ABSTRACT
The recently enacted MSW Rules, 2016 are found
to embrace the same old paradigm of segregation and treatment so as to avoid
landfilling, as was the case with their precursor MSW (Handling and Management)
Rules, 2000. As a matter of fact the new Rules incorporate more complexities in
terms of segregation in multiple streams; decentralised treatment down to each
habitation and institution; virtually prohibiting disposal of organics in
landfills but mandate installation of LFG collection and utilisation system,
and thereby make implementation more difficult. In their zest to promote
decentralised treatment and resource recovery, the Rules also appear to be
fully waste centric and do not take into account norms for town planning,
land-use zoning, urban aesthetics, sensitivities and sensibilities of urban
residents and potential adverse impacts on account of inevitable malfunction of
such facilities. Over the last two decades and more while a large number of
treatment plants have become dysfunctional, the Rules have still shown strong
preference for technology prescription, however no outcomes are defined in
terms of environment and public health; likewise while compost is positioned
as one of the most desired outputs, the associated adverse impacts during
its production on adjoining communities and on food chain upon its application
on edible crops are not being recognised. Interestingly the Rules attempt
to embrace the 'zero waste' paradigm which is an alien concept coming
from highly evolved European society and which is impractical in the Indian
setting. Apparently no lessons have been drawn from the experience of last
16 years and therefore the revised Rules are characterised by a fairly wide
range of inconsistencies. Evidently there is a need for embracing objectivity
and incorporating several amendments on an urgent basis, if environment and
public health are to be protected on priority. Otherwise, one can conveniently
call the new Rules as Municipal Solid Waste (Promotion of Treatment Plants and
Prevention of Sanitary Landfill) Rules, 2016.
INTRODUCTION
1.
After sixteen long years of living with some
kind of regulatory system, we now have the revised regulation system called Municipal
Solid Waste Management Rules, 2016. It is widely known that the precursor
system entitled ‘Municipal Solid Waste (Management and Handing) Rules, 2000’
could not be implemented even by a single urban local body (ULBs) across the
country. The MSW Rules, 2000 attempted to introduce, among others, the paradigm
of source segregation and diversion of organics from landfills by way of
elaborate treatment of waste; they virtually prohibited provision of sanitary
landfill and mandated construction of inherently unviable treatment plants
from the points of view of resource recovery and minimizing use of land for
waste disposal. However, out of around 8000 odd ULBs (urban local bodies)
across the country, one can count on fingers those which have been successful
in complying with only few aspects of the Rules but not in entirety. It is not
surprising, because the MSW Rules, 2000 envisioned a Utopian setting, and as a
result there was significant disconnect with the ground realities in terms of urban
citizens’ concern and commitment towards environment on one hand; and lack of
expertise, capacity and resources on the part of ULBs on the other hand.
2.
Notwithstanding the dismal experience of last
16 years, the revised MSW Management Rules, 2016 are embracing even higher
degree of complexities which will make them more difficult to implement. Although
the revised Rules have incorporated number of positive aspects e.g., broad
applicability/ coverage over almost all types of urban settlements, delineation
of diverse stakeholders at central and state levels and defining their
responsibilities, recommendation for formation of state level advisory body,
mandating submission of annual reports by ULBs and treatment plant operators,
proposing home composting as an option for waste management, etc.; this paper
brings out a set of complexities which make the task of effectively managing
municipal solid waste and safeguarding public health more challenging; and
therefore argues for modification of the Rules by adopting objectivity and
incorporating experience of last couple of decades.
THE
CHALLENGE OF SEGREGATION AT SOURCE
3.
Under Section
4, clause 1(a) of the revised Rules, 2016 it has been made mandatory
for every household to segregate waste in multiple streams – viz.,
biodegradable, non-biodegradable, hazardous and now even sanitary waste. However,
given the significant socio-economic diversity in the Indian society, the
significant disparity of education, and the deficit in awareness, concern and
commitment towards environment in particular and public health in general,
segregation of domestic waste uniformly all across a urban settlement into
biodegradable and non-biodegradable streams is an extremely challenging
proposition. In most middle and upper income households it is the domestic
servants who handle waste and they are least concerned because of, among
others, lack of education. Typically one could find over 300 different types of
materials in domestic solid waste and it is simply not possible to educate
domestic workers all across a town, let alone in one household to consistently
segregate into multiple streams. Over the last sixteen years - post MSW Rules,
2000, we do not have even a single community in any of the urban centres across
the country which can claim to have achieved and sustained this practice over
an extended period of time.
