EIA report of Motel project by Anant Raj raises many questions at a time when people whinge on EIA Draft 2020


Amidst the ongoing ruckus over EIA Draft Notification 2020; EIA data, information and report pertaining to Environmental Clearance (EC) of a Motel project by M/s Anant Raj Limited shows many gaps on technical and factual grounds. The company has submitted an EIA report regarding proposed demolition of an existing Motel building with built-up area 3229.05 SQM and its expansion to 48012.036 SQM, in Shahurpur, Hauz Khas of New Delhi. The EIA report has been prepared by a consultant, Perfact Enviro Solutions Pvt. Ltd., New Delhi.

As per Form-1A of the application seeking EC, during the construction phase, 80,000 cubic meter of soil will be excavated for 3 levels of basement and foundation. Top soil will be preserved for landscaping purposes and remaining soil will be reused for backfilling purposes and road construction etc. On the contrary, under the heading of Solid Waste Management at serial No. 11 of the same report it is stated that during construction stage, “soil will be excavated to provide the foundation. This excavated soil will be properly stacked under tarpaulin cover and will be reused for back filling purpose and road construction, etc. The top soil will be preserved separately and will be used for landscaping purposes only. The unused soil shall be sent to landfill site only”. At the point, it does not talk about reuse for soil in backfilling purposes and road construction. This is grossly confusing, and doubtful in respect of what exactly is to be pursued for environmental management. Such confusions are prevalent in many EIA reports. Now, whether so much of excavated earth could be accommodated in backfilling? This could be clarified with a supporting material balancing.

Further, as Hauz Khas area is quite populated, whether there is enough space to store construction and demolition wastes, including excavated soil? How long it needs to be stored? Whether the locals are taken into confidence? And, whether our landfills are supposed to accommodate so much of excavated soil from different projects? Another pertinent question could be whether it requires any approvals from urban local bodies for such disposal at landfill site? Instead of a suo-moto statement, had the report address these points, the environmental impact assessment could have been easily understood and convincing.

The EC application also states that “approximately 7 KLD of the waste water will be generated from laborers, which will be discharged to septic tank that will be cleaned regularly.” It is not clear whether the consultant has assessed any possibility of impact on groundwater environment due to such disposal method. This becomes important due to the fact that the area is populous and people in the area may be extracting groundwater for various domestic usages.

Similarly, source of water to be taken from tankers supply from nearby STP should be elaborated with availability, and assurance from suppliers, and a scientific statement regarding impact on fresh water environment in the surrounding. The report mentions that “ultimate source of water in the existing building is Delhi Jal Board (DJB) and the same will be the source after proposed development." Whether DJB has taken such prior estimations to accommodate a project that expands almost by 15 times than its existing capacity? In such case, what could be impact on the population of the project area?

It is also stated at 2.3 under the heading of Water Environment that “In case Delhi Jal Board is not made or the supply is inadequate then the water will be arranged through tankers complying IS0:10500 (Indian Drinking Water Standards)”. There should be an impact assessment on the groundwater environment taking into consideration both the volume of rainwater to be harvested and water supply through tankers, as envisaged in worst case. Further, IS0:10500 does not provide Indian Drinking Water Standards, it seems to be IS: 10500, 2012. It is also important in the part of the NABET accredited consultant to mention the impact and management of the wastewater in the process of purification of tanker water to the level of drinking water quality.

At a time, when the entire nation and Delhi in particular is crying for an emergency situation due to wrath of air pollution, and utilization of solar energy is being given thrust, this project still has proposed to install 4 Diesel Generator sets for power back up of combined capacity 3520 kVA. There is facility of PNG in New Delhi. Whether the project has taken into account various options and calculated the environmental impacts on air quality? Furthermore, the report does not state anything about energy auditing.

Hazardous wastes (as per Hazardous Waste Management Rules) 36 lit/month used oil generated from diesel generators will be carefully stored in HDPE drums in isolated covered facilities.

