My Experience with Three Landmark Reports on Waste Management with UNEP

Why this post?

The subject of waste management is rapidly evolving. National policies and regulations are getting redrafted, strengthened and expanded. Indeed, implementation continues to be the challenge but the interest from the community, entrepreneurs and investors is growing. The term waste is now closely linked to resources and innovation is now recognized as a product of this “union”. Achieving circularity in the material and energy flows using these innovations is imperative towards this planets sustainability. 

In the last decade, I was fortunate to work on three interesting reports brought out by the United Nations Environment Program (UNEP).  This post recounts these reports, describes their genesis and shares some of the findings. Though targeted to policy makers, these reports serve as a great resource to students, research workers and young practioners who are looking forward to making careers in the new era or avatara of waste management.

The Waste Chapter – UNEP Green Economy Project

The financial crisis of 2007–2008, also known as the global financial is considered by many economists as the worst financial crisis since the Great Depression of the 1930s. The housing market suffered, resulting in evictions, foreclosures, and prolonged unemployment. In particular, as businesses cut production in response to lower aggregate demand, workers were shed in large numbers, sharply increasing unemployment worldwide. This was a time of great depression.

As a consequence, between 2007 and the end of 2009, there was an unprecedented increase in the number of unemployed. Beyond job losses, the quality of employment also deteriorated. Across the globe, many workers who did not lose their jobs were forced to accept reduced working hours as well as lower wages and benefits. In developing countries, a large number of workers lost their jobs in export sectors and were forced into informal and vulnerable employment elsewhere. The situation was further aggravated by austerity measures in most developed economies. The great recession had thus created a global jobs crisis.

It was in the background, UNEP launched the Green Economy project in 2008.  Achim Steiner, then UNEP Executive Director played a crucial role on pushing the Green economy project. The Green economy project was coordinated by UNEP’s office in Geneva.  Do watch Achim in the video below.

The idea of the Green Economy project was to demonstrate that the greening of economies is not generally a drag on growth but rather a new engine of growth.

Green economy was defined as one that results in improved human well-being and social equity, while significantly reducing environmental risks and ecological scarcities. In its simplest expression, a green economy was thought of one which is low carbon, resource efficient and socially inclusive. UNEP’s definition of a green economy was influential in the build up to Rio+20.

The report was prepared in three Parts. Part I focused on investing in natural capital and had chapters on Agriculture, Fisheries, Water, Forests. Part II delved in Investing in Energy and Resource Efficiency,  Renewable Energy, Manufacturing, Waste, Buildings, Transport,  Tourism and Cities. Parts I and II thus illustrated how greening could be mainstreamed towards economic, environmental and social advantage.

Part III addressed supporting the transition to a global green economy with chapters on Modelling, Enabling Conditions and Finance. Modelling was carried out by the Millennium Institute (MI) from the United States. MI used Threshold 21 (T21) model that was developed after more than 20 years of research and application. The Chapters of Parts I and II provided inputs to T21 and results of T21 were in turn interpreted in the respective Chapters.

Armed with T21, the Green Economy report argued that Green investments will open up and enhance new sectors and technologies that will be the main sources of economic development and growth of the future. Sectors of potential included renewable energy technologies, resource and energy efficient buildings and equipment, low-carbon public transport systems, infrastructure for fuel efficient and clean energy vehicles, and waste management and recycling facilities. Greening was thus mainstreamed in the global economies as an engine of growth to revive the economy after the meltdown.

My company Environmental Management Centre LLP was contracted by UNEP to build the chapter on Waste. I was the Principal Author. We had benefit of five contributing authors representing various regions of the world and with extensive and varied experience in the waste sector. There were peer reviewers appointed as well and a global consultation was performed on the drafts we produced. I remember my colleague Swati Arunprasad had a harrowing time to compile and respond to some 400+ comments/inputs that we received! The Chapter was built over 8 months of painstaking work. I enjoyed interacting with the MI Team when it came to building scenarios or make predictions.

The tone of the Chapter was more on the economics of waste management. The global waste market, from collection to recycling, was estimated at US$ 410 billion a year, not including the sizable informal segment in developing countries. Recycling sector was considered as the main job-provider and attracting investments. The chapter recommended that we establish a global circular economy in which material use and waste generation is minimized, and any unavoidable waste is recycled or remanufactured.  Only remaining waste should be treated in a manner least harmful to the environment and human health, and in a way, that generates new value such as energy recovered from waste. The circularity concept was thus positioned. However, we did not emphasize enough on the aspects of reduce, refurbish, re-manufacture. Probably we had less data, only scant case studies and less experience to make a strong economic, environmental and social case. Unfortunately, this weakness continues even today.

Global Waste Management Outlook (GWMO)

Presentation of the Green Economy report and especially the Waste chapter, led to The UNEP Governing Council decision GC 27/12: ‘develop a global outlook of challenges, trends and policies in relation to waste prevention, minimization and management […] to provide guidance for national policy planning’.  In response to this decision, UNEP International Environment Technology Centre (IETC) in Osaka was asked to prepare Global Waste Management Outlook (GWMO). International Solid Waste Association (ISWA) joined as the partner.

The GWMO chose to focus primarily on the ‘governance’ issues– including the regulatory and other policy instruments, the partnerships and, crucially, the financing arrangements. Relatively less emphasis was given on the technology. The GWMO was result of two years’ work (by UNEP and ISWA) between 2014-2016 and provided an important and timely status report and call for action to the international community.

David Wilson from the UK was appointed as the Chief Editor of GWMO and I was taken on board as one of the four contributing authors. I had just completed then a Strategic Action Plan for Waste to Resource Management for UNEP. In the situation analyses of the Action Plan, I reviewed some 300 projects and programs of the UN across the world in the arena of waste management and assessed their effectiveness vis-e-vis investments made. This Action Plan was not published – perhaps outcome of this assessment was rather dismal!

During the work on GWMO, team at EMC LLP took the task of developing a “database” on waste generation, waste collection and processing infrastructure across the world. Apart from the waste related data, key “meta data” was also compiled on economic and social parameters. This was quite some sweat, requiring validation as the numbers were often conflicting and my colleagues Shreya Bhatia, Vishwa Trivedi, Tausif Farookhi and Anuja Sarangdhar helped me immensely. This database, now a bit dated, was put in Tableau platform for rapid processing and visualization. I wish I could update this work now. I am looking for researchers/interns to take this up.  Interested?

The GWMO stressed on costs of inaction – the public health and environmental damage costs of uncontrolled disposal and open burning – and cautioned that these costs far exceed the costs of sound waste management. We were hoping that this argument would influence the politicians to allocate more budget for management of waste. Pity that we did not have very many “convincing” case studies.

The GWMO noted that while developed countries have made good progress in increasing recycling rates and stabilizing waste growth –there was still much to be done across the world in making the transition from ‘end-of-pipe’ waste biased linear economy, to a circular economy.  So once again, the need for circularity in material/energy flows in waste management was emphasized.