4.
It is to be recognised that Indian society is
already doing a significant level of segregation and recovery in the form of
newspapers, glass and plastic bottles, metal items, etc. Typically every
housewife in middle and lower income households takes out all such items which
have some residual economic value and she is well supported by a vast network
of Kabariwallas (itinerant waste
collectors) across the country. Likewise, unlike US or Europe, Indian
households do not discard their white goods, electronic items, car tyres, etc.
along with their domestic waste. Instead such waste items are again sold to Kabariwallas who in turn dismantle and
extract each and every reusable or recyclable component.
5.
In the West from where the concept has come, segregation
is primarily for paper and bottles, (besides of course domestic hazardous
waste), etc. Further, over there the
concept of segregation of bio- and non-biodegradable waste as it is practiced,
it is primarily for bulk waste/generators, e.g., grass cuttings from lawn
mowing operations, dry leaves in fall season, department stores, hotels and
restaurants, etc. and not for post-consumer food waste i.e., meat
(biodegradable) and bones (non-biodegradables) from individual households as is
being attempted by the revised MSW Rules, 2016.
6.
Therefore over and above the existing segregation
practice of the Indian society, laying further emphasis on source segregation
of biodegradable and non-biodegradable fractions amounts to significant costs
for municipal authorities in terms of publicity for awareness creation and
behaviour change; provision of separate containers and vehicles for collection
and transport; multiple vehicle trips, etc. From logistics point of view this
does not turn out to be a practicable and feasible proposition and therefore
over the last 16 years no community, ULB or service provider has been able to
achieve such a paradigm in the country.
7.
As if the challenge of segregation of
biodegradables from non-biodegradables was not enough, under Section 4, clause 1(b) the
revised MSW Rules, 2016 have ambitiously introduced further complexity by
mandating segregation of ‘sanitary waste’ i.e., sanitary napkins, tampons,
nappies, baby and adult diapers, etc. It appears that the Rules consider
compost (and accordingly, the so called biodegradable fraction of waste outof which compost is made) to be rather sacred and therefore mandate sanitary
waste to be kept separate. It will be far too challenging to keep sanitary
waste separated all through its journey from household to the landfill site. Interestingly the Rules permit mixing of sanitary waste with ‘dry waste’, which is again
intriguing as it will expose the eventual dealers/ handlers/ recyclers of dry
waste to pathogens.
8.
Evidently the whole paradigm of waste segregation
is simply impractical and Utopian for a highly disorganized society like ours. Where
a large number of urban residents are practicing open defecation; where a
professor of Delhi University carelessly disposes of radioactive waste with
general solid waste; where a large number of small hospitals and nursing homes
dispose of hazardous hospital waste indiscriminately; where a large number of
municipalities burn horticulture waste (dry leaves and branches which the
Mother Nature gives in by and large segregated form) indiscriminately and with impunity; where leaking and poor quality ammunition is not removed and stored
separately (the case of Pulgaon disaster of June 2016 - they intended to either 'recycle' or 'reuse it' !); where people have no
regard for traffic rules and civic sense, expecting families from low and
middle income sections of the society to segregate their waste on a day in and
day out basis is simply Utopian (let alone the high income group where the priorities are different, any way). This is also a
highly impractical proposition as it does not consider challenges of
implementation and monitoring at households level on the part of a typical ULB.
9.
In this respect it is to be recognised that the
first inviolable rule in effective solid waste management is collection
efficiency. Before residents are asked to go for source segregation of solid
waste, ULBs must show effectively that they have reliable and efficient
collection programmes, else they stand to lose credibility. Further, it is
virtually impossible to have an efficient collection programme until ULBs have a
well-organised and designated site for delivery of the collected waste.
Worldwide, every successful solid waste management system has a fixed delivery
site – a landfill and a treatment site. On the contrary, on one hand the MSW
Rules, 2016 are not allowing construction of landfill sites but on the other
hand they are mandating waste segregation.
Segregation
of waste generated during large events
10.
Under Section
4, Clause 4 the Rules mandate organizers of large events (> 100
invitees) to take care of segregation of the generated waste. In the case of a
marriage party, it appears that the Rules expect father
of an India bride to be busy in segregation instead of ensuring her smooth Bidai ! Or expect guests to be mindful of what goes where!! This
is an impractical proposition as it expects the society to become waste
centric but does not consider challenges of
implementation and monitoring on the part of ULBs.
