| File Note: |
The report and recommendations submitted by the Regional Office (RO) in the subject application have been examined. It is observed that the project proponent has applied for grant of ‘Consent to Establish’ (NOC) under the Water (Prevention & Control of Pollution) Act, 1974 and the Air (Prevention & Control of Pollution) Act, 1981 for setting up a new Group Housing Project comprising Affordable Residential Flats (108 Nos.), EWS Plots (11 Nos.) and Community Centre (351 sqm), over a total land area of 4,723 sqm (1.16 acres).
The project proponent has already obtained Environmental Clearance (EC) vide No. EC25C3801PB5864800N dated 01.10.2025 for the project titled “Twin Towers”, located at Village Nabha, Zirakpur, District SAS Nagar, Punjab, with total land area of 4,721 sqm and built-up area of 20,354 sqm. As per EC conditions, total wastewater generation of 85 KLD is envisaged, to be treated in an STP of 150 KLD capacity based on SBR technology followed by UF. Out of the treated effluent, 37 KLD is proposed to be reused for flushing. Further, 6-2-1 KLD is proposed to be used on green areas of 1180 sqm during Summer–Winter–Monsoon seasons respectively, while the balance treated effluent of 42-46-47 KLD during the respective seasons is proposed to be discharged into the Municipal Corporation sewer.
However, in the present Consent to Establish application, the project proponent has proposed the following interim disposal arrangements “till sewer connection is obtained”:
• 33 KLD – On land for irrigation in a green area of 1181 sqm within the project (as per Karnal Technology)
• 10 KLD – For construction use in nearby projects
• 5 KLD – For sprinkling along road sides for dust suppression
The RO has reported the above position and stated that in the absence of alternate disposal arrangement, the proponent proposes to utilize 33 KLD within green area and the remaining 15 KLD for construction and road sprinkling. However, the RO has not submitted any conclusive remarks on adequacy/tenability of the proposed disposal scheme, yet has recommended the case for grant of Consent to Establish.
It is relevant to note that in a similar case relating to the project “Yuwenia Walk” (App ID 30509393), the RO had itself reported that proposal for disposal of excess treated wastewater @ 2 KLD through sprinkling along roads was inadequate and not feasible during rainy and winter seasons. The said application was recommended for refusal and was accordingly refused by the Board.
In the present case also, the project proponent seeks to justify disposal of surplus treated effluent @ approx. 5 KLD through sprinkling for dust suppression by citing the Hon’ble NGT order dated 03.12.2020 in O.A. No. 283/2020. It is clarified that the said directions are applicable specifically to Municipal Corporations/Urban Local Bodies for institutionalized sprinkling of STP-treated water on public roads prior to mechanized sweeping under GRAP/NCAP measures. These directions do not extend to private project proponents or housing developers. Moreover, dust suppression is seasonal and intermittent in nature and cannot be recognized as a permanent or sustainable effluent disposal mechanism. During monsoon/rainy periods, the said activity ceases, rendering the disposal route non-functional. Hence, this proposal cannot be accepted as a viable or compliant disposal arrangement under the Water Act, 1974.
Further, in another similar case of “City of Dreams-5” (App ID 28956870), the Board had refused CTE on the grounds that the proposal to dispose treated effluent through reuse in other construction projects and inter-project transfer was not practically or legally tenable, particularly in Zirakpur where terminal sewerage infrastructure is inadequate. It was also held that disposal of treated effluent is permissible only within the project premises and not through tanker transport to external locations.
The present proposal suffers from identical deficiencies. There is no assured, permanent, legally valid and technically feasible arrangement for disposal of treated effluent during the operational period of the project. The reliance on temporary/seasonal measures such as sprinkling and off-site reuse reflects inadequate planning for wastewater management. Grant of Consent to Establish in the absence of an appropriate disposal mechanism may also prejudice compliance under EC conditions and the Water Act.
In view of the foregoing facts and precedents, and as the proposed effluent disposal plan is neither adequate nor appropriate, it is recommended that the application of the project proponent for grant of Consent to Establish (NOC) under the Water (Prevention & Control of Pollution) Act, 1974 and the Air (Prevention & Control of Pollution) Act, 1981 be refused.
Comp.: Worthy MS of the Board |
