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!

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India’s True GDP


I was sitting at the terrace of my billionaire friend at his 101st floor apartment in Mumbai. It was a Sunday morning. He had called me and my Professor Friend for a breakfast.

Did I ever tell you about this billionaire friend of mine? He had wealth more than Tata, Birla, Jindal and Mahindra all put together. His daily receipts of cash across his various offices in the World were more than the annual income disclosed in India’s recent income tax amnesty scheme  – embarrassing Hon Union Finance Minister Arun Jaitley. He was always looked with great respect by all the ruling Governments and those interested to rule. A man so rich, influential but at the same time so simple and discrete. Such people of invisible power could only be found on 101st floor.

He had just returned from Delhi after a secret and a high level meeting with the PM.  The meeting was presided by the PM himself with Union Finance Minister Arun Jaitley, Union Environment Minister, Mrs Nirmala Sitharaman, Minister of State for the Ministry of Commerce & Industry, as well as a Minister of State for Finance and Mr. Anil Madhav Dave, Minister of Environment & Forests & Climate Change (MoEFCC). The topic was remediation and rehabilitation of contaminated lands in India. Mr. Piyush Goel, Union Minister of Power had also joined the meeting – a bit late though.

Mr. Prakash Javdekar, then Minister of State for MoEFCC had informed the Lok Sabha (India’s Parliament) in 2015 on the status and action on remediation of contaminated sites.  PM wanted to take stock of the situation and accelerate the program prior to the national elections.

Javdekar had said

“MoEFCC operates two programmes for rehabilitation of abandoned contaminated sites and dumps cross the country.  One is a project for rehabilitation of 12 contaminated areas in eight States having multiple sites is being implemented through Central Pollution Control Board (CPCB) at the cost of Rs 8050 million. Forty per cent of the funding will come from National Clean Energy Fund (NCEF) while the remaining 60 per cent are contributions are the contributions State Governments. The eight States where the project is being implemented are Kerala, Madhya Pradesh, Odisha, Tamil Nadu, Uttar Pradesh, West Bengal, Rajasthan and Gujarat. The project activities include assessment of contamination, preparation & implementation of remediation plans for each of the selected sites, and monitoring of 50 pre-selected contaminated sites. In the implementation phase, consultants have been selected for preparation of detailed project reports for remediation of 8 sites. The initial grant of Rs.100 million to CPCB is being put to use in preparation of Detailed Project Reports.

In addition, an Externally Aided Project from World Bank for Capacity Building for Industrial Pollution Management (CBIPM) is being implemented with three objectives namely, preparation of National Plan for Rehabilitation of Polluted Sites (NPRPS) which includes institutional and methodological framework for rehabilitation of highly polluted abandoned sites; capacity building of State Government agencies for remediation: and actual remediation of 4 pilot sites in States of West Bengal, Andhra Pradesh and Telangana with 15% cost sharing by State Governments. The project outlay is Rs.3390.26 million”

“CPCB is today a practically dead organization The CBIMB has always been a slow-starter – fraught with challenges on procurement” Professor said this while lighting his Cigar. Most of the “champions” at the MoEFCC, CPCB and key States have either retired or transferred. NPRPS is not yet out and has been more of an academic exercise with clips from Google searches. The website of CBIMP as last updated is of 2011. I don’t know why these “impotent” projects are even getting mentioned today. It’s simply a hogwash”

I thought the Professor was right. I was involved in the early formulation of CBIMP in 2002 with World Bank and had repeated warned the World Bank and MoEF that this program was simply not going to “sell”. There was no national policy on remediation and rehabilitation – There was absence of of risk based standards and technical guidelines and no thought given on the estimation of costs of “legacy pollution” and the potential involvement of the private sector. Although the importance of the above enabling framework was recognized to an extent in the Project Appraisal Document (PAD) of the World Bank, the general apathy at the MoEFCC (something not surprising), poor acceptance and understanding at the State Pollution Control Boards (SPCBs) of this project with maze of procurement and bureaucratic hurdles – brought the project to significant delays.

The Professor continued. “And I really don’t see why the Government is proposing to use the National Clean Energy Fund. So illogical isn’t it?”

My billionaire friend agreed.

Through Finance Bill 2010-11 a corpus called National Clean Energy Fund (NCEF) was created out of cess on coal produced / imported (“polluter pays” principle) for the purposes of financing and promoting clean energy initiatives, funding research in the area of clean energy or for any other purpose relating thereto. An Inter-Ministerial Group (IMG) chaired by Finance Secretary approves the projects/schemes eligible for financing under the NCEF. These projects include innovative schemes like Green Energy Corridor for boosting up the transmission sector, Jawaharlal Nehru National Solar Mission (JNNSM)’s installation of solar photovoltaic (SPV) lights and small capacity lights, installation of SPV water pumping systems, SPV Power Plants, Grid Connected Rooftop SPV Power Plants, pilot project to assess wind power potential etc.

In 2012, NCEF was permitted to be used to finance TSDFs for hazardous waste (not for remediation as such). Minister Goyal wasn’t quite happy with such arbitrary allocations and “fitment” of TSDF and remediation component under clean energy.

