Editorial

Treated Wastewater Reuse Policy

24.06.2020

National Mission for Clean Ganga (NMCG) has been working through a structure that attempts to bring all stakeholders on one platform to take a holistic approach towards the task of Ganga cleaning and rejuvenation. Recently, Director General, NMCG, Rajiv Ranjan Mishra was speaking on a programme regarding reuse of treated wastewater in the post CoVID19 era. He said treated wastewater reuse is one of the most instrumental techniques to keep Ganga clean and also reduce intake water from the river. DG NMCG also cited the example of treated wastewater reuse in Mathura Refinery.

The concept of the reuse of treated wastewater is not new in India. It has been a condition in various legal documents such as; Consent-to-Operate, Consent-to-Establish, Approval for groundwater extraction, Environmental Clearances. However, these documents are related to a particular project or industry. Industries, construction projects, hospitals, hotels, and other similar projects have declared reuse of treated wastewater for the watering of greenbelt, flushing system, and also for construction activities. Though, the ground reality may differ from what is declared, this kind of reuse often is misunderstood as Zero Liquid Discharge (ZLD). The National Green Tribunal (NGT) in an order dated 24.05.2019 in the matter of O.A. No. 348/2017, Shailesh Singh Vs Al-Dua Food Processing Pvt. Ltd., issued directions to the Central Pollution Control Board (CPCB), stating that ZLD needs to be considered with respect to the use of effluents in the industrial processes not in terms of its disposal on land or farm. The order further states that no industry can be permitted to dispose of treated effluents on land for irrigation, plantation or horticulture/gardening by prescribing standards applicable without assessment of adequate availability of land and impacts of such disposal on agricultural / crops / plants and the recipient groundwater. Impact of precipitation levels also need consideration while granting such approvals.

Subsequently, CPCB brought “Guidelines for Utilisation of Treated Effluent in Irrigation”, which states “ZLD implies that the industries are not discharging any effluent, either on the land or in the water body or at any other place i.e. recycling the same in the process entirely without releasing any effluent.”

The guideline also specifies requirements such as the industry needs to engage an agricultural scientist or take advice from an agricultural university or institute on the utilization or the rate of application of the effluent for irrigation considering the agro-climatic conditions. The industry has to prepare an Irrigation Management Plan (IMP), in consultation with the agricultural scientist or agricultural university or institute and submit to SPCBs/PCCs, which should verify the same while issuing Consent to the industry. Some other requirements stated in the guidelines are, the industry has to make provision of impervious lined storage tank of minimum 15 days capacity for storage of treated effluent during low/no demand, based on the Irrigation Management Plan. It is also required that the treated effluent should be analysed regularly, say after every 15 days. The effluent samples should be taken at the point from where the effluent is discharged for irrigation. Also, the physico-chemical characteristics of the soil under irrigation with treated effluent should be monitored twice in a year to assess conditions in summer and post-monsoon seasons, in order to determine the deterioration of soil quality.

Now, as the NMCG is working on a national level policy on the reuse of treated wastewater; some of the requirements may be relooked. Instead of individual treatment, common wastewater treatment plants could bring better results in terms of quality and quantity of treated wastewater. Developers of industrial areas should carry out study on utilization or the rate of application of the effluent for irrigation considering the agro-climatic conditions in their respective areas, and also prepare the IMPs. Special infrastructure such as pipelines should be laid to industries and end-users with proper metering. This could strengthen the effectiveness of regulations and also ensure Ease of Doing Business.

Easing MSMEs HWM Compliance Cost in COVID-2019 scenario

17.06.2020

Andhra Pradesh Environment Management Corporation (APEMC) has become the first online exchange waste management platform for safe disposal of toxic wastes. The process shall be based on proper scrutiny, tracking, and audit of the waste. APEMC will be working in close coordination with Andhra Pradesh State Pollution Control Board, proposed to handle the waste from its generation until its disposal. The SPCB will make necessary provisions for industries and organisations to hand over the waste generated by their units and that cannot be treated in their premises, to APEMC for the management of waste, as per in accordance with environmental rules and regulations. With this platform, Andhra Pradesh government targets to promote the six ‘R’s namely Reduce, Refurbish, Reuse, Recycle, Redesign and Remanufacture. Hazardous Waste Online Manifest Application has facility to generate effluent and waste manifest. Though it is missing a separate detailing of co-processing it has a provision of separating hazardous wastes based on calorific value ≤ 2500 Kcal/Kg. This may help to separate high hazardous wastes with caliorific value that could be sent for co-processing in cement kiln. co-processing is considered to be an environmentally sustainable option for the management of different kinds of wastes including hazardous and other wastes. In co-processing, these wastes are not only destroyed at a higher temperature of up to 1450 °C and long residence time during which its inorganic content gets fixed with the clinker and becomes part of cement apart from using the energy content of the wastes, thus no residues are left. Unlike incineration process, co-processing does not produce residual ash. Further, the acidic gases, if any generated during co-processing gets neutralized in the large alkaline environment available within the kiln system. This phenomenon also reduces the non-renewable resources requirement such as coal and limestone etc. Thus the utilization of wastes in cement kilns through co-processing provides a win-win option of waste disposal. It could also reduce cost of incineration, cost of pollution control measures due to incineration, cost of ash handling and disposal, and also increase the life of the TSDF site. Hence, the cost of hazardous waste disposal would come down, which could help MSMEs to meet the challenges originating from Covid-2019 scenario.

This method could also be very helpful in controlling improper disposal of various hazardous wastes, for example hydraulic oil, gear oils, transformer oil, etc., which is often not handed over to oil recyclers which do not issue a Form-10 as required under the Hazardous and

Other Wastes (Management and Transboundary Movement) Rules, 2016.

Another important point to be deliberated by the industries, especially the MSMEs, is about the testing in terms of “Finger Print Analysis” or “Quick Check Analysis”. Frequent testing and analysis should be avoided to reduce cost on the MSMEs. Further, it should be limited to the basic parameters like pH, and calorific value. There should not be any “Rejection of Waste” on the basis of a variation in hazardous waste characteristics, for example, by more than 5% when compared with the Finger Print Analysis.

The industries must focus on proper drying of hazardous wastes to reduce its weight. This would also help in reducing cost of disposal. Further, according to the provisions of Hazardous and Other Wastes (Management and Transboundary Movement) Rules, 2016 under section 8 demands that the occupiers of facilities may store the hazardous and other wastes for a period not exceeding 90 days. If this period could be extended to at least 180 days for those industries, which have a track record of being compliant, could also be an act of the ease of doing business in true sense. This could help to reduce some financial pressure inflicted by the Covid 2019.

Igniting Young Green Minds

10.06.2020

On the eve of World Oceans Day 2020, the United Nations Secretary-General, António Guterres has stated "As we work to end the pandemic and build back better, we have a once-in-a-generation opportunity - and responsibility - to correct our relationship with the natural world, including the world’s seas & oceans". To prevent the next pandemic, we must protect nature. Now, youth around the globe are increasingly using the power of their collective voice to advocate, lobby and lead campaigns towards adopting environmentally-friendly practices and policies. As more youth grow up in a world characterized by advanced technologies and information sharing, many are harnessing this opportunity to create innovative, sustainable environmental solutions.

