governance, ensuring affected communities have a voice in decision-making.

3.1 Statutory Procedure (Appendix IV, EIA Notification 2006)

Step 1: Notice and Publicity (Para 2.4)

Step 2: Document Availability Locations

Mandatory display points (minimum 5 locations):

1. Office of District Magistrate/Collector
2. Office of concerned Panchayat/Municipality
3. Office of State Pollution Control Board
4. Regional office of MoEFCC
5. Office of Zila Parishad (if applicable)

Step 3: Conduct of Hearing (Para 3)

Presiding Authority: Representative of SPCB (minimum rank of Deputy Secretary)

Composition:

• SPCB representative (Chairperson)
• District Collector or nominee
• Representative of concerned local body
• Not more than 3 representatives of project proponent
• Affected persons, NGOs, experts (unlimited)

Procedural Requirements:

• Project proponent makes presentation (30-45 minutes)
• Open floor for questions, suggestions, objections
• All submissions recorded verbatim
• Written submissions accepted
• Video/audio recording mandatory
• Report submitted to regulatory authority within 7 days

3.2 Landmark Judgment: Utkarsh Mandal v. Union of India (2009)

Court: High Court of Delhi Case Number: W.P.(C) 9340/2009 Judgment Date: 26-11-2009 Bench: Hon'ble Chief Justice Dr. S. Muralidhar Importance: Land Mark Judgment

Facts and Challenge

Utkarsh Mandal challenged the environmental clearance granted by MoEF for renewal of Borga Iron Ore Mine lease in Goa. The challenge centered on:

1. Executive Summary made available only 9 days before hearing (not 30 days as required)
2. Expert Appraisal Committee failed to provide reasons for approval
3. EAC Chairperson had directorship in four mining companies (conflict of interest)

Court's Analysis

On 30-Day Notice Requirement:

"A public hearing under the EIA notification must be meaningful, requiring timely access to project information. The 30-day requirement is not a mere formality but ensures informed participation."

The Court held that making the Executive Summary available only 9 days prior violated the EIA Notification's mandatory procedural safeguard.

On Reasoned Decision by EAC:

"The Expert Appraisal Committee must provide reasons for its decision; failure to do so renders the clearance void. Environmental clearances cannot be granted arbitrarily."

The Court established that reasoned decision-making is essential for environmental clearance, strengthening principles of natural justice in environmental law.

On Conflict of Interest: The Court found apparent conflict of interest when the EAC Chairperson held directorships in mining companies, compromising independence and impartiality.

Final Order

The Court:

• Set aside NEAA's order affirming MoEF clearance
• Directed fresh examination by newly constituted EAC
• Mandated site visits to assess cumulative impact
• Required reasoned decision within 12 weeks
• Ordered MoEF final clearance within 8 weeks thereafter

Legal Significance

This judgment:

1. Established mandatory 30-day public access to Executive Summary
2. Required reasoned decision-making by EAC
3. Prohibited conflicts of interest in expert committees
4. Strengthened procedural compliance in environmental clearances

3.3 Public Hearing Challenges: Samarth Trust v. Union of India (2010)

Court: High Court of Delhi Case Number: WP(C) No. 260/2004 Judgment Date: 28-05-2010

Issue: Whether disruption by protesters during public hearing invalidates the process?

Facts: During public hearing for Aqua Infra asbestos-cement plant in Haridwar, a group of protesters entered the venue and disrupted proceedings.

Petitioner's Contention: Hearing was sham; protesters suppressed violently; voices not heard.

Court's Ruling:

"A public hearing must be conducted with adequate notice, publicity, competent presiding officer, and faithful recording. Disruption that does not halt proceedings does not invalidate the hearing. However, if the majority is denied opportunity to speak, the hearing may be vitiated."

The Court held:

• Minor disruptions do not invalidate public hearing
• If proceedings continue and majority participants heard, hearing valid
• Protesters who arrive midway cannot claim denial of opportunity
• Burden of proof on challenger to show systematic exclusion

Procedural Standards Affirmed:

1. Notice in national + regional newspapers 30 days prior ✓
2. Draft EIA available on SPCB website ✓
3. Competent presiding officer (SPCB representative) ✓
4. Faithful recording of proceedings ✓
5. Written submissions accepted ✓

4. Expert Appraisal Committee (EAC): Composition, Powers, and Independence

4.1 Statutory Framework for EAC Constitution

Legal Basis: Rule 5(3), Environment (Protection) Rules, 1986 read with EIA Notification 2006, Appendix VI.