Storage
of segregated horticulture waste
11.
Under Section
4, Clause 1(d), the Rules mandate storage of horticulture waste at
source. However, in dry form this kind of waste is
prone to catch fire and therefore poses risk to households and community/
estate, unless it is stored in a closed container and/or quickly processed.
Therefore such a provision is not conducive for safety and well-being of
residents of a household with garden and the community. In absence of proper
in-situ storage and treatment, households will resort to putting the waste on
fire which will cause localised air pollution.
SCOPE
OF BURNING THE WASTE INSIDE ONE’S PREMISES
12.
Under Section
4, Clause 2 while disposal, burning or burying outside premises is
prohibited; but it appears that this leaves scope for burying and burning
within one’s premises. Apparently this is exactly what is happening in Kerala
where the State Government has amended Municipal Act whereby all households/
properties/ establishments are required to retain waste within their premises
and ensure appropriate treatment. As a result, burning of waste in backyards of
homesteads is now a common sight in several towns of Kerala.
THE
CHALLENGES OF DECENTRALISED TREATMENT
13.
Under Section
4, Clause 6, 7 and 8, the Rules mandate all residential colonies, gated
communities, market associations, institutions, hotels and restaurants to
arrange for treatment of biodegradable waste within their premises. This is an
extremely short-sighted proposition
which is assuming the society/ respective players to become waste centric at
the cost of performing their main Dharma
(it is not their job or responsibility and they do
not have time, energy, resources and expertise to do so). This
proposition is fraught with several challenges:
a.
This amounts to dereliction of duty on the
part of ULBs as they are the ones who are responsible for lifting/collection,
transport, treatment and safe disposal of waste and thereby safeguard
environment and public health.
b. This
amounts to violation of town planning and land-use policies and norms as
incompatible activity of waste treatment is being recommended in residential,
commercial and institutional areas. As if this is not enough, sewage management
agencies on the same lines are recommending decentralised sewage treatment
while unreliable power supply has anyway compelled people to install
decentralized private generators. This policy and fascination of
decentralisation of essential municipal infrastructure carries the risk of
undermining aesthetics, quality of life, property valuations and public health.
This is so because at the gross level solid waste treatment plants (and
likewise sewage treatment plants) have the inherent characteristics of causing
odour and fly nuisance while spilling of waste brought by all the vehicles
along the approach roads will be a bonus. At micro level such plants are known
to release bioaerosol (short for biological aerosol - a
suspension of airborne particles that contain living organisms. These are very
light and small – ranging from less than one micrometre to one hundred
micrometres which are released from, among others, rotting waste piles and
sewage ponds/ tanks under the effect of wind. On account of their fine size,
bioaerosols can easily enter and infect lungs) into the environment which carry
the risk of severely affecting health of residents (lung and skin infection,
asthma, etc.) in surrounding areas. Unfortunately as of now there are no
guidelines or air quality norms in India on bioaerolos as apparently this has
not be recognised to be an issue.
c.
Experience of last 16 years shows that
decentralized treatment initiatives come to a naught within a short span of
time because of, among others (a) paucity of resources, expertise, interest and
commitment on the part of residents in colonies or gated communities; and (b) odour
nuisance as a result of inevitable malfunction and consequent demolition/
vandalism by affected parties.
THERE
IS NO ENERGY, IT IS MAINLY INCINERATION
14.
Under Section
6, Clause 1(b) the Rules mandate formulation of a policy on, among
others, ‘waste-to-energy’ (WtE). And under Section 10, the Rules mandate
Ministry of New and Renewable Energy to facilitate infrastructure creation and
provision of subsidy for setting up of WtE plants. However, the Rules do not
seem to be drawing lessons from the experience of last 20 years where a number
of treatment plants (cutting across all technologies viz., WtE, RDF, biogas and
composting) have closed down despite having availed considerable subsidies.
15.
When it comes to WtE, it is not really the
energy which is the main output of an incineration plant. This is especially so
in a warm climate country like ours where the overall energy utilisation
efficiency for any feedstock in a WtE plant is as low as 22-25%; while in a
cold climatic setting due to the benefit of the feasibility of cogeneration (combined
heat and power system), typically the energy utilisation efficiency is in
excess of 65%. Therefore, in a warm climate country the WtE paradigm is only
notional as it essentially corresponds to simple incineration rather than
gainful energy generation on commercially viable terms. As a result,
fundamentally such plants need to be viewed as incinerators where the main
benefits are intangibles – i.e., waste volume reduction to the extent of 90%,
saving of area required for eventual safe disposal, and safeguarding of public
health.
