A Plumbing Consultant’s Role in MoEF

My first rendezvous with the Ministry of Environment and Forests (MoEF) was in January 2007 when
I attended a hearing for one of my upcoming mall projects. Totally unaware as to what would be
expected, I made it up the stairs at “Paryavaran Bhavan” in New Delhi. Initially, I was hoping that
since this was the ministry I could get away with “If you cannot convince, confuse”. But, fortunately, I
was mistaken; these were experts from various fields of the environment sector. I was quizzed on
topics like waste water treatment, rainwater harvesting and water conservation/reuse. After 40 long
minutes, the meeting concluded with the project being recommended. Many, like me, are caught
unaware or unprepared, my humble attempt to guide through this seemingly tedious process.

THE BACKGROUND

The Ministry of Environment and Forests

(MoEF) conducted a comprehensive review
of the then EC (environmental clearance)
process under the Environmental
Management Capacity Building Project in
2001. The Govindarajan Committee was
setup by the Central Government for
reforming investment approvals and
implementation procedures. The studies
brought out the need for reforms, which
were consistent with the committee’s
recommendations. A notification S.O. -801 (E)
by MoEF, New Delhi was passed on July 7,
2004 which brought new construction
projects like hotels, office/commercial,
industrial estates, residential complexes, etc. under the purview of environmental clearance. The
criteria for applicability of this new notification for projects included:
a) Population of more than 1000 people OR
b) Discharging sewage more than 50 KL/day OR
c) Investment of more than Rs. 50 crores.

Enter EIA Notification, 2006 on September 14, 2006 with the objective to involve stakeholders in the
public consultation process, identify developmental projects based on impact potential instead of
the Rs. 50 crore investment criteria and incorporate necessary environmental safeguards right at the
planning stage. This supersedes all earlier notifications and amendments thereafter till July 2004. It
has 8 categories of industrial/developmental activities identified in the Schedule. The criteria are
generally based on capacity/area/scale of operations.

Category 8 is for Construction/Building/Townships/Area development projects and is subdivided as:

8(a) for Building and Construction Projects and 8b for Townships and Area development Projects

Project or Activity Category with Threshold Limit

8 Type of Project
Building and
8(a)
Construction Projects
Townships and Area
8(b) Development
Projects
Conditions, if any
Category A Category B
≥ 20000 sq.m and < *Built-up area for covered
150000 sq.m of built- construction; in the case
up area* of facilities open to sky, it
will be the activity area.
Covering an area of ≥ ^All projects under Item
50 ha and/or built-up 8(b)shall be appraised as
area ≥ 1,50,000sq.m^ Category B1
All projects are classified under two categories:
Category A - Will require clearance from MoEF based on recommendations by the State
Environmental Appraisal Committee (SEAC)
Category B - Will require clearance from the State EIA Authority (SEIAA) based on the State
Environmental Appraisal Committee (SEAC) The SEIAA will be constituted by Central Government
based on nominations from State. No site development as well as construction can begin until EC is
obtained.

Proponent

Feasibility study or
Project Proposal
Process duration

Secretary, Env. Impact

30 days

Assessment Authority (SEIAA)

Meeting with SEAC

once in every month

Screening
(identify Project Category)

Category A Category B
Process duration

B2
B1
30 days

Building & Construction

Township and Area Technical review by Member

Development Project Secretary (SEIAA)

Projects / Activity for Technical Committee

Expansion & or changing (Decision Making SEAC)
product mix of existing
project or activity
Meeting with SEIAA for
Process duration

Approval of Project
5 days

Approved Not Approved

Issue EC
(Valid for 5 years)

Rejection letter with

Project reason for the same
Implementation

Post Project Monitoring

(carried out by Regional
MoEF office)

Audit Commissioning
WHERE DOES PLUMBING STEP IN?
As we all very well know that water is one of the most precious and crucial element when it comes
to environment preservation and conservation. Right from the source for consumption to disposal,
water impacts the environment.

The MoEF’s concern begins right from the moment a project is planned.

Concern 1: Is enough water available to the project from the Municipal Corporation, Municipality,
Gram Panchayat or other water distribution agency?

A formal document needs to be obtained by

the client from the Municipal Corporation or
other competent water distribution agency
as to the fact that the required amount of
water will be provided to the project. Details
like water requirement calculations,
depending on the type of occupancy may
additionally be furnished. Efficient solar
water heating will also effectively convice
the committee for energy savings.

Concern 2: Is a public sewer network

available? If not, what are the provisions?