Young people constitute a large part of the world’s population and young people will have to live longer with the consequences of current environmental decisions than will their elders. Future generations will also be affected by these decisions and the extent to which they have addressed concerns such as the depletion of resources, biodiversity loss, and long-lived radioactive wastes. According to the World Programme of Action on Youth (WPAY), youth participation is crucial. Youth are willing to take the lead to meaningfully engage in platforms related to the protection of the environment, at the local, national, or global levels. However, to harness their talents and innovations, there is a need to ensure that youth are equal partners and torchbearers in creating and implementing the goals toward environmental sustainability. Supporting youth participation and engagement in environmental preservation requires a holistic and inclusive approach.

Enviro Annotations is engaged with a group of environmental engineering students from the Civil Engineering Department of Lucknow University to discuss practical aspects in industry and society. Above 50 students participate in the programme, enabled through the web. Head of Department, J. P. Singh, who himself is a young gun, has initiated the move in an effort to create and undiminishing network amongst the industry, professionals, society, and institutions. In the programme, Virender Sharma, a legend in the field industry environmental services deliberated on various aspects of industrial waste management, wastewater management, and applicable legal frameworks. The importance of data collection and analysis was also a part of his deliberation. Chandan Mohanty, a water and wastewater expert, with a microbiology background, which is essential in the current pandemic scenario; discussed various aspects of wastewater management including treatment, reuse, and recycle. Ravinder Tyagi, an EHS expert shared his experience spanning over more than four decades with various multinational industrial corporations. He bestowed the students with some valuable takeaways from his treasure of fine learnings from experiences earned from Asian as well as American corporates.

Dr. Ruby Makhija, a practicing Ophthalmologist, also the General Secretary of Navjiwan Resident Welfare Association, New Delhi, who is one of the leading heroes in community waste management in India; gave a detailed presentation of case studies. She showcased on composting, upcycling and the adoption of biodegradable items. She emphasized her strong belief in zero waste to landfill by changing people’s attitudes towards their lifestyle, which can be imbibed into the society by the youth in a forceful manner, by their acts and exhibits.

The time spent by the leading examples from industries to society would bear fruit. Youth is the backbone of the nation. They can change the future of society with their well-being and courageous behavior. They can change their lifestyle and how it affects the environment. They can make their homes, schools, and youth organizations more environmentally friendly by adopting environmentally friendly practices, recycling of different materials as well as preserving resources such as water and electricity. Engaging youth in environmental protection not only creates a direct impact on changing youth behaviors and attitudes, but possibly influence their parents, relatives, families, and thereby the society at large.

BOD reported < 2 ppm: Trustworthy?

03.06.2020

With the advent of Online Continuous Environmental Monitoring System (OCEMS) it is possible for anyone to learn about treated effluent and air emission data. There are still limitations to have an access to a full scale data. A recent data regarding the treated effluent characteristics of Banaskantha Dist. Co-op. Milk Producers Union Ltd., Faridabad in Haryana, shows the Bio-chemical Oxygen Demand (BOD) value to be 3.7 milligram per liter (mg/L). Here comes a question. The sensors used in OCEMS are not calibrated as there is rarely any calibration facility available in India. Therefore, all the OCEMS suppliers deliberate on validation of test results. For the validation of test results it is required to test the sample simultaneously in a laboratory. And, in the laboratory it takes 3 days to get the result of BOD. Further, it involves sample preservation and transportation to the laboratory. There is also a factor of time, at what time after sample collection the testing was started.

River water is considered to be fit for bathing purpose when it meets the criteria of having BOD less than 3.0 mg/L, along with other requirements pertaining to Dissolved Oxygen and Faecal Coliform concentration. Now-a-days, measurement of BOD is being undertaken through manual as well as online monitoring and measurement systems in several projects working on cleaning of the River Ganga, Yamuna, and many others in India. The matter of test results quality remains equally same in these cases too. A casual look at the data shared by some State Pollution Control Boards (SPCBs) and Pollution Control Committee (PCC) indicates that test results obtained with regard to BOD, the ubiquitous parameter for water and wastewater characterization, was as low as 0.9 mg/L. Some environmental laboratories, possessing due approvals from SPCBs, Ministry of Environment, Forest and Climate Change, and National Accreditation Board for Calibration and Testing Laboratories (NABL) accreditation have reported BOD to be <2 mg/L, which is the laboratory's detection limit.

Another significant issue is that the laboratory’s quality system is not so robust to test BOD to a level of <5 mg/L, because of several reasons. Firstly, availability and cost effectiveness of certified reference materials (CRM) or standard reference material (SRM) of such a low range to test BOD. According to the test method developed by Bureau of Indian Standards, Glucose-Glutamic Acid solution is to be used as a CRM/SRM. This is required to be prepared fresh and immediately before use. Nonetheless, the value for comparison stands at 220 ± 37 mg/L. Now, there is a need to clarify on this point as to whether this result could be compared with the test results in low range below 2 mg/L?

Beyond this, as per Indian Standards specifications, BOD value is based on average of number of tests of the same sample, in same condition and at the same time. Another befitting point is about the sensitivity of measuring device or the least count of a standard burette – depending upon the method adopted.

To enhance trust level of data, there is a methodology of Proficiency Test, widely known as PT. It has become essential to participate in PT to obtain NABL Accreditation. The Central Pollution Control Board (CPCB) also conducts PT programmes, time-to-time. It is important to review, whether, the laboratory, which has generated such a low concentration BOD result, has undergone such PT programmes? Whether PT programmes are available for such low range of BOD measurement? The CPCB has been pursuing the matter of OCEMS since more than 6 years. The NABL, which comes under the Quality Council of India (QCI), should have taken this matter with equal importance in developing PT programmes, which they did not.

Climate Change, Locust Swarms & National Loss

27.05.2020

Swarms of Locust have entered into some states in northern part of India. This is a threatening of major damage to standing cotton crops, and vegetables. Rajasthan seems to be the worst affected State. During the current year, the swarm of locust have entered India prior to the normal time of June and July. This early migration of locusts could be a consequence of excessive pre-monsoon rain that triggers the growth of vegetation in arid areas where desert locusts can then grow and breed. These locusts which migrated to India early this year might have found greener pastures as the pre-monsoon rains during March-May were in excess over north India this year.

Keith Cressman, Senior Locust Forecasting Officer at the FAO, also sees a longer term trend of increasing cyclone activity in the Indian Ocean leading to heavy rains in Arabian peninsula and parts of Africa, and that is, in turn, leading to more desert locust upsurges. “There were eight cyclones in 2019 when in most years there are only one or two. Three cyclones in 2018 and two in 2019 have contributed to the current desert locust upsurge in the Horn of Africa where large and numerous swarms are present in Ethiopia, Somalia and Kenya,” said Cressman. He also said that if the trend continues more desert locust outbreaks can be expected.

