A Plumbing Consultants Role in MoEFMy 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 committees 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 Activity8 8(a) Type of Project Building and Construction Projects

Category with Threshold Limit Conditions, if anyCategory A Category B 20000 sq.m and < *Built-up area for covered 150000 sq.m of built- construction; in the case of facilities open to sky, it up area*will be the activity area.

Townships and Area 8(b) Development Projects

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.ProponentFeasibility study or Project Proposal

Process duration 30 days

Secretary, Env. Impact Assessment Authority (SEIAA) Meeting with SEAC once in every month

Screening(identify Project Category)

Category A

Category B

Process duration 30 days

B1

B2 Building & Construction Technical review by Member Secretary (SEIAA)

Township and Area Development Project

Projects / Activity for Expansion & or changing product mix of existing project or activity

Technical Committee (Decision Making SEAC)

Process duration 5 days

Meeting with SEIAA for Approval of Project

Approved Issue EC(Valid for 5 years)

Not Approved

Project Implementation

Rejection letter with reason for the same

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 MoEFs 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 wont 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. Theres 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 1,044 KLD

Recycled Water 622 KLD

Landscaping 87 KLD

Flushing 535 KLD

1263 KLD

STP 1300 KLD 514 KLD

Domestic 1,044 KLDMonsoon (84 days)

Dry Season

20-Acre HorticultureDry Season

Holding Pond 42,870 Cu.M

FarmsDry Season 14 KLD or 3850 KL/yr

142 KLD or 39,050 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, contours, and rainwater harvesting. design,

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