16.
Secondly, it has to be recognised that there
is no energy in the Indian MSW – it has lots of moisture, wet organics, sand,
dust, stones, construction debris, etc. and the calorific value is seldom more
than 1100 kCal/kg (way below the desirable limit of 1600 kCal/kg for self-sustaining
combustion).
17.
As long as the Rules and the policy perceive
WtE plants to be ‘standalone power plants’ and do not place premium on the
intangibles (by way of user charges/ tipping fee/ gate fee), they will continue
to close down due to financial unviability.
PROVISION
OF FINANCES TO MEET UNREALISTIC TIMELINES
18.
Under Section 6, Clause 1(f), the Rules mandate provision of
project finances to ULBs to meet strict timelines (1-3 years for around 8000
ULBs) for setting up, among others, treatment plants. It is noteworthy that as
in the case of MSW Rules 2000, here also the time lines, are unrealistic and
unfeasible. Mandating compliance with such unrealistic timelines and
accordingly providing finances will again lead to wasteful expenditure as has
been the case in the past and not deriving the desired outcomes in terms of
improved environment and public health. It has to be recognised that there is
not that much of capacity (i.e., consultants, contractors and equipment
suppliers) in the country to develop and implement projects.
NO
AGENCY FOR MONITOIRNG QUALITY OF COMPOST AND ITS IMPACTS
19.
Under Section 7 and 8, while defining duties of the Department of
Fertiliser (Min. of Chemicals and Fertilisers), and Ministry of Agriculture, the
Rules do not specify which agencies across the country shall be responsible for
ensuring quality of compost derived from municipal solid waste; its suitability
or otherwise for application on food crops; monitoring impact on soil and food
crops; monitoring impact on public health, etc. Compost derived from MSW
invariably contains comparatively high levels of heavy metals, antibiotics,
weed seeds, pathogens and contraries such as glass, etc. Heavy metals in
particular pose the rick of cancer among consumers of crops grown using such
compost and therefore in several advanced economies it is not recommended for
food crop application. The Rules do not make it clear as to which agency will
be responsible for monitoring how compost is being used, how much is getting sold
and for what applications it is being sold, etc.
OVERLOOKING
BURNING OF WASTE AT DUMP SITES
20.
Under Section 14 while defining duties of the Central Pollution
Control Board, apparently the Rules do not take into account serious issue of
rampant and indiscriminate burning of waste on open dumps sites. In this
respect the Rules do not define what action should be taken, by whom and
against whom such actions should be taken? Evidently, the urban local bodies
have a lot to answer as they do not set up properly designed sanitary
landfills, but continue to dispose of waste in open dumps and allow it to burn
on its own (due to release of landfill gas) or to be burnt by rag pickers (due
to unrestricted access).
DECENTRLISED
TREATMENT IMPAIRS QUALITY OF LIFE
21.
Under Section 11, Clause 1(h), the Rules mandate State Urban
Departments and their Town and Country Planning Organisations to make
provisions in land use plans for decentralised treatment. However, as described
earlier this provision carries severe risk of undermining public health and
quality of life.
22.
Under Section 11, Clause 1(l), in the zest for implementing
decentralised treatment paradigm the Rules apparently do not recommend (or
rather waive off) buffer zone for smaller treatment units/ plants (with capacity
< 5 MT/day). Evidently every time there will be a malfunction (and there are
too many and too frequent in the case of a typical waste treatment plant), they
will make lives of nearby residents miserable on account of odour, flies, etc.
The accumulated waste (approximately 5 MT/day x 60 days x 0.75 = 225 MT) and
the resultant odour nuisance will invariably lead to adverse psychosomatic
impacts (viz., nausea, headache, loss of appetite), general decline in health
and skin infection, etc.
23.
Under Section 15, Clause (m) and (q), the Rules again mandate
local authorities of urban agglomerations and village panchayats of census
towns to set up decentralised or on-site treatment facilities (either
composting or biomethanation) in market areas. These recommendations are
completely impractical as they call for creating infrastructure with inherent
potential for odour nuisance in dense commercial and residential areas.
Secondly, small ULBs have neither the resources nor the expertise to sustain
operations of such facilities, let alone take environmental and social
safeguards. It is therefore not surprising that several such small plants in
the past have malfunctioned and closed down; and eventually they were either
vandalised, demolished or abandoned.
24.
