Sanjaya Kumar Mishra
The Proponent’s Sector-3, Gurgaon, Haryana project has been accorded EC by MoEF&CC
M/s Godrej Properties Ltd. has proposed a “Group Housing Colony” involving 3.0225 hectare of land at sector-3, Gurgaon in Haryana. The project falls under Category ‘B’ of EIA Notification, 2006. However, since the tenure of State Environment Appraisal Committee (SEAC) of Haryana has been completed, the application was applied to the Ministry of Environment, Forest and Climate Change (MoEF&CC), which accorded EC to the project. A review of the application was conducted by Enviro Annotations with an objective to find scope of improvement, if any, in such cases. The Rs. 290 Crore project, proposes Ground+19 floors with two basements. The project also proposed 2633 number of residents, 50 staff during operation and 250 visitors. The project is located at one of the thickly populated areas of the city. At 6.3 in the application form the project has stated that “it has been estimated that during the construction period the average noise level is 70-75 dB (A) during peak construction hours.”, while Standards for Construction Site out of industrial area as specified as 65 dB (A), maximum, in the code of practice for construction activities prescribed by Noise Pollution Control Committee constituted by CPCB, which were later notified in Environment (Protection) Rules, 1986. Further, at paragraph 188.8.131.52 of the Executive Summary of the project report it is contradictorily mentioned that during the construction stage, expected noise levels will be in the range of 80-100 dB (A), which will decrease with increase in distance. To avoid Noise impacts during night time, majorly all the noise generating construction activities shall be carried out during the daytime.
At paragraph 1.23 of the Form-1 it is mentioned that “at present, 2 bore wells are present at the site. However, no ground water abstraction is proposed. Abstraction of water if required will be done only after getting permission from CGWA.” It is important to note that the CGWA has already declared Gurgaon as a dark zone and in prevailing time, projects situated in Gurgaon are not eligible to apply for the grant of NOC to abstract groundwater. Therefore, this statement of the project proponent company seems redundant and incomplete. Furthermore, the Expert Appraisal Committee, could review this case as well as similar cases to ensure sealing or dismantling of bore wells before starting construction.
The report also depicts that solar energy will be used inside the colony by installing Solar Photovoltaic panel as per HAREDA norms, which pertains to the Haryana state. It can save 11.14 % of total energy by using solar power generation. At a time, when India and the entire world is invoking use of renewable energy utilization, the recent projects are still adopting the same age-old technology, irrespective of their brand values. Though, the report sourced from the MoEF&CC site, does not provide all enclosures such as air pollution dispersion model and a detailed environment management plan – it is evident that installation of DG sets and raising height up to a level required by the Central Pollution Control Board (CPCB) above the 20th floor of the buildings, there will be incremental air pollution. Some reports have declared Gurgaon as the worst polluted city and according to the MoEF&CC’s reply to a Lok Sbha question – Gurgaon is amongst worst 10 polluting cities. In such a juncture, why is it necessary to allow running of DG Sets and not finding a viable alternative solution?
The report also does not provide adequate details of management of hazardous wastes such as disposal of empty paint and thinner drums. Under the paragraph 184.108.40.206.2 titled Hazardous waste management it is mentioned as “All hazardous wastes are required to be treated and disposed off in the prescribed manner.” It does not specify how the project will practice. Below it, under Table 3-13: Hazardous & E-Waste Management it only specifies that used oil (category 5.1) will be the only hazardous waste to be generated. Nevertheless, there could be sources of other hazardous wastes such as, those may fall under category 5.2 of the prevailing hazardous waste management rules and many others as per amendments in E-Waste and hazardous waste rules. As the EC, often reads, to practice EMP with letter of spirit, without detailed management procedure in the approved EIA/EMP report – the projects may end up with remaining non-compliers. Therefore, it seems to be reviewed by the appropriate authorities for a detailed deliberation.
Although, not of much significance, but desired under the EIA Notifications and part information provided under the heading of Environmental Sensitivity – the report has not considered many other establishments such as hospitals, places of worship, post office, schools and banks. This gives an impression that the report has not provided complete information and data. Views from Expert in the domain are welcome, as the objective is to leap forward to progressive society with enormous value for environmental professionals.
This article is also published in the 23rd issue of environmental weekly, Enviro Annotations on 1st May 2019
By Leena Patidar
(The writer is a freelancer in the field of Education, Environment and a strong believer of life-long learning) Published in Editorial Column of 25th Issue of Enviro Annotations on 15th May 2019
It was an unusual sight at polling booths across Delhi and the National Capital Region (NCR) on 12th May 2019, the polling day. No banners, no posters, no handouts & no loudspeakers.
While elections and mode of election campaigning has changed with time, there has been a visible difference in making elections more friendly to the environment.
Since the first prototype of Electronic Voting Machines (EVMs) was demonstrated by Bharat Electronics Limited (BHEL) in 1977, EVMs have slowly replaced paper ballots and have become norms for conducting polling despite various questions raised by political parties from time to time.
According to some estimates, 7000-8000 tonnes of paper was required to print ballots if elections were using paper ballots, which meant felling of nearly 1.2 lakh fully grown trees. This is in addition to the other impacts on the environment due to transportation, storage, and disposal of such a large number of paper ballots.
