16^th May, 2021, 12 noon-1pm

Key points from the discussions:

• Environmental compliances by the industries during the pandemic are very poor because of various reasons such as lockdown/ curfew imposed, inadequate manpower etc.
• Last year during the Nation-wide lockdown, we actually experienced what is wholesome and pristine air. But we have not learnt any lesson and we did not set any target for the maintenance of wholesomeness of environmental components (air and water quality) irrespective of the situation and circumstances.
• This year the pandemic was unprecedented and unpredicted which is affecting human health. Environmental health and human health are interdependent. We have failed to educate the people about this and not learnt lessons from the past.
• Sewage Treatment Plants (STPs)/ Effluent Treatment Plants (ETPs), Air Pollution Control Devices   (APCDs) are not properly operated and monitored during the pandemic. Other important issues that have been affected are solid waste management, biomedical waste management (collection of discarded PPE kit/masks from hospitals and COVID care centers) etc. The entire composition and quantification of biomedical waste has changed in this pandemic. Waste generation has increased and we do not have the capacity to handle the biomedical waste. Mixing of biomedical waste with municipal waste is a big problem. Though, Staff engaged in municipal solid waste management/biomedical waste management doing remarkable work has rightly been called frontline warriors as they are collecting and disposing the waste in such critical times.  
• Though, there is a robust system for grant of Environmental Clearances, Consents and Authorizations. But these documents which were earlier limited to one page are now almost 10 pages long and include several conditions (around 60).  There are multiple Regulatory Authorities. We should be aware of the challenges of implementing of these conditions, many of which are qualitative. The conditions should be measureable, monitorable and quantifiable to reflect into actual enforcement of compliance.
• The pandemic has thrown up several challenges, especially for environmental compliances, during the COVID times. There have been many disasters in the industries because of leniency in compliances and poor safety standards such as the gas leak at the polymer chemical plant in Visakhapatnam (Andhra Pradesh), boiler blasts in Tamil Nadu and Gujarat. Environmental compliance continues to be a big issue even today and may be much more in the future.
• Industries are facing many challenges such as reduced staff because of which they cannot function properly e.g. poor functioning of Air Pollution Control Devices, ETPs, STPs, poor housekeeping, especially getting third party contractors who do the sampling and monitoring of the environmental parameters in the industries. There are limitations of delivery of proper and efficient services at remote locations as it is difficult to travel during the pandemic. A loss of market demand has also been seen because of which many activities have been curtailed. As they are not able to perform in full capacity therefore they are not able to comply with the environmental regulations.
• Indian environmental standards are merely pollution control standards and not environmental or ecological restoration standards. Besides, our environmental standards are load based standards and not cluster based standards especially for the industries. However, most of the operations and pollution control in industries have become automated. If industries are functional, pollution control systems must be operated. Relaxation can be considered in white and green category industries, but only to a certain extent – sewage treatment; if more than 25 KLD, it needs to be treated; if less than 25 KLD, relaxation can be given during the pandemic. For Red and orange category industries,  the regular operation of pollution control systems should be insisted upon. Green and white industries can be considered for giving relaxation.
• Therefore, some flexibility may be considered in enforcement in the present context particularly with regards to monitoring and reporting. But all reports must be kept for potential legal defense with due diligence. However, industry should not relax any safety standards. Extension of Consent to Establish (CTE), Consent to Operate (CTO) may be granted. The validity of CTE & CTO has been extended up to October/November by some Pollution Control Boards and Committees.
• Economic slowdown is a concern, but economic revival can run parallel to environmental revival. Therefore, Environmental Compliances should continue to be followed. However, most of the environmental regulations are very stringent and difficult to adhere to. There should be a dialogue between the industry and the experts.
• For example, In DMRC, the environmental compliance is a part of the construction tender document. Covid requirements have also been added now. The problem they are facing is that most of the labor has gone back to their native villages and so productivity/output has gone down. Working capital has also gone down for the contractors. Inadequate availability of raw material is another issue. Physical visits for monitoring have reduced. Construction activities at sites are being monitored via CCTVs and video conferencing to fulfil the environmental conditions laid down in the contract. Covid compliances (thermal scan, double mask etc) are also being monitored via CCTVs.
• There is no emergency management plan for example, if there is fire. Roads should be kept empty and not be a parking place for fire vehicles to move quickly. The general public is also unaware of what is an emergency management system.
• Authorities have to be visionaries; technologies will bring convenience, they will not bring comfort. We have to assess how each new technology/activity is going to adversely affect the environment. For this, we have to either expand the scope of environmental compliances or completely stop that particular activity.

Recommendations 

• Laws for environmental compliances are integral to industrial activities and should be followed regardless of the pandemic situation.
• Extension of validity of Environmental Clearance (EC), Consent to Establish (CTE), Consent to Operate (CTO) and Authorization may be granted.
• No relaxation should be given as far as compliance to environmental regulations and standards is concerned. Relaxing the standards even during the pandemic will only result in an ecological boomerang.
• Integrated action by Industries, Regulatory Authorities and application of technologies in monitoring will lead to proper environmental compliances.

Participants

Dr KK Aggarwal, Dr Anil Kumar, Dr Ajay Deshpande, Dr SK Tyagi, Dr SK Gupta, Dr Dipankar Saha, Dr M Dwarkanath, Mr P Khandelwal, Mr RS Tyagi, Mr Vivek Kumar, Mr Vikas Singhal, Mr SA Verma, Mr Aishwarya Mukherjee, Mr Varun Singh, Mr Neeraj Tyagi, Mr Kamal Sharma, Ms Ira Gupta, Dr S Sharma