Apparently, Union Minister of Commerce Mrs Sitharaman offered that she could insert in Schedule 7 of the CSR directive under the Company’s Act that industry’s expenditure on remediation of contaminated lands will be permitted as CSR spent. “I will discuss this possibility with IICA” she said

“Well, this is certainly not acceptable” I said “On one side you allow industries to recklessly pollute our lands and then allow the expenditure for clean up or remediate as a CSR”

My billionaire friend was listening. He nodded to our observations.

After the briefing and discussions, PM had requested him to put some 100 billion Rs. as a “private sector involvement”, set an example to industries and help the Government. No CSR and no NCEF – he said emphatically. And we are not interested in the World Bank unlike Jayaram Ramesh. Bank just wants to “experiment” their half-baked ideas from Harvard and MIT on countries like us.

He came directly to the point.

I asked my billionaire friend about his response. He had said “Sir, billions here and there is no problem for me. I will send my accountant to Mr. Jaitleys office and you may advise how you want to have this money to be delivered. From Zurich or via Mauritius or in the form of carefully packed gold bars that I stock in Dubai or in form of real estate on the Pacific Islands that you can sell and give you cash from drug mafia. Sorry, I have stopped using the Nationalized Banks for fund transfer after the tightening of screws done by Raghuram, earlier RBI Governor.  My only request will be not use my money for UP and Punjab elections. In return, please allow me to “sell” the decontaminated lands for brownfield development in the real estate market. This is how I will recover my “investments”

Mr. Jaitley was not however very comfortable with my billionaire friends options. “I will have to look into very carefully” he said. But the real scale of the problem of contaminated lands was worrying him. The actual number of contaminated lands will be far more than the one officially reported he guessed – like cases reported on dengue fever in Delhi. The 2013 report of Blacksmith Institute had already shown presence of 41 prominent contaminated sites in India

He then whispered to the PM. “The National Green Tribunal (NGT) is  already breathing down our neck slapping orders for “compensation”. How the NGT arrives at these costs is debatable, but the news headlines are screaming on this issue already.

The problem is serious PM said but Arun – you seem to be too much perturbed

“Well Sir, I was about to show trend of India’s GDP over past 5 years and next 5 years of likely projection. I now realize that I will have to lower the figure by at least 1.5% to reflect the costs to be incurred to remediate and rehabilitate the contaminated lands. That will the India’s true GDP”

Jaitley is right – Professor said while getting up and extinguishing his cigar. It could even be 2% if you looked at economic impacts (health and natural resources) of hundreds of city landfills or rather dumps that are leaching and emitting pollutants every day.

“So is the Government going to borrow money from you” I asked a stupid question in closing that my billionaire friend did not answer – as if he never heard. Have some corn flakes imported for you from Australia he said instead.

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Games of Tomorrow – Play them Now!


My Professor Friend was asking “Dr Modak, have you recently played any of the computer games on your iPad or iPhone lately?”

“Well Professor, I am not that game type person” I responded – disappointing the Professor.

“You must have tried the Angry Birds at least” Professor asked. “And you must have played Flight Simulator for sure”. When he saw my face blank with no response, he was simply amazed. “Oh almost everyone who owns an iPhone or iPad know these games. You will see people playing these games when the flights are delayed or when they are in the aircraft or when they are trying to reach their destinations on arrival and are stuck with a traffic jam”

I said I don’t fly that much and if I fly then I don’t take Jet Airways where flights are often delayed (while paying a premium price) or I don’t  go to Delhi where time taken from airport to Noida is more than the flying time between Mumbai to New Delhi.

Professor was not amused with my explanation. He continued

“My friend’s son has opened up a Game Parlor at Shivaji Park. Today is the inaugural. Why don’t you join me and take a look at some of the latest games he is offering, be at least a game-literate

I was reluctant but agreed when Professor told me that Preity Zinta is inaugurating the Games Parlor. She has been rather out of the games lately (I mean IPL) for various reasons. I like Preity Zinta and her acting

Vikram, Professors friend’s son greeted us at the entrance of the Parlor that had a neon sign “Games of Tomorrow – Play Today!” The Parlor was really well designed with hi-tech consoles fitted with gadgets such as peddles, wheels, levers, gears, track balls and the like. It gave a feeling of the future or the outer space. All consoles were occupied by the guests who had come for the inaugural. There was a lot of noise around, gurrs.. & blips !! & poops ?? from the machines; yelling and screaming dotted by shouts like “Oh Shit”, “You Smuck”, “I Got you” etc. Vikram asked me to “tour around” and see the kind of games that were being played. I had to weed through the people who were watching and waiting for their turns. I noticed some NSG or commandos. They were at the Parlor in disguise as apparently games of tomorrow had a potential to become a source of inspiration to the amateur terrorists. The NSGs had a special console with games of different kind.

I saw on the first gaming console, a friend who works as the Head (Environment) of a major Chemical industry operating in Vapi Industrial Estate.

“Hey, Patel bhai”, I tapped on his shoulder and asked “what’s the game you are playing?”