Under hazardous waste management, the report has deliberated on 36 liter per month of used oil expected to be generated from diesel generators. It does not specify any thing on other related to used oil filters, air filters and oil soaked materials, and any other used oil including spent oil, gear oil, hydraulic oil, turbine oil, compressor oil, industrial gear oil, heat transfer oil, transformer oil and their tank bottom sludges, if any. The disposal of used oil has no reference of Delhi Pollution Control Committee’s prevailing regulation but states “will be sold to vendors authorized by the Central Pollution Control Board for the treatment of the same. Also, prior permission will be taken from the pollution board for the storage of any hazardous material if required. The quantity will be within prescribed limits.” Suitable care will be taken so that spills/leaks of used oil from storage could be avoided. The remedial action and management plan should also be cited if such a contamination takes place.

According to the report about 15 kg/day of dried sludge, which 5475 kg/year will be generated from sewage treatment plant (STP) within the motel building during the operation phase and the wet sludge will be passed through filter press where it will be dewatered/ dried to form a cake and then will be used as manure in green areas. The unused sludge will be given to farmers or nurseries. It has failed deliberate on quality control of manure as required by CEEPHO guidelines. In case, the sludge is found to be hazardous it needs to be treated as hazardous waste and disposed under the Hazardous and Other Waste (Management and Transboundary Movement) Rules, 2016. The green area, as per the report, will be 1773.63 SQM, a mere 16.3 % of the net plot area. The report also states that 95 tonne per year of organic solid waste will be processed through Organic Waste Convertor to get converted into manure. There is a need to create material balancing. As the area is not close to any farmers’ hub, a detail plan may be stated or manure distribution could be attained through the Ministry of Chemicals and Fertilizers, which is mandated by the Solid Waste Management Rules 2016 to create market. This approach could be realistic. Otherwise, there is a huge possibility of such wastes being dumped in low-lying area, which is practically happening in many places.

With NABET coming into picture since EIA Notification 2006, the EIA reporting was expected to be of high standard. When the Ministry of Environment, Forest and Climate Change has been recalibrating its own standards and guidelines in the EIA process, there are many factors need to be considered and not overlooked in order to attain a valuable outcome of the entire EIA exercise.

Environment First in every business


Recently, Apple has said to have reduced their carbon footprint by 35% from the peak in 2015. By 2030, Apple will be 100% carbon neutral. Their comprehensive carbon footprint will net to zero - a standard worth emulating for the corporate world. Earlier, Procter & Gamble had also announced plans to go beyond their existing science-based target of reducing emissions from operations 50% by 2030 to have global operations become carbon neutral for the next decade. The consumer goods corporation wants to get there by investing in a portfolio of “natural climate solutions.”

Morgan Stanley to Become First US Bank to Publicly Disclose How Much Its Loans and Investments Contribute to Climate Change. As per definition; Central Government or State Government Departments, public sector undertakings, banks, educational institutions, multinational organisations, international agencies, partnership and public or private companies that are registered under the Factories Act, 1948 (63 of 1948) and the Companies Act, 2013 (18 of 2013) and health care facilities which have turnover of more than one crore or have more than twenty employees; are bulk consumers under the E-Waste (Management) Rules, 2016. It is time that Indian banks, both public and private sector, should also disclose their own attainments first.

Coca-Cola European Partners (CCEP), the world’s largest independent Coca-Cola bottler, began funding Dutch startup CuRe Technology, which is developing a process for transforming difficult-to-recycle plastic polyester waste into high-quality recycled PET. Results will show the reality. UN Environment has reported 300 million tonnes of plastic waste produced each year, out of which 8 million tonnes end up in the ocean. Remaining pose mammoth challenges to human life - flooding being a common. In India, it is high time for corporates like Coca Cola, Pepsi, Amazon and Flipkart to demonstrate their commitment towards zero single-use plastics.

Purity of Solar Energy needs to be protected with befitting Policy

India generated 3230 kt of e-waste in 2019, and the per capita generation of e-waste was 2.4 kg, against the world average of 7.3 kg per capita: Global E-waste Monitor 2020

Tata Motors drives Urban Forests to protect environment

In Warje Urban Forest overall oxygen production going up to 7 lakh kg and sequestration of 3 lakh kg of carbon, annually, besides reducing soil erosion by 130%.