Biodiversity scientists agree that such locust swarms could occur more frequently in the future given the changing rainfall patterns.

Locust is a polyphagous feeder, which attacks in swarms and causes extensive damage to crops. Locusts can change their DNA according to the prevailing environmental situation. In the seasons of availability of adequate food, the locust multiplies their progeny faster from eggs to nymphs and adults.

Locusts can assess the location of crops at harvest stage and fly as a swarm in the direction of the wind. Locust swarm invasions are swift and incredibly destructive. A desert locust adult can consume roughly its own weight in fresh food per day that is about two grams every day. 1 square kilometer size of swarm contains nearly 40 million locusts, which eat the same amount of food in one day as about 35,000 people. This is based on a person eating an average of 2.3 kg of food per day, according to the United States Department of Agriculture (USDA),” the UN Food & Agriculture Organisation. Quantum of loss of food grains and cotton could be envisaged from this data.

Malathion96 is most widely used insecticide against locusts, which can be deadly if human comes in contact with it. Insects like locust are usually prey for birds like crow, myna, cuckoo, starling, and many farm birds. There are chances of death of birds or animals that eat Locusts that die because of malathion96. Further, the insecticide has definite impact on the water bodies and the soil. The control strategies also include spraying environmental-friendly neem-based pesticides, and spraying bio-pesticide Metarhizium anisopliae. Mass aerial spraying of pesticides with the permission of government is also done to control the locust swarms effectively. This can lead to contamination of air quality.

Climate change culminates series of challenges to various components of the environment. It has emerged as the biggest developmental challenge for the planet. Its impacts on economy, human health and the environment, make it a major governance issue. Adaptation to climate change through soil and water conservation could be a meaningful way. It is ironical that despite scientific prescription for drastic reductions in emission, no country is talking about limiting their emissions. Survival emissions should be differentiated from the luxury emissions, and must be curtained.

Making of Jakhni – Jalgram

20.05.2020

Bundelkhand in central India was a prominent name for water scarcity. The impact of drought in the area could be well imagined from the fact that government had sent drinking water through goods trains. This contradicts with the fact that the region has been naturally blessed with about 35 small rivers, out of which 5 are five major rivers. There are about 225 big and small dams. There were 27000 ponds, 52000 wells, 300 drains, 350 stepwells and Chandel, about 51 traditional and natural water resources and research centers established by the Kings of Bundelkhand. Asia's largest drinking water scheme "Patha" was in Chitrakoot, Bundelkhand. Above all, billions of rupees spent on water projects by the Central and State Government. Still the people in Bundelkhand remained thirsty. In the absence of agriculture and employment people migrated. Village after village got void.

Amidst so much of discouraging challenges, the people of Jakhani village in Banda district of Bundelkhand gathered confidence. The whole village, led by a determined Umashankar Pandey, devised a policy “Farm water in the farm, Village water in the village”. An excellent thinking. Valuable guidance from traditional water scientist Late Shri Anupam Mishra, time-to-time inputs on traditional community technique of ground water from Hydrologist Shri Avinash Mishra, and of remarkable self-reliance policy of Padma Vibhushan Late Didi Nirmala Deshpande, brought an enormous result. As soon as the first rain came, the fields were filled. Then the water moved towards the ponds. One after another, all the 6 ponds in the village got filled. Side by side, 30 wells of the village also became alive with water level between 15 to 20 feet. The encouraged villagers started planting trees in the village that has a significant role in the water cycle.

15 years of continuous hard work transformed a drought-prone Jakhni village into a leading agricultural hub that produced Basmati paddy, wheat, gram, oilseeds, pulses, as well as vegetable, milk and fish farming. It made the farmers rich and resourceful. The transformation resulted in reverse migration of 99% of the youth. Jakhni village attained the status of the richest village in the state.

This water management success story without any government support became a word of mouth and continue to spread in surrounding villages, and reached to the knowledge of Prime Minister Shri Narendra Modi, who praised the achievements. Words of the Prime Minister was a further booster for the farmers. Shri U. P. Singh, Secretary, Water Resources, River Development & Ganga Rejuvenation personally visited the fields of Jakhni, discussed with the farmers, reviewed work and results; and finally the village Jakhni got the recognition of Jalgram for the whole of India as part of the government's water revolution campaign. Shri Singh often cites example of Jakhni Jalgram in his speeches and addresses. In each district, 2 villages were selected for Jalgram on Jakhani model and currently under Jal Shakti Abhiyan, the Ministry of Jal Shakti has made a list of 1050 villages in the country to construct Jalgram on Jakhani model. Jakhni model of water conservation is being discussed globally. To understand model and explore knowledge on this water conservation technique, 2030 World Water Resource Group, an Expert Committee from Israel Government have visited the renowned village. Agricultural Industrial University, Banda, Officers from Central Ground Water Board, Water Scientists, and Students have been reaching the village on regular basis.

A simple-looking, simple-living, and highly optimistic Umashankar Pandey says 15 years ago he was inspired by a clarion call of the Former President Late Abdul Kalam to create Jalgram (Water Villages).

Induct Law Degree Holders to implement environmental rules

13.05.2020

COVID-19 shows that the health of people and the planet are one and the same. According to United Nations, 75% of all emerging infectious diseases in humans cross from animals. The long-term threats of climate change and ecosystem and biodiversity loss also spring from the destruction of nature. Inger Andersen, Executive Director of the United Nations Environment Programme (UNEP) and Under-Secretary-General says, “UNEP will support nations and partners to deliver stronger science, policies that back a healthier planet and more green investments through its core mandate and Programme of Work.”

UNEP deliberates on finding solutions to environmental issues. UNEP is reviewing the implications of moving environmental governance and multilateralism towards virtual, and thus lower environmental footprint, meeting platforms. On the other hand, the multinational companies are flouting environmental norms set by the country where their factories operate. The latest one being the lethal gas leakage from LG Polymers India in Visakhapatnam district of Andhra Pradesh. Usually, large scale industries and multinational companies carry out Due Diligence studies, which also includes Environmental Due Diligence. This helps to assess legal liabilities. Whether LGPI carried out such a study? And, if yes, whether it was prepared by a competent organization? Further, did the report consider all the prevailing legal aspects?

Some apoplectic environmentalist friends have raised questions by relating the project activity with EIA Notification, 1994 (Item no 7 of Schedule). These facts will be clear from the report shortly expected from the five-member committee constituted by the National Green Tribunal (NGT). Nevertheless, available information from various sources shows that the factory was started in 1961 when no environmental rules were prevailing in India. And, LGPI took over the factory in 1997. EIA Notification should have been applicable when there was a capacity expansion or modernization. However, the company’s affidavits make it clear that it has undertaken several expansions without obtaining prior environmental clearance.

