Review of EIA Report and Environmental Clearance

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 Environmental Clearance

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. 

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 


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