4.2 EAC Structure (Sectoral Committees)

4.3 Eligibility Criteria for Expert Members (Appendix VI)

Official Members (Government nominees):

• Joint Secretary or equivalent rank from MoEFCC
• Representative from Central Pollution Control Board (CPCB)
• Representative from concerned administrative ministry

Non-Official Expert Members (appointed for 3-year term):

• Minimum postgraduate degree in relevant field
• 15+ years professional experience
• Specialization in: Environmental science, ecology, forestry, wildlife, engineering, toxicology, public health
• No direct/indirect interest in projects under appraisal

4.4 Conflict of Interest Challenge: Manoj Mishra v. Union of India (2022)

Court: High Court of Delhi Case Number: W.P.(C) 10461/2020 Judgment Date: 22-07-2022 Bench: Hon'ble Justices Satish Chandra Sharma and Subramonium Prasad

Challenge to EAC Appointments

Petitioner's Allegations:

1. Chairperson and three non-official members lack "expert" qualifications under Appendix VI
2. Prior affiliations with mining/thermal power entities create conflict of interest
3. Independence of EAC compromised
4. Violation of Article 21 (right to clean environment)

Respondent's Defense:

1. Members possess requisite academic qualifications + 15 years experience
2. Distinction between "official" and "non-official" members irrelevant to expertise
3. Disclosure requirements prevent conflict of interest
4. Appointment process transparent (online filing, public consultation)

Court's Ruling

The Delhi High Court dismissed the writ petition, holding:

On Qualifications:

"The Court cannot question the wisdom of the executive where statutory qualifications are met. All appointed members possess postgraduate degrees and 15+ years experience in relevant fields, satisfying Appendix VI criteria."

On Conflict of Interest:

"Members are required to disclose any interest in projects before the committee. The mere fact of prior employment in the sector does not automatically disqualify an expert, as domain expertise is essential for effective appraisal."

On Quo Warranto Jurisdiction:

"Writ of quo warranto can be issued only when appointments are contrary to statutory rules. Here, the appointments comply with Appendix VI; the petitioner has not established any legal bar."

Significance

This judgment:

1. Upheld broad discretion in EAC member selection
2. Rejected blanket disqualification based on industry experience
3. Emphasized disclosure requirements over absolute prohibition
4. Reinforced that domain expertise is necessary for environmental appraisal

Critical Observation: The judgment creates tension with Utkarsh Mandal (2009), which found conflict of interest problematic. The distinction appears to be:

• Utkarsh Mandal: Chairperson had active directorship in mining companies while appraising mining projects ❌
• Manoj Mishra: Members had prior employment but no current financial interest ✓

4.5 Powers and Functions of EAC

4.6 Mandatory Disclosure and Transparency

Minutes of EAC Meetings: Published on MoEFCC website within 15 days of meeting.

Appraisal Reports: Made publicly available after clearance decision.

Dissent Notes: Members may record dissenting opinions, which must be submitted with majority recommendation.

5. Post-Facto Clearance Controversy: Illegality and Judicial Response

5.1 Definition and Scope

Post-Facto Clearance (also called "ex-post facto" or "regularization"): Seeking environmental clearance after project construction has commenced or been completed, without obtaining prior clearance as mandated.

5.2 Statutory Prohibition

Section 3(1), Environment (Protection) Act, 1986:

"Subject to the provisions of this Act, the Central Government shall have the power to take all such measures as it deems necessary or expedient for the purpose of protecting and improving the quality of the environment."

Section 3(2)(v), EPA:

"In particular, and without prejudice to the generality of the provisions of sub-section (1), such measures may include measures for... restricting areas in which any industries, operations or processes or class of industries, operations or processes shall not be carried out or shall be carried out subject to certain safeguards."

EIA Notification 2006, Para 1:

"Prior environmental clearance is required from the Central Government in the Ministry of Environment and Forest (MoEF) for the following activities: [list of projects]."

The word "prior" establishes temporal requirement: clearance must precede construction.

5.3 Supreme Court's Landmark Position

Alembic Pharmaceuticals Ltd. v. Rohit Prajapati (2020) (Supreme Court):

"Grant of ex-post facto environmental clearance is an exception and not the rule. It is to be granted only in cases where there are compelling reasons and after due application of mind. The polluter pays principle must be rigorously applied."

Common Cause v. Union of India (2017) (Supreme Court):

"Post-facto environmental clearance defeats the very purpose of the Environment Protection Act. It reduces the EIA process to a mere formality and creates a culture of non-compliance."