@SunitaM25130525 Published in Enviro Annotations of 1st July 2020 issue

Tata Motors, a leading global automobile manufacturer of cars, utility vehicles, pick-ups, trucks and buses, a part of the Tata group has been consistently exhibiting its working towards environmental protection. On the occasion of the World Environment Day 2020 celebration, which was based on the theme Nagar Van (Urban Forests), the Warje Urban Forest is model was presented. Tata Motors piloted the concept of Urban Forestry in Warje near Pune, few years back, in collaboration with Technology, Education, Research and Rehabilitation for the Environment (TERRE) Policy Centre, an international environmental organisation. In a span of just 3 years, a project that started on a 40-acre barren plot witnessed immense success and was scaled up to 100-acres, transformed into a lush greenspace, becoming a micro-habitat and a recreational attraction to the local communities.

Emphasizing on the Indian culture, the Union Minister for Environment, Forest and Climate Change, Prakash Javadekar has stated “India is probably the only country where trees are worshiped, where animals, birds and reptiles are worshiped, which demonstrates enormous respect the Indian society carries for the environment. We had a very important tradition of village forest since ages, now this new scheme of urban forest will fill up the gap because urban areas have Gardens but very rarely forests. With this activity of creating urban forest we will also create additional carbon sink.”

Research is increasingly supporting the thesis that urban forests and urban trees are good for our physical and mental health and that it provides a range of benefits to local communities. According to a 29th June 2020 press release, Tata Motors has stated that since 2015, more than 2000 company volunteers have planted over 50,000 indigenous saplings (with 98% survival rate) at Warje. With 40% canopy cover, Warje Urban Forestry is rich in biodiversity hosting 10 species of animals and reptile, 50 avian species, 200 species of insects and 15 species of vegetation. The increased green cover has provided the city with fresh clean air with the overall oxygen production going up to 7 lakh kg and sequestration of 3 lakh kg of carbon, annually. Additionally, the project also focused on reducing soil erosion by 130%.

Tata Motors has stated that Warje Urban Forestry project today stands as the grand success among Tata Motors’ CSR activities. Expressing joy, Vinod Kulkarni, CSR – Head, Tata Motors said “For the last several years, we at Tata Motors has been contributing to the green cover, as a part of our consistent tree plantation drive, which started on June 5, 2009, World Environment Day. We firmly believe in actively assessing the improvement of the quality of life of the people in the communities, giving preference to local areas around our business operations. With the Urban Forestry project, the local communities were made its custodian and they were offered an honorarium to ensure the upkeep of the forest, thereby creating a more aware group of citizens towards environmental protection and have demonstrated a high degree of ownership.”

Tree plantation and soil moisture conservation works as a core strategy for biodiversity conservation in the country. He emphasized on the need to address the problems of silting, soil degradation, and reduced water flow in the river basins. This could be better attained through a collective work by everyone.

Vizag Gas Leak reminds compliance status of Public Liability Insurance (PLI) Act, 1991


Recently, the Ministry of Environment, Forest and Climate Change (MoEF&CC) is circulating a letter regarding implementation of Public Liability Insurance (PLI) Act, 1991 and Public Liability Insurance Rules. The Ministry has developed a web based portal Public Liability Insurance Policy Management System (PLIPMS) to monitor the compliance. MoEF&CC is asking industries, which don’t possess valid PLI Policy, to procure and comply with the regulations. The Ministry has also asked SPCBs/UTPCCs to refuse Consent-to-Operate under Water and Air Acts in case the defaulting units fail to renew the expired PLI policies or fail to comply with regulations.

The MoEF&CC has issued directions under section 18 (1) (a) of the Water Act and the Air Act to Central Pollution Control Board (CPCB) to ensure better implementation of PLI Act, and Rules. The PLI Act, 1991 provides immediate relief to the person(s) affected by accident occurring during handling any hazardous substances, vicarious liability of the every industries to protect physical harm or death of employees during the course of employment and adequate compensate for injury or death of employees this burden of compensate of industries shifted toward the insurance company by giving premium or remuneration, so that to sake of welfare of the employees and guarantees to safe guard the compensate the government of India implemented this act.