The MoEF strongly recommends sewage treatment plants, irrelevant of the technology, the
CPCB/SPCB (state pollution control board) guidelines have to be followed in such a selection and the
treated effluent quality is also governed by such norms, I won’t go in those details since we are not
discussing waste water characteristics here. But, carrying such details during the SEAC presentation
is recommended. Usage of septic tanks is formidably dissuaded. In many cases the Advisory
Committee may deem it inappropriate to dispose the treated effluent in natural resources or other
means which may be acceptable in other conditions. This is basically to avoid situations where if, for
some reason, the STP is ill-maintained or malfunctioning, raw sewage is not spewed into natural
resources. It would be an impossible mission to evacuate a residential township in such an event.
Hence, any excess treated effluent can only be discharged in the public sewer. It does make a lot of
sense to recirculate the treated effluent for flushing and allied purposes like irrigation, car wash, etc.
especially when many corporations are restricting to supply 45 litres per capita per day. There’s
nothing like enough amount of water, right?

In the absence of public sewer networks, the project may have to be re-designed to accommodate
holding ponds for the treated effluent. The design of the holding pond may have to be done
considering space available in the project and population; also it would be important to consider
facts like rainfall, evaporation
and soil percolation for such a
pond and procedures to avoid
stagnation and contamination.
Though a developer may not
be too happy to reduce the
population of the project but
that too may be warranted.
Another safety factor to
consider for such a pond
would be that it does not
overflow into a free-flowing stream or nullah, remember this is a “holding” pond. Importantly, this is
proposed just as a “stop-gap” arrangement, and may also be not permissible in locations where
public sewer network is not expected for a long time and the project is expected to expand.
Also, sludge disposal process may need to be
highlighted as many civic bodies like the Municipal
Corporation of Greater Mumbai refuse to accept
sludge from STPs. Provisioning like drying beds,
dewatering system, sludge compactors, centrifuges
etc. may need to be made. The image of such a
centrifuge is shown herewith.

Reduction of grey-water (kitchens not included, as per

UPC-I 2008) by using it for irrigation as explained in
UPC-I 2008, chapter 16 may be implemented, if
permissible by local pollution control board norms.

Fresh Water Recycled Water

1,044 KLD 622 KLD

Landscaping
87 KLD

Flushing
535 KLD
1263
KLD STP
1300 KLD
Domestic 514
1,044 KLD KLD
Monsoon Dry
Season
(84 days)
20-Acre
Horticulture Holding Pond Farms
Dry 42,870 Cu.M Dry
Season Season
142 KLD or 39,050 KL/yr 14 KLD or 3850 KL/yr

Usage of water for landscaping and irrigation may require further explanation as to how many trees
are relocated/planted and what kind of water requirement does that may have. Proper zoning for
different landscapes is recommended, separate zones of different types would be required for
lawns, small plants, and large trees; it may also vary of type of irrigation, e.g. drip, sprinklers, etc.

Concern 3: Storm-water runoffs, design,

contours, and rainwater harvesting.

In some cases, this would be handled by a rain

harvesting consultant. But as plumbing
professional, we equally hold a pivotal role here.
Runoff calculations for storm drains should be
provided to the appraisal committee. The UPC-I
2008, chapter 11 elicits important methodology
for working out rainwater runoffs (even from
sidewalls draining onto a roof).

Calculation of rainwater storage from rooftops and the positive impact such water usage could
create on the Municipal supply will definitely bring brownie points. It would be pragmatic to avoid
using rainwater collected from rooftops having lead flashing or asbestos for potable purposes.
Innovative rainwater harvesting technologies and techniques like first flush devices, storage criteria,
etc. as trained in the “Green Plumbers India” are appreciated here. Soil permeability tests, aquifer
levels, and earth moisture saturation will be required as per actual on-site conditions to determine
the harvest and to effectively present a clear picture to the committee.

Importantly one would also be required to explain as to where and how excess rainwater or
overflows would be discharged. In the absence of municipal storm-water infrastructure, a natural
resource like a stream, river or lake may be used, provided separators and screens for sediments,
greases, and oils are utilized to avoid pollution. A study of the natural resource may be required, to
explain how such a natural resource would not flood the project.

Concern 4: Fire, Safety and Population Density

Designs for fire installations, illustrations showing

schematic riser drawings, layout showing hydrant
layouts per National Building Code are appreciated
and should be carried for such an appraisal. The
architect may be right person to decide if a Fire
Station is to be provided in larger developments like
townships, airports or industrial / commercial
complexes, but input from the consultant is equally
important. Again, the architect would be the right
person to comment on the population density.

Thus, these are things which we probably implement on almost all of our projects, but all it takes to
put across this design scheme to the State Environment Appraisal Committee (SEAC) and State EIA
Authority (SEIAA) to get a nod from the Ministry of Environment and Forests as pertains to the
plumbing sector.

- Chintan Daiya