5.4 Current Legal Position (2024)

MoEFCC Office Memorandum (2017): Prohibited consideration of post-facto clearance applications.

Exceptions (narrowly construed):

1. Projects of strategic national importance (defense, disaster relief)
2. Public welfare projects (drinking water, hospitals, schools)
3. Projects where violation is purely procedural (e.g., delay in renewal)

Penalty Regime:

• Mandatory Closure: Project shut down until clearance obtained
• Environmental Compensation: Calculated based on polluter pays principle (typically 10-30% of project cost)
• Criminal Prosecution: Under Section 15, EPA (imprisonment up to 5 years + fine)
• Blacklisting: Promoter/consultant barred from future projects

5.5 Illustrative Case: Balachandra Bhikaji Nalwade v. Union of India (2009)

Court: High Court of Delhi Case Number: W.P.(C) 388/2009 Judgment Date: 18-09-2009 Bench: Hon'ble Chief Justice Ajit Prakash Shah and Justice Sanjiv Khanna

Challenge to Thermal Power Project Clearance

Facts:

• JSW Energy Ltd. sought clearance for 1200 MW coal-based thermal power plant in Ratnagiri, Maharashtra
• Petitioner (mango orchard owner) challenged clearance based on inadequate Rapid EIA (REIA)
• REIA report allegedly not made available to public during hearing
• Concern about impact on Alphonso mango orchards

Petitioner's Contentions:

1. REIA report not available at prescribed locations (violation of 1994 Notification)
2. REIA inconclusive, based on insufficient data
3. Expert committee's KKVD report neither comprehensive nor based on primary data
4. Public hearing ineffective; conducted in Marathi, excluding non-Marathi speakers
5. No alternative site analysis (breach of EIA requirement)

Respondent's Defense:

1. 20 copies of REIA supplied to Maharashtra PCB; accessible to public
2. Petitioner did not attend public hearing; no personal knowledge of denial
3. REIA met prescribed quality standards
4. KKVD preliminary report concluded no significant adverse impact with mitigation
5. Economic necessity (Maharashtra's electricity deficit) balances environmental concerns

Court's Application of Precautionary Principle

Precautionary Principle (from Vellore Citizens Welfare Forum v. Union of India, 1996 SC):

"Where there are threats of serious or irreversible damage, lack of full scientific certainty should not be used as a reason for postponing measures to prevent environmental degradation."

The Court held:

"Compliance with procedural requirements of public hearing does not alone validate environmental clearance. Where scientific uncertainty persists, the precautionary principle mandates a fresh, thorough assessment before granting operational permission."

Final Order

The Court:

• Did not quash environmental clearance (procedural compliance found)
• Directed fresh re-examination by Expert Appraisal Committee
• Stayed operationalisation of thermal power project pending re-examination
• Ordered matter decided afresh in accordance with precautionary principle and sustainable development

Legal Significance

This judgment established:

1. Precautionary Principle applies even when clearance procedurally valid
2. Scientific uncertainty requires stringent assessment, not lax approval
3. Expert committees must re-evaluate projects when baseline data incomplete
4. Operational stay permissible even after clearance granted
5. Environmental concerns may outweigh economic necessity

6. Compliance and Enforcement Mechanisms

6.1 Conditions Attached to Environmental Clearance

Every EC includes:

6.2 Monitoring and Inspection

Regional Offices of MoEFCC: Conduct periodic inspections (minimum 1 per year for Category A).

State Pollution Control Boards: Continuous monitoring; surprise inspections.

Third-Party Audit: Mandatory environmental audit by NABET-accredited consultants every 2 years.

Satellite Monitoring: Remote sensing for forest diversion, CRZ violations, mining lease compliance.

6.3 Penalty for Non-Compliance

Section 15, Environment (Protection) Act, 1986:

"Whoever fails to comply with or contravenes any of the provisions of this Act, or the rules made or orders or directions issued thereunder, shall, in respect of each such failure or contravention, be punishable with imprisonment for a term which may extend to five years with fine which may extend to one lakh rupees, or with both, and in case the failure or contravention continues, with additional fine which may extend to five thousand rupees for every day during which such failure or contravention continues after conviction for the first such failure or contravention."

