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It is submitted that:
1. As per the policy of the Board, the feasibility report to be submitted along-with the application for NOC shall be prepared by a consultant having acquired at least Bachelor's Degree/AMIE in Environmental Engineering/ Chemical Engineering/Civil Engineering from a recognized Institution/University or from the institution having degree courses in Environment / Chemical/Civil Engineering field. Besides the above, Charted Engineers to be approved by the Board will also be competent to prepare a feasibility report. Such consultant/Charted Engineer/Institution will append an undertaking to such an effect with the feasibility report relating to the above-mentioned qualification. However, the feasibility report submitted by the project proponent does not contain any information related to the consultant and his/her qualification. Therefore, cannot be considered.
2. The project proponent has submitted details only for the cost of land. No cost w.r.t. construction and other components has been mentioned.
3. The proposal for utilizing effluent in the flushing and in the plantation area is not a full proof mechanism with no details and no drawings for plumbing has been submitted.
Further, no new construction projects are allowed:
"It is brought to attention that the Board, through letter no. SEE(HQ-2)/2022/F.No.82 dated 11.03.2022, officially notified the State Level Environment Impact Assessment Authority (SEIAA) regarding concerns over granting Environment Clearances (EC) for projects proposing effluent discharge into public sewers. The letter highlighted that in cities such as Zirakpur and Kharar, existing sewage treatment plants (STPs) lack the capacity to treat additional effluent loads, leading to environmental risks from untreated or partially treated waste. Despite these clear observations and recommendations that ECs should not be granted unless sustainable effluent disposal arrangements are demonstrated, SEIAA has continued to approve projects allowing sewer disposal where STP capacity is inadequate. This has resulted in environmental damage and the adoption of unsafe disposal practices by project proponents.
It is further brought to notice that the competent authority of the Board is not according approval for grant of Consent to Establish to any new projects which have proposal of discharge of their treated effluent into the sewerage network leading to terminal STP of ULB/ Development Authority which lack the capacity to treat additional effluent loads such as in cases of MC Zirakpur and Kharar. Since, (MoEF&CC), Govt. of India has issued O.M dated 05.02.2020 regarding the modalities for making CTE and EC a one-step process and O.M dated 14.01.2025 regarding streamlining the implementation of Notifications G.S.R 702 & G.S.R 703 dated 12.11.2024; it is imperative that the such project shall not be accorded Environment Clearance unless sustainable effluent disposal arrangements are demonstrated or alternate disposal arrangements such as availability of plantation area etc. are proposed by the project proponent.”
Therefore, it is recommended that fresh consent to establish (NOC) under the provisions of Water Act, 1974 and Air Act, 1981 may be refused, please.
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