Under Section 15, Clause (p), the Rules prescribe ‘processing’ of
horticulture waste in public parks and gardens again on decentralised basis.
This provision carries the risk of spoiling aesthetics of public parks and runs
contrary to the concept of offering amenities to the general public for
recreation. It appears that the people who have framed these rules are heavily
focused on the objective of getting rid of waste without any regard to public
sensibilities, sensitivities, aesthetics, etc.
25.
Lastly, decentralised paradigm
does not allow economy of scale; instead, it requires multiple teams of skilled
operators and maintenance staff which is a costly proposition.
PROHIBITION
ON LAND FILLING OF MIXED WASTE
26.
Under Section
15 Clause (w) and Schedule-II Section A, Clause (d), only residual
waste/ process rejects is allowed to be disposed of into landfills. Municipal
Solid Waste Management Rules, 2000 had also mandated that mixed MSW shall not be
disposed of in sanitary landfills, and it should perforce be treated. Ideally
the intent is to reduce volume of waste and thereby reduce the land area that
would be required for sanitary landfilling (but unfortunately, the moment a
‘processing’ plant is installed, it is perceived to be standalone profit centre
like an industry). In this context, provision of a ‘treatment’ plant is
understood to be compulsory as interpreted by state and central regulatory
authorities – notwithstanding the technical-commercial unviability or
affordability on the part of ULBs.
27.
In this respect it is noteworthy that in 2005-06
the Surat Municipal Corporation was not allowed to commission its well designed
and constructed sanitary landfill site for several years because it did not
have a ‘treatment plant’ in place; As a
result the landfill was kept empty while the mixed municipal waste was
disposed of openly on an adjoining plot of land - in the process the landfill
experienced degradation due to climatic
factors; the public did not have the benefit of improved environment and
health; and the investment of over Rs. 4 Crore did not yield desired results.
There are several such cases across the country.
28.
Further, this clause imposes unrealistic
conditions on service providers/ plant operators/ municipal authorities to
reduce treatment plant rejects and residuals. Drawing from this, typically
municipal authorities stipulate a limit of as low as 20% residuals post
treatment in their contract documents,
which entail significant capital investments for multiple stages of treatment. However,
from technical and scientific point of views it is extremely challenging to
reduce rejects below a certain level (in reality it comes down to only around
50%) without defying the laws of nature
and the law of diminishing returns. On this aspect it is also noteworthy
that some technology providers create confusion by promising zero rejects and
residuals and unjustly attempt to influence bidding process in their favour
(e.g., take the case of Gurgaon-Faridabad waste treatment plant under JNNURM).
29.
Imposition of significant restrictions on the
nature of the material that can be disposed of into landfills is
counterproductive as that fraction which is not allowed to be disposed of either
piles up in open dumps sites (most often right in front of the engineered SLF),
or disposed of in rivers/sea or remains in unorganised heaps all across the
city which undermine environment, public health and safety. While the concern
and intent of ‘reducing the burden on landfill’ are noble, but they should not
be at the cost of the environment and public health.
30.
In this context it is pertinent to present
proven hierarchy of technical options practiced worldwide, as shown in Exhibit
1, wherein the option of landfill represents bedrock of a robust, integrated
and effective solid waste management system. As against this proven hierarchy, as shown in Exhibit 2, the MSW Rules, 2016 embrace an inverted
hierarchy wherein landfill is given the least priority while bulk of the
problem is presumed to be addressed
through the intractable 3R or 4R
measures, viz., reduce, reuse, recycle and recover. However, with
recent implementation of the Seventh Pay Commission recommendations, the
economy in general will witness more consumption rather than reduction. Moreover,
looking at the changing lifestyles, and rising aspirations to achieve
increasingly higher standard of living (American Dream), the 3R paradigm is
only a rhetoric; and municipalities and waste managers cannot take recourse to
that.
31.
Further, the Rules appear to prescribe a
series of options for reuse of inerts (e.g., making bricks and pavement blocks,
etc.) which shows that prima facie
the intent and priority of the Rules is not
safeguarding public health at least cost but pursuing the paradigm of resource
recovery at any cost. However, as mentioned earlier, every incremental
processing of the waste material comes at a significant cost which does not
necessarily translate into commensurate value addition and price realisation.