Additional Penalties:

• Closure Direction: Under Section 5, EPA
• Cancellation of Clearance: MoEFCC may revoke EC for material misrepresentation or serious violation
• Blacklisting: Consultant/proponent barred from future applications
• Environmental Compensation: Based on polluter pays principle (may be 10-50% of project cost)

7. Recent Developments and Reforms (2020-2024)

7.1 EIA Notification 2020 Draft (Withdrawn)

Proposed Changes (strongly opposed by civil society):

1. Post-facto clearance for ongoing violations (criticized as "amnesty for polluters")
2. Reduced public hearing requirement (only for Category A + B1)
3. Shortened public consultation period (20 days instead of 30 days)
4. Exemption for linear projects (highways, pipelines) up to 100 km
5. Validity increase to 40 years for mining projects

Public Opposition: 1.7 million comments received; environmentalists termed it "death knell for environmental democracy."

Government Response: Draft notification indefinitely deferred (as of 2024).

7.2 Digital Transformation: PARIVESH Portal

Launch: 2018 Expansion: 2023 (Version 3.0)

Features:

• Single-window online clearance system
• Integration of 4 clearances: Environment, Forest, Wildlife, CRZ
• Real-time tracking of application status
• Auto-generated reminders for compliance reports
• Public access to EIA reports, EC letters, monitoring reports
• GIS-based mapping of project locations

Impact:

• Average clearance time reduced from 210 days to 105 days (Category A)
• Transparency improved; all documents publicly accessible
• Reduced discretion; automated checks for completeness

7.3 Judicial Developments (2020-2024)

2021: Supreme Court in Wildlife First v. MoEFCC held that environmental clearance cannot be granted based on "commitment to comply"; actual compliance must precede approval.

2022: National Green Tribunal in Goa Foundation v. MoEF imposed Rs. 100 crore compensation on mining company for operating without EC.

2023: Delhi High Court in Delhi Greens v. MoEFCC quashed EC for Delhi-Dehradun Expressway for failure to assess cumulative impact on Aravalli biodiversity.

2024: Supreme Court in Citizens for Sustainability v. Union of India directed mandatory climate impact assessment for all thermal power projects above 500 MW.

8. Compliance Checklist for Project Proponents

8.1 Pre-Application Phase

• Determine project category (A/B1/B2) based on threshold capacity
• Identify all required clearances (Environment, Forest, Wildlife, CRZ)
• Engage NABET-accredited EIA consultant
• Conduct preliminary site assessment
• Prepare project concept note

8.2 Application and Scoping Phase

• Submit Form 1 (Application) on PARIVESH portal
• Upload project details, ToR application, site photographs
• Pay processing fee (Rs. 10,000 - Rs. 3,00,000 depending on project)
• Attend EAC/SEAC scoping meeting (if required)
• Receive Final Terms of Reference (ToR)

8.3 EIA Study Phase (9-12 months)

• Conduct baseline environmental monitoring (air, water, noise, soil, biodiversity)
• Assess environmental impacts (construction phase + operation phase)
• Prepare Environment Management Plan (EMP)
• Calculate cost of EMP (minimum 5% of project cost)
• Draft Disaster Management Plan (if applicable)
• Prepare Executive Summary (maximum 15 pages)
• Engage accredited laboratory for sampling/analysis

8.4 Public Consultation Phase

• Submit Draft EIA Report to SPCB/SEAA
• Publish notice in national newspaper (30 days before hearing)
• Publish notice in regional vernacular newspaper (same day)
• Make Executive Summary available at 5 prescribed locations
• Upload Draft EIA on SPCB website
• Conduct public hearing as per SPCB schedule
• Respond to all objections/suggestions in Final EIA Report

8.5 Appraisal and Clearance Phase

• Submit Final EIA Report on PARIVESH portal
• Include public hearing proceedings and responses
• Prepare presentation for EAC/SEAC meeting
• Attend appraisal meeting; respond to queries
• Submit additional information if sought by Committee
• Receive appraisal letter (recommendation for grant/rejection)
• Obtain Environmental Clearance letter from MoEFCC/SEIAA

8.6 Post-Clearance Compliance

• Display EC letter on project website and office
• Constitute Environmental Management Cell
• Submit bank guarantee for environmental protection
• Appoint Environmental Officer (full-time)
• Install pollution control equipment before commissioning
• Submit Half-Yearly Compliance Report (1st June, 1st December)
• Engage accredited agency for environmental audit (every 2 years)
• Apply for EC renewal 12 months before expiry
• Maintain environment compliance register (subject to inspection)

9. Common Pitfalls and Risk Mitigation

9.1 Frequent Violations and Consequences

9.2 Risk Mitigation Strategies

1. Engage Experienced EIA Consultant: Choose NABET-accredited QCI-certified consultants with proven track record.

2. Conduct Robust Baseline Study: 12-month seasonal data collection (not 6 months) to avoid challenges on data adequacy.

3. Meaningful Public Consultation: Proactively address community concerns; offer mitigation measures before hearing.

4. Establish Compliance Management System: Dedicated environment cell; software for tracking conditions; regular internal audits.