The report corroborated with findings of the Green Economy report and recommended a steep increase in the level of funding on waste management sector. It came up with targets to consider such as  – achieving 100% collection coverage in all cities with a population more than 1 million. Integrated strategies to simultaneously address sanitation and solid waste management services were emphasized. GWMO urged that producer responsibility programmes should be promoted and monitored to ensure that international companies take more responsibility for waste management associated with their products and wastes in developing countries.  We realized that we were working on inconsistent and incomplete numbers and were many times apologetic. Poor data  was also the experience of one of the well-known reports of the World Bank called “What a Waste?”.  So, a plea was made to improve the availability and reliability of waste and resource related data.

Asia Waste Management Outlook (AWMO)

The success and experience of GWMO and to respond to requests from countries, UNEP IETC  considered building Regional Waste Management Outlooks. Accordingly, a project on preparation of Asia Waste Management Outlook (AWMO) was launched in partnership with ISWA. I was appointed as the Chief Editor with contributions from three other authors. UNEPs Regional Resource Center at Asian Institute of Technology (AIT) did the coordination and final production. My students Asha Panwar and Malavika Gopinath from IIT Bombay assisted me.

By then I had realized that the Outlooks and associated reports were getting rather rhetoric. Lot was said before and many a times more. More focused and strategic recommendations were needed. In AWMO, we therefore stressed the importance of developing and promoting Green products and introducing Green Public Procurement as recycling was dominating the understanding of circularity. Since informal waste pickers play a major role in waste management in Asia, sorting centres and materials recovery facilities were recommended providing a safe environment for waste pickers to work. Segregation was stressed as something vital for circularity.

We also realized that the secondary materials industry in Asia is growing rapidly. This sector needed to be factored in the national economies as done in countries like Japan, Korea, Taiwan and China. The growth of this industry was important because it provides an alternative to the use of virgin materials, thereby improving resource security and reducing GHG emissions.

To build more consistent data, standardization of definitions of waste streams and waste-related terminologies was recommended while generating inventories, tracking progress and making comparisons. Today, each country “defines” waste differently.

Studies on “costs of inaction” on health, environmental and social impacts of indiscriminate waste disposal were found to be rather scant. In this context, remediation of contaminated dumpsites was suggested as a priority intervention by the national governments. Further, necessity of preparing strategic action plans to address upcoming and challenging waste streams, such as marine litter, mining and disaster waste was also emphasized.

The AWMO, amongst its several recommendations, made following four key suggestions for strategic action

  • Test the effectiveness of economic instruments for effective and sustainable waste management. We realized that Asia lacks this experience.
  • Develop a referral framework assessment of policy equivalence, implementation and tracking of progress to guide national governments. The idea was to attempt a regional harmonization on waste and resource related governance. Material flows that dominate movement of waste and resources through trade are dominating today and are getting skewed due to differentials in pricing and governance.
  • Emphasize holistic or zero waste management addressing waste in all three media (solid, liquid and air). This suggestion came from Surendra Shrestha, then Director of UNEP IETC. Indeed, a needed expansion of the “mandate”, but rather ambitious and difficult to achieve. Needs piloting.
  • Consider development of an Asian Directive on Circular Economy to guide the national governments. I thought this was an important intervention to consider.

The Outlooks are expected to get updated every two to three years. I do hope I get an opportunity to work on the next updates. The experience has been inspirational, enjoyable and with a lot of learning.

Access the Green Economy reports here. Follow link here to access the Outlooks.


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Are We Future Ready? The 4Cs of Sustainability

Sustainability today is no more a concept. It is a framework that provides direction to the Governance and influences the business strategy.

The need for sustainable development is no longer debated, what is argued, however, is how this should be achieved.

In India, we do see an awakening and evidence of the paradigm shift towards sustainability. It is important however that we understand this progression, identify the barriers and come up with strategies to overcome them.

The Bombay Chamber of Commerce and Industries (BCCI) and my organization Environmental Management Centre LLP (EMC) came up with a project to understand the “pulse” on Sustainability by connecting with some of the top leaders in the Indian business.

Interviews were conducted of Chief Sustainability Officers and their Teams representing 20 leading Corporates in India. Objectives of the Survey were

  • To assess the understanding of the concept of ‘sustainability’ in businesses
  • To understand to what extent Sustainability is mainstreamed into the business processes
  • To learn about the Sustainability initiatives being undertaken and share best practices
  • To understand the driving forces and future trends

I am presenting below some of the key findings of this survey. The full report  ‘Business & Sustainability’ Survey 2017′ can be downloaded at BCCI’s website

Sustainability means different things to different people. Common phrases used to define sustainability included responsible growth, value-add through sustainability, conserving natural resources through inclusive growth, produce more with less, “profit, people and planet”. Not commonly used phrases include “less problems and more solutions”, “making sustainable living commonplace”, “sustainability means relationships” and lastly, “sustainability means newly articulated but ancient wisdom”

Top focus areas majority of the organizations studied were Energy, Water and Green House Gas (GHG) Emissions. Many have implemented renewable energy solutions to reduce their dependency on conventional or fossil fuel based sources of energy. All organizations surveyed mentioned initiatives on recycling of waste water. Being a common good, organizations have embarked on community engagement and taken initiatives to conserve and share this valuable and increasingly scarce resource.

All organizations are going beyond compliance and have taken initiatives to ensure that resources are used cautiously and more efficiently. Next or in many cases equal priority has been environmental management, health and safety (EHS). This is because risks of non-compliance on EHS are high. For some, sustainability program has evolved from the solid foundation built on EHS systems and processes.

We found that only few organizations have begun looking at Sustainability across their supply chains. There are few leaders who have put in place policies and requirements to bring up the standards of their vendors and suppliers. Organizations however recognize that it is a risk to ignore the supply chain since any slip up on this front will mar the company image and hurt the brand. As a result, these companies are renaming departments to include supply chain management, setting up procurement conditions asking for management systems (like ISO 14001 and OHSAS 18001) and forming supplier forums to support smaller companies. These requirements and facilitation is expected to raise the bar and help to monitor risks as well as improvements. Some organizations have stipulated business codes of conduct on infringement of laws like child labor and human rights and have developed guidelines which the vendors are required to sign and adhere to.

We expected that Innovation would be everywhere among the organizations we spoke with. Businesses believe that innovation promises to reduce dependence as well as improve productivity and providing new market opportunities. Many suggested that Innovation and Sustainability are closely linked. Leading organizations are teaming up with academia and investing in research, startups and such efforts, to develop new technologies. A sizable amount of investment is spent on R&D for such innovation which is expected to save money as well as lessen the adverse impact on society and environment. Some organizations are highlighting such innovations on the canvas of their corporate philosophy on Sustainability. However, resources for upscaling the innovation are not always available. There is also a low appetite from stakeholders –less encouragement from the Government, not enough of a push from the consumer and low interest from employees.

Largely the focus of all CSR activity is aimed at the benefit of the community. Most initiatives are in the areas of Education, Health & Sanitation, Skill Development and creation of Livelihoods. In line with the organization’s business, some offer to support the community with their needs for example a cement manufacturing company provides low cost housing to the community. Areas for implementing CSR projects are usually around the location of the organization’s projects or manufacturing facilities and units. Community transformation is the main objective of all CSR initiatives. Often the employees of the organization are roped in through volunteering programs to provide community service in the form of teaching, managing health programs and making donations. We found that sometimes compliances to CSR forms part of the KPI for the Managing Director of the business. CSR expenditures often exceed the 2% PAT requirement as per the companies act. Many businesses have been offering community support services even before the mandate and continue to do so without the pressure of the requirement. Large organizations find their CSR directives being derived out of the vision and mission of the Group as a whole. Of course, all business do not fail to take advantage of any opportunities that come up by way of doing CSR. It’s almost standard practice to do so.

