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Buildings: Earthscrapers

Environment Impact Assessment of Buildings

he Centre for Science and Environment (CSE) is a public interest research and advocacy organisation based in New Delhi. The Centre researches into, lobbies for and communicates the urgency of development that is both sustainable and equitable. The scenario today demands using knowledge to bring about change. In other words, working India’s democracy. This is what we aim to do. The challenge, we see, is two-pronged. On the one hand, millions live within a biomassbased subsistence economy, at the margins of survival. The environment is their only natural asset. But a degraded environment means stress on land, water and forest resources for survival. It means increasing destitution and poverty. Here, opportunity to bring about change is enormous. But it will need a commitment to reform — structural reform — in the way we do business with local communities. On the other hand, rapid industrialisation is throwing up new problems: growing toxification and a costly disease burden. The answers will be in reinventing the growth model of the Western world for ourselves, so that we can leapfrog technology choices and find new ways of building wealth that will not cost us the earth. This is the challenge of the balance. Our aim is to raise these concerns, participate in seeking answers and — more importantly — in pushing for answers and transforming these into policy and practice. We do this through our research and by communicating our understanding through our publications. We call this knowledge-based activism. We hope we will make a difference.

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Buildings: Earthscrapers
Environment Impact Assessment of Buildings

SUSTAINABLE BUILDING PROGRAMME

2011

CENTRE FOR SCIENCE AND ENVIRONMENT, NEW DELHI

THIRD DRAFT

RESEARCH AND DIRECTION Anumita Roychowdhury Research Sakshi Dasgupta Arun Bhandari Photographs Down To Earth Layout Shri Krishan Production Rakesh Shrivastava and Gundhar Das

© August 2011 Centre for Science and Environment Material from this publication can be used, but only with proper acknowledgement.

CENTRE FOR SCIENCE AND ENVIRONMENT 41, Tughlakabad Institutional Area, New Delhi 110 062 Phones: 91-11-2995 5124, 2995 6394, 2995 6399 Fax: 91-11-2995 5879 E-mail: cse@cseindia.org Website: www.cseindia.org

EIA and water … … … … … … … … … … … … … … … … … … … … … … … … … … … …81 EIA and water usage Review of information provided by project proponents How environmental clearance and NOCs given in water stressed areas? Nature and quality of interventions for water conservation Monitoring – compliance and violation 4. Environment Impact Assessment for buildings: The critical path tool How is the environmental clearance designed for buildings? EIA rules for buildings different from industrial EIA Why EIA rules for buildings ineffective? 2. EIA and traffic impacts of buildings … … … … … … … … … … … … … … … … … … …98 … … … … … … … … … … … … … …100 5. Regulatory best practies: Learning from others 6. The way ahead … … … … … … … … … … … … … … … … … … … … … … … … … … …102 Annexure Reference … … … … … … … … … … … … … … … … … … … … … … … … … … … … … …107 … … … … … … … … … … … … … … … … … … … … … … … … … … … … … …114 . EIA and Energy … … … … … … … … … … … … … … … … … … … … … … … … … … …66 … … … … … …43 What EIA demands to know about energy savings? EIA and energy performance: A red herring Buildings in energy stressed cities Monitoring and compliance 3.THIRD DRAFT CONTENTS Why this study? … … … … … … … … … … … … … … … … … … … … … … … … … … … … …5 What are the green worries in the building sector? Environment impact assessment for building: Is it delivering? What ails EIA for buildings? The way ahead 1.

Our small decisions -. It also creates waste. dispose waste define livability. public support. Centre for Science and Environment’s’ Sustainable Building Programme is designed to create policy and public awareness for aggressive steps to cut the resource imprint of the building sector. knowledge based activism.THIRD DRAFT Sustainable Building Programme Our personal choices about the level of comfort we want and the means of getting that comfort decide sustainability of our lifestyle. offices and shops. energy and material. and the operations of our buildings we can make enormous difference. and grass roots action can make a difference. But just by changing the design. Science based direction. material.how do we light and air condition our home. Buildings are the core of all our demand for water. avert environmental consequences and achieve green code of living. . and promote building designs and structure that help to reduce demand for energy and water. give the right market signal to prevent guzzling and inefficiency. use water. This demands strong public policy to promote efficient use of resources. Break the insidious link between resource use and building. This programme is designed to set the vision for resource efficiency in buildings and push and track policy development for effective implementation. Green building policies have begun to take shape in India.