Vikrant Tongad, Founder - Social Action for Forest & Environment (SAFE), says, they are not satisfied with the work of the Government and the National Green Tribunal (NGT), so far. He suggested this matter should be taken up by the Supreme Court. And, the Government of India should file FIR against the officers concerned in the State Pollution Control Board (SPCB), under criminal acts, for not taking an idoneous legal action, and allowed the plant operation without the necessary environmental approvals.

The SPCB is undoubtedly, equally responsible for such a prolonged non-compliance. It should not have granted Consent-to-Operate (CTO). The Consent-to-Establish (CTE) for expansion was not to be accorded without appropriate EC. The 2006 EIA Notification changed the mechanism of EC process and implemented EC first and then CTE, so that non-compliance of EIA Notification could be avoided. This raises a question in the capability of the right understanding and interpretation of environmental rules by SPCB officials.

It is a serious matter. It was a fatal accident and a recurrence after the horrific Bhopal Gas tragedy. It exposes that no lessons learned. This grave incidence that caused the loss of human lives should be taken into account for reconsideration of Draft EIA Notification 2020 for the removal of a provision to entertain post facto environmental clearance of any project. Existing industries that have flouted environmental regulations and orders issued by Supreme Courts, should be treated with punitive legal action against. The UN Environment should take cognizance of such issues.

With growing environmental non-compliances, whether India needs to amend the recruitment policy of environmental officials? The engineers and scientists are found to have faltered time and again. The excruciating legal procedures keep them busy unyielding to their potential. Often external lawyers are hired, who can’t spare adequate time. Therefore, induction of officials possessing law degree with science and engineering backgrounds at regional office levels of SPCBs and UTPCCs could be instrumental in the enforcement of laws devised for environmental protection.

Consumers can force businesses to be environment-centric

06.05.2020

An intense disorder is prevailing in our society right now. Needless to mention that the reason is COVID-19 inflicted lockdown. Optimists say, good is coming, as Friedrich Nietzsche taught us, “Chaos gives birth to dancing stars”.

During the prolonged three phase lockdown, which is pretty unclear when going to end, many people have learned, tried different lifestyles and gleefully shared through social media. This period has so far resulted minimum consumption, and less wastes. The Indian consumers are broadly categorized in to three types: huge middle class, relatively large affluent class and a small economically disadvantaged class. According to a 2015 European study, the middle class consumers tend to focus on the family, plan ahead for the future and place an importance on their image. They are increasingly health-aware and eco-friendly whilst also choosing convenience in almost all aspects of life. These values and attitudes influence most purchasing decisions they make. Nevertheless, advertising has often played it otherwise. Most of the Indian consumers, unbeknown to the end result, have chosen products and lifestyles, which are not eco-friendly.

One glittering example is the Indian Premier League (IPL), today, called as world’s richest and largest sports leagues. IPL has a massive carbon footprint, as well as a colossal water foot print. Few years back, the Bombay High Court was urged to consider the wastage of water on the watering of the pitches for cricket, on the ground of acute water scarcity in the city. Such movements forced teams to explore image building opportunities. The Kolkata Knight Riders initiated waste reduction by plastic reduction through cloth bags and organic waste converters. There was also an initiative ‘Plant a six’. There were many other similar initiatives. Nevertheless, it is widely known that the gigantic environmental challenges originate in many ways from the power plants. Measures taken and achievements with regard to electricity consumption, electronic and hazardous wastes from electrical appliances have remained untold. It would have a far more impact, if the water and carbon foot print advertised on each player’s caps, bats and helmets. There is no need to make an ad film, which itself has a further carbon footprint.

Yes, the entertainment industry does a significant amount of environmental damage. The film and television professionals proudly name their fraternity as film industry, though the common man, the customer, the viewer does not tend not to think of the entertainment industry as an industry. Environmental sustainability is a necessary part of the corporate world. When film business has been given the industry status, there is a need set environmental standards. Every movie and TV show depends on electricians, carpenters, designers, and all sorts of other specialized laborers and artisans working in offices and workshops in support of actors, writers, directors, and camera people. Creating the film requires use of fuel-guzzling on-site generators, flying hundreds of staffers in different departments like art, costuming, creature effects, special effects, visual effects, editing, and so on. Some of these needs camping in jungles too. And all of that emitted a huge quantity of carbon, and resulted in a lot of waste. According to British Academy of Film and Television Arts (BAFTA), the British film organization, a single hour of television produced in the U.K.—fiction or nonfiction—produces 13 metric tons of carbon dioxide, which is nearly 7 times that of an Indian in one year. Mumbai-based CERE specializes in environmental sustainability. Kudos to the visionary Indian director Biswajeet Bora, who made film Aisa Yeh Jahaan, India’s first carbon neutral film. A Mumbai-based organization, Centre for Environmental Research and Education (CERE) scientifically calculated the film’s emission as 78.47 metric tonnes of carbon dioxide equivalent. Thus, environment-friendly film and television programmes are quite possible. Therefore, there is a need to create national level standards in this direction. And the Censor Board certificates should also display compliance level with respect to the standards. This can be possible, when Indians, as consumers and customers, will exhort demand.

Upgrade Disinfection: UV Treatment of wastewater

29.04.2020

Ultraviolet (UV) treatment in water and wastewater industry is quite well known. For the past few decades, and increasingly today, UV has been successfully used in many parts of the world for municipal wastewater disinfection. It has growingly become an alternative and a direct replacement technology to chlorine based disinfection. Recently, it was also found that coronavirus is sensitive to UVC light, as in the case of other viruses and bacteria. The germicidal effects of UVC irradiation with a peak intensity at 254 nm results in cellular damage of the virus, thereby inhibiting cellular replication.

UV radiation is present in sunlight, and constitutes nearly 10% of the total electromagnetic radiation output from the Sun. Wavelengths from 10 to 400 nanometers are known as ultraviolet. The parts of this spectrum that reach Earth’s surface are the longer UVA and UVB rays, vital for all life and for humans to produce vitamin D and other essential body processes, but also causing tanning, sunburn, skin cancer and wrinkles depending on skin type. UVC is the deadly one, ­long-established for water and air sanitizing. But the invisible light is highly carcinogenic, with disinfecting results that vary widely in professional settings depending on the setup.

Traditionally, the use of chlorine gas was the most common method of wastewater disinfection. Chlorine gas itself is relatively inexpensive but is a highly toxic chemical that must be transported and handled with extreme caution. It is stored under pressure in large tanks and is released into the wastewater as a gas. Sodium hypochlorite is a diluted liquid form of chlorine that is also commonly used.

Since more than a decade, the Ministry of Environment, Forest and Climate Change (MoEF&CC) has categorically specified in many Environmental Clearances (EC) that Chlorination based treatment of wastewater should not be done, and UV or Ozone based treatment should be adopted. The Ministry’s approach was very positive in order to reuse and recycle the treated wastewater, especially treated in sewage treatment plants (STPs). Reuse and recycle of treated wastewater with chlorination would eventually disrupt the biological treatment process of the STP. While, UV and ozone based treatment has no impact on the chemical composition of the wastewater. Therefore, the function of STPs is also not affected. Additionally, the UV and ozone based treatment produces no disinfection byproducts or a chlorine residual, which is harmful to the environment. The retention time required to achieve disinfection by using UV and ozone treatment ranges from a few seconds compared to more than 30 minutes for chlorine disinfection. Further, there are pathogens, such as Cryptosporidium and Giardia, which are known to be chlorine-resistant but can be disinfected by UV light.

