Review of EIA Report and Environmental Clearance

Review of EIA Report based on which EC granted to DLF Homes Developers Limited for expansion of “Group Housing” at SIEL Complex, Shivaji Marg, New Delhi-110015 

 

Sunita Mishra 

@enviannotations 


The EC bearing F.No.21-111/2017-1A-III dated 11th October 2019 states that the Project is an expansion of already been granted EC for the development of DLF Tower vide letter No. 21-277/2008-IA.III dated 19.01.2009. The total built-up area after expansion could be 1000726.78 square meter (SQM). 

The EC letter also states that amendment in ToR was granted vide letter F.No.21-111/2017-1A-III dated 22.4.2019, while EC application was filed on the very next day that is 23rd April 2019. However, the EIA Report available on the website of MoEF&CC shows that the report was prepared in February 2019 and baseline season was March 2017 to May 2017. The reason for issuing amended ToR and its compliance in just 1 day remains unclear.   

A good thing cited in the EC is that the project has not proposed any tree felling, nor transplantation of existing trees. However, the greenbelt area has been reduced by nearly 13% from 33427.752 SQM to 29213.88 SQM. On the contrary the built-up area increases by almost 132%. Another disappointing note is that in 10 years, the project developed only 3023 SQM (less than 10%) of green area as compared to proposed 33427.752 SQM. Furthermore, the Certified Compliance Report issued by the Lucknow Regional Office of the MoEF&CC has ignored this fact and certified as complied.

Water requirement of 37000 liter per day during construction phase, according to the EC and EIA Report, will be met through tankers supply. However, it does not clarify whether the tanker supply water will be sourced from Delhi Jal Board (DJB), or any DJB approved agencies, if any or groundwater sources. At 4.1.1 of EIAR it is stated that there will be no impact on hydrology and geology. This claim could have been supported with information of source of tanker water supply. On the contrary, the section 4.3.8 of the report under the heading “Hydrology and Geology” states that “The major activities which would most probable to negatively impact the hydrology and geology would be working of daily activity of labours, staff and visitors and Transportation during Construction and Operation Phase. The aspects of the activities would be generation of Solid Waste, E-Waste and Bio-Medical Waste, Wastewater generation which would impact in deterioration of water quality (in both Surface Water and Ground Water). To minimize such impacts, mitigation measures like installation of Rainwater Harvesting Pits and Proper treatment and disposal of Waste water shall be adapted in the project site.” This implies the analysis and reporting is inconsistent and inappropriate. The EIA Report has not dealt with site specific hydrology data. It rather repeats generalized data from secondary sources. The EC condition under the heading of Water quality monitoring and preservation specifies a condition that “Any ground water dewatering should be properly managed and shall conform to the approvals and the guidelines of the CGWA in the matter. Formal approval shall be taken from the CGWA for any ground water abstraction or dewatering.” The table 4.1.2 of the EIA report shows that water table in the area is approx. 1.1-25.05 m below ground level, which is a too wide range. However, considering the lower side that is 1.1 meter, dewatering groundwater is indispensable to construct 3 or 4 basements. It will also cause huge impact to the hydrology and geology of the project area. Therefore, a formal approval from the Central Ground Water Authority (CGWA) for any ground water abstraction or dewatering is essential.

Further, after expansion, the total fresh water requirement could rise to the level of 2637 kilo-liter per day, which is slightly above 61% of the total water requirement of the project. As per EC and EIA documents, the entire fresh water requirement will be met through the ultimate source that is DJB. However, the information supplied in the Form-2, EC application at serial No. 15 against the details of Water Requirement (During Operation) as a permission vide letter No. TP/4/2302 dated 30th November 2018 is not a permission from the DJB. It is just a layout plan forwarded by Town Planning Department of North Delhi Municipal Corporation.

The EIA report states that during the construction of the proposed project, the services required like water supply and sewage facilities shall be arranged on a temporary basis and the same shall be maintained without any adverse impact on the environment. The water required for demolition purposes, curing and other construction purposes shall be taken from tanker supplier. However, it does not deliberate on how the facilities could be arranged temporarily without disturbing the environmental setting. Nevertheless, it has also mentioned that the total 22 KLD of wastewater generation expected during construction phase shall be treated in mobile sewage treatment plant (STP). If that practically happens, it could be a good step. But there is no further deliberation on the use of the treated wastewater during construction phase.