For instance. shops — are the end users of energy. A deeper policy understanding of the emerging challenges in the building sector and the potential and constraints of this instrument can provide the much needed insight into the future action.000 sq meters. energy. energy. 1986. For instance. Even though the comprehensive list of total number of buildings that have been assessed or cleared so far under the EIA is not available in the public domain. If the scale of application of EIA (that includes energy impact assessment among others) and ECBC are compared then EIA surpasses in scope and ambit at present. Though this tool is meant for only large construction projects with area more than 20. But other green building regulations are mainly sectoral in scope such as water. the Energy Conservation Building Code (ECBC) administered by the Bureau of Energy Efficiency is designed to promote energy efficiency in buildings is still a voluntary system and confined to commercial buildings with atleast 100 KW load. for livable cities. The area data is available for 446 buildings and that amounts to 5 . They are also waste creators and waste wasters. The exact area for each building is not available. In India the only holistic legal instrument that is available to consider the environmental impact of high impact segment of the building construction sector is the Environment Impact Assessment rules introduced under the Environment (Protection) Act.THIRD DRAFT ENGINES OF THE DEVIL WHY THIS STUDY? The urban building sector – our homes. waste management and are limited in scope of application and are mostly voluntary in nature. about 927 building projects have been reviewed for environmental clearance between 2008-2011. offices. no other legal instrument that directly and explicitly deals with green aspects of buildings influence as large an area as those dealt with by EIA instrument. It is now increasingly recognized that buildings — just not as structures but also as operational units have to be managed well to be able to cut its gregarious resource use and the waste it generates. Only in one state of Haryana. Why the EIA tool is expected to make a difference? The scope and ambit of the EIA tool is wider and deeper than the most other tools that are currently available related to greening of buildings. and land impacts among others to reduce the overall damage caused by buildings. and more secured environment. the partial data only for a few states indicate that the buildings that come for EIA clearance runs into thousands with huge area coverage. sustainability assessment of buildings is needed at the early stages of its planning – even before a commitment has been made to create it. This tool also offers the opportunity to influence the design and planning of buildings to achieve sustainability. In view of this. As an isolated and a voluntary measure its current scale is very limited. This is the only legal instrument that holistically assesses water. a quick review of this strategy has become necessary to understand if India is geared and prepared to assess and mitigate the environmental impact of the urban building construction sector effectively. the sum total of urban demand that largely defines the footprint of cities. water and other material. waste.