Employee engagement and training of employees is believed to be an essential step in the organization’s roadmap to achieving targets, increasing shareholder value and growing the bottom-line. Raising awareness of the human resource on Sustainability and ensuring their meaningful engagement with the associated initiatives is critical. The general feeling is that the business will not be able to conduct sustainability initiatives without the involvement, constant support and understanding of its employees.

Businesses always look for Compliance, Competitiveness, Continuity and Collaboration i.e. the 4Cs. These 4Cs pave the path towards Sustainability.

No organization wishes to downscale or shut down operations. Business honchos lead with best practices while Governments keep pace with regulations and imperatives. Governments also encourage businesses to take up targets that are aligned to national targets on global issues of climate change. With the conversation around sustainability reaching a stage where actions speak louder than words, more and more organizations wish to demonstrate their commitment to the public and the world including their stakeholders.

There are many pressures other than social and environmental perspectives. Maintaining a balance is a huge challenge. How does a business ensure that they continue to operate when the business does not perform well financially? Here is where many resort to innovation in doing business. Sustainability is often the unintended result of this effort rather than the goal. This goal is to be financially viable. So it is ‘Smart Sustainability’ that the business is looking for.

For many, running the business within the constraints of externalities such as globalization, resource constraints and political stability was itself a challenge. Given these complexities, the process of communicating, convincing and committing to Sustainability has become a daunting task.

We therefore still need more evidence to prove that Sustainability is not just ethos or a responsibility but that it is material and can be monetized. This realization will send ripples across the supply chains influencing small and medium enterprises.

Certainly, the doctrine on Sustainability is not going to be limited to large corporates and multinationals. We will also see many organizations investing in Sustainability to spur innovation – there will be an increase in innovative technologies and materials which will improve products and processes. Employees will hold greater value for management who will invest more in aligning them to their organization’s sustainability goals. The Human Resource Managers may position sustainability related awareness and training as a Primer or core of Induction Program.

Sustainability is now seen as an opportunity – to cut costs, to increase revenue, to innovate, to look good and to stand apart. Sustainability will be the business strategy to be Future Ready. And here, the 4Cs of Sustainability will guide.


You may like to watch following short videos

 

 


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Resources, Residues and Circular Economy

Sustainability of this planet depends heavily on the availability of resources.

Resources are under threat today due to severe depletion and degradation.

Depletion has been on a steep rise due to increasing population, urbanization and consumption. Degradation has been a result of reckless disposal of residues.

Strangely and oddly enough, the national governments, particularly the Ministries of Environment, have focused more on the management of residues rather than management of the resources. Legislation was evolved to set limits on the residues that will have to be met prior to disposal but not much attention was given on the limits of extraction of resources and resource pricing. The latter was more of a political issue.

Limits on residues became stricter over the years as our understanding of the adverse impacts and risks to the environment improved. We realized that residues when not properly disposed could lead to considerable damage to the humans and the ecosystems. There were severe economic implications both on damage and restoration. Many of the impacts were found to be long term and irreversible and further compounded with risks that were not easy to anticipate.

Most national governments followed a precautionary approach following “do no harm principle” in setting the limits. Over the years, advances were made in the monitoring of pollutants in the residues and the technologies were developed that could be economically used for treatment. These advances made tightening of the limits on residues possible.

Having framed the legislation and limits or standards on the residues, the national governments established institutions for monitoring and enforcement. Procedures and practices of documentation were laid down. Most legislations began with addressing wastewater but soon air emissions, solid and hazardous wastes were included. In the last two decades, specific residues such as municipal solid wastes, construction and demolition wastes, plastic waste, electronic (e) waste were also addressed by setting limits and requirements for safe disposal. Consequently, the investments on the end of pipe management of residues increased.

Unfortunately, since the institutions made responsible for monitoring and enforcement were weak, compliance to the standards or limits was not satisfactorily achieved. The resources continued to be degraded.

The polluters realized that to reduce cost of the end of pipe treatment and remain competitive, efforts were required to reduce generation of residues at the source. Concepts such as waste minimization and pollution prevention therefore emerged and the polluters did every effort to reduce residue generation by deploying better housekeeping and practicing reuse, recycling, recovery to the extent possible. This required a behavioral change, application of management systems, use of productivity improvement tools and adoption to modern technologies. The investments for management of residues essentially moved upstream leading to “ecological modernization”.  Unlike end of pipe investments, the “upstream” investments had a payback or economic returns.Strategies such as Cleaner Production, Green Productivity and Eco-efficiency emerged. These strategies showed a link between resources (in specific the resource use efficiency) and the residues that could be converted as a resource.

Gradually, importance of product design was understood that connected resources and residues.  Our understanding of Life Cycle impacts of the products made us realize that we must think of both resources and residues at every stage of life cycle i.e. extraction, transportation, processing, packaging, distribution, use, disposal.   The two R’s (viz. Resources and Residues) were thus integrated with the opportunities of 3R (Reduce, Reuse and Recycle)

Over a period of time, the legislation on residues expanded and became more comprehensive. Figure below shows an illustration of evolution of limits, expectations and requirements for the pulp and paper sector.

Clearly, enforcement of such limits could not be done solely by the Government. It required a partnership approach where the markets (consumers, retailers) and investors were also involved. An enunciation of an umbrella policy and coordination between ministries was also necessary. The new paradigm of governance addressed both resources and residues, across the life cycle and in partnership with G-B-FI-C (Government, Business, Financing Institutions and Communities)

In India, importance of green products is not understood even today.  We are still far lagging on the strategy of eco or sustainable product design and green public procurement. Our eco-labelling program “Eco-mark” failed long ago, with no efforts made for revival. There are only handful schools in India who teach sustainable product design today. There isn’t much “market demand” either.

You can assess the “maturity of the environmental governance” of a country based on how the limits are set and are operated considering both resources and residues and how key stakeholders are involved. I would rate India at level of 4 if there was a maturity scale between 0 to 10.

As earlier said, the Indian environmental governance is still biased to the management of residues. But remember that even on the residues we have not looked into risks on disposal from ecological perspective. Although the name of Ministry is now Ministry of Environment & Forests & Climate Change, we have not paid attention to the  risks posed on our resource security due to climate change. Our approach is still conventional and dated.

Resource management in India is in the purview of line ministries e.g. water, energy, agriculture. There is a poor coordination between the Ministries in visualizing a “systems” perspective where resources and residues are integrated. Years ago, New Zeeland enacted Resource Management Act (RMA). The RMA has not been a smooth ride but there are interesting lessons that could be learnt.

The recently promulgated concept of Circular Economy added additional 3Rs namely- Repair, Refurbish and Remanufacture.   These 3Rs introduced three significant components viz. social (employment), investment and innovation. Once material flows become circular, compliance becomes of interest to every stakeholder. 

China legislated Circular Economy Law as early as in 2007 focusing on industrial estates.  Japan promoted this concept at Eco-Towns. European Union came up with country specific targets, indicators and reporting requirements on Circular Economy.