The EC has specified a condition that Consent to Operate (CTO)/Occupancy Certificate (OC) shall be issued only after getting necessary permission for required water supply from DJB/concerned authority. However, it has not marked any copy to the DJB and OC issuing authority. It is also important to ponder as on why should Consent to Establish (CTE) be issued without approval from DJB regarding water supply?

As per the report during Construction, 9.94 Lakh cubic meter of soil will be excavated, which will be used in backfilling purposes. It also states that the Construction and Demolition (C&D) Wastes will be used for flooring and back filling in roads etc. to the maximum extent possible. Whether such a huge quantity of excavated earth could be accommodated in backfilling? This could have been clear with supporting data in the form of material balancing. Further, akin to many other reports, this EIA report also considers only the impact on flora species due to excavation and does not consider organisms those inside the soil surface. 

Under hazardous waste management, the report has deliberated on used oil expected to be generated from maintenance of diesel generators. It does not specify any thing on other related to used oil filters, air filters and oil soaked materials, if any. Furthermore, the report has failed to deal with the management practices of empty paints and related chemical containers, which is prevalent in a construction project.

According to the report, after expansion, approximately 242 Kg per day of dry sludge will be generated from STP within complex during operation phase and this sludge will be passed through filter press where it will be dewatered or dried to form a cake and then will be used as manure in green areas. The unused sludge shall be given to farmers or nursery. When India is concerned about Faecal Coliform in water, whether, this practice will meet the norms? Should the government allow this practice without characterization of sludge? According to a research article “Regrowth of faecal coliforms and salmonellae in stored biosolids and soil amended with biosolids” by R.A. Gibbs, C. J. Hu and others “results suggest that faecal coliforms and salmonellae were at undetectable concentrations through the summer period but were able to grow when provided with favourable conditions. From this limited trial it was concluded that soil amended with biosolids could not be considered free from pathogens for at least one year following amendment.” Furthermore, the EC, recently accorded to the project, states that “Sludge from the onsite sewage treatment, including septic tanks, shall be collected, conveyed and disposed as per the Ministry of Urban Development, Central Public Health and Environmental Engineering Organization (CPHEEO) Manual on Sewerage and Sewage Treatment Systems, 2013.” Therefore the Certified Compliance Report issued by the Lucknow Regional Office of the MoEF&CC, which certifies the present use of STP sludge as manure as a compliance and no violation is questionable. Another obvious question is whether this certification was based on any scientific evaluation of quantification of manure required for the greenbelt area, which accommodates the entire volume of STP sludge as well as compost from Organic Waste Converter? 

In the EIA data generation part of ambient air quality monitoring, the report has not detailed monitoring method adopted for carbon monoxide parameter. Whether the monitoring locations were meeting the sampling criteria? This could have been supported with photographic evidence. Similarly, it has not cited any statement on the calibration status of equipment used. 

It has been stated that the project has installed 4 diesel generator sets totaling 3410 kVA capacity. Further, there is a proposal to install 17 diesel generator sets totaling 23400 kVA. At a time, when the entire Delhi NCR is crying for an emergency situation due to wrath of air pollution, and the Government of India is being given thrust for the maximum utilization of solar energy, whether projects of such standards should be allowed to commission diesel generators? Such an approval from MoEF&CC needs a serious review at a point of time when it has notified Graded Response Action Plan (GRAP) on 12th January 2017 and the Environment Pollution (Prevention and Control) Authority for NCR (EPCA) is striving for the implementation. Further, there is no specific condition imposed regarding compliance of GRAP, EPCA and DPCC orders with regard to DG set operation. MoEF&CC should look into this matter with urgency. 

For the sake of good governance for a better environment, being demanded by school children worldwide, the MoEF&CC needs to review these points and take appropriate action. This will also ensure smooth functioning of the project in future. Nevertheless, the EC has mentioned that any appeal against this EC shall lie with the National Green Tribunal (NGT), if preferred, within a period of 30 days as prescribed under Section 16 of the National Green Tribunal Act, 2010. Therefore, one can approach the authorities and Hon’ble NGT on or before 10th November 2019

EIA report prepared by M/s Perfact Enviro Solutions Pvt. Ltd., New Delhi

EC granted on 11th October 2019 by MoEF&CC

Review of EIA Report and Environment Clearance for Group Housing Project measuring 14.793 acres at Village Babupur, Sector-106, Gurugram, Haryana by M/s Godrej Real View Developers Pvt. Ltd, 3rdfloor, UM House, Plot No. 35, Sector-44, Gurugram 