Activists, Non-Governmental Organizations (NGOs), Judiciary, Election Commission, Press, and Media have made sustained efforts to reduce the use of single-use plastic and also lessen the use of loudspeakers in 2019 General Elections.
Use of plastic and other non-bio-degradable material in campaigning was another concern. The World Wide Fund for Nature-India, in a letter to the EC in 1999, had stated that it was “very perturbed over the excessive and non-sensible use of plastic by political parties”, which not only caused “choking of drainage systems in major towns and cities” but also contaminated agricultural fields.
The Election Commission had asked all political parties and contesting candidates to desist from using environmentally hazardous material like plastics in banners, hoardings, cut-outs and other poll-related articles during upcoming general elections.
Election Commission and Haritha Keralam Mission jointly came out with rules to observe green protocol during elections in Kerala.
Punjab and Haryana High Court has also taken a serious note of the impact of usage of PVC flex boards and other harmful material being used by the candidates during the elections based on Public Interest Litigation (PIL) filed by activist Rohit Sabharwal.
Gone are the days when loudspeakers of candidates ran through the streets disturbing people all through the day. Now, it seems that elections have become quite noiseless. Use of sound limiters to reduce the decibel level of loudspeakers and restricting hours of use of loudspeakers have helped bring down the decibel level of election campaigns. The National Green Tribunal (NGT) in its order categorically said that poll campaigns are not exempt from its order of using sound-limiter.
While technology such as the Internet and mobile phones have helped change the mode of the campaign to personalize and focus the campaigning using the technology, evolving election protocol, increasing awareness and activism have also helped to make elections eco-friendly.
Sanjaya Kumar Mishra
The sustainability report cites Chairmen message that reads, “We are pleased to share with you 16th Corporate Sustainability Report prepared in accordance with the GRI Standards ‘Comprehensive’ option. This year we have tried to present how we have imbibed the principles of ‘Creating Value Sustainably’ which are reflected in our regular business actions. We drive to create and share lasting value to our stakeholders, which is integral to our long-term business success. The confidence entrusted upon us by our stakeholders: investors, customers, employees, community and others have made us what we are today and we have tried to meet their expectations sustainably in the past 40 years of our existence. We invite you to learn more about our initiatives towards creating value for our stakeholders in this report”.
In the sustainability report Jubilant Life Sciences has declared “Climate change and its impact on the planet is very evident and is a global phenomenon. Our company is no exception to this. Jubilant understand the damage potential this can bring to our business. Management is continuously gauging the changes in global, regional and national level policies and regulations on climate change and its mitigation. To be a partner to this global drive for climate action the Company is striving to reduce its carbon footprint in all possible means. Growing cost of energy and its linkage with climate change impact is a major business concern at Jubilant like any other industry. To tackle this issue, Jubilant has decided to focus on improving process energy efficiency, find alternate sources of uninterrupted low cost energy and increasing the percentage of renewable energy in present energy mix.”
Under the key highlights of the report it is mentioned that the revenue in the financial year 2017-18 grew by 26% and the figure reached Rs. 75578.1 million as against Rs. 60063.3 million during 2016-17. The company has approved investment of Rs. 822.5 million towards environmental Pollution Control and Management. Alongside, 37 million was spent on CSR initiatives. However, the report says that all Corporate Social Responsibility (CSR) programs of JLL are taken care by Jubilant Bhartia Foundation (JBF) which is a “not-for-profit” organization established in 2007 by Jubilant Bhartia Group. In the CSR Performance Improvement Trend Assessed by EcoVadis the score for the element environment has remained same at 60% for last three years that is from 2015 to 2018, despite the company has approved capital expenditure projects worth more than Rs. 822.5 million for environmental pollution control and management measures in Indian operation. The element sustainable procurement improved from 40% to 50%.
Another information shared in the sustainability report is that Walkathon event raised over Rs. 2.1 million funds through collective effort of over 1600 individuals. This stands unclear as the industry or corporate ought to spend towards community development, while here the company has gathered funds, and here is no data on where and how it was spent.
Furthermore, the report declares that 25% increase in recycle and reuse of water. But the data is limited to Life Sciences Ingredients (LSI) unit only and does not talk about other units. The company has claimed that 913 million saved through resource saving projects estimated saving of 224 TJ equivalent of energy and reduction of 21326 MT of CO2 equivalent. As compared to 2016-17, 8% reduction in Specific Energy Consumption for Solid Dosage Formulations business. The total direct energy consumption from Renewable energy is merely 3.74%.
Overall 10% increase in fly ash utilization, when there was an increase in consumption of coal has increased by over 7.2% from 401339 MT to 430371 MT. Also, the generation, reuse, and disposal data reflect that there is still a storage of some 6000MT of flyash. The company must have chalked out strategy to handle this, although it was not mentioned in the report. The company has declared that the specific GHG emissions reduction was 13% in APIs Business, and 5% in Solid Dosage Formulation (SDF) business. Total GHG emissions stood at 959000 Ton of CO2 equivalent, which is nearly 12.56% up as compared to the previous fiscal. As per the report, use of Furnace Oil, which is reckoned as a high level of pollution-generating fuel, has increased from 5081 MT to 7882 MT.