India is estimated to become the fourth largest economy in the world in about two decades. This economic growth is however going to come with challenges such as urbanization with increased vulnerability (especially due to climate change), poor resource quality and scarcity and high level of unevenness in the socio-economic matrix due to acute poverty. India, if it makes the right and systemic choices, has a potential to move towards positive, regenerative, and value-creating development. Its young population, growing use of IT, increasing emphasis on social and financial inclusion as well as the emerging manufacturing sector can make this happen. For this, the conventional linear ‘take, make, dispose’ model of growth must change and an enabling policy framework at the national and sectoral level needs to be evolved. Developing a national policy framework on Circular Economy therefore makes sense.

The recent report by the Ellen MacArthur Foundation on India shows that a circular economy path to development could bring India annual benefits of ₹40 lakh crores (US$ 624 billion) in 2050 compared with the current development path – a benefit equivalent to 30% of India’s current GDP. Following a circular economy path would also reduce negative externalities. For example, Greenhouse Gas emissions (GHGs) would be 44% lower in 2050 compared to the current development path, and other externalities like congestion and pollution would fall significantly, providing health and economic benefits to Indian citizens. This conclusion was drawn based on high-level economic analysis of three focus areas viz. cities and construction, food and agriculture, and mobility and vehicle manufacturing.

The Ministry of Environment and Forests and Climate Change (MoEFCC) of Government of India set up the India Resource Panel (InRP) in 2016 to examine the material and energy flows across key sectors following a life cycle approach and to assess resource efficiency. I am a member of InRP. Sectors such as Construction, Automobiles, Iron & Steel and Metals were considered and key cross-cutting areas were examined. Recommendations of InRP are now taken up by India’s Niti Ayog (Planning Commission chaired by the Prime Minister) and is expected to develop a national framework to foster and support India’s Circular Economy.

The Government of India has embarked on several iconic projects to improve and expand its infrastructure (transport, cities and energy) and undertake ecological modernization of important sectors such as water, agriculture and food. In these Mega projects, Foreign Direct Investment is encouraged and these investors are asking for good practices on Environmental and Social Governance (ESG) apart from conventional compliance. The 100 Smart Cities program, Make in India initiative, Swatch Bharat Abhiyan (Clean India), Namami Gange (Ganga River Action Plan), Interlinking of Rivers, Climate Resilient Agriculture etc. are a few examples. In all these projects, an application of the principles of the Circular Economy is extremely relevant and, more critically, leadership on the circular economy will need to be built in Cities, Industries, Investors, Project Developers and with Policy makers and Regulators.

Circular Economy is thus a concept that brings management and resources and residues together in the interest of economy, livelihoods and the environment. If implemented well then it will spur innovation and stimulate investments. The question is which institution in India will champion and how will we mainstream Circular Economy at national, state, city and industrial estate levels. Leadership in Circular Economy is going to be the key to bring in the necessary change.

We need to start walking the talk. But who will bell the cat?


Cover image sourced from http://www.guengl.eu/news/article/a-true-circular-economy-must-be-anchored-in-the-grassroots


I am developing an international leadership program on Circular Economy to be launched in 2018. Do write to me if you are interested to learn more or get involved 


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A Minimum Environmental Care Size for an Industry  

(click on the Figure to enlarge)

Industrial production is important to meet our needs and generate employment. To ensure that the industrial production is economically feasible, the industry must operate above a Minimum Efficient Scale (MES).

MES can be computed by equating average cost  with marginal cost . The rationale behind this is that if an industry were to produce a small number of units, its average cost per output would be high because the bulk of the costs would come from fixed costs. But if the industry produces more units, then the average cost incurred per unit will be lower as the fixed costs are spread over a larger number of units.In such a case, the marginal cost is below the average cost, pulling the latter down. An efficient scale of production is reached when the average cost is at its minimum and therefore the same as the marginal cost. If we exceed the MES, then the marginal costs may increase due to pressures on product distribution (logistics), additional labor oversight and need for tapping more resources that are not locally available.

I was reading on the concept of MES. I told my Professor Friend that Government of India should make a toolkit for all the entrepreneurs to guide on choosing the right MES for their business focusing on the priority manufacturing areas.

“Well, you have a point Dr Modak” said the Professor lighting his cigar. “ Perhaps we should train the lenders (bankers) and investors on this subject so that they do not finance industries that are way off from the MES. This could help reduce the Non Performing Assets (NPAs) as well – Professor winked.

Professor took a deep puff, walked to the window and turned back to me and asked “You mentioned about the Minimum Efficient Scale or MES, but do you think there could be a concept of Minimum Environmental Care Size (MECS) for the polluting industries? The MECS must accommodate the costs of environmental pollution control that have often no economic return”

I liked the term Minimum Environmental Care Size.

Professor continued

“Dr Modak, many industries don’t do well because they arrive at MES without considering or sometimes not adequately internalizing the costs that they must incur on environmental pollution control. When they approach the Pollution Control Board (PCB) for a consent, they are stipulated several conditions on permissible pollution discharge. Compliance to these conditions often upsets the overall profitability of their operations. Consequently, many industries receive closure orders from the PCBs and judiciary directives due to non-compliance. The case often gets a political overtone as a closure means loss of employment. So, the industry is “allowed” to operate while not in compliance and the environment continues to deteriorate”

I thought the Professor was right. Why should we let these industries to come up at less than MECS in the first place”? I thought of including Department of Industry and Department of Environment in Professors training program (By the way, have you ever seen these two departments talking to each other? – but thats another story)

Could MECS be generally be higher than a conventional MES?

Professor smiled when I asked this question. He walked to the white board in his room and drew Figure as below. The Figure was complex but self-explanatory.

(click on the Figure to enlarge)

“This is just one scenario” – Professor said. “There would a number of variations based on the context”

I noted the following points

  • Many times, industries that operate on the MES are unable to do an environmentally sound or responsible business. Perhaps scales higher than MES allow use of more resource minimal and efficient technologies. A minimum environmental care size or MECS may therefore be higher than a conventional MES.
  • At this scale, the costs/output would be lower and hence even if the costs of investments may be higher, the overall economic returns will be impressive.
  • Besides, the MECS will exhibit higher resilience to the volatility of the markets. (I thought this perspective is interesting and requires a good case study)

While agreeing to my observations, Professor further elaborated

“Dr Modak, apart from the economic objectives, we need to ensure that products we produce have least life cycle impacts and the waste streams we generate in the “overall system” (i.e. covering extraction, processing, transportation etc.) are reused, recycled and recovered (3Rs) to the extent possible. Only the residues that are left need to be treated and disposed in a secured manner. All these costs and benefits must be included in the computation of MECS. In all above, we need to ensure that resource are minimally extracted, used at high efficiency and the 3Rs are followed to the letter and spirit”

I said “Professor, Indeed both scale and technology will play a significant role in arriving at the MECS. Of course, there are other equally important variables such as the location (where resources are extracted and processed) and the demand on the products (especially the green products) from the market”

An analysis of the cost of production break down between a large forest based pulp mill in India with chemical recovery and an agrobased small mill without chemical recovery has shown that the chemical cost alone is 30% of the total cost of production against a figure of 21% for forest based mills. A decade ago, Indian machinery manufacturing companies have shown that, when the mills reach a level of 100 TPD Black liquor solids, it is viable to set up a chemical recovery plant. Today, this threshold could be lower.