Sunita Mishra 

@enviannotations 

The project was already granted Environmental Clearance vide No SEIAA/HR/2010/1415 dated 21/01/2010 that stood expired in light of applicable notification issued by the Ministry of Environment, Forest and Climate Change (MoEF&CC) on dated 29th April 2015 and subsequent clarification vide OM issued on the subject on dated 12thApril 2016. The EC application as cited in the EC under discussion was received by SEIAA on 22nd August 2017, where it states that construction work was not started yet and therefore, it is a new case. It does not cite the reason of not starting construction for almost 7 years. EC process bears a direct costing to the state and nation. Genuine reasons must be cited, verified by authorities and also some provisions be made to compensate the involved costing. 


The EC reads that the Group Housing project shall comprise of 2 Basements, 7 Residential Tower + EWS + GF + 34 Floors. The proposed project shall have 754 Dwelling units, 135 EWS units and 76 Servant units, Nursery Schools, Convenient Shopping and Community Building/ club. The maximum height of the building shall be 107.35 meter. The total water requirement shall be 541 KLD. The fresh water requirement shall be 308 KLD. The waste water generation shall be 348 KLD which will be treated in the STP of 650 KLD capacity. The total power requirement shall be 11 MVA which will be supplied by DHBVN. The Project Proponent has proposed to develop green belt on 18048.82 sqm (30.15%) of project area (Green Belt area 1753.06 sqm + Periphery plantation 2384.46 sqm + Avenue Plantation 2551.85 sqm + Lawn area 11359.45 sqm). The Project Proponent proposed to construct 8 rain water harvesting pits. The solid waste generation will be 2161kg/day. The bio-degradable waste will be treated in the project area by adopting appropriate technology. The total parking spaces proposed are 1357 ECS.


At 1.21, in the Form 1 the appraisal process questions “Impoundment, damming, culverting, realignment or other changes to the hydrology of watercourses or aquifers?” The project proponent states “No impoundment, damming, culverting, realignment or other changes to the hydrology of surface water courses is required”, and it remains silent on groundwater aquifers. Further, in the EIA report available on the website, under Hydrology it describes “In the industrial area of Manesar, the top most aquifer can be encountered at 20 m”, which is more than 10 kilometers away from the project site. According to certain reports submitted by civil engineering surveyors and consultants, who carries load bearing tests, and interviews with local residents, it is reported that groundwater table was very high and water was available at a depth of 10 foot in many parts of the study area, during 2010. The EIA report fails to display the factual status of the project area, which is essential as the project requires excavation of two levels of basements which in turn may require pumping out the groundwater. Therefore, there could be a change in the hydrology of aquifers. The SEIAA has also overlooked this matter, which defeats the purpose of delegation of powers from the Union Government.


The condition No. 16 of the EC reads “In view of the severe constrains in water supply augmentation in the region and sustainability of water resources, the developer will submit the NOC from CGWA specifying water extraction quantities and assurance from HUDA/ utility provider indicating source of water supply and quantity of water with details of intended use of water –potable and non-potable. Assurance is required for both construction and operation stages separately. It shall be submitted to the SEIAA and RO, MOEF, Chandigarh before the start of construction.” The factual condition during 2017 and 2018 was that groundwater extraction in the project area was banned by the Central Ground Water Authority due to a reason cited in very EC at condition No. 17. In such a situation how is justified by the SEIAA to impose a condition without supporting detailed? What result should be expected from this?


The condition No. 17 of the EC reads “Overexploited groundwater and impending severe shortage of water supply in the region requires the developer to redraw the water and energy conservation plan. Developer shall reduce the overall footprint of the proposed development. Project proponent shall incorporate water efficiency /savings measures as well as water reuse/recycling within 3 months and before start of construction to the SEIAA, Haryana and RO, MOEF, GOI, Chandigarh.” 


The above condition could have been pragmatically imposed at the time of appraisal. However, as on date the guidelines of water consumption has changed and therefore, an amendment could be easily sought by the project proponent. Nevertheless, the document must also seek a complete water balance – starting from groundwater extraction to replenishment by means of rainwater harvesting during construction phase. Rainwater harvesting could be attained by means of modular structures available in these days and also the final structure be constructed through a proper planning. 


