India’s budget for 2022 finally recognised the urgency of acting on India’s clean energy and climate ambitions, but remains far from describing a clean low-carbon development plan
Over the past two years, it has become clearer that infrastructure is India’s big economic bet for the decade. Prime Minister Narendra Modi made this vision known through his announcement of the Gati Shakti plan last year. This ₹100-crore national infrastructure master plan “will make a foundation for holistic infrastructure and give an integrated pathway to our economy,” PM Modi had said, while launching it on Independence Day last year. This “holistic infrastructure” includes railways, roads, airports, ports, mass transport, waterways and logistics. But a plan of this magnitude needs an incredible amount of energy to develop and sustain—and increasingly, a roadmap that is clean and green.
By many indications, the Union Budget presented a glimpse of where the government’s priorities will lie in pulling together such a roadmap. Finance minister Nirmala Sitharaman’s budget speech was peppered with references to clean energy transition and sustainable living—especially in cities—green bonds and a climate action fund. While in previous budgets, these terms were buried deep in sections pertaining to climate change or sustainability, their prominence this year shows they are a priority. But a bit of number crunching reveals that there is still a significant gap between what is being said and what is on paper.
“At a macro level, increase in Capex will boost economic growth, however, not much additional budgetary support or tax incentives have been provided to clean energy, both grid and off-grid, including solar rooftop, storage technologies and green hydrogen. This is despite the big expectation that support will be provided to these new technologies to improve its commercial viability,” says Vibhuti Garg, Energy Economist, Lead India, IEEFA.
What the budget says on climate, clean energy
At this year’s COP, PM Modi announced India would become net zero by 2070. While this move was welcomed by the world, questions were also raised about how the country would go about achieving this goal, especially with climate disasters on the rise. According to a study by the Overseas Development Institute, India is set to lose 3-10% of its GDP to global warming. Not surprising, considering a single event such as Cyclone Amphan in 2020 affected 13 million people and caused over $13 billion in damage, according to the study.
To get India closer to its 2070 goal, Sitharaman announced the following plans for India’s climate action and clean energy transition goals.
- A climate action fund to achieve its ambitious green targets. The government’s contribution will be a maximum 20%, while the remaining will be made by private participants.
- Four pilot projects for coal gasification and conversion of coal into chemicals
- Biomass pellets will be used to reduce carbon dioxide, saving 38 MMT annually, Sitharaman said. This would also provide extra income to farmers, jobs to locals and reduce stubble burning.
- Green bonds will be issued to mobilise green infrastructure. The funds generated will be used for projects that will help reduce carbon intensity of the economy, Sitharaman said.
- 400 new generation Vande Bharat trains with better energy efficiency and passenger riding experience will be manufactured in the next three years.
- To promote a shift to the use of public transport in urban areas, Sitharaman announced special mobility zones with zero fossil fuel policy to be introduced.
- Considering space constraints in urban areas, a ‘Battery Swapping Policy’ will be brought in, the FM said. As per this policy, an owner of an electric vehicle can exchange a depleted battery with one that has been fully charged at a station without having to wait to charge the existing one.
- To facilitate domestic manufacturing for India’s ambitious goal of 280 GW of installed solar capacity by 2030, Sitharaman announced an additional allocation of ₹19,500 crore for production-linked incentives (PLI) to manufacture high-efficiency modules with priority to fully integrate manufacturing units to solar PV modules.
An analysis by the Centre for Budget and Governance Accountability (CBGA) stated Budget 2022 “sent an important signal to markets, financial institutions and the workforce by mentioning the clean energy and climate section as a sunrise industry and an employment generator.” But are signals enough when the country seems to be haemorrhaging money with each climate disaster?
The truth lies somewhere in between.
What the budget means
“The Union budget 2022 prioritised climate action as one of the four pillars and explicitly acknowledged the threat of climate risks, but it clearly missed on providing a booster shot to climate adaptation and resilience. While a renewed focus on urban planning was one of the key takeaways in the budget, there was no mention of climate-proofing these investments and infrastructure. More than 75% of Indian districts are extreme event hotspots as a result of which India has suffered an annual average loss of $87 billion,” said Abinash Mohanty, Programme Lead, Council on Energy, Environment and Water (CEEW).