Pulp mills of small sizes (20-30 TPD capacity) cannot afford a chemical recovery unit and they would continue to discharge harmful chemicals into the environment. As the society and the State cannot allow continuation of discharge of polluted effluent, either the industry will have to close down or find out alternative methods production to stop pollution or take production to higher scale. This is often not possible due to shortage of finance.

(Do read, though dated, a very interesting report on above)

When I cited this example on MECS and the challenge of financing, Professor got up and responded while extinguishing his Cigar.

“Dr Modak, in such cases, one may conceive a central or common chemical recovery for a number of pulp mills, where Black liquor of individual mills can be collected and processed in a Central Recovery Plant. The white cooking liquor produced in the Central Chemical recovery plant can be transported to the individual mills for their use. Again, the Central chemical recovery unit shall be of a capacity which is technically desirable and is viable financially.

In order to make this concept implementable, one must identify a cluster of pulp mills suitably located within an economic zone. The cluster can harbor at least 6-8 mills. The economic zone can be of a radius of 60-75 Km. The Centralized Recovery unit can either be an independent unit or an integrated unit with one of large mills in the cluster.

There are advantages and disadvantages of setting up an independent central recovery plant. A recovery plant, independent of the pulp mills, and non-integrated with any pulp mill, must have its own infrastructural facilities, such as water supply, steam and power supply, workshop and laboratory in addition to its own Management. The Management which would control the functioning of the central recovery, is independent of the pulp and paper mill operation. Its function is to procure black liquor free of cost from the mills and in return sell the white (cooking) liquor to them at the market price. It must generate its own steam and power required to run the various sections of the Recovery unit.  The extra power can be sold to the State Electricity grid system.

Professor walked back to the white board and drew a New Figure as below.

(click on the Figure to enlarge)

“Look at Points B and C carefully. The MECS with support of a common resource recovery center and a common end of pipe solution will be lower than the MECS for a larger industry. The Small and Medium Enterprises (SMEs) under a cooperative agreement can still do business sustainably on a smaller production scale. What you need is a proper industrial planning, right institutional set up and an interested technology provider/investor for a joint venture” He said

I could see potential of this concept for chrome recovery in tannery clusters, metal recovery in the cluster of electroplating industries and spent acid recovery in chemical industries. There will be several such examples I thought that we could use to develop guidelines for key polluting  SMEs.

“So Dr Modak, what we need is to deepen the concept of MECS and guide the industries, lenders & investors, PCBs, Industry and Environment departments. There is so much to do”

Professor left the room for a meeting

Indeed, we want to see more of Make in India but on a scale that will ensure environmentally and socially sound production – I decided to bring this topic to the attention of MoEFCC and Central PCB when next in Delhi. On a second thought, I thought that it should be the job of the Niti Ayog (India’s earlier Planning Commission). They are the Gurus and can bring in a change at national level.

Friends, whats your take?


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The Black Hole of Capacity Building at Pollution Control Boards in India

For several, especially the polluters, Pollution Control Board (PCB) is an important institution. PCBs grant or renew consents to pollute, demand and accept payments for the Cess and carry out monitoring to check the compliance. No wonder, the atmosphere at a PCB is sometimes like a Police Station. You are not sure about the justice!

The Member Secretary (MS) is the Chief Administrator of PCB while the Chairman gives strategic direction. Both MS and Chairman are difficult to meet, not just because they are extremely busy but because they often belong to the IFS/IAS category. Once you belong to this category, then you have to keep people waiting outside the room and say “no” after a long wait.

I have been however quite fortunate in working with the PCBs. My first interaction was with Mr. B V Rotkar, MS at the Maharashtra Pollution Control Board (MPCB) in 1978. I met him in his office at the Grant Road that was dimly lit. Later, in 1979, I met Dr Niloy Chaudhari, Chairman of Central Pollution Control Board (CPCB) at CPCB’s very first office at the Shahajahan road in New Delhi. That office was like a barrack. I made propositions to both Mr. Rotkar and Dr Chaudhari on modelling water quality for preparing rational river water quality management plans. They gave me patient hearing, showed interest and promised support (which they actually did). These were technical discussions that are rare today at the PCBs.

I became a retainer consultant to CPCB for 4 years from 1984 and started visiting Delhi every month for 3 to 4 days. The office was at Nehru Place with Roopa and Sona (shops selling samosa, paneer dishes and sweets) at the ground floor. I used to frequent there with my CPCB colleagues and bump into some of the activists from Centre for Science and Environment.

I did not have precise terms of reference for work so I used to be working with Dr Niloy Choudhari on a variety of areas. His vision, depth of the subject and way of conducting and summing up the meetings was phenomenal. I got groomed in this process. Oh, the Chairman of the PCB matters.

I was connected to almost all the key officers of CPCB. I used to stay at the Guest house of CPCB at Alaknanda housing complex across Chittaranjan Park. Those were really memorable days as after the day’s work, dinners used to be with colleagues at CPCB. Dr Sudhir and Usha Ghosh were the regular hosts (Usha was Statistical Offer then and was my key contact). I used to be with the Baruahs (who later moved to Vadodara regional office) and S P Chakraborty (who later became MS of CPCB) for dinners as well. We used to talk about the politics and the problems but building capacities of PCBs was always a central topic of discussions.

While at the Guesthouse, I used to be with other CPCB consultants like Prof Mukherjee of Center for Man and Environment from Kolkata and bump into some of the senior Regional Officers of CPCB such as Dr R N Bhattacharya (RNB). I remember I used to scare RNB by telling weird ghost stories at night and Prof Mukherji used to have a good laugh at my “stories”. Prof Mukherjee introduced me the importance of creating maps and the “infographics”. He created several maps for CPCB, especially for Ganga. Today, PCBs seldom make such maps. I strongly believe that map making builds capacities, improves understanding and builds teams.

Helmut Krist was one of the first GTZ consultants to CPCB. We gelled very well – along with Dr Sudhir and Usha Ghosh. I was keen that CPCB embarks the era of computerization. There was however some resistance at CPCB on use of computers. On my insistence, Krist found money to purchase the first Personal Computer (PC).

I wrote the database management software for the CPCB using this machine. The coding was done in dBASE III+/Clipper (following Simpson’s book) and Mita Bhattacharya (who is still with CPCB) helped me along with Usha Ghosh. I wrote codes for managing water quality, air quality and industrial pollution data. I also wrote codes for computation of Cess (that unfortunately got the most priority!). These codes on testing were provided to all key State PCBs and a week-long training was conducted in New Delhi. The computer era at PCBs thus begun. My major contention was to bring in discipline in data collection and organization of data rather than just the computer application. Unfortunately, few understood (even today) this hidden objective and the benefit.

Later, the National Informatics Center (NIC) took over to develop several “modules” in the style of Management Information System (MIS). The modules were installed in several State PCBs for the interest of harmonization. Today, after nearly 30 years, only some PCBs are actually using these systems to their advantage.  Gujarat and Maharashtra PCBs are the lead examples where the systems are in active use. Unfortunately, the focus still continues to be computation and recovery of Cess.