Some definitions for better understanding of this act are:

Accident: Sec. 2(a) of the act mentions that an accident involving a fortuitous or sudden or unintended occurrence while handling of hazardous substance resulting continue or intermittent or repeated, exposure to death or injury to any person or damage to any property


Sec.2 (g) of the act specifies that Owner means a person who owns or has control over handling any hazardous substance at the time of accident and includes:

(i) In the case of Firm, any of its partner

(ii) In the case of an association any of its members

(iii) In case of company, any of its directors, secretary, manager, or other officers who is directly charge of and is responsible to the company for the conduct of business of the company.

Hazardous substance: Sec.2 (d) of the act states that Hazardous substance means which is defined in Environment (Protection) Act, 1986 and exceeding such quantity

Duty of owner of industries or company: Section 4 of the act states Duty of owner is first to safe guard the life of member of the company who engage in the handling of hazardous substance and life insurance

(1) Owner of any hazardous company shall take out insurance policy as soon as commencement of this act

(2) It renew the policy before expiry of the policy or within period of limitation

(3) The face value of the insurance policy may be paid-up-capital for the unit or Rs 50 (fifty) Crore, whichever is less. The amount of policy(ies) is decided on the basis of the assessment of damage estimated by the maximum credible loss analysed and paid up capital of the industry. Amount of insurance not less then the paid up capital of the company and not more that fifty crore rupees.

(4) Liability of insurance under on insurance shall not exceed the amount specified in terms of contract of insurance policy.

Section 1 of the act has provisions to issue directions like (a) Stoppage or regulation of handling of hazardous substance (b) Stoppage or regulation of water, electricity or any other services.


Section 14 of the act has provisions of penalty for contravention of section 4 and section 12 of this act. Punishment shall be imprisonment of terms not less than one year and not exceed six year or fine up to one lakh rupees or both.

Under section 15 of the act provisions are made for penalty for failure to comply with the direction under section 9 to section 11. For abstraction any person of discharging of above section, he shall be punishment with imprisonment which may extent to three month or fine up to 20 thousand rupees.

The provided the classification of the offences on the basis of the private and Government owned industries or company

A) Offences by company (sec.16)

(1) If offences under this Act, has been committed by companies, every person at the time the offence was committed directly in charge of and was responsible to the company for conduct of business

(2) If Act done with the Consent of the Company, Director, Manager or other officer are deemed to be liable.

B) This act has special provision for the Government department handling of hazardous work. Act done by Government department then head of the department is liable except act done without intention. Cognizance of offence of the act when taken: Court make complaint cognizable only when as

a) Complaint made by central government or his authority appoint

b) 60 day notice by any person to central government


  1. Liability to give relief in case of death / injury to any person or damage to property

  2. Responsibility to take insurance policies against liability

  3. Provide Information to Central Government / empowered Agencies

  4. Allow entry and inspection to Central Government Officials

  5. Comply with Directions

Industry To Know

  1. Hearing by District Collector before making award of relief

  2. File objections against proposed directions

  3. Central govt. to record reasons in writing in case not providing above opportunity

  4. Cognizance of Offence

The Public Liability Insurance (PLI) Act, 1991 makes it obligatory upon the user industries handling 179 types of chemicals and compounds and other classes of flammable substances to subscribe a special insurance policy to cover the liabilities likely to arise on account of any chemical (industrial) disaster/accident and payable to those affected people who are not the workers on ‘no fault basis’/ ‘absolute liability’. The Act establishes an Environment Relief Fund (ERF), which is subscribed by all such user industries by an amount equal to the annual premium amount of such insurance policies.

PLI insurance policies are sold by General Insurance Companies. It does not cost too much to procure a PLI Policy. As per some company documents, the annual cost of procurement of PLI Policy with an indemnity limit of Rs. 5 Crore in respect of any accident and not exceeding 3 times thereof in the aggregate during the policy period could be around Rs. 11,000/=. The buyer must ensure that the policy is bought under PLI Act, 1991 and should review the exclusions.