Take the Gati Shakti plan as an example. The plan alludes to clean energy through the use of high-efficiency trains. But there is no mention of funds to make the “holistic infrastructure” pertaining to roads and airports and other forms of mass transport more climate-resilient. Climate adaptation also did not get any special attention.
According to official estimates, India would require $4.5 trillion in clean infrastructure investments by 2040 to meet its current climate action commitments. Adaptation efforts in the country too are slated to require about $206 billion (at 2014-15 prices, eq. to about $257 billion at current prices) between 2015-2030— an annual average of $17.1 billion. According to the 2021-22 Economic Survey, released a day before the Budget, India’s adaptation efforts are predominantly financed domestically. Between 2015-19, just $113 million (around ₹847.5 crore), at an annual average of $7.5 million, was spent on adaptation covering 30 projects across the country.
Budgetary allocations are only a drop in the bucket when relative to the quantum of funds required. The budget finally carried a tacit acknowledgement of the massive deficit in climate action spending. The government will now look to close these gaps through the issue of green bonds, which will lock in funds for low-carbon infrastructure and the setting up of the Climate Action Fund, 75% of which will be contributed by the private sector.
While the allocation of ₹19,500 crore for production-linked incentives (PLI) is a step in the right direction to boost domestic manufacturing of solar, what is missing is the allocations to research and develop solar technology that will have more far-reaching outcomes. The enthusiastic official endorsements of green hydrogen over the past year are not reflected in the budget, with an outlay of just ₹1 lakh. Instead, India’s priority in the budget was clearly natural gas. While most outlays under the Ministry of Petroleum and Natural Gas remained static or showed modest changes, exploration and production capex allocations towards the Gas Authority of India Limited (GAIL) increased by over 20%. The refinery and marketing allocations for the public sector company more than doubled from last year.
The bullishness on gas, however, is not evident in the outlay for domestic subsidies. According to an analysis by the Centre for Policy Research, this budget nullified the rapid success of the expansion of LPG for cooking through the Pradhan Mantri Ujjwala Yojana (PMUY) in the fight to control air pollution. It allocated only ₹4,000 crore for LPG subsidies (down from over ₹12,000 crore in 2021-22, and over ₹26,000 crore in 2020-21), the analysis found. As far as biomass pellets are concerned, the analysis stated that the plan to increase their use remains unexplained and their effectiveness at reducing stubble burning is still up for debate.
In keeping with India’s commitment to phase down coal, allocations towards coal and lignite have dropped sharply after the big push for exploration in the past few years. After the tepid response to commercial coal auctions, there are clear signs of a pivot from the direct usage of raw coal. While allocations for this aren’t clear in the budget documents, the FM’s announcement of pilot coal gasification projects may be construed as an indication of the direction the Indian government intends to head towards respect to the future of coal.
A welcome change, however, is the mega boost that the budget has given to electric vehicles. The allocation for the FAME India subsidy scheme increased from ₹800 crore in 2021-22 to ₹2,908 crore in 2022-23. The PLI scheme for National Programme on Advanced Chemistry Cell (ACC) Battery Storage also got a ₹3-crore boost. This could work well under the government’s vision to turn urban areas into special mobility zones with zero fossil fuel policy.
The most glaring problem, however, is which ministry will deliver on India’s 2070 net-zero aim. The Ministry of New and Renewable Energy (MNRE) and the Ministry of Environment, Forests and Climate Change (MoEF&CC), which are largely in-charge of India’s climate efforts, got ₹6,788 crore and ₹3,030 crore, respectively, but this is not nearly enough as the expectations of the 2070 target loom large over both. “Presently no single ministry can deliver Modi’s panchamrit—the five nectar elements announced at COP26 last year. Climate scientists have been demanding that there should be a separate ministry of climate change, which will give the impetus needed to PM pledge of net zero by 2070,” says Dr Anjal Prakash, research director and adjunct associate professor at the Bharti Institute of Public Policy, Indian School of Business.
Extremely high temperatures over the Indian Ocean is reducing rainfall over central India, but increasing it over the country’s south peninsular region, a new research paper found. The paper by the Centre for Climate Change Research at the Indian Institute of Tropical Meteorology revealed that between 1982 and 2018, marine heatwaves increased the most in the western Indian Ocean region, at a rate of 1.5 events per decade. This was followed by the north Bay of Bengal (0.5 events per decade).
