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It is submitted that the industry has submitted the following reply to the observations (annotated form attached) raised in the SCN:
1. About 50% of the project development has been completed, the construction of the proposed 664 KLD STP has not yet been initiated, indicating that the development of pollution control infrastructure is not commensurate with the progress of the main project.
Reply: The industry has submitted that approximately 65% of the project development has been completed and that, the delay in initiation of the proposed 664 KLD STP was due to planning and financial scheduling constraints and it is now being taken up on priority………………
2. Moreover, the Project Proponent had not provided a definite timeline for construction and commissioning of the STP nor proposed any interim sewage management arrangement.
Reply: The industry has submitted that the work for installation of the 664 KLD STP will be commenced within 30 days and will be completed and commissioned on or before 31st December 2026.
3. The project proponent is required to submit CA certificate showing upto date fixed assets (FA).
Reply: The industry has submitted a CA certificate dated 26.03.2026 (copy attached) showing the value of fixed assets as Rs. 10,50,00,000/-, which includes land valued at Rs. 5,30,00,000/- and expenditure on building amounting to Rs. 5,20,00,000/-.
From above, it is clear that the reply submitted by the project proponent is not satisfactory due to following
(i) The Project proponent has not clearly provided step wise timelines for construction of STP, instead, only a final deadline for completion has been given.
(ii) It has neither proposed any interim sewage management arrangement, despite specifically asked in the SCN.
(iii) Also, there are inconsistencies in the project proponent’s reply as the project proponent has mentioned that 65% of the project has been completed. However, based on CA certificate, the asset value comes out to be around 76%.
Hence, it is recommended that the case for extension in the validity of consent to establish (NOC) under the provisions of Water Act, 1974 & Air Act, 1981 may be refused after giving an opportunity of personal hearing, please.
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