I found training programmes as a great platform to connect with the PCBs. In 1987, the Ganga Project Directorate sponsored a project with me on water quality modelling – keeping a focus on application of these models for river Ganga. After the field establishment of these models (called as STREAM-I and STREAM-II), I conducted 10 training programs for the staff of PCBs and trained nearly 200 scientists and engineers over 2 years. Many of these “students” later rose to the level of Chief Engineers/Scientists and even MS in various State PCBs. These connections helped me to continue my interactions with PCBs – one way or other. Of course, what was “taught” was quickly forgotten!  The friendship however continued!!

In 1991, the Industrial Pollution Control (IPC) project was launched by the Ministry of Environment & Forests with the support of the World Bank. Strengthening of the capacities of the State PCBs and CPCB was one of the project components. The IPC project was followed by the Industrial Pollution Prevention (IPP) and later by the project on Environmental Management Capacity Building (EMCB). Strengthening involved upgrdation of the laboratories, installation of computer systems and applications based on GIS and training of staff in India as well as overseas. These projects lasted over 10 years till 2001. I worked with the World Bank as a Consultant for IPC, IPP and EMCB in this entire duration. I was closely involved in the capacity building component. Indeed, these efforts transformed the PCBs “for a while” but as the MS’s changed, seniors retired and the World Bank support ended, the situation returned to the same dismal state.

In 2004, another project called Capacity Building for Industrial Pollution Management Project (CBIPM) was taken up by MoEF and the World Bank for capacity building focusing on rehabilitation of the contaminated lands. I was involved in the project formulation of CBIPM. The capacity building under CBIPM improved the laboratories further but could hardly create a dent due to poor project management. These four World Bank assisted projects “spent” nearly 150 million USD on capacity building of the State PCBs and CPCB over nearly 30 years.

There were efforts made through bi-lateral assistance too. Examples are the Environmental Training Institute (ETI) at Tamil Nadu Pollution Control Board and ETI at the Karnataka State Pollution Control Board (that was later transformed into Environmental Management and Pollution Research Institute – EMPRI) that received Danish (DANIDA) Support. Then there was Environmental Protection & Training Research Institute – EPTRI) an off shoot of Andhra Pradesh Pollution Control Board that received support from SIDA. GIZ (earlier GTZ) provided assistance to modernize the laboratories at various State PCBs. NORAD provided such assistance to the Orissa Pollution Control Board. In fact, I was called to design a Centre for EIA in Bhubaneshwar that never materialized. NORAD and SIDA provided some assistance to the Rajasthan PCB and Madhya Pradesh PCB as well. AusAID assisted the Andhra Pradesh PCB by taking nearly 100 staff members to Australia for training. I would estimate that another 150 million USD were spent by the bi-lateral development agencies for capacity building of the PCBs.

Despite these efforts, do you think the capacity of PCBs has improved? It seems that capacity building at PCBs was like a black hole – you send beams of light that get simply swallowed and nothing comes back!

There have been efforts made for different institutional design and arrangements to circumvent the challenges on capacity building. The West Bengal PCB partnered with IMC to establish Environmental Management Centre to serve as a facilitator. The Maharashtra PCB signed MoU with YashDa as a twinning partner for capacity building.  The Tamil Nadu PCB has initiated Technology Demonstration Centre with IIT Madras for demonstrating best available technologies. A financial support of Rs 50 million has been provided. The Rajasthan PCB has embarked a program on promoting entrepreneurship in the waste sector under State’s Start up Policy. Most of  these efforts have however not been successful.

Few years ago, Andhra Pradesh PCB (APPCB) prepared a blue print for Environmental Compliance Assistance Centre (ECAC) – structured in the form of a Special Purpose Vehicle (SPV). This SPV was intended to provide services to improve compliance and competitiveness of the SMEs – keeping an arms distance from the regulator. My company Environmental Management Centre,  prepared this blue print for APPCB after a painstaking process but as soon as the blue print got finalized the State of Andhra split!

Today, PCBs perhaps do not have a single case to show that because of the actions, the pollution load has been contained or reduced. The environment continues to deteriorate. The staff at the PCBs has remained incompetent and is inadequate while the responsibilities have increased. The heads of the institution are mostly the administrators who are not familiar with the domain. They change seats frequently. The courts are intervening and interfere. More importantly there seems to be no interest in the staff for learning and catching up with the new paradigms on environmental management. Mr. T N Seshan, Ex-Secretary, MoEF had once said that PCBs should be closed. The TSR Subramanium report has made recommendations on demolishing PCBs and restructuring the environmental governance. The Supreme Court of India has already given directions.

The situation is no different in other countries. I can say this having worked closely with regulators in Egypt, Thailand, Indonesia, Philippines, Mauritius, Bangladesh, Malaysia and Vietnam for the past 20 years. The black hole of capacity building of environmental regulators continues.

I was not surprised when Mr. Trump announced that he would close or shut down the US Environmental Protection Agency. Well, he may have other reasons but he could just be right.

But let us look at solutions and take an optimistic outlook. What can be done?

Some say (like commented by Sajid Hussain below) that we must bring in the component of training in the career progression of the PCB staff. Some believe that twinning with an academic institution should be the way. Some argue that dont limit capacity building only to PCBs but address the core eco-system i.e. consultants, environmental monitoring agencies etc. from the private sector. Having a resident expert to provide hands on training is also considered another idea (this was attempted by GTZ). Instituting induction program at the “base of the pyramid” (as suggested by Dr Singhal in his comment) and leadership program at senior and top levels (suggested by Prof Pratim Biswas) could be an effective strategy of bottom-up and top-down approach.

May be a combination of all could work. Financial resource is no more a constraint.

I would be very interested to listen to your point of view. Let us hope that the magic of capacity building works and PCBs become the lighthouses and not black holes.


(cover image sourced from http://rmc.org/what-we-do/capacity-building/)


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Common Environmental Infrastructure  – Its Evolution and Future

 

“Environmental infrastructure” is a general term that refers to infrastructure facilities as well as public services that are essential for protection, conservation and enhancement of the environment. Environmental infrastructure reduces risks to the humans and ecosystems and improves quality of life.

Environmental infrastructure that is developed for the common interests of a targeted group of users is referred to as “Common Environment Infrastructure” (CEI).

Urban infrastructure such as water supply; sewage collection and treatment; collection, treatment and disposal of solid wastes and provision of public toilets are examples of Urban CEI. This infrastructure is built using resources from the Urban Local Bodies (ULBs), State or Central Government in the form of grants or schemes or more recently partnering with the private sector. The public that is benefited through CEI is charged through tariffs and taxes. The charges are often subsidized and are differential (e.g. different for domestic, commercial and industrial uses)

There are CEIs for the industries as well. Common Effluent Treatment Plants (CETPs)  are examples of CEI for industrial clusters/estates.

The concept of CETPs emerged from a workshop led by Professor Niloy Choudhari, then Chairman of the Central Pollution Control Board in 1977 held in Jabalpur, Madhya Pradesh, India. CETPs were conceived to help Small and Medium Enterprises (SMEs) to connect their effluents to a central effluent treatment plant and contribute financially to its construction and operation.

The proceedings of this workshop provide the concept and rationale for CETPs. I still hold a copy of the proceedings. Only few will have this copy. The CETP and its operationalization is India’s contribution to the World. Countries like Vietnam, Thailand, China, Brazil etc. adopted CETPs, much based on India’s experience.