The western Indian Ocean experienced 66 marine heatwaves during this period, while the Bay of Bengal reported 94, according to the study. These events are only likely to increase in the future as the Indian Ocean warms further, the study warned.
Meanwhile, a new study found the North Indian Ocean is showing an increasing frequency of extremely severe and higher-category cyclonic storms, especially in the month of May. A possible cause for this is the warmer ocean temperature in May and the weakening summer monsoon circulation, according to the study.
Heavy rains trigger devastation in Brazil
Weeks of incessant rains have killed well over a hundred people in Brazil, with the maximum damage being reported from the mountainous regions of Brazil’s Rio de Janeiro state. Mudslides and floods triggered by heavy rainfall killed at least 94 people in the “imperial city”, Petrópolis, in the latest spell that began on Tuesday. The deluge in Petrópolis is the latest in a series of heavy rains and flooding episodes that begin in December 2021.
US in the midst of the worst drought in recorded history
A ‘megadrought’ in the American Southwest that has stretched on for 22 years is the worst the region has seen in at least 1200 years. According to new research, an exceptionally dry 2021 cemented the current drought as the worst since scientific record-taking began in the year 800. The study has categorically highlighted the influence of human-induced climate change, stating that in the absence of background warming due to climate change, current conditions probably wouldn’t be classified as a megadrought at all. “It probably wouldn’t even be a continuous drought. We still would have had a drought. It still would have been reasonably bad. But it would be nowhere near the record-breaking event that we’re seeing right now,” said Benjamin Cook.
1.5°C warming scenario catastrophic for remaining coral reefs, says study
A new study confirmed that a 1.5°C warming scenario could be “catastrophic” for the world’s remaining coral reefs. Around 84% of these reefs are in regions that can currently withstand the impacts of marine heatwaves. But with 1.5°C warming, the study projected this percentage to drop to 0.2%. In a 2°C warming scenario, all coral reefs will cease to exist, the study warned.
A new analysis found a majority of multinational companies, which Science-Based Targets initiative (SBTi) had found to be 1.5°C-2°C compatible, did not actually live up to these labels. The analysis by The New Climate Institute (NCI) found the green targets of 11 of the 18 MNCs that it observed to be “highly contentious due to subtle technicalities”.
The climate plans of Several high-profile brands such as Nestlé, Ikea and Unilever were found to have “very low integrity”. The SBTi has previously endorsed thousands of companies to be in line with global climate targets. But according to the NCI, there is a conflict of interest because the SBTI is funded by the same companies whose climate plans it approves.
Experiences with extreme weather raise people’s concern about environment, promotes green voting: Study
A new study found that people’s personal climate change experiences had “significant and sizeable effect” on their concern for the environment and voting for green parties. These experiences included temperature anomalies, heat episodes and dry spells. The study analysed how the experience of climate extremes influences people’s environmental attitudes and willingness to vote for Green parties in Europe.
The magnitude of this effect, however, differed substantially across European regions. It was stronger in regions with a cooler Continental or temperate Atlantic climate and weaker in regions with a warmer Mediterranean climate, according to the study published in the journal Nature.
India’s only national green party, however, is failing to find supporters despite the country experiencing a rise in extreme weather events. The India Greens Party is struggling to make its presence felt ahead of UP Assembly elections due to lack of funds, candidates.
Public perception and political response emerge as key drivers of climate change and climate action in exhaustive study
Climate policy ambitions are largely determined by political appetite and public opinion, yet most climate change simulations exclude political and social drivers of policy, and rely purely on technological pathways. A new study has taken the first step towards plugging this gap in projection science. The study, which simulates 100,000 possible future policy and emissions trajectories, indicates that public perceptions and how political institutions respond to public pressure will be key determinants in the evolution of climate change and climate action over the 21st century, in addition to the development of mitigation technologies.
The integrated, multi-disciplinary model used for the study integrates social and political variables to create scenarios to reflect factors such as public and political support, social perceptions of climate change, how quickly collective action or carbon pricing responds to changes in public opinion. The resultant pathways fell into five clusters, with warming in 2100 varying between 1.8 to 3.6 degrees Celsius above the 1880-1910 average, but with a strong probability of warming between 2 and 3 degrees Celsius at the end of the century.
