| File Note: |
It is submitted that the RO had earlier processed the application for grant of CTO to the unit. While processing the application, certain observations were raised by the ZO vide note dated 11.01.2026 with a request to furnish clarification on the same.
Thereafter, the RO vide note dated 21.01.2026 stated that the project proponent was asked to submit clarification on the said observations but had failed to do so, and accordingly recommended that the application be returned to the project proponent for re-application after addressing the observations.
However, it was observed that the RO had neither raised any online clarification on the OCMMS portal nor placed on record any formal communication/email issued to the project proponent seeking the requisite information. In absence of any documentary evidence, the claim that the unit failed to submit reply could not be substantiated. Accordingly, vide note dated 27.01.2026, the RO was directed to first issue a formal communication to the project proponent and place the same on record before further processing of the case.
Now, the RO vide note dated 10.03.2026, i.e., after a lapse of more than 1.5 months, has merely attached the reply submitted by the unit and recorded that the same is “found satisfactory”, without furnishing any point-wise examination or comments on the observations earlier raised.
In this regard, it is pertinent to mention that:
1. The RO was specifically required to examine the reply submitted by the project proponent vis-à-vis each observation raised vide note dated 11.01.2026 and provide its own reasoned and speaking comments. However, no such analysis has been provided.
2. The RO has again failed to place on record any formal mode of communication (online clarification/letter/email) through which the observations were conveyed to the project proponent. It appears that the observations may have been conveyed informally/verbally, which is not acceptable in official processing and lacks transparency and audit trail.
3. It is further observed that several observations (particularly related to site verification, water consumption justification, plantation details, flow meters, and compliance of CTO conditions) were required to be verified and commented upon by the visiting officer based on field inspection. However, no such verification report or specific comments have been furnished by the RO.
4. The approach adopted by the RO reflects non-compliance of due procedure, as neither the deficiencies were formally communicated nor has the reply been critically examined before recommending the case.
In view of the above; if approved, the following actions be taken at this stage:
In view of the above; if approved, the following actions may be taken at this stage:
1. The EE, RO may be directed to seek a written explanation from the concerned dealing officer(s) for the inordinate and unexplained delay of more than 1.5 months in processing the case, despite specific directions issued vide note dated 27.01.2026, and for not adhering to due procedure in the matter.
2. The application be sent back to the RO with directions to:
a. Examine the reply submitted by the project proponent in a point-wise and reasoned manner against each observation raised vide note dated 11.01.2026;
b. place on record the formal communication/online clarification issued to the project proponent;
c. furnish specific comments based on field verification, wherever required (particularly with respect to water consumption, ETP adequacy, plantation details, flow meters, and compliance of previous CTO conditions); and
d. submit a comprehensive, speaking recommendation for further consideration of the case. |