However, the implementation has not been attained to the extent it should have been. One of the major deterrents, as understood, has been the capital cost. The chlorination is considered to be less capital intensive. Practically, it is not true. The installation of UV treatment system eliminates requirement of storage tanks for chemical and treated wastewater. It also eliminates cost of disposal of hazardous wastes generated from chlorination process. Further, the operational cost of chlorination is high as compared to UV. However, the cost of installation of ozone based treatment is high. The projects, which sought an expansion of EC, were genuinely forced by the MoEF&CC to comply with the EC conditions. However, it did not happen before that, not it happened in other projects. Now, after the COVID pandemic experience, there is a need to ensure installation of UV or ozone based treatment of wastewater for disinfection system, before its reuse and recycle. This should be made legally mandatory for all the STPs including the projects out of the purview of EIA notification. The State Pollution Control Boards and Union Territory Pollution Control Committees should also include this as a common minimum condition in their Consent-to-Operate given under Water Act.

Mother and Motherland are greater than heaven

22.04.2020

Earth day 2020 is the 50th anniversary of Earth Day. April 22 is celebrated as the Earth Day or International Mother Earth Day (UN) all over the world. On this day, 20 million Americans, nearly 10% of the U.S. population at the time protested environmental ignorance and demand a new way forward for our planet. It was founded by Senator Gaylord Nelson to promote ecology and respect for life on the planet as well as to encourage awareness of the growing problems of air, water, and soil pollution. It is a day held to demonstrate and promote environmental awareness and calls for the protection of our planet. With growing awareness, access to information, and dynamic social media this day has gained huge attention. Despite that amazing success and decades of environmental progress, the human race is facing a dire, almost existential, set of global environmental challenges from one new infection disease. According to the United Nations (UN) Environment one new infection disease emerges in humans every 4 months. And, 75% of these emerging diseases come from animals. Acclaimed environmentalist, Vandana Shiva nicely articulated in her article - A virus, humanity & the earth, “Science is informing us that as we invade forest ecosystems, destroy the homes of species and manipulate plants and animals for profits, we create conditions for new diseases. Over the past 50 years, 300 new pathogens have emerged. It is well documented that around 70% of the human pathogens, including HIV, Ebola, influenza, MERS, and SARS, emerge when forest ecosystems are invaded and viruses jump from animals to humans. When animals are cramped in factory farms for profit maximisation, new diseases like swine flu and bird flu spread.”

This reminds how the environmental impact assessment (EIA) reporting overtly sidelines any study on the soil microorganisms with a statement of no major impact envisaged in the soil environment. This is a very common statement for almost all projects; be it a construction project that deals with 3-basements or a project to treat and dispose of hazardous wastes.

The close relationships between human, animal, and environmental health is not unknown to the human being, which is the primary ruler of the earth. Despite this knowledge, the horrid hoggish human became so severely infatuated for an improperly defined development that today it is facing tremendous problems from loss of biodiversity to climate change to plastic pollution to air pollution to water pollution, and land pollution. The lockdown during the reigning of coronavirus has shown the real picture.

It is notable that the price of petroleum products has crashed badly, worldwide. This is happening at a time when the electricity supply is adequate in most parts of the nation. India has about 25 cars per 1000 persons, while the USA has 400 per 1000 persons. Examples like this show the developed nations are high-end consumers. Moreover, India has a tradition of need-based consumption pattern. We, in India, believe in जननी जन्म भूमिश्च स्वर्गादपि गरीयसी॥ This means “Mother and Motherland are greater than heaven. Every particle of dust, everything living or nonliving, every stock and stone, tree, and a rivulet of this land is holy to us. Our faith and our constitution are pro-environment. India has to maintain its traditional ethos. The only important thing that we have to do is not to remain a silent spectator at any deed or misdeed that goes against Mother Earth.

Green Growth, Indispensable Now

15.04.2020

As the only best measure to protect human lives from the draconian COVID-19, people in India, and worldwide have gone incarcerated. The dramatic emergence of COVID-19 has brought our way of life to a near halt. Isolation, lockdowns, and social distancing being practiced to curb the spread of the virus. The health crisis is having a severe impact on economic activity. According to International Monetary Fund (IMF) the pandemic has resulted a sharp contraction of the global economy projected to be –3% in 2020, much worse than during the 2008–09 financial crisis. In the IMF’s World Economic Outlook Report, it is projected that India’s GDP could be 1.9% in 2020, while 7.4% in 2021. This means a nearly four-fold growth in mere one year. This is such a panglossian report for an Indian national, while deepens the general loathing of an environmentalist. It is widely being discussed as earth getting a second wind through COVID-19. Though most people have recognized the degree to which we are responsible for our environmental problems, and the degree to which we will have to change in order to resolve these problems there is an apprehension that post-COVID19 may bring an accelerated growth, setting aside the environmental objectives. Today, we live in a culture that is significantly shaped by the industry forces. We cannot abruptly refuse the industrial products. They are needed to support the normal way of life. On the other side, the environmental cost is not always immediately visible. It is true that the blue sky through improved air quality or reduced greenhouse gas emissions, rejuvenated and clear river water – are temporary, because they come on the back of terrible economic slowdown and human distress.

Any positive environmental impact in the wake of this distasteful pandemic, must therefore be in our changing our production and consumption habits towards cleaner and greener. Though Gandhian philosophy was not visible in social media during the COVID lockdowns, we probably have rediscovered the art of being a minimalist. We need to stretch this habit of lower consumption. Also there is a need to infuse a practice of choosing products with low carbon footprints, water footprints, and least waste-generating. The Scripps Institute of Oceanography has highlighted that fossil fuel use would have to decline by about 10 percent around the world, and would need to be sustained for a year to show up clearly in carbon dioxide levels. Only long-term systemic shifts will change the trajectory of carbon dioxide levels in the atmosphere. So, in the aftermath of the crisis, we must relook into our needs, consumption pattern, development strategy, and financial allocations.

It is evident now from this pandemic that a healthy environment means a healthy society, a healthy nation. This is why the post-2020, we need to review and reassess our environmental challenges and development paths. Local production, where least transportation is involved may play a vital role in India. This will address India’s mammoth human migration in search of job. This never-ending temporary job asylum has a significant impact of health and environment of the nation. This needs a serious relook at the existing policies, whereby local employment is given preference. Public must raise demand from the elected governments and also prudently allocate their investments in sustainable agriculture, renewable energy, only essentially required real estate, infrastructure and public transport, etc. It is indispensable now that the agencies which implement environmental regulations show the credibility. There is a need to create more environmental jobs. Green growth, which is not unknown, should now be the new slogan, and not ease-of-doing business. Because, by now, we have realized two things. One, who all are doing responsible business like the Tatas. Secondly, that the health of people and the health of planet are one and the same, and both can thrive in equal measure.