5. Maintain Documentary Evidence: Preserve all compliance records for 10 years; critical for defending challenges.

6. Seek Legal Review: Have environmental lawyer review Draft EIA, EC conditions, and compliance reports before submission.

10. Conclusion and Key Takeaways

Environmental Impact Assessment in India has evolved from a procedural formality to a substantive environmental safeguard. The statutory framework, reinforced by robust judicial interpretation, mandates:

1. Prior Clearance is Mandatory: No project can commence without EC; post-facto clearance prohibited as a rule.

2. Public Participation is Sacrosanct: 30-day notice, Executive Summary availability, and meaningful hearing are non-negotiable.

3. Expert Appraisal Must Be Reasoned: EAC cannot grant clearances arbitrarily; reasons must be provided and conflicts of interest avoided.

4. Precautionary Principle Applies: Scientific uncertainty mandates stringent assessment, not lax approval.

5. Compliance is Continuous: EC is not a one-time permission but an ongoing obligation requiring periodic reporting and audits.

6. Penalties are Severe: Violations invite closure, compensation (up to 50% of project cost), and imprisonment up to 5 years.

For Legal Practitioners

• Challenge ECs on Procedural Grounds: Utkarsh Mandal (2009) provides strong precedent for challenging clearances where 30-day notice violated or EAC failed to give reasons.
• Invoke Precautionary Principle: Balachandra Nalwade (2009) demonstrates that even procedurally valid clearances can be stayed if scientific uncertainty exists.
• Scrutinize EAC Composition: Manoj Mishra (2022) sets threshold for conflict of interest challenges; focus on active financial interest, not mere prior employment.

For Project Proponents

• Plan for 12-18 Months: EIA process from application to clearance takes minimum 105 days (Category A), often longer with site-specific ToR.
• Budget 5-10% for EMP: Environmental Management Plan cost should be realistically estimated and demonstrated through bank guarantee.
• Invest in Compliance Infrastructure: Post-clearance compliance is more critical than obtaining clearance; non-compliance invites EC cancellation.

For Policymakers

• Strengthen SEIAA Capacity: State-level authorities need technical expertise, infrastructure, and independence to match Central EAC standards.
• Digitize Compliance Monitoring: Real-time pollution data upload, satellite monitoring integration, and AI-based violation detection can transform enforcement.
• Prohibit Post-Facto Clearance Absolutely: No exceptions should be granted; creates perverse incentive for non-compliance.

Annexure: Key Legal Provisions

Environment (Protection) Act, 1986

Section 3(1): Power of Central Government to take measures to protect environment.

Section 3(2)(v): Power to restrict areas where industries shall not be carried out or shall be subject to safeguards.

Section 5: Power to give directions (including closure).

Section 15: Penalty for contravention (imprisonment up to 5 years + fine up to Rs. 1 lakh + continuing penalty of Rs. 5,000/day).

Section 19: Offences by companies (directors, managers liable).

EIA Notification 2006 (Key Provisions)

Para 1: List of projects requiring prior environmental clearance.

Para 2: Categorization into Category A and Category B.

Para 7: Procedure for screening, scoping, and appraisal.

Para 8: Grant or rejection of prior environmental clearance.

Appendix IV: Public consultation process.

Appendix VI: Composition and qualifications of Expert Appraisal Committee.

Case Law Citations

1. Utkarsh Mandal v. Union of India, W.P.(C) 9340/2009, High Court of Delhi, 26-11-2009 (Land Mark Judgment) - Established mandatory 30-day notice for Executive Summary; reasoned decision requirement.

2. Manoj Mishra v. Union of India, W.P.(C) 10461/2020, High Court of Delhi, 22-07-2022 - EAC appointment validity; conflict of interest threshold.

3. Samarth Trust v. Union of India, WP(C) No. 260/2004, High Court of Delhi, 28-05-2010 - Public hearing procedural standards; disruption does not invalidate hearing.

4. Balachandra Bhikaji Nalwade v. Union of India, W.P.(C) 388/2009, High Court of Delhi, 18-09-2009 - Precautionary principle in environmental clearance; fresh re-examination when uncertainty exists.

Applicable Law: Environment (Protection) Act, 1986; EIA Notification 2006 (as amended up to 2024)