According to the report co-processing of hazardous waste improved in Indian operations to 4935 MT in FY 2018 from 1355 MT in FY 2017.
The report states that Compliance with respect to various statutes, rules and regulations applicable to the Company is managed by the Secretarial Department. Status of compliance is governed through an intranet based application- Statutory Compliance Reporting System (SCRS). Respective control owners certify their compliances on a quarterly basis and a compliance report is prepared through SCRS. The objective of the SCRS certification is to ensure that the compliances are effectively managed and controlled supporting the Company’s business objectives and corporate policy requirements. Under the heading “Principle for Defining Report Content and Context” it is stated that the Company focuses on data accuracy, balance, clarity, comparability, reliability and timeliness. To ensure such report quality, the company undergoes several internal audits along with dedicated sustainability assurance audit by independent third party every year.
In order to track timely closure of environmental issues ‘Jagriti’- an in-house developed software has been deployed for tracking environmental related observations and analysis. This helps us to identify and implement preventive measures. But it doesn’t share any confirmation regarding installation of the Online Continuous Emission Monitoring Systems (OCEMS), a real-time air and water pollution monitoring system, which is legally required to be installed as per the Central Pollution Control Board (CPCB) letter dated 05.02.2014. This is a major compliance required to be attained as the industry falls in one of the 17 categories of highly polluting industrial sectors.
According to the report, the company does not manufacture products containing Ozone Depleting Substances (ODS). All banned ODS have been phased out as per applicable regulations of the land. At Jubilant, emission of ODS is primarily from ODS based refrigerants in air-conditioners and chilling plants. During 2017-18 total ODS emission was 174 kg CFC 11 equivalent against 114 kg CFC 11 equivalent in FY 2016-17.
The report also states “To the best of our knowledge no material impact envisaged in the water sources due to withdrawal of water by the Company”. But the claim needs to be substantiated with data and information. The report informs that the group has implemented 5 new rain water harvesting facilities this year to recharge groundwater. However, it doesn’t specify the quantity or volume. Around 60 village ponds adopted as an initiative to recharge large scale potential to recharge the groundwater table by about 3 million cubic meter per year. However, whether this act is linked to the requirements of Central Ground Water Authority (CGWA) or a pure CSR initiative, is not mentioned clearly, if the company’s facilities have obtained approvals groundwater abstraction with due permission from CGWA .
Analysis of the report raises another question, why the combined quantum of effluent has significantly increased, despite less water consumption. Furthermore, when air pollution has been a major point discussion, the report has given no reference to ambient air quality in the vicinity of industry premises, although it is generating and having storage of a huge quantity of flyash, and other gases. The sustainability report should share the data of PM2.5, PM10 and H2S gas.
Under the heading of compliance – it doesn’t cite the name of the Ministry of Environment, Forest and Climate Change (MoEF&CC) and none of its compliance reporting. It is understood that the industry must have sought environmental clearance from the MoEF&CC, which requires submission of six-monthly compliance reports, regularly. Such reports should also be displayed on the websites. It was also found that the sustainability report of Jubilant Life Sciences Limited has not stated the name Press or Media in the list of stakeholder groups or anywhere.
Jubilant Life Sciences Limited is an integrated global pharmaceutical and life sciences company engaged in Pharmaceuticals, Life Science Ingredients and Other businesses including Drug Discovery Solutions and India Branded Pharmaceuticals. The Company claims as being well recognized as a ‘Partner of Choice’ by leading pharmaceuticals and life sciences companies globally. Jubilant Life Sciences Limited (JLL) has been publishing its sustainability report since 2003 following GRI guidelines and its principles. An effort was made to review the company’s sustainability report for the period 2017-18.
Sanjaya Kumar Mishra
The Central Ground Water Authority (CGWA) was constituted under Section 3 (3) of the Environment (Protection) Act, 1986 to regulate and control development and management of ground water resources in the country. It works under the Ministry of Water Resources, River Development & Ganga Rejuvenation, However, the Central Ground Water Board (CGWB), another subordinate office of the Ministry, is the National Apex Agency entrusted with the responsibilities of providing scientific inputs for management, exploration, monitoring, assessment, augmentation and regulation of ground water resources of the country. Central Ground Water Board was established in 1970 by renaming the Exploratory Tube wells Organization under the Ministry of Agriculture, Government of India. It was merged with the Ground Water Wing of the Geological Survey of India during 1972.
Nearly two decades back, the CGWA formulated a policy to register existing bore wells. In the national level, the registration process was not a major success. Need of obtaining prior approval or no objection certificate (NOC) has been stressed upon for almost the last two decades. This condition could be found in various environmental clearances issued by the erstwhile Ministry of Environment and Forests. A number of Orders from legal institutions like National Green Tribunal (NGT) for the last couple years have also failed to generate that degree of response in favour of CGWA.
Obtaining No Objection Certificate (NOC ) or approval from Central Ground Water Authority is legally mandatory to abstract water from underground source.
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