In 1987, i.e. 10 years later after Prof Choudhari’s  workshop, a group of seven entrepreneurs owning and operating small and medium chemical and pharma industries came forward to promote Jeedimetla Effluent Treatment Limited (JETL). A CETPs was set up on the outskirts of Hyderabad following “Polluter to Pay Principle”. The treatment facility was commissioned in April, 1989 at cost of Rs. 4.6 million to treat 350 m3/day of effluent using Activated Sludge Process.

Today there are nearly 200 CETPs operating in India. In their promotion, following aspects were considered

  1. Institutional – To establish CETP, a company had to be formed under the Companies Act by the interested polluters for parties. SMEs had to be the major stakeholders or the beneficiaries, especially if subsidies were to be enjoyed.
  2. Financial – The CETPs were subsidized by the State (initially by the State Government and later in some cases by the State Pollution Control Boards (SPCBs) and also by the Center (using initially the Central Loan Scheme and later through a grant from Ministry of Environment & Forests (MoEF) using the IDA funds from the World Bank (under the projects Industrial Pollution Control (IPC) and Industrial Pollution Prevention (IPP). The early financial structuring for capital contribution was as follows.

25% State subsidy, 25% Central subsidy (both provided as reimbursement), 20% Equity from the participating industries and 30% Loan (provided by Industrial Development Bank of India (IDBI) through IBRD money made available by the World Bank.

Now the financial structuring is different. The contributions are 25% Central subsidy, 25% by the State and 50% by the member industries. For CETPs involving primary / secondary / tertiary treatment, central financial assistance would be to the tune of 50% of maximum Rs.15 million / MLD capacity, subject to a ceiling of Rs. 150 million  per CETP. For CETPs involving primary / secondary / tertiary treatment and Zero Liquid Discharge (ZLD) treatment, financial assistance would be provided by GOI to the tune of 50% of maximum Rs. 45 million / MLD capacity, subject to a ceiling of Central assistance of Rs. 200 million  per CETP.

  1. Technical – The design of the CETPs had to be vetted to enjoy the subsidy. This was done by the National Environmental Engineering and Research Institute (NEERI). MoEF specified the effluent standards.

Figure 1: Typical Institutional Framework for CETP as CEI

I spent around 8 years on CETPs as a Consultant to the World Bank under IPC and IPP projects. In this period, I had opportunities to interact with SPCBs, MoEF, Private sector and Industry Associations.

Each CETP company had their own method of sharing the 20% equity. Further, they used their own formula for computing the charges to be paid (to meet the operational costs) including repayment of the loan. The formula for charging typically considered effluent flow and effluent characteristics such Chemical Oxygen Demand (COD). In addition, each polluter was required to do certain minimum pre-treatment (e.g. neutralization). Additional costs included costs of managing effluent conveyance e.g. through a piped underground network or fleet of tankers.

Although essential, CETPs require today the Environmental Clearance (EC). MoEF has produced elaborate guidelines for this purpose.  EC for CETPs takes substantial time. Unfortunately, no one considers the “cost of delayed action” on the environment in the interim period i.e. in the absence of CETP!

There is a lot of unevenness across CETP companies today. There is no “national regulator” who controls and provides rationale for equity contributions (addressing the procedures for late entry and early exits) and importantly the basis of charging schemes. There is also no mechanism of “trading effluent loads” to encourage the effluent load reduction. Industries who reduce effluent load to the CETPs are generally discouraged as this leads to reduction in the revenue to the CETP.    I will highly recommend that readers to this post refer to the presentations made at a national conference in New Delhi on CETPs in 2014. I wish there was an active association of CETP companies at the national level to continue such dialogues.

There have been several reports on the performance evaluation of the CETPs by Central Pollution Control Board (CPCB), agencies like NEERI and Environmental NGOs. All these studies by different institutions indicate a high degree of non-compliance. Dealing with non-compliance of CETP could mean en-mass closure – that can have ramifications on the production and employment in the member industries. I had recommended that CETPs should be given operational subsidies over 5 years based on performance rather than one time capital grants. This recommendation was well received but not followed.

Some of the reasons for non-compliance at CETPs include lack of proper pre-treatment, extreme variability in the flow and composition of the influents, poor treatment design and operation and deficits in the cash flow due to inadequate collection of effluent charges. Many believe that the root cause of the problem is however lack of ownership.  When infrastructure is common, there is hiding of the identity. So, who cares? You simply pass the buck or blame each other.  Its more of an attitudinal or cultural issue – isn’t it? You badly need an iconic leader and a facilitator who motivates the CETP members and get them committed for the COMMON CAUSE. We do have such good stories to tell.

Today the CETP concept is expanded to address collective management of other residues e.g. hazardous waste and biomedical waste. CEIs that will manage E-waste will soon follow. CEI for management and recycling of Construction & Demolition (C&D) wastes are already established in Delhi. My organization Environmental Management Centre LLP recently drafted national guidelines for establishing CEI for C&D waste for GIZ.

CETPs are however gradually evolving to more sophisticated reuse and recovery systems (refer to Figure 2) and not just limit to compliance. CETPs are now being recognized as part of a more holistic treatment-recovery-reuse solution comprising of add-ons such a By-Product Recovery Facility (e.g. common chromium recovery in CETPs for tanneries, common solvent recoveries and common heat & power units), a water recycling facility (like operated at CETPs in Tirupur in India). CETPs are often expanded to include a Hazardous Waste Treatment, Storage and Disposal Facility that can have a potential of recovery and recycling. It is important that any future funding of CETPs follows this holistic treatment-recovery-reuse solution, rather than restricting only to compliance. The Zero Liquid Discharge (ZLD) directive from SPCBs has been a driver in this direction. Sure, there will be motivation for Compliance, moment there are reverse operations (like water recycling) and clear financial returns.  

 

Figure 2: Gradual Evolution of CETPs from Standalone to More Sophisticated Reuse and Recovery Systems

As CEIs will spread to address specific waste streams like plastic, waste oil and metal scrap; there will be transformation of the informal sector. This sector that has major linkages will play a vital role if skilled and supported by micro-finance schemes and mentoring provided by the formal sector.  Waste to Energy is already a major CEI across the world.

Experience has shown that CEIs work best through PPP with lead taken by the private sector operator.  In such cases, Government provides concession or guarantees and does not invest. We should soon see more such CEIs in India. Example are Material Recovery Facilities (MRFs) located in the industrial estates that are bided out. These MRFs essentially become gateway of Circular Economy by ensuring least leakage of material and energy flows outside the boundaries of the industrial estate. I wish the Industrial Development Corporations build MRF for every Industrial Estate as a part of the CEI apart from CETPs.  

I spoke top my Professor Friend about the evolution and future of CEI in India.  I also expressed my displeasure on the poor leadership of MoEF&CC in this sector and its lack of vision.

Professor lit his cigar and smiled at me. “Dr Modak, I agree with your concerns but you are still thinking conventionally”. He said

Haven’t you thought of CEI in the form of Common Environmental Monitoring Systems invested by private sector in cities and industrial areas? How about commonly designed and operated Environmental Information Centers that help in raising awareness, assist in decision making and help conduct scrutiny or independent evaluation? Disaster Management Centers around Industrial Estates is another example that can be considered as CEI.