“Oh Dr Modak, didn’t know you are here. I am playing a simply fascinating game” Patel exclaimed. I saw that the screen of Patel’s console showed a complicated maze of streets with buildings, nallahs or drains, open spaces etc.  with a huge tanker and several blue colored little wagons racing around.

Patel turned around and explained “Look, I am here with a tanker full of hazardous waste and my job is to dump this waste illegally at some place without getting caught by the environmental crimes department or get under the scanner of the CCTVs placed at locations unknown. See these blue colored police vans chasing me all over? The game allows me to jump the traffic signals, take one way streets in any direction, hide under a flyover, cross speed limits and even clone as an ambulance (but allowed only twice). My objective is to dump the hazardous waste somehow and if I can do this within the time allotted (10 minutes) without getting caught or confronted then I win!! “Patel winked and said “Real case isn’t it?” I couldn’t disagree.  Vikram told me later that this game (called “Run to dump”) was going to be one of the most popular games in the Parlor.

I moved ahead and found another friend on the gaming console who was doing a great business with municipal corporations on solid waste. “Hey, Reddy – Dr Modak here. How come you are here and what kind of game are you playing?” I asked Reddy who was fully concentrating on the screen with his hands firmly on the track ball. He did not even turn around to talk to me

He screamed (as there was already too much of noise) “Dr Modak, This game is called “Dig for the Gold”. See these waste heaps on the screen? You have a vehicle to reach these waste heaps and are given “tools” to dig (amount of waste you can scoop at one time) and extract any “gold” that you may get to make money. To illustrate, Reddy reached a waste heap, “applied” his extraction tool that could mine 1 ton of waste. In return, he got only the muck and not the gold. Reddy  then attempted second time a scoop of 3 tons and in this attempt managed 1 kg of gold. He got points or was rewarded raising his score

” Oh, why don’t you scoop 10 tons at a time then you will have more chance to get gold?” I asked a stupid question. Reddy laughed and said, “Well you try scooping more then you have to pay more (you lose points) plus  you have to pay for the muck as well as the “tipping fee”.  If you scoop less then you have less chances of such liabilities but then you may not get that much of gold – so it’s more like risk taking – something I do in my real life!” I understood the complexity of the game now. “Are there any levels in this game” I asked. This question was answered by Vikram. He said that higher levels of this game present you more number of waste heaps, shorter time and with more complex composition of metals like aluminum. “This game must be making folks real waste-hungry, I guess” I mused. You would like to see waste heaps everywhere as an opportunity. I was convinced that people who will become master of this game will certainly hate Swatch Bharat Abhiyan 

I saw many such novel games or games of the future running on other consoles. There was a new SIMS Version for managing flash floods in a city due to climate change and a new version of the Farming Simulator was around where it was found that spurious pesticides were used contaminated with metals in farming. All these games were very challenging and looked pretty real to prepare us for tomorrow.

In this while, the Professor was looking for me as Preity Zinta had arrived. She was asked to inaugurate one of the latest games called “Water Wars”. She inaugurated the game by pressing the “start” key. (I don’t know how many of you know but Preity Zinta did something commendable for drought-hit villages in Nashik during the IPL matches by funding a new well in Nirhale-Phattepur. Apart from providing water to the village via water tankers, Preity put in a lot of efforts to address the village water scarcity. So I thought that she was the right person to be asked to inaugurate the game “Water Wars”. She seemed like an actor who “acts”)

This game was to be played by two people at the same time. On the screen was an interstate river crossing two States (I thought the river was Cauvery but Vikram vehemently denied). There was a menu of options for water use or for water withdrawal for a player to exercise in the interest of the State the “player” belonged. The flow and quality of the river would change whenever a choice was made affecting the State downstream. In the gaming period of 10 minutes, a player could take a maximum of 10 decisions, but sequentially. (I thought that this was not a good idea – fundamentally!)

The underlying “model” of the game must be real complex (and I could see Professor’s hand there) as it accounted for variations in the rainfall. It had the “groundwater connection”, it factored the impact of cropping patterns, accounted for drinking, cattle and industrial water requirements. River use for waste assimilation and impact on river biodiversity were also addressed.

The player in the upstream of the river was making life miserable for the player downstream who was expected to use “coping tools”, political response and take support of the judiciary for fairness and justice. The judiciary in some cases would stop the player upstream and “penalize” for the unfair decision and lower the score. This “water war” would thus continue and at the end of the 10 minutes, winner would be the player who will meet interest (economic, social and environmental) of both the States in an amicable manner.

As we watched the game, we realized that this was not going to be true. Both the players were doing their best to meet their own State’s interest and kept exploiting the river in a manner that seemed reckless.

When nine minutes crossed and the last option or decision was to be exercised by the player upstream, a loud and screechy sound came from the console and the screen started blinking like a malfunctioned traffic light. Everybody was stunned as game had halted.

“Oh my mistake” Professor said sheepishly. “I never thought that in the gaming process there will be a situation of no water in the Cauvery – I will need to refix my simulation model Vikram”

So the beans got spilled. It was indeed the river Cauvery.

But was this only a game or a reality? I said to myself after getting an autograph from Preity Zinta.

