Can you ever be 100% Compliant to Environmental Standards on 24×7 basis?

Compliance to environmental standards is expected to be 100% and on 24×7 basis in most countries including India. This means that draw a sample any time and the concentrations of the specified pollutant must be seen within the set limits or standards. If not then then it becomes a case of violation or non-compliance that the regulator can act upon. Even one single default becomes a case of non-compliance.


This situation is applicable for meeting both emission/effluents as well as for ambient environmental standards. Given this expectation, can any polluter be truly compliant? And when ambient environmental standard gets violated, how do we find the “culprit”? And do we act against such a violation on the regulator or the regional responsible agency?


But I wonder how realistic it is to ask for 100% and 24×7 compliance in the first place. We all know that emissions and effluent streams are to be released after required treatment. The design of treatment and disposal systems is to be done such that compliance can be ensured. The treatment systems however receive variable quantities and sometimes unpredictable characteristics of “inputs”. Against this variability (often beyond control of the treatment system designer and operator), “outputs” are  expected to meet the standard 100% time.  Is this reasonable? And isn’t it asking for too much?


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Operations without Certification

Today in India, you cannot operate a boiler without a certified operator, but you can operate a wastewater treatment plant without such a certification requirement. Our regulators, the Pollution Control Boards (PCBs), do not think that it is critical to insist that operators running the wastewater treatment plants must have the necessary training.


Programs for training and certification for operation of wastewater treatment plans have matured over decades in countries such as Germany (German Association for Water, Wastewater and Waste or DWA) and United States of America (Water Environment Federation). In these countries, certification of operators of the wastewater treatment plants is an ”industry” and a career for young professionals.


I do not know how many wastewater treatment plants are “registered” or in the lens of the PCBs in India. I don’t recall any recent work done on such an inventorization. But as a guestimate, the number could well be close to 100,000. And if we assume an average of 4 operators at each treatment works, then we are talking about training and employment of 400,000 to 500,000 young professionals!!


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Consent to Close

In India and so in most countries, permits are required to establish and operate businesses that have environmental and social sensitivities. The Pollution Control Boards (PCBs) in India require that consents to establish and operate are obtained by the business following a well laid down review and permitting process.


These consents prescribe the conditions that are to be met. The conditions generally refer to the mitigation plans, environmental monitoring and reporting. Inspections are then carried out by the staff of the PCB to check the compliance.  The consent to operate requires to be renewed after a stipulated time period.


The business on account of economic conditions, labour issues, dispute etc. sometimes shut down the operations and exit. There are several approvals required in closing down the business. However, there is no consent required from the PCB.


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Utmost Good Faith

The TSR Subramanian Committee in India came up with several radical recommendations to improve India’s environmental governance


A new concept of ‘utmost good faith’ is proposed through a new legislation, Environmental Laws (Management) Act (ELMA). ELMA would oblige an applicant to disclose everything about proposed project. The disclosure will need to include project’s possible potential to pollute and the proposed solution thereto– in short all that would be relevant to making a decision on granting or refusing the environmental clearance applied for.  The project proponent and the experts who support the case will be required by this law to certify that ‘the facts stated are true and that no information that would be relevant to the clearance has been concealed or suppressed’.


If at any time after the application is received – even after the project has been implemented and in operation – it is discovered that the proponent had in fact concealed some vital information or had given wrong information or that the certificates issued by the experts suffer from similar defects, then severe consequences will follow under ELMA. They include heavy fine, penalties including imprisonment and revocation of the clearance, – and in serious cases arrest of the polluter.


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Left vs. Right?

Industrial clusters in India often pose a daunting task to the regulators on environmental enforcement. The clusters consist of micro-small-medium enterprises (MSMEs) who do not have adequate technical capacity, capital and space to install individual pollution control plants. Consequently common solutions are sought where pollution control plant for a cluster is established and operated. Industries collect effluents and send for treatment and disposal to this common plant after some pre-treatment.