Debt, tax justice needed to meet global biodiversity targets: Study
The lack of public financing is the reason for the failure to reach global biodiversity targets, particularly in the Global South, according to a new study. The study proposed relying on tax reform and debt justice to supercharge public financing for biodiversity and deflate harmful financial flows, while trying to analyse the causes of state austerity. “We must move beyond simply attempting to fill the funding gap, and initiate transformative change that addresses underlying drivers [political and economic] of biodiversity loss,” the study stated.
Start using PNG or biomass fuel by September 30 this year, or face a shut down, that’s the warning all industries in Haryana, Uttar Pradesh (UP) and Rajasthan located within the National Capital Region (NCR) have been issued. The Commission for Air Quality Management (CAQM) said the decision was taken after conversations with companies, associations and the state governments concerned. The CAQM order said a large number of associations and individuals sought permissions for the use of biomass fuels in addition to PNG [piped natural gas], citing that biomass-based fuels are cleaner than fossil fuels like HSD [high-speed diesel] and coal. Industries in Delhi have already shifted to cleaner fuels, including PNG, the panel said in its order to the three states.
IMD extends air quality information service to 6 more cities
The India Meteorological Department (IMD) has now extended its operational air quality information services for general public and pollution control authorities to Varanasi, Lucknow, Allahabad, Kolkata, Bengaluru and Patna. Earlier, air quality information was being provided only for New Delhi, Chennai, Mumbai, Ahmedabad and Pune. The SAFAR-Air web application developed by the Indian Institute of Tropical Meteorology (IITM), Pune, gives location specific air quality index and advisory in Delhi, Pune, Mumbai and Ahmedabad.
Chennai air pollution 5 times higher than WHO standards: Greenpeace study
A Greenpeace study found Chennai’s air quality levels for 2021 exceeded the World Health Organisation (WHO) limits by five times. The WHO annual limit for PM 2.5 levels is 5 microgram/m3. Chennai’s annual average, calculated from November 2020 to November 2021, was 27 microgram/m3). TOI reported that Manali and Kodungaiyur TNPCB stations recorded six times higher PM 2.5 levels than WHO standards, with 30 microgram/m3, while stations at Perungudi. Royapuram and Velachery recorded three to four times more. Experts pointed out that Chennai is part of the Centre’s ‘million-plus city’ plan that has about 30 cities in it. But the plan does not identify the exact sources of pollution, instead it classifies them generally as vehicular, construction or road dust.
Aggregators asked to increase EV fleet by May to curb air pollution
To bring down air pollution, the Centre asked the Delhi government to ensure all cab-hailing companies and delivery services provide 10% of electric two-wheelers and 5% electric four-wheelers within the next three months. The department of Environment and Forests draft notification directed the Delhi government to increase electric vehicle adoption stating that the transport sector is the primary source of PM2.5 emissions in Delhi, with vehicular emissions accounting for 80% of NO2, CO in Delhi.
Centre’s budget to fight air pollution reduced: Green think-tanks
Différent think-tanks said the government’s 2022-23 budget allocations to fight air pollution have been reduced, reported TOI. The Delhi-based Legal Initiative for Forest and Environment
(LIFE) and Centre for Policy and Research point out that although the overall budget of the ministry has been increased by 20%, from Rs2,520 crore in 2021-22 to Rs3,030 crore in 2022-23, the amount allocated to fight air pollution is not adequate.
LIFE analysis stated that Rs460 crore for ‘control of pollution’ is insufficient to even cover the cost of monitoring air quality in 132 cities where the National Clean Air Plan is implemented. This does not include the 4,000 polluted cities and towns outside the purview of NCAP. The CPR stated that the financial allocation for the Commission on Air Quality Management (CAQM) has decreased and it remained unchanged for the NCAP.
Vehicular traffic, domestic heating key drivers of air pollution in Europe
Europe’s efforts to improve air quality across its cities resulted in the submission of 944 air quality plans to the EEA from 2014 to 2020. With respect to the dominant contributors to poor air quality, the report found that just under two thirds of all reported breaches ofair quality standards were linked to traffic in urban centers and proximity to major roads. Vehicular traffic was identified as a key source of air pollution in western and northern Europe. Austria, Denmark, Finland, the Netherlands, Portugal, and the United Kingdom reported traffic as the only source of exceedances. In southern and eastern Europe, the key driver of air quality standard breaches was identified as domestic heating. Two-thirds of the air pollution control measures focus on reducing emissions of NOx from the transport sector. Despite being important sources of particulate matter, only 12% and 4% of the plans focused on domestic heating and agriculture.