This opinion has been published on the print version of Enviro Annotations on 16th April 2020 issue.

Changing Dynamics of Environment

08.04.2020

The draconian COVID pandemic has brought some respite to the environment. At a time when COVID-19 has incarcerated the whole nation, rivers like the Yamuna have started flowing. Sky has become natural blue with extended visibility. Articles and reports describe that the lockdown has improved the air quality index to satisfactory levels in nearly 90% of the 103 cities monitored by the Central Pollution Control Board (CPCB). The clean air could be a blessing for the country fighting against the pneumonia-like virus as air pollution makes people more vulnerable to lung disease. Decrease in air pollution could be attributed to many factors. The CPCB has quoted in its 31st March 2020 report as in source apportionment study conducted by The Energy Research Institute (TERI) & Automotive Research Association of India (ARAI), 2018, during summers, dust & construction activities (35%), transport sector (20%) and industry (20%), are major source of PM2.5 in Delhi. With regard to PM10, dust & construction activities (43%), industry (20%) and transport (17%) are major contributing sources. As result of complete restrictions on non-essential vehicular movement, air pollution from construction activities have come down, barring air blown dust pollution from under construction sites. The on-road vehicles were relatively sparse compared to normal days thus contribution from road dust re-suspension and transport sector was much reduced. A broad analysis was attempted to explain the improved air pollution levels due to lockdown. Air quality monitoring data reveal that during lockdown period PM10 and PM2.5 levels were reduced by about 35 to 40%, which may be explained as possible reduction from industries (~10%; considering continued operation of power plants with ~7 – 8% share, conversion of industries to natural gas, etc.), and transport (~15%; with essential service vehicles and a small part of fleet still plying on roads), and dust (~10-15%; with continued contribution due to soil and wind-blown dust because of high surface winds). There may be some further reduction from other activities such as refuse burning, airport, etc. as well.

Secondly, most of the offices and commercial buildings are shut due to lockdown. Air emissions from commercial activities and most of the industries have ceased. Thereby, electricity generators were not operated, and did not emit air pollution. This has further resulted in sharp reduction in power demand, which has fallen about 30% since the lockdown began. Thus, a significant reduction in water consumption industries as well as commercial sector, and an obvious least disposal of untreated wastewater. It is so evident from the rejuvenation of river Yamuna, a tributary of River Ganga, with good flow and clear water in some parts, though, not throughout.

This triggers a question against the all government departments concerned, on whether they kept working unbelievably niggardly for the last almost 27 years. Government of India has supplemented the efforts of the States for checking the rising level of pollution of river Yamuna by providing financial assistance to States of Haryana, Delhi and Uttar Pradesh in phased manner since 1993 under the Yamuna Action Plan (YAP). The total expenditure incurred on conservation of river Yamuna under the YAP Phase – I & II is Rs. 1514.70 crore. So, what should be done once the COVID-19 pandemic is over? Should the SPCBs/UTPCCs concerned be contained till all the industries are installed with effective and resulting wastewater treatment plants? All the measures being adopted must be recalibrated, jettison the unproductive approach and imbibe the right technologies under the able direction of Supreme Court. The restart after COVID-19 pandemic should be done very carefully to ensure that pollution level does not soar again with the industry’s attempt for a speedy recovery.

Amidst COVID-19 Pandemic Mask Disposal Advisory Indispensable

27th March 2020

According to an advisory issued by the Directorate General of Health Services, Ministry of Health and Family Welfare, Govt. of India, there is no scientific evidence to show health benefit of using triple layer masks for members of public. In fact erroneous use of masks or continuous use of a disposable mask for longer than 6 hours or repeated use of same mask may actually increase risk of infection further.

Suspect/ probable/confirmed cases of influenza should use Triple layer surgical mask. The care provider in home care settings should use triple layer mask. Close family contacts of such cases undergoing home care should also use Triple layer surgical mask. Triple layer mask should not be re-used. Masks used by patients / care givers/ close contacts during home care and should be disinfected using ordinary bleach solution (5%) or Sodium Hypochlorite solution (1%) or appropriate concentration of Quaternary Ammonium household disinfectant and then disposed off either by burning or deep burial.

Th advisory also states that disposal of used masks should be considered as potentially infected medical waste. In the hospital setting it should be disposed off in the identified infectious waste disposal bag/container. In community settings where medical waste management protocol cannot be practiced, it may be disposed off either by burning or deep burial. This deliberates on mask management related to medical ground, which is very much managed under the scope of Bio-Medical Waste (BMW).

Notwithstanding the fact that there is a widespread use of mask by the general public there is no clear advisory on its use, management and disposal. Unnecessary usage will increase load in solid waste management, the cycle of garbage collection and plastic recycling. And, improper disposal may lead to serious consequences to our health and environment. Those who are not nCoV infected, but have some other airborne diseases may cause health impact on the safety of municipal workers and ragpickers. According to a tweet, New Delhi Municipal Corporation (NDMC) has provided all Personal Protection Equipment (PPE) and essential devices to each member of the work force of sanitation and other staff, while working to sanitize Parliament House, Safdarajng Hospital, NDMC's buildings and all Public Toilet Utilities, and many other premises in New Delhi area. The home page of the website of NDMC has also provided information on COVID-19. However, there was no trace of mask disposal in it. The South Delhi Municipal Corporation and North Delhi Municipal Corporation did not display any information regarding COVID-19. The website of East Delhi Municipal Corporation was placed with a copy of notice dated 21.03.2020 pertaining to to closure of non-essential service in the wake of COVID-19. This was also not that visible.

It is important that the governments, including the municipal bodies, issue advisory and share information on the use, management and disposal of mask. The public must also behave responsibly, and not throw it just anywhere.

Treatment of coronaviruses in wastewater

23rd March 2020

The outbreak of respiratory illness, known as #COVID19, continues to spread around the world. India is no exception. In India, the number COVID confirmed cases is increasing alarmingly. As a preventive measure, the hospitals are also trying to keep COVID positive patients away from other patients. Therefore, it is becoming imminent to create temporary medical centers.

With this, a question arises, whether COVID-19 can be transferred via wastewater? On wastewater treatment, WHO has stated that there “is no evidence to date that the COVID-19 virus has been transmitted via sewerage systems with or without wastewater treatment”.

The United States Environmental Protection Agency (USEPA) said wastewater treatment plants do treat viruses and other pathogens and that the virus is "particularly susceptible to disinfection".

No COVID-19-specific protections are recommended for employees involved in wastewater management operations, said the Water Environment Federation (WEF). Workers should follow routine practices to prevent exposure to wastewater. However, the WEF added that COVID-19 may be transmitted through the faecal-oral route. The virus RNA was detected in patient stool after scientists noticed that some patients infected with the COVID-19 virus experienced diarrhea in the early stages of infection instead of a fever, the latter being more common. Many experts say that there have been no reports of faecal-oral transmission of COVID-19 to date.