I thought Professor was right. So much innovation is possible and experiences to share!

I realized we badly need a brainstorming on this subject at the national level. We must look into the Future of CEIs. Perhaps Mr. Hardik Shah, PS to the Hon Minister should consider holding such a meeting. He comes from the State of Gujarat that has maximum number of CETPs and Common Hazardous Waste Treatment & Disposal Facilities in the country,

You know my views now but I do hope Mr Hardik Shah is reading my blogs!


Cover image sourced from http://shreyanswater.tradeindia.com/common-effluent-treatment-plant-1252361.html


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The Story of Environmental Information Centre in India

It was June 1999. The Chambers at Taj Mansingh in New Delhi was booked for an important meeting. Those present included Mr. K Roypaul, Additional Secretary of Ministry of Environment & Forests (MoEF), Dr Dilip Biswas, Chairman, Central Pollution Control Board (CPCB), Dr Subramanium, Director at MoEF, Richard Ackerman, Sector Director Environment, The World Bank; Hari Sankaran and Mahesh Babu from IL&FS Ltd. It was a small group and I was the presenter. Topic was Environmental Information Centre (EIC). The meeting began at 7 pm in the evening.

For many years, I was stressing the need to establish a national centre on Environmental Information. I saw its need for providing quality data in a comprehensive and timely manner to project proponents and consultants for conducting Environmental Impact Assessments (EIA). The regulators could use the Environmental Information Centre (EIC) to verify the baseline information provided and carry out regional and cumulative impact assessments to come up with recommendations on environmentally sound planning and development. EIC could mosaic the secondary data from key sources including remote sensed imageries and host this data and its interpretation on a WebGIS platform for the interest of all stakeholders including environmental NGOs and communities.  To ensure populating of the primary and current information, the data structures of the EIA reports could be standardized with mandatary data (and maps) uploads. EIC could also do the job of State Environmental Assessment and Reporting.  The ENVIS Centres of MoEF could be “connected” to the EIC to bring in and update thematic information on environment.

I was convinced that the EIC cannot happen solely with the Government. EIC had to be conceived as a Public Private Partnership (PPP). For promoting and operating EIC, private sector was needed and Government’s support was required to hook the data residing with various key ministries and departments and bring recognition. The attendees at the Chambers in Taj Mansingh therefore included Government  (Ministry and CPCB) and private sector with domain expertise and experience on PPP (IL&FS Ltd).  I was keen to involve academia as well such as Centre for Studies in Resources Engineering (CSRE) at IIT Bombay.

When EIC was presented and discussed, the World Bank was working with Ministry of Environment & Forests on the Environmental Management Capacity Building (EMCB) project. I made a plea to the World Bank and MoEF to use resources available in EMCB project to establish EIC in India. Richard Ackerman from the World Bank was present in the meeting for this purpose.

I had a very interesting position in this memorable meeting. I was a “friend” to MoEF, a consultant cum “insider” to the CPCB, and a consultant to The World Bank and IL&FS. I was thus the point of “intersection”. The discussions were therefore very cordial, full of ideas and support. Perhaps it was the best situation for me to make EIC happen.

And EIC happened. It got support of around 1 million USD from the EMCB Project and was installed as a pilot project with IL&FS Ecosmart Ltd.  States of Maharashtra, Andhra Pradesh and Gujarat were chosen as the focal States for EIC to provide the service. Arc GIS was chosen as the platform. Nearly 30 “layers” of key information were prepared for the three focus States. To understand the “demand” and “supply” as well as commercials, several workshops were held. These workshops led to better understanding on the scope of the services of EIC.

IL&FS Ecosmart started “marketing” the services of EIC and several project proponents and consultants started placing orders for accessing information (as one stop shop) needed to conduct EIAs. Review committees at the MoEF used EIC service for verification of the information stated in the EIA report. The World Bank utilized EIC’s service for its projects, especially for screening and scoping. I was hoping that EIC will now escalate further to cover other States and provides service pan India as an independent institution.

The idea was to move EIC as a Special Purpose Vehicle (SPV) after piloting for two years at IL&FS Ecosmart. SPV structure was necessary to make the operations autonomous and allow functioning like an independent business organization. Unfortunately, EIC as SPV did not happen. IL&FS Ecosmart could operate EIC only as a project. There were severe limitations as EMCB project got over. Mr. Roypaul had left MoEF by then and so also Dr Biswas at CPCB. The new team (especially Secretaries and Joint Secretaries) had reservations on the SPV concept.  The SPV concept for “servicing information” was perhaps too new or rather early at that time. After 2 years of pilot operation, EIC was shut down. I would squarely blame the MoEF and its bureaucracy for the closure or death of the EIC.

[ Last year the TSR Subramanium report stressed a dire need to set up EIC and to many it sounded as a new idea. Today, I understand that MoEFCC is envisaging a massive 5-year project in this direction with the help of National Informatics Centre (NIC). But I wonder whether such a fully Government owned and supply-driven model will ever work]

I remember I visited State Environmental Protection Agency (SEPA) in Beijing for the World Bank in 2002. I mentioned about the concept of EIC and its benefits to the Director of SEPA. He was very attentive in listening to me. He called some four senior officials of SEPA immediately and engaged with discussions to get more insight. In the next mission I did to Beijing, I was told that EIC was established in China. It runs as a Government project today and not as a PPP – a structure that I would have ideally preferred. It lacks therefore the innovation element that is essential when you work with dynamic, diverse and BIG environmental data.  The Centre however delivers the data to the stakeholders and supports the EIA process. The Chinese implement, once convinced and not just talk.

Today several countries operate EIC. Most EICs are Government driven and some are Government owned but operated/managed by Private Sector or by Extensions of Universities. The latter seem to work better and are more efficient and effective. EIC in India must look at such hybrids.

My company, Environmental Management Centre LLP, operates a “mini EIC” that provides customized environmental information service to our clients. This service is getting popular. The key is not to provide just the raw data but provide insightful interpretation after application of data analytics as well as modeling. Examples of such applications are change detection to see impact of thermal plumes over time in the coastal areas, district level mapping of water stress that is based on water availability, quality and uncertainty due to climate change and  mapping of diversity indices of birds and bats around the wind farms etc. Operation of this “mini-EIC” helps my team to understand the dynamics of environmental data and importantly its role in decision making.

There have been however considerable improvements in data repositories and sharing of environmental information in India. Right to Information Act has perhaps been one key factor for the “push”.   The websites of regulators like Maharashtra Pollution Cntrol Board now provide considerable information with spatial visualization and the website of National Green Tribunal is rich with regular updates. Bhuvan database is another example that provides map based information. We will soon see dash boards in  smart cities based on real time data – that may contain important environmental information.

I still hope that EIC at national level on an overarching basis happens. Given the developments in IT and operations of several thematic and geographically distributed databases across institutions, its structure will have to be quite different than what I conceived in 1999. It may be in the form of a Mega-Portal sewing several databases for an organized access but with “intelligence”. Creation of indicators will be an important element of the analytics apart from “change detection”. I wish that we book Chambers at the Taj Mansingh once again for a discussion on EIC in this new context.

But if this meeting happens, I will certainly miss the team that was present in the Taj Chambers in 1999. Those encouraging and enriching discussions and the vision expressed on EIC will never be forgotten.


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