Improvement in air quality reduces cognitive declines in older women: Study
According to a PLOS Medicine study, improvement in long-term air quality in late life is associated with slower cognitive declines in older women. Scientists from the University of Southern California in Los Angeles examined whether AQ improvement was associated with slower rates of cognitive decline in older women (aged 74 to 92 years). The analysis included 2,232 American women enrolled in the Women’s Health Initiative Memory Study-Epidemiology of Cognitive Health Outcomes study, who were dementia free at baseline (2008 to 2012).
The researchers found that during a median 6.2 years of follow-up, there were declines in both general cognitive status and episodic memory. When adjusting for covariates, there was an association seen between greater AQ improvement and slower decline, the study stated.
Last fortnight the government in the Union budget announced an additional allocation of ₹19,500 crore for Production Linked Incentive (PLI) for manufacture of high efficiency solar modules to fully integrated manufacturing units that can transition from polysilicon to solar PV modules, HT reported. This is expected to boost domestic manufacturing for implementation of 280 GW of installed solar capacity by 2030.
The government also announced sovereign Green Bonds under the government’s overall market borrowings in 2022-23, which will be used to mobilise resources for green or climate-friendly infrastructure. The money from the green bonds will be deployed in public sector projects that help in reducing the carbon intensity of the economy, she said.
Green bonds are one of the most prevalent bond instruments to fund renewable energy infrastructure.
ACME-Scatec put 900 MW solar project on hold over upcoming 40% import duty
The impending 40% import duty from April 1 and supply chain bottlenecks led India’s ACME and Norwegian company Scatec to put the 900 MW, $400 million, solar energy plant in Rajasthan on hold. Last year, Scatec entered into partnership with ACME to build the plant in Rajasthan under a 25-year power purchase agreement with Solar Energy Corporation of India (SECI), Reuters reported. The plant was expected to be completed in 2022, but building work had not yet begun.
India plans to levy Customs duties on solar modules and solar cells to cut its dependence on China-made imports and boost local manufacturing
DISCOM Terminating PPAs unilaterally not in public interest: Supreme Court
In an Andhra Pradesh renewable energy project case, India’s Supreme Court said it was not in public interest for a state DISCOM to terminate an existing Power Purchase Agreement unilaterally. The top court backed the verdict passed by Appellate Tribunal for Electricity, which had directed the state commission to pass an order to determine capital cost and approve the restated PPAas requested by solar developer Hinduja National Power Corporation.
House panel suggests setting up of green banks to boost RE
A Parliamentary panel asked the government to set up green banks as one of the innovative tools to deal with financial constraints in the renewable energy sector. The panel also recommended that the government explore the possibility of prescribing Renewable Finance Obligation on the lines of Renewable Purchase Obligation (RPO) for banks and financial institutions.
The panel also suggested the use of alternative funding avenues like Infrastructure Development Fund (IDF), Infrastructure Investment Trusts (InVITs) Alternate Investment Funds, Green/Masala Bonds, crowdfunding, etc, for the RE sector. The panel noted that India would need an annual investment of Rs1.5-2 lakh crore in the RE sector, but the estimated investment for the past few years has been around Rs75,000 crore only.
China shifts focus to Gobi desert for fresh renewables push
China’s new plans for expansion of renewable energy will focus on the Gobi and various other desert regions of the country. In a fresh policy record, Chinese energy regulators stated that the country will aim to double its current 600GW capacity of solar and wind energy by 2030. The record also states that by the end of the decade, a system that ensures all new energy needs are met by renewables will be established. The National Energy Administration (NEA) also plans to expand financing channels for renewable projects, and roll out a green certification program to incentivize investments. While coal use in China is set to rise until 2025, the policy note reiterates the country’s plan to wind up unabated and inefficient coal capacity, while increasing support for carbon capture and storage space at thermal plants.
The Indian government is likely to offer incentives to promote the use of battery swapping across the country, with the objective of lowering the charging times and the upfront purchase costs of EVs. The incentives are likely to come as a part of a new battery swapping policy to be announced by NITI Aayog in three months, and would allow customers to avail up to 20% of the cost of the battery — the most expensive component of an EV — over and above the subsidies available for buying the vehicles themselves. The batteries’ form factors and charging standards will be standardised, and the announcement comes even though Tesla, the world’s most popular electric vehicle manufacturer, has decided not to adopt battery swapping.