I got home with a membership form for the Parlor that Vikram tucked in my pocket

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Making Waste as the Business


I was on a tour out of India for couple of weeks. When I returned, I was passing over the dump site of Deonar Dharavi in Mumbai. This site is on the way when you travel from Airport to Chembur where my Professor friend lives. The dump site is supposedly one of the largest in Asia –something not to feel proud about. Its also more known today because of the movie slumdog millionaire.

I was amazed to see that there was a tall wireframe barricade with checkposts rimmed at the boundary of the dump site. This was new to me. The dump site looked like a mountain.At the checkposts, there were armed forces guarding the dump site with real guns and search lights. I even noticed a combat tank with ammunition at the main entrance. Did we start a war on waste? Crazy – I mumbled to myself.

When I reached Professors home and settled on the sofa, the first question I asked “What’s going on Professor around the Deonar dump site?”

Well Professor said, all this is because of the new initiative that I have launched in India. I advised the Government that let us use market based mechanisms to tackle the problem of waste and not depend on regulations and enforcement anymore. For years, we have had the regulations, regulators, environmental NGOs and now abhiyans and despite all these, the problem of waste remains – We continue to see more and more waste. New waste streams have emerged that are difficult to handle. People litter, don’t segregate waste and merrily dump. Our land and water resources get contaminated. Biodiversity comes under threat.


Image source from

I proposed that the Government pays for the waste delivered and go on a buying spree. Treat waste as an asset essentially.

Municipal Corporation of Greater Mumbai (MCGM) generates nearly 10000 tons of mixed waste every day. All this waste is now bought by MCGM from the waste generators at an attractive price. The city has opened up 30 waste depots where waste can be brought by anybody to get paid. At each depot, the waste is weighed and payments are made based on the volume and characteristics of the waste. If you bring waste in segregated form then you get better price. Rates are also fixed for buying specific waste streams and materials like e-waste, metals, glass, plastic etc.  And if you bring waste in the form of a component (through some disassembly and re-engineering) then you get paid even better. The idea is here promote innovation.

Professor took a deep puff.

Moment such a policy and scheme was announced, people all over Mumbai have gone crazy. No waste is now “wasted”. Everyone is rushing to the depots with waste they generate, waste that is dumped and waste that they could even steal. Many have resigned their jobs and have taken waste collection and selling as their full time profession. Centres of waste to resource conversion have come about with training courses and micro-finance. Some have started offering transport services by switching from what they currently do. These waste vans run on the bio-gas that is generated from the organic waste. This has threatened distribution of essential services. Railways have introduced 9 10, 12 40, 3 30 pm and 7 05 pm special shuttles from Churchgate and VT stations that will carry only waste and not commuters. Getting into these trains is not easy.

All the waste from depots is now transported to the Deonar dump site. This is the main job the Municipality does.

The dump site now looks like a mountain. Several attempts are made by the underworld and waste mafia of Mumbai to steal this waste reserve and sell the waste in the suburbs or in the black market to make money. Hence all the security measures are taken by putting high wire fence and by planting check posts around the dump site. In fact, all dump sites in India are now heavily guarded on similar lines as the national treasure. Given the years of callousness on waste management in India, we believe that the value of the waste bank created on this basis will be as important as the Gold reserve. This bank will provide resources for India’s next three generations. Once waste is recognized as an important national commodity, we expect a sharp rise in India’s GDP as well as the Gross Ecological Product (GEP)

I was astonished with this bold and far sighted approach.

No wonder, the streets of Mumbai now look clean and litter free. No risks of flooding and dengue anymore. Long lines of vehicles and waste vans outside the waste depots show citizen commitment to the principle – waste is wealth.  The co-benefit of supporting livelihoods of thousands of people, would certainly help this Government to win the next election.

I said “But what will you do with the millions of tons of waste that will be collected in this process? And what about the finance? How will you pay and continue to pay to the waste suppliers on national scale?

The Professor probably expected this “stupid” question. We examined this challenge – he said lighting his second Cigar.

The waste bought will be auctioned and processed to make products to put back to the market. For example, used computers will be refurbished with new hard disks fixed and legal software installed and provided to the schools at low cost.  Plastic will be processed to make diesel and sold at the petrol pumps. Tetrapack cartons will be converted into furniture.

We have spoken to the private sector and held several rounds of discussion. One of the major problems of the waste processing industry in India today is the waste supply guarantee. Through our approach towards waste as commodity and centralized procurement, the waste processing industry will feel confident now to buy waste from us and invest to make recycled products. We are in addition signing product purchase agreement (PPA) with waste processing companies. No taxes levied on the recycled products.  We will now see more recycled products than virgin products.

Because waste to electricity conversion, electricity rates have crashed. In 30 kms radius, no chemical fertilizers are bought because of the abundant compost. Biggies like Tatas, Birlas, Ambanis and Vedantas have set up large waste verticals in their business.  Waste materials appear now on commodity trading exchanges. Waste bonds are also out. This is the idea of circular economy.

Besides, organizing efficient collection and recycling of waste at the national level, is going to save further contamination of our natural resources – thereby improving our resource security. Tourism will improve too. These benefits far outweigh the investments.