Evidently as shown in Exhibit 3, most of the so called processing
facilities face severe financial challenges and irrespective of technology or
geographical location close down in short- to medium-term. For a detailed
analysis of multitude of risk factors associated with MSW treatment plants and reasons
for closing down of such large number of plants across the country please refer
to my paper titled ‘Risk factors associated with
treatment of mixed municipal solid waste treatment in the Indian context’, Waste Management and
Research (Official Journal of the International Solid Waste Management
Association), Volume 27, Issue 10 December 2009, (doi : 10.1177/0734242X09102637;
http://wmr.sagepub.com/content/27/10/996.abstract).
EXHIBIT 1: HIERARCHY OF OPTIONS FOR
SUSTAINABLE AND EFFECTIVE WASTE MANAGEMENT
EXHIBIT 2: INVERTED AND IMPRACTICAL HIERARCHY OF OPTIONS EMBRACED BY THE MSW RULES, 2016
EXHIBIT 3: CLOSED TREATMENT PLANTS ACROSS THE COUNTRY
Technology
|
Location of closed plants
|
Composting
|
-
Trivendrum, Vijaywada, Bangalore (2)
-
Kolkata, Asansol, Durgapur, Jagganathpuri
-
Mumbai (3), Thane, Ahmadabad
-
Delhi (2), Gwalior, Bhopal, Faridabad-Gurgaon
-
Shimla, Shillong
-
All Air Field Stn. (6)
-
Kanpur,
Barielly
|
Vermi-composting
|
-
Mumbai
(400 MT/d)
-
Suryapet, Ramagundam
-
Chalisgaon, Phaltan
|
Biomethanation
|
-
Lucknow
-
Chennai, Vijaywada
|
Mass
burn
|
-
Timarpur @ Delhi
|
Refuse
Derived Fuel
|
-
Baroda,
Mumbai, Jaipur
-
Bangalore, Hyderabad, Guntur-Vijaywada
|
Pyrolysis
|
-
Pune
|
Plasma
Arc
|
-
Nagpur (Hazardous industrial waste)
|
32.
By imposing such restrictions, on one hand the
Rules apparently do not recognise sanitary landfill as the most robust,
flexible, forgiving and least cost option of waste management; prevent adoption
of the option of ‘bioreactor’ landfill
(which allows combined treatment and disposal of organic waste without
investment in a plant, but maximise capture of landfill gas – methane, for
possible conversion into energy - ftp://ftp.solutionexchange-un.net.in/public/wes/cr/res-15120803.pdf),
and on the other hand make it virtually compulsory to set up capital intensive
treatment plants which are prone to high wear and tear, corrosion, break down
and represent depreciating assets. It is therefore to be recognised that this
is one of the most contentious and unfeasible clauses of the MSW Rules which
must be objectively reappraised and removed.
OVERWHELMING
CHALLENGES IN TREATMENT OF MSW
33.
Under Section 15, Clause (m) and Clause (v), it is
noteworthy that the Rules are prescriptive in terms of technology, instead of
focusing on public health outcomes. For instance, under the referred clauses,
the Rules prescribe construction of, among others, compost, biogas or
vermicompost plants with the underlying intent
‘for optimum utilisation of various components of solid waste’. Secondly,
under the same clauses the Rules recommend decentralised treatment to ‘reduce
transportation costs’.
34.
However, we would like to emphasise here that
the main objective of a MSW treatment plant is basically to reduce the volume
of waste (which is putrefying, pathogenic, offensive and at times contains
hazardous material) as well as to render it as innocuous as possible for
eventual safe disposal but not to make use of it for production of any value
added products and generate profit therefrom; or to reduce transportation cost.
Setting up decentralised treatment plants with the objective of reducing
transport costs is also running contrary to safeguarding urban aesthetics and
public health.
35.
Some of the common challenges faced by all solid
waste treatment plants comprise (a) severe wear and tear and corrosion of
equipment and as result, very high breakdown and need for replacement, (b) lack
of any guarantee on quality and quantity of feedstock and as result severe
shocks on sensitive biological processes, (c) very adverse environmental and
social impacts, and as a result the affected communities virtually get
ostracised and take recourse to litigation. On top of these, there are is very
wide range of technology specific challenges which are described in the
paragraphs that follow.
The
challenges of earthworms
36.
As regards vermicomposting as an option for
MSW treatment, we would like to submit that this is not an option for
addressing city level challenge where waste quantities are very large. Earthworms
are very sensitive to climatic factors (temperature variation), predators,
feedstock quality/toxins, moisture content, etc. and are typically
characterised by very high die-off rate. Further, it has been found that
indigenous species are not effective and instead one needs to procure exotic
species (from Germany and Italy) at fairly high prices. Therefore, suggesting this
as an option for scaled up facilities is not pragmatic.