Older cars in Delhi to be approved for electric retrofitment
The Transport Department at the Delhi government approved the registration of old petrol and diesel cars in Delhi retrofitted with electric conversion kits, so long as the retrofitment is carried out by one of the 10 empanelled kit manufacturers. The vehicles will need to be modified by trained technicians and must undergo fitness tests at least once a year and the age limits for the cars will be more than 15 years for petrol units and more than 10 years for diesel. The cost of the retrofitment is estimated to range from Rs. 3-5 lakh.
GM to up e-truck production by 600%, Volvo to adopt Tesla-style mega casting
GM’s CEO Mary Barra announced that the automaker would ramp up the production of its electric trucks by six-fold within 2022 alone as it gets ready to deliver 400,000 EVs across North America before 2024. Trucks are a popular vehicle for private purchase in the US and the increased production rate will be supported by GM investments in its new EV battery and cell assembly capacities that will enable it to put together one million EVs by 2025.
Also, Swedish carmaker Volvo will reportedly switch to the “mega casting” method of manufacturing car bodies, under which entire components of the vehicles are cast from a single aluminium block. The switch is said to be inspired by what Tesla does at its Texas factory and is supposedly instrumental in boosting its production efficiency and lowering costs. The mega casting method will be unveiled at Volvo’s Torslanda plant in southern Sweden, which itself will transition to manufacturing only electric cars by 2030.
The European Commission endorsed natural gas as a transition fuel under its new sustainable financial taxonomy, stressing that the “imperfect solution” was simply to make way for greater transparency in the region’s energy finance sector and not to influence energy policy. The decision to back the fossil fuel was supported by Eastern European nations, Central European countries and Germany, but may be dragged to the courts by the smaller economies of Luxembourg, Austria, Netherlands, Denmark and Sweden. It was also criticised by Greenpeace EU, which called it the “biggest greenwashing exercise” of all time, and something that might lead to greater emissions in the face of an urgent need to slash the bloc’s use of fossil fuels.
Most importantly, the Commission’s decision may be taken up by other large economies, such as India, the US, South Africa and the entire ASEAN region, even though natural gas and clean coal do not find a mention in China’s green taxonomy labels.
UK to permanently close its two fracking sites
The Oil and Gas Authority (OGA) of the UK ordered for the country’s only two fracking sites to be permanently plugged with concrete after testing at the controversial sites was abandoned amongst massive protests in 2020. The two shale gas wells in Lancashire county experienced earth tremors (earthquakes) that sparked strong local opposition to any further exploration and to fracking in general. However, the head of the firm responsible for the sites, Cuadrilla, said that the permanent closure of the sites was “ridiculous” amongst the record high prices of natural gas, and that the fuel could have met the UK’s energy needs “for decades to come”.
Carbon Tracker: Poland to miss net-zero target if it builds gas-fired plants
A new report by Carbon Tracker found that Poland, which was planning to build 3.7GW of new gas-fired plants, would certainly make it impossible for itself to meet its goal of net-zero emissions by 2050. At an expense of $4.4 billion (€3.8bn) and a commencement date of somewhere between 2023-2027, the plants’ tariffs would be higher than new offshore or offshore wind, as well as new solar capacity. The latter’s tariffs, in particular, when combined with energy storage, would be cheaper than natural gas from 2024 onward. However, Polish policymakers were reportedly of the opinion that any steps to meet the EU’s 2050 climate targets would have to be “safe for society and beneficial for the economy” — despite the fact that natural gas prices were at an all-time high. The fuel is also increasingly used as a political tool by Russia against NATO countries.
IMF deletes reference to Japan’s support for coal in mission document
The International Monetary Fund (IMF) curiously omitted any criticism of Japan’s continued support to coal projects (within its borders and around Asia) in the draft version of its latest mission document on the country. Instead, it said that the country would find it difficult to meet its emissions reduction targets if it did not end its reliance on the fuel. However, the omission comes despite the IMF having resolved to increase its coverage of climate-relevant energy finance in 2021, and bizarrely, the IMF has commented that neither its board members nor its management had any role to play in the surveillance reports that are prepared on a country.