Funds for buying waste will be mobilized mainly through the revenue made out of selling waste to the processing industry. Trimming down the waste management cells of urban local bodies, pollution control boards, departments of environment etc. will also help reduce the costs. Due to the lead taken by the market based approach, I see that regulators will have little role to play.

“Professor, this is an amazing approach. You have really ushered the Green Economy in India.  I am sure other countries will follow the suit – do you see any challenges”

Professor got up and walked towards the window and looked outside. “Here I need your help”

Due to pricing of the waste as commodity, there is now a new transformation.

Everybody wants to generate more waste to make money. I see increase in the per capita waste generation from 0.5 kg /day to nearly 1.5 kg/day. Some folks have found innovative ways on how to generate more waste in the production operations, especially the SMEs. This has led to two fold increase on waste generation per ton basis for some products. Apparently, price they get from us on supplying waste provides more income than selling of product itself in the market! I have come across cases where SMEs are selling their products as waste at our depots. The reason being we guarantee purchase and offer good price.

The price line is very important. If I lower the rates, then people won’t supply us the waste. If I increase the rate then more waste will be generated and brought to the depots. Thats not good from sustainability perspective. It’s a tight rope walk.

I realized the gravity of the problem Professor was getting into. I did not have an easy answer.

I wish people realize that why do they consume beyond their needs and generate waste in the first place. I said.

Oh I am tired listening to this philosophy Prasad – Professor said this while extinguishing his cigar.

Talk something real and practical.

I returned home – this time not going over the dumpsite of Deonar Dharavi.


The report Global Waste Management Outlook  led by UNEP International Environmental Technology Centre (IETC) and International Solid Waste Association (ISWA) is now out. I was one of the four principal authors and contributed to the chapter on situation analyses – challenges & opportunities. This was a yearlong grueling project. Access this report at and know more  about it at


At Ekonnect Knowledge Foundation we just concluded a video competition in Mumbai called Anvaya (means in Sanskrit – positive action) on waste to resource management. There were 14 entries. Visit to download the report and to access the YouTube channel to view the films.


Cover image sourced from

Pollution Upstream, By Products Downstream – and Who should Pay?


Last week I was in the chamber of Member Secretary of one of the progressive State Pollution Control Boards in India. A discussion was ongoing to set effluent standard for COD for a pulp and paper mill upstream the water intake of a major city.  The discussions centred around modelling of COD from the point of effluent discharge to the point of water intake and arrive at the COD limit.

I found the discussion not focusing on the real issue. The impact of COD on the generation of disinfection by products (DBPs) leading to potential THMs and associated health risks in the water supply was completely missed out. Hence this post …..

Most rivers in India are today polluted. Untreated domestic wastes, industrial effluents and agriculture return waters have been the principal sources of pollution. Dumping of solid wastes has also been an important contributor.

To top, indiscriminate withdrawal of river waters is carried out for the interest of irrigation, power generation and industrial consumption. This has led to reduced river flows offering less dilution and low flushing velocities. Importance of maintaining “environmental flows” is generally discussed only in the conferences and serious attempts towards setting policies to this effect are not seen. Will we ever see?

River water quality is understood through basic parameters like Dissolved Oxygen (DO), Biochemical Oxygen Demand (BOD), Most Probable Number (MPN) of Coliforms and pH. Classes of water quality are defined based on the levels of these four parameters.

Water quality is considered to be Class A when DO > 6 mg/l, BOD < 2 mg/l, MPN < 50/100 ml and pH in the range of 6.5 to 8.5. Water of class A could be used or consumed with minimal or no treatment. You would hardly expect to see Water quality Class A in the river stretches of India. Perhaps, that’s a dream not to come true.

So, we need to treat water before consumption for drinking. Water treatment plants are designed, installed and operated at the locations of river intakes and only then water is transported to serve the population in cities. We want water we drink to be “safe”.

Water treatment plants are designed to meet the drinking water quality standards. These standards are guided by the Indian Standard IS 10500. Amongst the several parameters listed, the principal parameters where standards are specified include Turbidity, MPN of Coliforms, pH, Total Dissolved Solids (TDS), Iron, and Nitrates etc.

Performance of the water treatment plant depends on the quality of water it receives. Worse is the quality of raw water, more are the efforts expected on treatment of water. Dose of chemicals e.g. for flocculation and disinfection increases as pollution increases. Cleaning of the filters is more frequent generating more backwash water and longer retention times may have to be maintained in disinfection units. All this adds to the cost of operations.

More importantly, since most water treatment plants are designed as conventional, several specific pollutants such as metals, AOX etc do not get intercepted or treated posing risks to the consumer. This risk is rarely understood and not adequately addressed. In some of the States in India, water intake works have been shifted “upstream” due to the problem of increasing pollution downstream. But is this way to “solve” the “problem”?

Pollution in rivers has thus indeed influenced the water treatment works in India both on costs and efficiency.  The risk of supplying safe drinking water has steeply increased.