The
challenges of composting
37.
Compost made out of MSW invariably contains
heavy metals, toxins, antibiotics, weed seeds, pathogens, glass, sharps, etc.
therefore it is not suitable for food crop application. Secondly, compost has
very low nutrient value and very low shelf life therefore farmers are not very
motivated to use it. Thirdly, while compost production is 365 days, its demand
is only three times a year coinciding with sowing seasons; and as a result the
plant operator has very poor cash flow.
The
challenges of biomethanation
38.
The bacteria in the biogas reactor are highly
sensitive to (a) fluctuation in temperature (they cannot tolerate more that ±
2⁰C and therefore addition of large quantity of cold water in winter severely
affects their performance); (b) fluctuations in feedstock quality, consistency
and feeding rate; and (c) toxicity due to heavy metals, etc. As a result
performance of the technology is very unreliable, i.e., over the seasons there
is high fluctuation in gas production. Next, the gas is highly corrosive which
adversely affects plant and equipment and reduces their effective lifespan. The
gas engines required for conversion of biogas into energy have to be imported -
they turn out to be very expensive, and their spare parts are either not easily
available or they are too expensive to procure. Lastly, in absence of the
possibility of cogeneration (combined heat and power) the net energy
utilisation efficiency is as low as 22% which makes the whole proposition
commercially unviable.
The
challenges of refuse derived fuel/ incineration
39.
Typically Indian MSW contains fairly high
moisture and non-combustible (viz., sand, stones, dust, silt of road side
drains, construction debris, etc.) and as a result its calorific value is low.
It does not burn on its own, instead it requires auxiliary fuel which entails
additional cost for the operator. Secondly, the boiler of a WtE plant
experiences severe damage to its tubes due to the higher presence of inerts.
Thirdly, an RDF/incineration/WtE plant requires skilled manpower to operate the
plant. Fourthly, it requires robust emission control system. Lastly, as
mentioned earlier, in this case also the net energy utilisation efficiency is
as low as 22%.
40.
As a result of the above described
technological challenges, any entrepreneur operating a MSW treatment plant
based on any technology without any financial incentives finds it next to
impossible to sustain operations beyond 3-4 years. Therefore it is necessary
that the whole issue of waste treatment be looked objectively and after taking
into consideration the experience of a large number of failed plants across the
country over the last one and a half decade. It appears that the revised Rules
have not drawn lessons from the experiments of last 16 years where the results
have been most unfavourable.
41.
In view of the above, instead of going down to
the level of specifying treatment technologies, the Rules should ideally
restrict themselves to specification of performance standards in terms of,
among others, environment and public health.
UNREALISTIC
TIMEFRAME FOR IMPLEMENTATION
42.
Under Section 22, the recommended timeframe of 1, 2 and 3 years is
ambitious and absolutely unrealistic. MSW Rules, 2000 had also adopted the same
timeframe and we know that even after 16 years there is not a single ULB which
can claim to comply with the said Rules in entirety. Evidently the people
involved in drafting of the MSW Rules 2016 do not appear to be drawing lessons
from the experience of the last 16 years.
It needs to be recognised that there are around 8000 large, medium and
small ULBs all across the country and there is not enough capacity in the
country to implement envisioned works (planning, designing, getting
environmental and social clearances, preparing contract documents, inviting
bids and awarding contracts, financial closures, construction, etc.) within
such a short time frame for such large number of cities and towns. Showing
unnecessary haste carries the risk of wasteful expenditure and poor
implementation.
WHAT
IF THERE IS NO COMPLIANCE?
43.
Over the last 16 years, while not a single ULB
could achieve compliance with MSW Rules, 2000, we do not have a case of any one
of them being taken to court for any punitive action. It is so because the
Rules did not have any clauses to that effect. Likewise, it is found that in
their new version the MSW Rules, 2016 also do not have any specific mention of
punitive action that can be initiated against any ULB in case of either
non-compliance with the strict and ambitious timeline; with collection and safe
disposal of waste; or due to adverse socio-environmental and public health
impacts.
THERE
IS NO SUCH THING AS TEMPORARY STORAGE
44.
Under Schedule-I, Section (A) Clause (xi) and Schedule-II Section A Clause
(c), the Rules variously mandate provision of ‘temporary storage’ /
‘temporary processing site’/ ‘temporary landfill site’ at each landfill site. This
is with the objectives of (a) storing the incoming waste for the duration over
which treatment plant may not be operational, and (b) saving landfill volume.