According to USEPA. the wastewater treatment plants treat viruses and other pathogens. COVID-19 is a type of virus that is particularly susceptible to disinfection. Standard treatment and disinfectant processes at wastewater treatment plants are expected to be effective.

Nevertheless, the USEPA has added that the decentralized wastewater treatment (i.e., septic tanks) do not disinfect, EPA expects a properly managed septic system to treat COVID-19 the same way it safely manages other viruses often found in wastewater. Additionally, when properly installed, a septic system is located at a distance and location designed to avoid impacting a water supply well.

Thus, the temporary medical centres, which are connected with sewer lines may be a better choice. In the case of non-availability of such arrangements, it seems to be prudent to avoid use of the water sourced from borewell or any groundwater adjacent to the septic tank disposing the wastewater from a temporary medical centre or camp.

Zero Liquid Discharge

18th March 2020

Zero Liquid discharge, well known as ZLD is not a new term to many practicing environmental professionals. ZLD technology has been available and mandated in industries in Europe since the 1980s. The implementation in India has gained success in some industries, such as distilleries and also did not result any good in many others, for example pulp and paper. Some experts blame that the definition of ZLD is not very clear. The Central Pollution Control Board (CPCB) defines ZLD as installation of facilities and system which will enable industrial effluent for absolute recycling of permeate and converting solute (dissolved organic and in-organic compounds/salts) into residue in the solid form by adopting method of concentration and thermal evaporation. ZLD will be recognized and certified based on two broad parameters that is, water consumption versus waste water re-used or recycled (permeate) and corresponding solids recovered (percent total dissolved / suspended solids in effluents). This definition is often misunderstood. Many regulators in India have also twisted the requirement of ZLD, which has diluted the need and perception. In simple terms ZLD means 100% recycle or reuse of treated wastewater in manufacturing and allied processes or in domestic usages. However, use of treated wastewater in watering greenbelt is not considered as ZLD.

A close look at the Environment Statement for the Financial Year 2018-19 submitted by Aditya Aluminium, Lapanga to the Odisha State Pollution Control Board, shows that the company claims zero disposal of wastewater. Under Part-C, the water pollution discharged to the environment per unit of output has been stated as “Nil”, as against water consumption of nearly 32802 KLD (process+cooling+domestic). There is no statement regarding RO reject characterization and disposal. Further, the treated wastewater from Sewage Treatment Plants of capacity 600 KLD +300 KLD is disposed of onto the land for watering greenbelt. This disposal falls under regulation and is a part of the water pollution pertaining to the industry's activities. Therefore, this pollution, RO reject should have been accounted for. The Odisha State Pollution Control Board, the Zonal Office of the Central Pollution Control Board, and also the Regional Office of the Ministry of Environment, Forest, and Climate Change should act on this. All these authorities must have received copies of the statement, as per applicable legal requirements. There might be several cases like this in India.

Another important factor is that ZLD systems are associated with significantly high capital investments and even higher operating expenses. There is a need to find various options to reduce the ZLD CAPEX and OPEX. Although currently the industry is looking at it as a challenge and a sunk cost, in long term ZLD has the potential to provide tangible as well as intangible benefits to the companies. Apart from this in some cases this cost can be offset by the resource recovery i.e. salt and other chemicals which can be again reused in the process. In textile industry for example there is enough scope to recover salts and brine solution which can be reused in the manufacturing process and reduce the impact of treatment cost on the overall cost of production. Nevertheless, there are several industries, such as; pharmaceutical industries and food industries, where implementation of ZLD seems to be highly impractical or needs to be designed very carefully.

The ZLD mandate has helped increase the focus of the industry to water which has traditionally been an underpriced resource.


This opinion has been published on the print version of Enviro Annotations on 18th March 2020 issue.

Suggestions to incoprorate in EIA Notification 2020

11th March 2020

The new EIA notification proposed by the Ministry of Environment, Forest and Climate Change (MoEF&CC) has been prepared very diligently. Sharing of power or responsibility with the State Pollution Control Boards (SPCBs) and Union Territory Pollution Control Committees (UTPCCs) to carry out inspections and monitoring of compliance with regard to the conditions laid in environmental clearance (EC) is meaningful. Taking the NGT order with regard to OA No. 639/2018 into account, the responsibility sharing step by the MoEF&CC will be eco-friendly too. The projects could be reviewed both for consent and EC compliance in one go by the officials deputed for inspection. If executed properly, it could be very resultant, as the MoEF&CC was not able to review many projects after grant of EC. Nevertheless, it is well known that the level of environmental degradation attained, despite availability of water act since 1974, air act since 1981 and hazardous waste management and handling rules since 1989. Also, there is a significant increase in environmental activism pertaining to the matters handled by the SPCBs and UTPCCs. Therefore, it is a concern from a national perspective as to how things will yield.

The validity of EC to projects except Mining, River Valley or Irrigation projects or Nuclear power projects shall be 10 years, which was earlier for 7 years. With the EIA Notification 2006, some projects come back to authorities for expansion/modification of EC within 2 years, or even less time from the date of EC grant, which is much before the expiry of validity. Such projects could be observed as improperly planned. Many such projects have come back with extremely high increase in pollution load. And, sometimes with proposal of lesser greenbelt area. Obviously, this brings additional workload on the appraising authorities. On the other hand, there is a cost involved in the part of the government to appraise an application seeking EC. But there is no fee involved in the EC process. It is important to impose a significant amount of fee in the cases, which seek expansion/modification within EC validity with a high degree of pollution load. However, projects needing expansion because of national interest should be exempted.

The penalty clause for defaulters in compliance reporting is a welcome step. There were many projects going to sleep mode after obtaining EC. It is also a need to incorporate a generic structure and a list of enclosures to support the EC compliance reporting. The reports should also be prepared by professionals with appropriate knowledge and experience. The condition regarding the availability of only the latest compliance reports on the project proponents’ (PP) websites needs to be reviewed. As many times the government sites either found not accessible or don’t provide adequate information, the compliance reports must be made available at least for 3 years on the PP’s website. This is certainly not going to cause any hurdle in their ease of doing business. Further, the notification should also incorporate a clause regarding the revocation of EC in case of a project’s regular and consistent failure in complying with the conditions outlined in it. The decision should be reserved by the MoEF&CC.

Dealing with the violation cases seems to be in need a review. If a project has been issued Consent to Operate (CTO) without prior-EC or prior-EP, the same should come to cease, once it is found to be in violation. Secondly, most of the violation cases practically fall in B1 and B2 category. Such projects fall under the SEIAA AND UTEIAA. As the SPCBs and UTPCCs are now going to be involved in the post EC monitoring, they should be given the responsibility to evaluate the applicability of EIA notification at the time of granting CTO. Further, there should be a provision that the projects under violation should compulsorily undergo public consultation, irrespective of its type and category.


This opinion has been published on the print version of Enviro Annotations on 11th March 2020 issue.