The true cost of not treating pollution upstream can be significant to the downstream population or the water users. Somewhere someone saves moneys and somebody else pays elsewhere! This has always been a differential, a skew and a case of inequity requiring an inquiry in the economics of environmental management.

We need to take a systems perspective. Unfortunately, agencies that manage pollution do not interact with water works agencies. They need to talk and work together.

Let us take BOD as a parameter of concern for expressing the level of pollution in river waters. This parameter is understood better when we connect it with Chemical Oxygen Demand (COD). Both BOD and COD are not generally measured at the intake of water treatment works. An associated parameter is Total Organic Carbon (TOC) that provides further insight. Few water treatment plants that operate sophisticated disinfection systems and tertiary treatment processes measure TOC.

BOD, COD and TOC show relationships and one can set up “regression models” to map one from another when data is collected over time.

Higher is the value of TOC, higher is the dose of chlorine required in the process of disinfection to ensure destruction of Coliforms and to maintain desired levels of residual chlorine. The cost of operating disinfection unit increases as the TOC in the raw water goes up – which is the result of pollution released “upstream”. It will be interesting to see trend of chlorine consumed per Million Liters Day (MLD) and operating costs at a water treatment plant as a function of average TOC/COD/BOD levels at the raw water intake works! I wish such data is collected, analyzed and reported.

The issue is however not just increase in the operating costs. A new dimension of health risk gets introduced. In the process of disinfection of polluted (high TOC) water, several Disinfection By Products (DBPs) are formed. These DBPs can pose significant health risks, especially on occurrence of cancer and lead to substantial medical costs.

You should visit web page of US EPA that provides information on what disinfection byproducts does EPA regulate, how are they formed, and what are their health effects in drinking water at levels above the maximum contaminant level?

Chlorinated DBPs are considered potentially carcinogenic and have been associated with adverse reproductive outcomes following exposure during pregnancy. Tri Halo Methanes (THMs) are the most important group of DBPs.

THMs include chloroform, dichlorobromomethane (DCBM), dibromochloromethane (DBCM) and bromoform (BF). Organic matter in natural water, expressed as TOC, is considered as the dominant THM precursor in drinking water. The World Health Organization (WHO) has set limits on THM. Indian Standard 10500 also specifies thresholds to THMs in drinking water.

Figures (a), (b), (c) and (d) show various relationships between COD, TOC, Chlorine dose, THMs and health risks.


Figure 2 below shows the “dynamics” of TOC and THMs from upstream to downstream.



Figure (2)

How much do we know about the levels of THM in our drinking water?

Research carried out in India on formation of THMs is very limited and has shown mixed results when water was analyzed at the water treatment plants, at the reservoirs and in the swimming pools. There is a need to conduct THM monitoring systematically over a year, on a national basis and at all major water treatment plants. We need to understand and assess the cause that leads to generation of the THMs. Here, wastewater inventories at the upstream will also need to be carried out. Occurrence of cancer instances, especially of the bladder will also need to be looked at through community health surveys. Results of this field work must be shared with the public with a preventive and corrective plan launched. We need to seriously tackle pollution at the upstream, optimize operation of chlorine based disinfection and even think of substitutes to chlorine.


We could perhaps develop a Risk Index or a Score Card for a water treatment works based on potential generation of THMs and pay for water accordingly. If the risk index is high then the water treatment plant will need to be compensated by the wastewater dischargers upstream. The Regulator will have an important role to play by slapping additional fines.

Indeed, we must address the nexus of Pollution upstream and By Products downstream. We also need to raise the question who should pay? For this, the Regulators, Wastewater dischargers upstream,  Water Treatment Plant operators downstream, Medical practioners and the Community must talk and come up a rounded solution. We need to look at the problem in 3600  and not in a narrow perspective of mere compliance to in-stream BOD and COD standards.

Cover image sourced from


Changing Lifestyles in Air Polluted Cities


I wanted to refill petrol in my car so I drove to my usual petrol pump located at Turner road in Bandra. The lane to the petrol pump was choked and it was after more than 15 minutes of ‘car crawl’ that I finally managed to reach the pump. When I asked Abdul, my usual pump mechanic, he pointed me to a billboard that red – “Buy 40 liters of petrol and get 2
Portable Oxygen Cylinders Free”. Apparently this “hot deal” was the reason for the rush. “Oxygen cylinders for what?”, I asked and the guy ahead of me in the queue said “to save you from air pollution” in a matter-of-fact tone. I didn’t quite like the idea of marketing emissions (i.e. petrol) with oxygen!

I was visualizing the city of Mumbai looking like a planet with no atmosphere and people carrying oxygen cylinders like astronauts. I was simply horrified at the thought.

“Are we exaggerating this issue of air pollution in Indian cities?” I called on my Professor friend in anguish. “Given the contaminated food we eat and the polluted water we drink, air pollution that we breathe in should not be a big deal. We know how to survive or otherwise. We better worry about the high incidence of lifestyle disorders like diabetes. We should offer sugar-free candies at the petrol pumps instead of oxygen cylinders. These candies should be sponsored with the CSR budgets of Parley or Cadbury”

My Professor friend was busy taking a close look at one of the N-95 masks that was produced by a Chinese company for marketing in Mumbai. This company was planning to manufacture some 1 million masks a month for Mumbai, to start with. The mask carried a certification “Proven Effective in Beijing”. The Professor turned to me and said, “Look at these masks – they filter almost all the PM2.5 matter in the air and cost only Rs. 5! Next time you go the shopping mall, you will be asked – do you want to buy a carry bag or a mask?”