Multiple Benefits of Medbandi - Making of Ridges by Dr. N. K. Bajpa

JAKHNI – The First Water Village (Jal Gram) of India

Chinar Tree “The number is decreasing in Kashmir Valley”

Women and Waste Management: The New Paradigm

Environmental Degradation in Kashmir

Henna Gull

M. Tech. (Environmental Science and Engineering), Department of Civil Engineering, Jamia Millia Islamia University, New Delhi-110025 (Published on 27th May 2020 issue)

Over the last three to four decades, Kashmir has witnessed huge environmental degradation either naturally or as a result of anthropogenic activities. The State has suffered heavily on account of natural disasters like floods, drought, wildfires, and landslides and still, the vulnerabilities are increasing. The environmental destruction by humans has been deliberate and intentional purely for material greed. The forests are shrinking due to deforestation, though officially licensed wood is available. A black market of timber smuggling has risen as the smuggling industry involves a lot of corrupt bureaucrats, kiths and kins of ministers, and wealthy merchants. In South Kashmir, the area under dense forests around the tourist resort of Pahalgam has fallen by 191 square km from 1961 to 2010 with an average annual loss of 3.9 square km, largely due to illegal construction hotels and houses over forested areas. Once dense forests, the stripped forest areas such as Krala Sangri, Ramunhar, Pareezapan, Zam Pathar, and Baerbal Damdam have now become denuded areas. In the last two decades of Kashmir conflict, security forces had allegedly cleared vast tracts of forestland to target militants taking cover. They also used forests as an artillery firing range, converting them into a military garrison.

Kashmir used to be famous for wildlife. The history of biodiversity degradation is as old as its conflict which is over 70 years. When Indian and Pakistani armies were deployed in the state, it reportedly led to large-scale poaching of rare species like Ibex, Blue Sheep, Snow Leopard, and Urian—the big-horned sheep. While these species were initially killed for food, later they were slaughtered for valuable furs and skins. The Dachigam National Park boasted of over 800 Hangul or Kashmir Stag, but according to some reports now the number had gone down to 150 or so. The wetlands which provided a home to hundreds of thousands of migratory birds seem to have gone too. Similar is the case with trout fish in the mountain streams and high-altitude lakes. It has been reported that during the disturbed period, the trout in the wild streams was freely poached.

Kashmir’s world-famous Dal Lake is virtually at the point of extinction. It looks as it has been converted into an oversized septic tank in which tons of raw sewage and untreated waste is being disposed and dumped, respectively from over 2,000 house-boats and dozens of hotels on its banks. The aquatic life has been badly disturbed. All these years the greedy people have been constructing colonies of permanent houses on islands in the very heart of the lake hidden by a thick cover of vegetation. One of the disasters was the construction of Hotel Centaur and the Convention Centre into the lake by Government itself. Not only Dal Lake, but water bodies like Wular, Manasbal, River Jehlum, and the River Indus are equally polluted and under constant threat. After Lake Baikal of Russia, Wular Lake is supposed to be the second-largest sweet water lake in this part of the world. But after the muck it has been absorbing for decades, one is not sure whether the water is still sweet. The size of the lake has considerably shrunken and has become shallow due to the deposition of silt. The story of Manasbal is no different from the others. It is also getting choked by the abundant weed growth accelerated by inputs from villages around it including Kondabal and Jarogbal. Limekilns of Kondabal are the worst culprits. River Jehlum used to be dredged periodically and the silt was taken out of it during the time of Maharaja. But no such operation has been undertaken for decades now. On the contrary, the entire muck from the City and other habitations on its bank is being dumped constantly into it without any treatment. The Kolhai glacier, which feeds the River Jhelum, has reduced down to 11.4 square kilometers, from 13 square kilometers, meaning it has shrunk by 18 percent. Also, in Sonamarg, the waste and sewage generated by thousands of tourists are thrown and disposed of in the Indus river without proper management or treatment as there are no landfill or sewage treatment plant in the area.

Another cause for environmental concern is air pollution. The quality of air of the valley was once famous for its purity, freshness, and rejuvenation. But the situation is now just the opposite particularly in Srinagar. The quality is reduced and has become just like any other state of India. The air pollution, which comes mostly from vehicle exhaust, the burning of fossil fuels in smaller industrial units, and the mismanagement of solid and liquid waste in Srinagar is a major concern. The lack of a proper public transport system has been driving up car sales, resulting in more emission of harmful gases into the atmosphere. While Kashmir has more than 150,000 vehicles and more than 55 percent of Kashmir’s vehicles do not conform to pollution norms set by the board. Adulterated fuel – kerosene mixed in with diesel for higher profit also results in more black carbon being pushed into the atmosphere. Illegal brick kilns and stone crushers are other sources. In a recent survey, it was found that there were only 59 authorized brick kilns, out of a total of 374. Similarly, only 83 out of the total 204 stone-crushers surveyed had permission from the Pollution Control Board.

