Integrating Environmental Conditions in Building and Construction Project. Comments on draft notification

Integrating Environmental Conditions in Building and Construction Project. Comments on   Draft Notification.

Published on 016/05/2018

A draft notification no. S.O. 1132(E) dated- 13-03-2018 has been issued by the MoEF and CC on the subject as above suggestios invited..

All of us by now, have probably come to realize the despair of the Urban deluge, both in terms of carrying capacity and infrastructure inadequacies as also increased  pollution and  the ‘on edge’ reactions of our people. We would also like to appreciate the fact that law mandates that all Master Plans seek an Environmental Clearance at the initial stage and on proposed modifications and also that if the ambient air quality is beyond the prescribed standards it should be controlled and no further increments allowed. By integrating environmental conditions in building and construction projects, without ensuring that the Master plans have an Environmental Clearance, we may somehow be missing on the overall carrying capacities and infrastructure adequacies for the broader area development. This may need to be looked into.

Some suggestions and observations, in this connection are being forwarded as below

Comments on Draft notification

1. At page 11 the threshold value is printed as 500000 square meters. This probably would not have been the intention.
2. The E.I.A. notification mandates that Master plans developed by Local Authorities, which are in fact area development projects, also need an environmental clearance.
3. The draft suggests exemption to certain projects from seeking a separate Environmental Clearance. There are severe environmental consequences due to commercialization of residential areas and the arbitrary increase in F.A.R. The increased population densities may have impacts on the carrying capacities of Roads, the  Power, Water, Sewage and Solid Waste Handling infrastructure and on Air and Water Pollution. The Integration of environmental conditions in building permissions could therefore only be limited to areas and activities which are covered in master plans with a valid environmental clearance and subject also to those conditions that are prescribed in the said clearance.
4. The Master plan, with a valid Environmental Clearance, should prescribe the carrying capacities of different areas in terms of allowable project/activity mixes, population density, vehicular densities and power, water, sewage and solid waste handling facilities duly approved by the MoEF & CC.  Activities which comply with conditions of the Environmental Clearance as granted to the Master Plan should only be allowed. Only those projects should be exempted which comply with the conditions of Environmental Clearance granted to the Master Plan. No exemption from a MoEF and CC scrutiny should be given to any development if the Master Plan does not have a proper Environmental Clearance .In areas not covered by Master Plans, individual projects or activities as covered in the Schedule to the notification of 2006 as amended may be asked to continue to avail Environmental Clearance individually.
5. Similarly exemptions to industrial sheds, Universities, College, Hostel for educational institutions could be considered only if located in the Master Plan areas and for which the Master Plan duly possesses an Environmental Clearance under the E.I.A. notification of 2006 as amended. Parking problems and secondary activities round educational institutions etc. are major urban inconveniences.
6. An E.C. should be required under all other circumstances in order to prevent urban burst and stupendously deteriorated Air Quality and infrastructure inadequacies.