“Wearing masks will help in many ways – he said. It will reduce the incidence of H1N1 and the future H2N2 series. And since it will be difficult to know who is behind the mask – masks will reduce the incidents of eve teasing by ogling men at bus stops – That could be an immense social benefit – something not easily understood and appreciated”

“But what about disposal of the 1 million used masks” I ventured to argue with the Professor. We will need to dedicate a special landfill site for getting rid of used masks. Besides the city will look like a place infested by dacoits like in the movie ‘Sholay’. The Professor was in no mood to listen.

“We have to think out of the box for reducing air pollution first” he said. The 100 smart cities program of the Prime Minister is hoping to achieve, for instance, optimization of traffic signals based on real-time measurement of air pollution. When the air quality index at a traffic junction goes high, you will be asked to change your route and will be
guided accordingly to reach your destination”

I was wondering how hard it will then be to drive from my office in Nariman point to home on Carter road, if such an intelligent air pollution sensitive system was put in place. I would perhaps be ‘circling’ the whole town for over two hours to help reduce air pollution at a traffic signal but emitting an extra ton of air pollutants in the process. Not such a smart an idea I thought.

Professor had more ideas to share. “I have recommended to the Secretary, Transport to introduce a rule whereby vehicles ending with odd number plates will be allowed on the road for Mondays, Wednesdays and Fridays and those with even number plates on Tuesdays, Thursdays and Saturdays. Sundays will be for cars with number plates ending in zero. This will greatly reduce the road traffic and hence the air emissions. Public transport will be encouraged”

“People will use fake number plates, Professor and have duplicate plate numbers” I said with a smirk.

Professor ignored my pessimistic view.

“Display boards will be set up at all major traffic junctions in the city to make people aware of the average air quality they breathe. Mobile apps will be developed so that you can browse the air quality trends and also get some forecasts. If the forecast shows that high levels of air pollution are expected, then the public may decide to stay indoors.” I wasn’t much in the favor of this option as people would stay home watching TV shows giving an excuse of outdoor air pollution.

The Professor then moved the focus to emission monitoring and control. “Directions will be given  to industries to monitor emissions from stack online. The emission data will be pooled through the server of the Pollution Control Board. Initially we will measure the Particulate Matter (PM) and provide a star rating. Industry with PM emissions well below the prescribed standard for instance will get a 5-star rating” Impressive Professor – I said.

“Hold on – the big game is much more than just emission monitoring and rating”. Professor said this with a mysterious smile.

The star ratings will be displayed real time at the Bombay Stock Exchange (BSE). This will greatly influence the psyche of the stock traders. More stocks will be bought of companies with 5-star ratings and companies with one star rating will simply be dumped – independent of their financial performance.

(I started visualizing that air pollution sensitive and committed stock trader of BSE …)


“I am conducting a series of training programs for stock traders in Gujarati (PMO likes that) to explain air pollution, its seriousness, stock traders’ responsibility and the environmental and economic implications. You should give a couple of lectures in my course, my friend”

I was even more impressed even though my Gujarati was no good …

“The Indian insurance industry has already initiated discussions on re-fixing premiums based on an Air Quality Index (AQI). Lower is the AQI (implying higher level of air pollution), higher will be the premium,” Professor explained. That’s another economic implication.

But why don’t you think more radically, Professor? All this discussion is happening  because we are perhaps monitoring and reporting air quality from wrong locations in  the cities. Many of the stations that are operated are next to streets under direct influence of traffic emissions and not reflecting the ambient levels where the prescribed standards are strictly applicable. City of Pune for instance was declared as highly polluted because the reporting was done from a kerbside monitoring station and ambient air quality standards were compared! The air quality levels ‘improved’, the moment the station was shifted.

“Oh – for a change you are talking sense,” The Professor said taking a deep puff from his cigar. He looked outside the window at a grey sky. “Let me come up with a national site audit program right away for re-siting of monitoring stations to be done on an immediate basis. Relocating stations at correct and representative places will indeed lead to lower level of air pollution and the problem will be solved bang at the source!!”

I left Professor’s office with the N-95 mask that the Chinese company had left behind on his desk.

Cover image sourced from


The Union Minister of Environment & Forests in India has announced a national Air Quality Index (AQI). The AQI will reflect eight major pollutants that impact respiratory health. AQI will be reported first in cities with populations exceeding one million and in the next five years AQI will be gradually mandated to the rest of the country. Details on the proposed AQI could be found in

Do visit This website is supported by a team located in Beijing. Much of the data on this website is driven by the real time data monitored at the US consulates.