The concept Common Effluent Treatment Plants (CETPs) for industrial clusters emerged in early 1977. Professor Nilay Choudhuri, then Chairman of Central Pollution Control Board (CPCB) produced one of the landmark publications “Industrial Estate Planning” after a consultative workshop. I still have a copy of the workshop proceedings. This publication is a must read.


A scheme to finance CETPs was launched under the Central Loan Scheme. Later, between 1991-1999, the Scheme was supported by the World Bank under the credits lines – Industrial Pollution Control and Industrial Pollution Prevention & Control. Today, nearly 200 CETPs operate in India. These CETPs are owned by companies formed by the member MSMEs who employ or contract operational staff and collect effluent charges based on a formula.


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Who’s Safeguard Anyway?

It’s clear that the world needs development banks both to scale up the level of investment and to give developing countries better representation in the world of development finance. Yet these new banks will also need to play another role: championing sustainability as they usher in more development. Will this really happen?


The Asian Infrastructure Investment Bank (AIIB) was proposed by China in 2013 and launched at a ceremony in Beijing in October 2014. The AIIB to be fully established by the end of 2015.


AIIB is considered by some as a rival for the IMF, the World Bank and the Asian Development Bank (ADB), which are regarded as dominated by developed countries like the United States. The United Nations has addressed the launch of AIIB as “scaling up financing for sustainable development” for the concern of Global Economic Governance.


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Why was beef banned in India? The Real Reason

“Most believe that the Prime Minister supported ban on Beef due to religious reasons. Pity that none understood his real motive”


My Professor friend said this, lit his cigar and took a deep puff. We were sitting in his verandah enjoying the drizzle of the rain.


I said “Indeed, the reasons were religious. We have been worshiping cows for centuries in India and the cattle are the pillars of our agro-economy”


The Professor smiled.


“The real reason for banning beef was to protect India and the World from the water stress. Actually it was my idea”.


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Buy Nothing Day

The breaking news in all newspapers and TV channels was about India’s adoption to the Buy Nothing Day (BND).


There were intense debates and opinions on the pros and cons of BND.


Few protested – especially from the industry and retail business, and several celebrations were held in the streets mainly by the environmental activists. BND is a great idea – they said.


Whats Buy Nothing Day?


Buy Nothing Day (BND) is an international day of protest against consumerism. BND was founded in Vancouver by artist Ted Dave and subsequently promoted by Adbusters magazine, based in Canada.


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Zero, Positive or Negative?

Most Pollution Control Boards in India are now insisting that industries meet the directive on Zero Liquid Discharge (ZLD). So also the judiciary.


The idea of ZLD is not to let polluting liquids discharge to the environment


ZLD is directed to industries in locations where there is no receiving body of water for evacuating the effluents or the receiving water bodies are already severely polluted. We ask for ZLD here as we don’t want to burden these water bodies anymore!


ZLD implies that effluents are “contained” within the plant itself and intake of fresh water for production is expected to be minimal or near zero. Hence ZLD is often imposed on industries at locations where there is poor water availability or the neighborhood is a water stressed area. In most cases, ZLD leads to 90- 92% water recovery, which reduces input water required by industrial processes by as much as by 80%.


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Change the Lens and the Climate will change

World leaders are meeting this week in Paris (COP21) to discuss and agree on collective actions to be taken to combat Climate Change. I don’t know whether the 100C weather in Paris is going to be conducive to the discussions on the 20C plus issue, especially to the warm and warming country like India.


The UN Environment Programme (UNEP) published a report showing that global emissions levels should not exceed 48 gigatonnes (GT) of carbon dioxide equivalent by 2025, and 42 GT in 2030 to avoid crossing the change of 20C on average above pre-industrial temperatures. The 20C threshold is regarded by scientists as the limit of safety, beyond which the ravages of climate change – such as droughts, floods, heat waves and sea level rises – are likely to become catastrophic and irreversible.


Think about rise in our body temperature by 20C – isn’t it enough to feel feverish? So for the planet earth a 20C rise is like an influenza hit by viral infection that may not be easy to handle through conventional medications such as a crocin or metacin. Perhaps even the antibiotics may not work!


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