EIA report prepared by M/s Perfact Enviro Solutions Pvt. Ltd., New Delhi

EC granted on 4th April 2018 by the SEIAA Haryana

Review of EIA Report and EC granted to Proposed Treatment Storage and Disposal Facility (Incineration Only) at B-28 & 29, Industrial Area, Focal Point, Malout, Punjab by M/s Sevrin Environ Management Co., Danewala, Malout - 152107  


Sunita Mishra 

@enviannotations 


The proposal has got environmental clearance (EC) from the Ministry of Environment, Forest and Climate Change (MoEF&CC) vide letter No. F. No. 10-69/2018-IA-III Dated 20thSeptember 2019. As per the EC, the project will be an Incinerator based Hazardous Waste Management Plant with installed capacity to process 4000 liters per day of Liquid Waste and 1000 kg/day of Solid Waste. The EC has diligently detailed various aspects and stipulated conditions. It describes that about 90% water will be evaporated from circulation tanks of scrubbers due to high temperature of flue gases. The remaining water will be filtered before reuse in the scrubbing tank. The sludge will be sent to the Primary Chamber for Incineration same as other waste. The industry will be using water to satisfy cooling water requirements and for vacuum pumps. All of the water will be continuously re-circulated. There won't be any rejection of the water and, hence, there will be no effluent generation. Sevrin Environ Management Co. is a newly established Partnership concern. Disposal of hazardous waste in common and captive incinerators leads to the loss of vital resource besides having potential to cause severe environmental risks if not operated in an environmentally sound manner. However, Co-processing of hazardous wastes in cement kiln, wherever, characteristics so suggests, will eradicate such risks and harness the encapsulated energy, hence a priority area. In order to streamline the procedure of co-processing so as to give a thrust to such activity, the Central Pollution Control Board (CPCB) has prepared guidelines.


The EIA report states that Punjab state is generating 4978 ton of incinerable waste per year, some of which is being treated in the Captive Incinerator Plant. The 2016-17 data published in a CPCB report shows that 2246.5 Ton of hazardous waste was treated captive incinerators, while 1734.3 Ton was treated in common incineration in TSDF and 418.81 Ton of hazardous waste was taken for co-processing in cement kiln. However, the stated report also shows that Punjab has no Integrated Treatment, Storage and Disposal Facility (TSDF) with both Secured Landfill Facility (SLF) and Incinerator nor it has TSDFs with only Common Incinerators. Furthermore, there is a cement plant at a distance of nearly 50 kilometer from the project site. In such a case, whether it is feasible to install of such a low capacity incinerator? 


The total fresh water requirement is as low as 2 kilo-liter per day. However, the water balance is not very transparent. 


The report has some contents, which will be very useful in the part of the project proponent. One example could be that at 6.3 of the EIA report under the heading Environmental Monitoring the consultant has suggested that apart from the standard parameters stipulated under the National Ambient Air Quality Standards (NAAQS), additional parameters, namely, Total Volatile Organic Compounds (VOCs), Polycyclic Aromatic Hydrocarbons (PAH), to align the monitoring Programme with the potential impacts of TSDF operations, should be monitored. Similarly, it has recommended parameter and frequency for the monitoring of groundwater as well as soil. However, some difference may be found in the tabulated data given under the Table 34 with heading Monitoring Schedule for Environmental Parameters and the contents under paragraph description. 

The above mention could have been more valuable if a pre-project baseline data could have been generated and placed in the EIA report with respect to all the parameters suggested. This effort gives scope for correlation of pre-project and post-project environmental scenarios. 


The consultant has also mentioned the applicability of Public Liability Insurance Act. The EIA report states that the operator of the facility shall also take Insurance under Public Liability Insurance Act.


Under the heading of Corporate Environment Responsibility the EC has placed a condition that the project will carry out self environmental audit on annual basis. Every three years, a third party


environmental audit shall be carried out by the project. This condition is going to reduce the scope of environmental services business to a further low level. Furthermore, there is no details on whether a third party audit is required to cross verify the TSDF operations and establish the compliance of HWM rules and the consented stipulations as per CPCB guidelines.


The EC does not specify the applicability of displaying of general information through Electronic digital display board at the main gate of the facility. To some extent the EIA report has addressed but it not clearly specified. This is an important condition as it was ordered by the Hon’ble Supreme Court of India. 

EIA report prepared by M/s Shivalik Solid Waste Management Ltd. (SSWML), SCO 20-21, II floor, Near Kalka -Shimla Highway Zirakpur, Baltana, Punjab 140604