You may like to visit to see real time AQ reporting in some of the Indian cities. US Embassies report AQI as per US Environmental Protection Agency (EPA). The Indian Meteorological Department (IMD) in Delhi displays AQ using IMD’s own AQI that is different from that of the U.S. EPA as well as from the proposed national AQI.  The State Pollution Control Boards provide data in raw format (concentrations) and currently do not follow any AQI. I guess in the period of next six months, the reporting will happen through the proposed national AQI. The US Consulates should then ideally report results in Indian AQI to avoid confusion.  So should be done by the IMD in Delhi.

Speaking about consulates, in India a number of countries have now issued guidelines for their diplomats on how they can protect themselves from air pollution. Countries like US, Germany and Japan have reduced the tenure of their diplomats in Delhi from three years to two years. Further, concerned over high pollution level in the capital, European Union has directed its diplomats here to soon install air purifiers in their offices and residences.

Greenpeace provides a very telling infographics on effects of PM2.5 and how to use N95 masks. See A joint study by universities of Chicago, Yale and Harvard found that half of India’s population may be losing up to three years’ lifespan because of poor air quality.

Beijing has put in place a time-bound action plan with health advisory and a four-level alarm system which includes closing of schools, factories and cutting down the number of cars on the roads depending on pollution levels. Indian metros such as Delhi or Mumbai have no such plan. See


Upstream vs. Downstream


Resource extraction across the world is getting more and more intensive. Material flows (both of virgin and used materials) are getting skewed.

Some of the important factors responsible for the shift are market globalization, presence of perverse subsidies (i.e. unrealistic resource pricing) and unevenness in
environmental governance.

These changes have a major significance for the economy and more so for the very resource security of this planet. There is no doubt that we need to think of waste and
resources at the same time as it is followed in a circular economy.



One of the most effective UPSTREAM strategies to address this increasing threat to resources is to REDUCE consumption and redesign the products we make and the services we offer.

The first strategy requires change in the behavioural patterns or the way we live. Given the rising rate of urbanization, the increasingly prosperous middle class (especially in Asia) and the promotion of consumerism through media, it is
extremely difficult to expect this change will ever happen! If you say no to a product because you feel there is no need, someone will simply dump the product on you (as a free trial or as a friendly gift) to trap you or enslave you!!

The second UPSTREAM strategy of REDESIGN requires innovation, risk appetite and top management commitment – and this cannot be achieved overnight.

Here, companies need to exhibit outof-the-box thinking to find ways to reduce material and energy intensity and increase recycled content in their products. Products need to be redesigned to reduce/eliminate hazardous substances, increase
recyclability (and improve safety during recycling) and make remanufacturing possible with most of the components getting reused.

Here, we are essentially talking about smart manufacturing in the true sense. All this should lead to reduction in the wastes we produce and reduce consumption of our
limited resources.

Due to increasing consumption and years of inefficiencies in manufacturing practices, however, waste volumes across the world have been on a steep rise. This has led to a
sunrise in the global waste management industry. This industry is thriving on the DOWNSTREAM strategies of waste RECYCLING & REUSE – extracting metals, biosolids, Refuse or Solid Derived Fuels, bio-gas, syngas, heat, electricity, engineered materials etc. from and reversing material flows and thereby reducing the consumption of virgin resources. The waste industry today supports significant employment – both in formal and informal sectors. Millions of poor people in the world’s largest cities earn their livelihood because waste is around.

Therefore the waste industry wants more waste to be produced– so that it can grow and survive. REDUCE at UPSTREAM can affect the DOWNSTREAM opportunities of

I remember the CEO of a waste-toenergy plant who used to hate bans on plastics as they would reduce the calorific value of waste. A Common Effluent Treatment Plant (CETP) company I know, discouraged members of the CETP to reduce the effluent volumes by specifying in the contract a guarantee for effluent supply. So has been the case in many Public Private Partnership contracts (PPP) for managing Municipal Solid
Waste wherein waste supply guarantee is an essential precondition. ‘Don’t you ever REDUCE waste’, the PPP partner warns.

There are many such examples of conflicting interests between UPSTREAM and DOWNSTREAM resource and waste management. There is no doubt, it defeats

I like the picture below that shows priority among REDUCE, REUSE and RECYCLE.


Source –

So REDUCE should always be the first priority, followed by REUSE and RECYCLING.

Note that the players in the REDUCE and REUSE & RECYCLE space are generally different. In REDUCE, top management, product designers and consumers play a dominant role whereas in REUSE & RECYCLE, waste pickers, community and waste
processing specialists have a greater interest.

What we need is an integrated approach. Bringing these stakeholders together to ensure an integrated waste & resource thinking is very important. We don’t see that
happening. Very rarely do product designers and waste processors talk. Products when redesigned cleverly can not only REDUCE material and energy intensity or eliminate
hazardous substances but also increase potential REUSE and provide more opportunities for RECYCLING. A systems thinking is necessary. And we need examples that show possibilities and benefits of such integration.

I would love to conduct workshops to bring these stakeholders together and explore how to resolve the apparent conflicts between UPSTREAM and DOWNSTREAM. These workshops will perhaps help in better communication between the stakeholders and lead to more partnerships and motivational examples to share. Let UPSTREAM meet DOWNSTREAM.


(cover image sourced from