However, this provision runs contrary to the basic premise of a sanitary
landfill which is provided to take care of, among others, such emergencies
e.g., shut down or closure of treatment plants, arrival of excess or
incompatible waste loads, inclement weather, etc. By insisting on ‘temporary
storage’ (which will be nothing but open stocking and open burning) of a large
quantity of putrefying waste (say @300 MT/day x 30 days of plant closure = 9000
MT) the Rules do not seem to take into account (a) the potential adverse impacts
on the environment and public health and (b) the associated cost of multiple
handling of waste. Actually when it comes to proper operations of sanitary
landfills, there is nothing called ‘temporary storage’ of municipal waste.
THERE
IS NO SEWER LINE NEXT TO LANDFILL
45.
Under Schedule-I, Section D, Clause (iii), regarding management of
leachate, interestingly the Rules suggest, among others, disposal of treated
leachate into sewer lines. This recommendation assumes as if a landfill is
located within a city and a sewer line is passing nearby.
46.
Under the same clause the Rules
recommend ‘recycling of treated leachate’; however international best practice
is the other way round - to recycle untreated leachate with the objective of,
among others, getting it treated during its passage through the landfill and
also enhance landfill gas production for gainful use. This shows that the Rules
are rather idealistic and do not align with established best practices.
THERE
IS NO SCOPE FOR LANDFILL GAS HERE
47.
Under Schedule-I, Section (F), Clause (i) and Clause (iii),
amazingly and intriguingly the Rules recommend enhanced recovery of landfill
gas (LFG) by way of installation of, among others, collection system and gas
wells; and its utilisation for power generation. This is amazing because on one
hand the Rules prohibit disposal of organic material in the landfill which is
the singular factor which contributes in generation of landfill; and on the
other hand the same set of Rules recommend installation of infrastructure for
collection, treatment and utilisation (a turbine or a generator system) which
is capital intensive. In absence of organics, there is no scope of ‘enhanced
recovery’ of LFG and power generation on commercial terms and the operator will
not be able to recover the investment. Evidently, and as in previous several
instances, this provision of the Rules is purely theoretical.
HOW CAN
THERE BE HUMAN SETTLEMENTS ON LANDFILLS
48.
Under Schedule-I, Section (H), Clause 2, the Rules allow use of
closed landfill sites for human settlement after 15 years of closure.
Apparently the Rules do not take into account the risks of release of poisonous
LFG over an extended period of time, subsidence due to degradation and
compaction of waste; and the risks of indiscriminate drilling of bore wells by
residents in search of groundwater and withdrawal of possibly contaminated
water therefrom.
THERE
CAN BE NO COMPOSTING SANS AIR POLLUTION CONTROL
49.
Under Schedule-II, Section A, Clause f, the Rules recommend
monitoring of air quality to determine odour nuisance, however they do not
specify the appropriate composting technology of ‘aerated static pile‘ (ASP)
which is followed worldwide to minimise odour nuisance. An ASP system ensures
regular supply of air into rotting pile of waste and thereby does not allow
formation of anaerobic conditions which essentially lead to odour nuisance. It
will be pragmatic if the Rules made this recommendation which will save many
compost plants from closure.
CONCLUSIONS
50.
Based on a rigorous analysis it is evident
that on the whole the revised MSW Rules, 2016 are not very different from the
original MSW (Management and Handling) Rules, 2000. The revised Rules have
embraced the same old paradigm and have not drawn lessons from the experience
of last 16 years and more where it is known that none of the municipalities -
large, medium or small alike across the country was able to comply with them.
51.
It is also evident that the Rules
are heavily inclined towards waste ‘processing’ - converting waste into wealth
and energy, and least towards safe disposal of waste into sanitary landfills
which represent a least cost and most robust and dependable option. Based
on this analysis we are therefore constrained to feel that, it would be perhaps
not inappropriate to call the revised rules as Municipal Solid Waste (Promotion of Treatment Plants and Prevention of
Sanitary Landfill) Rules, 2016.
52. In view of the above,
it is our considered view that unless the policy of MSW management in the
country adopts an objective and practical approach, we will continue to witness
the same level of poor solid waste management what we have been experiencing
over the last several decades and environment and public health will continue
to suffer. Therefore in the interest of the People of India it is urgent and
necessary that the MSW Rules, 2016 be suitably modified.
