| File Note: |
It is submitted that pointwise reply to the observations is as under:
1. The RO has calculated wastewater generation considering only 303 residential plots and has assessed wastewater generation at 490.860 KLD. However, the calculation does not account for wastewater generation from the clubhouse, mandir, and school. The RO is required to clarify whether the wastewater generation would exceed the proposed STP capacity of 500 KLD after considering these components. The RO should also assess and justify the adequacy of the proposed wastewater treatment and disposal arrangements.
Reply: The PP has calculated wastewater generation considering only 303 residential plots and has assessed wastewater generation at 490.860 KLD. However, the calculation does not account for wastewater generation from the clubhouse, mandir, and school. Accordingly, the CTE/NOC vide no. CTE/Fresh/MKS/2023/23680166 dated 31/10/2023 valid upto 30.10.2024 was granted with the special condition that the project proponent will be bound to increase the capacity of the STP alongwith adequate disposal arrangement, if at any time the quantum of generation of effluent increases beyond 500 KLD.
2. A portion of the treated effluent is proposed to be disposed of on third-party land measuring 2.75 acres, based on an agreement. However, the validity period of the agreement and contingency arrangements in case of termination of the agreement have not been specified. Further, while recommending the case, the RO has not stipulated any conditions for blocking the concerned Khasra number of the said land for the proposed purpose. The RO is requested to clarify these aspects and propose appropriate safeguards.
Reply: The project proponent has submitted an agreement with third party, however, there is no mention of validity period in the agreement. Moreover, no contingency arrangements have been specified by the PP in case of termination of agreement. Further, following conditions may be imposed on the PP by the board to address the environmental concerns such as (i) PP must submit registerd agreement with third party owner for minimum 15 years validity with auto renew clause unless both party terminate. (ii) On agreement expiry or termination, PP shall arrange alternate treated effluent disposal/reuse and get Board approval atleast 3–6 months before. (iii) Concerned Khasra number land shall be blocked/endorsed in revenue record for treated effluent disposal/irrigation purpose and mutation copy submit to Board..
3. As per the opinion of the SLO, Environmental Clearance (EC) is required for industrial sheds, schools, colleges, and hostels for educational institutions where the built-up area of the project is ≥ 20,000 sqm and < 1,50,000 sqm. The RO is requested to submit supporting documents in support of the built-up area calculations (as per AEE note dated 14.01.2026) and to assess the collective built-up area of all constructions within the project, to confirm whether it exceeds 1,50,000 sqm or not.
Reply: It is submitted that the Project Proponent (PP) has, at different times, submitted inconsistent documents. In one document submitted on the letterhead of Snow Palm Infrastructure LLP, the built-up area of different entities has been calculated as follows:
(i) Built-up area of saleable plotted area has been calculated by assuming an FAR of 2.1 and ground coverage of 70%, resulting in a built-up area of 109,120.963 sq. m.
(ii) Built-up area of the Club House has been calculated by assuming an FAR of 1.5 and ground coverage of 50%, resulting in a built-up area of 2,418.682 sq. m.
(iii) Built-up area of the Mandir has been calculated by assuming an FAR of 1.5 and ground coverage of 50%, resulting in a built-up area of 188.129 sq. m.
(iv) Built-up area of the School has been calculated by assuming an FAR of 1.5 and ground coverage of 50%, resulting in a built-up area of 4,553.704 sq. m.
Accordingly, the total built-up area of the above four entities comes out to be 116,281.478 sq. m…………………….
However, in another document submitted by the PP on the letterhead of Nirmaan Architects, the built-up area calculations have been made by assuming an FAR of 1.65 for the saleable plotted area, an FAR of 1.1 for the School and Club House, and an FAR of 1.05 for the Temple. On this basis, the resultant total built-up area of the four entities comes out to be 132,810.66 sq. m.
In view of the above, a significant discrepancy is observed between the two sets of built-up area calculations. Due to this discrepancy, the applicability of the EIA Notification cannot be ascertained. Hence, it is recommended that a Show Cause Notice (SCN) be issued to the industry under the provisions of the Water Act, 1974 and the Air Act, 1981 for the above discrepancy.
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