After forests, biodiversity, water bodies and air, the fate of mountains is no different. The stone quarries of Pandh Chok show the brutality done to the beautiful Mountains at the entrance of Srinagar. The incessant blasting must be shaking the whole Mountain and one fine day it is going to disappear as it was never there. Not only Pandh Chok but right from this spot to Dara along the Zabarwan Range, there are many quarry sites where the same cruelty is being repeated. Not even the molehills in the middle of the valley have been spared. The laying of a trans-valley railway line has eaten away dozens of small hills and mounds which have disappeared by providing earth filling for the track.

I believe the protection and conservation of the environment are only possible if all responsible citizens come together with one motive “Ann Poshi Teli Yeli Wan Poshi” (food will last as long as forests last). Also, electronic as well as print media both need to rise above commercial gains and start campaigning to enlighten people about environmental concerns and continuously laud efforts to save it.

(The views and opinions expressed are of the Author.)

Coronavirus Pandemic, Climate Change and Environment

by Dr. Ashaq Hussain Khan, Lecturer in Botany, Govt. Degree College, Bhaderwah (Jammu & Kashmir)

Climate change is a burning issue and is a real threat in the world. The Intergovernmental Panel on Climate Change (IPCC) has confirmed in several reports climate change is man-made and caused by the excessive emission of greenhouse gases (GHGs). Nowadays the accumulation of green house gases has reached dangerous levels threatening climate change and global warming beyond the limits of human tolerance. The UN calls for push to cut green house gases level to avoid climate chaos. But what has been observed that there is lack of seriousness in world leaders towards urgency of situation.

“The threat from corona virus is temporary,

But threat from climate change will remains with us for years”

Our interactions with environment have brought more wild life diseases to our homes. Research reveals that all viral diseases such as Corona, AIDS, Zika, Ebola and other viruses spreads because of human interference with nature.

When you harm the nature, nature will harm you back

And Interference with nature brings disasters”

On 31st December, 2019 China alerted world health organization to several cases of unusual pneumonia in Wuhan. Wuhan went to lockdown on 31st January, 2020. Like fire the corona virus spread worldwide and finally the corona virus outbreak has been labelled a pandemic by world health organization. While the whole world grapples with the corona virus pandemic, the slowdown in anthropogenic activity has shown positive impact on mother earth. To combat the rapidly spreading of virus, many global countries have put a complete lockdown resulting in limited travel and industrial activities. Due to this pandemic lockdown green house gases emissions are falling sharply as its has restricted the fossil fuel consumption. The literature reveals that in china carbon dioxide emission were down an estimated 18% between early February and mid March due to fall in coal consumption and industrial output. Meanwhile, in the European Union, decline in power demand and depressed manufacturing allowed green house gas emission to fall by nearly 400 million metric tons this year, a figure that represents about 9% percent of the European cumulative 2020 emission target.

Therefore it is clear that corona virus pandemic lockdown is having positive impact on climate change. Though the Green house gases emission is sharply declining due this pandemic lockdown and mother earth is healing rapidly, but this planetary breather is nothing to celebrate, as it is a deadly virus that will prove major catastrophe, if not checked immediately.

(This article has been published in Enviro Annotations, 29th April 2020 issue)

Ecological Rejuvenation of Mowa Lake, Raipur

Madhukar Swayambhu

Water needs to be cured Ecologically

Madhukar Swayambhu

Sustainability Report of Havells India

Sanjaya Kumar Mishra

Scope of Vertical Farming in India

Henna Gull, Jamia Millia Islamia, New Delhi

Sustainable Transport in the Quest of More Cars & Less Emissions

Sunita Mishra

I Can Be a Change Maker

Inaayat Passi

Student, Grade 10, Vasant Valley School, Resident of Sunder Nagar, New Delhi

I was on my way to Delhi from Ghaziabad and I crossed a huge landfill, almost the height of the Qutub Minar. It was so disturbing to pass by and see children of my age handling and separating wastes with their bare hands. Read more