Thermal Power Plants: A curse to the environment?

4th March 2020

Early in February, in her budget speech, the Finance Minister, Smt. Nirmala Sitharaman expressed concerns about environment and clean air. She also said that the Central government will advise closure of utilities running thermal power plants, which are old and have higher carbon emissions. By the end of February, the Chief Justice of India also said he wanted all thermal plants in the country shut to prevent further environmental pollution. “You cannot destroy the ecology. You can consider keeping it out of ecologically fragile areas,” the Chief Justice said.

The total installed capacity of thermal power in India, as on 31st January 2020 stands to be 230,189 MW, against the total installed capacity of 368,689.82 MW. This means installed capacity of thermal power in India is above 62% of the total installed capacity. Moreover, coal based power has a share of 55.6%, which is 204,724.5 MW. The greenhouse gas (GHG) emissions from electricity generation (2017) 2,194.74 metric tons of carbon dioxide equivalent.

China, with the world’s largest thermal fleet of 981 GW capacity, about 55 % of its total electricity generation mix, revolutionized its highly polluting coal power sector to tackle the problem of air pollution. Emissions from coal plants contributed to around 40% of PM(2.5) emissions in China (China Power Team, 2016). The Chinese Ministry of Environmental Protection reported that since 2012, Sulphur Dioxide emissions from coal-based plants decreased by 38%, while Oxides of Nitrogen emissions declined by 42%.

According to a 2019 publication “India’s Energy Transition: The Cost of Meeting Air Pollution Standards in the Coal-fired Electricity Sector” Srinivasan et al. (2018) and Ramanathan (2017) identify costs of the various pollution-control technology on a normalized basis per MW of installed plant capacity. The costs are subject to change, based on improvements in technology, the economies of scale achieved over large number of installations and most importantly, plant- or unit-level constraints. For example, the cost of a wet flue gas desulphurization system was as low as Rs. 19 lakhs per MW, in a recent bid. However, this was an outlier, and the average cost, as suggested by technology providers and the literature they reviewed, is Rs. 50 lakh per MW.

In an editorial opinion, the Economic Times on 17th February 2020 has deliberated that the renewable energy sector, which has witnessed the vast bulk of private funding in power in the last six years, now faces the real threat of transforming into non-performing assets (NPAs) due to lax payment for power supplied, never mind if it’s ‘green’. The powers that be clearly need to proactively address mounting non-payment; otherwise, India’s target to have 175 GW of renewable capacity will simply not see the light of day by 2022, or ever. The article further articulates that the Finance Minister has, rightly, flagged the issue of ‘financial stress’ in state power distribution companies, or discoms, due to rampant non-payment of user charges and widespread revenue leakage.

In such a juncture, whether, India can bear such a mammoth financial burden towards technology change or shutting down of thermal power plants? It is extremely necessary to carry cost-benefit analysis to phase out the polluting industrial processes. Renewable energy is a good option. However, there is a need for detailed impact analysis on the questions being raised against Photovoltaic Cells in solar energy sector. It is well understood that it can’t be attained in a very short time. But the good sign for the nation’s environment is that air pollution issues are being seriously considered. Late better than never. Now, solid action is a necessity. Defaults must not be tolerated.


This opinion has been published on the print version of Enviro Annotations on 4th March 2020 issue.

MoEF&CC proposes Amendments to Battery Waste Management Rules

26th February 2020

Year 2020 has been described as a Super Year for Environment. The Ministry of Environment, Forest and Climate Change has brought several proposals to amend existing rules. The latest one being the Battery Waste Management Rules 2020, vide S.O. 770(E) dated 20th February 2020. Earlier, the Batteries Management and Handling Rules were notified in 2001 and amended in 2010.

The earlier rules were considering only lead acid battery. The 2020 rules incorporate all types of batteries; such as non-rechargeable and rechargeable batteries, regardless of their shape, volume, weight, material composition or use. Under the new rules 'battery' or “accumulator” means any source of electrical energy generated by direct conversion of chemical energy and includes disposable primary (Alkaline/Mercury/Silver oxide/Zinc Carbon) batteries or rechargeable secondary (Lead Acid/Lithium Ion/Lithium Metal/Nickel Cadmium) batteries or any other battery which is a source of electrical energy and contains (or may produce at end of its life) potassium hydroxide or sodium hydroxide or ammonium chloride or zinc chloride or sulfuric acid or pressurized sulfur dioxide gas or thionyl chloride or magnesium bromide or magnesium perchlorate or mercury or zinc or cadmium or nickel or lithium chloride or any other hazardous material as defined in Hazardous and Other Wastes (Management and Transboundary Movement) Rules, 2016. Schedule-I of the new rule has listed all batteries including alkaline batteries, and lead acid batteries. It will become applicable to every manufacturer, producer, collection center, importer, re-conditioner, re-furbisher, dismantler, assembler, dealer, recycler, auctioneer, vehicle service center, consumer and bulk consumer involved in manufacture, processing, sale, purchase, collection, storage, re-processing and use of batteries or components thereof including their components, consumables and spare parts, which make the product operational; all appliances into which a battery is or may be incorporated.

The new regulations do not apply to batteries used in (1) equipment connected with the protection of the essential security interests such as arms, ammunition and war material, and intended specifically for military purposes; (2) equipment designed to be sent into space (space exploration); (3) emergency and alarm systems; (4) emergency lighting; and (5) Medical Equipment.

The definition 'bulk consumer' has also changed, and it means a consumer such as Central Government, Railways, Defense, Telecom, Posts and Telegraph, departments of State Government, public sector undertakings, Boards, banks, educational institutions, multinational organizations, international agencies and public or private companies that are registered under the Factories Act, 1948 and Companies Act, 2013 and health care facilities, which have turnover of more than 1 crore or have more than 20 employees and other agencies or companies who purchase hundred or more than 100 batteries per annum.

What are the responsibilities of a consumer and bulk consumer? Consumers shall be required to ensure that used batteries are not disposed of in any manner other than depositing with the seller or in demarcated areas form whom the consumer has bought the new battery. The consumer shall obtain proper GST invoice in respect of new battery purchased from the dealer. Additionally, the consumer shall receive an invoice, along with payment voucher from the dealer in respect of every used battery sold, as per CGST Act, 2017.

The new rule has proposed bulk consumer to get registered with State Pollution Control Board (SPCB), which was not required earlier. The bulk consumer shall ensure that that scrap batteries are not disposed off in any manner other than depositing it to registered recyclers. Previously, the scrap batteries were considered under hazardous waste regulation. The bulk consumer shall file annual return in Form 1, which is yet to be finalized, to the SPCB. Further, bulk consumer shall provide data of new batteries purchased and old batteries sold with their tariff heading and GSTN. The rules have provisions for the bulk consumers or their user units that may go to contract or auction for used batteries to registered recyclers only. Bulk consumers are also required to keep a record of valid license of registered recyclers with whom scrap batteries are being deposited.


This opinion has been published on the print version of Enviro Annotations on 26th February 2020 issue.