transformation of lifestyle and aspiration for high end resource intensive comfort level. But even if we assume the minimum area criterion of about 20.797 square meter of built up area. But buildings are a very small component of the construction industry which is an omnibus that includes all infrastructure related construction – industry and mining infrastructure. But in contrast.000 per annum) will be the most dominating income class and is expected to be half of all urban households by 2025. On a nationwide basis this area of influence is expected to be much higher. cities will face the challenge of ensuring higher level of comforts to be balanced with resource efficient ways.000 – 500.THIRD DRAFT 8. Data bases are fragmented and do not capture the detail trends in residential. commercial and institutional space will reflect this trend. land revenue. Other higher income categories will also see some increase. in absolute numbers it is significantly substantial — more than the total population of the United States. according to the BEE website the ECBC registered buildings nationwide accounted for 829. roads and highways.85. and the environment and forestry department do have the data of all the applicants who have applied for respective approvals for 6 .000 sq meter of land in only Haryana has been influenced through the environmental clearance process. Trends in building spaces – how big is the problem? Data base on buildings and built up spaces is the weakest link in India. Increasingly. a conservative minimum of 1. Future urban growth will see more pronounced middle class with greater buying power in cities. May be the actual number of buildings adopting some part of ECBC could be higher but that has not been properly recorded. Dominance of urban poverty and dominance of low cost housing has kept the baseline of resource use low in our cities though inequity is increasing sharply. Residential. The changing income levels in cities essentially points towards the fact that in the future cities will see more concentrated buying power. commercial and office sectors in the country. Though India’s urbanisation is still modest at 30 per cent and is expected to be 40 per cent by 2030. etc. In Delhi alone 75 building projects have received environmental clearance during 2009-11 which accounts for 35.22. urban development.787 sq meter in 2010. This bears out that EIA is not only an opportunity today to influence a much larger high impact building stock but also an opportunity to tie together the other green building provisioning in the area of water.89. Hence. power. Ministry of housing and poverty alleviation tracks demand for housing units but not other built up areas. The actual trend in the urban buildings sector is not often clearly delineated. irrigation. this interest in assessing the scope of reforming the EIA rules for buildings to meet green building objectives.000 sqm for each building. Though the income tax. The 2010 McKinsey study on urban infrastructure estimates that the so called seeker class (with household income of 200. It is also evident that the voluntary rating programme of GRIHA and LEED that are aligned with the ECBC have registered about 112 GRIHA and 1241 LEED rated buidlings. Poor official estimates and statistical data for the real estate industry make rigorous impact assessment of the building sector difficult. energy and waste management for a more effective impact. The overall contribution of the construction industry to the GDP is about 10 percent which is substantial.29. Planning commission and other concerned departments assess the trends in the construction sector. WHAT ARE THE GREEN WORRIES IN THE BUILDING SECTOR? Buildings and Urban Growth: The real estate sector is directly influenced by the scale and speed of urban growth.836 square meters.40.

CREDAI etc. The metamorphosis. and research foundations have become the principal source of information for this sector. Amongst the built up 2011 142 50 20 15 spaces by usage the demand for 2012 152 54 22 16 residential space dominates the Total 562 199 79 59 demand at 63 per cent. The organized real estate industry and the related consultant agencies maintain their respective databases that are often not comparable or even publicly available. 2009 132 47 18 14 Estimated pan India real estate 2010 136 48 19 14 demand). Cushman & Wakefield. shall achieve higher CAGRs in range of 8 percent – 10 percent and will become by 2030. So far government has been providing housing for different income groups – economically weaker section (EWS) less than Rs 3300 monthly income. a rough jigsaw of the available data helps to reflect some trends in built up areas in the country. In terms of constructed area the maximum growth will be seen by residential and commercial sector reaching to a size of four to five times of 2005 figures. which have had a relatively overall smaller constructed area so far. Nonetheless. and Gujarat) also record highest number of projects. A sustained CAGR between 5 to 10 percent is likely to be achieved for the same duration across different building types. So far in many states government has focused on providing housing for all these 7 . Office and retail demand will also Source: Anon. a New Delhi based consultancy agency that has compiled a report for the Climate Works the overall constructed area in 2005 has been estimated to be close to 21 billion square feet and is expected to swell to around 5 times of this size and reach to approximately 104 billion square feet by 2030. The states recording maximum urbanization rate in the range 5030 percent (Maharashtra. Additionally. given the housing deficit in our cities the demand for residential buildings will continue to dominate. Hospitality and Retail. In the absence of official data the estimates available from some real estate service providers. 7 to 11 times of what they were in 2005. Tamil Nadu. This sector is not recognized in the books of the government. (EDS). This is a very opaque industry. The Planning Commission has estimated that at the end of the eleventh five year plan the housing shortage is expected to be more than 26 million housing units for all income classes. High income group (HIG) – more than Rs 14500 per month. investment banks. Some of these sources are Green Building Council. according to the real estate consultant the Cushman & Wakefield India is ranked number two in Global Retail Development Index 2008. But there might be a lot variation in their estimation. changing dynamics of Indian realty sector. There is another estimate on Table 1: Estimated pan India real estate the trends in projected demand demand (Area in million sq feet) in real estate sector by different usage (See table 1: Estimated Year Residential Commercial Retail Hospitality pan India real estate demand).THIRD DRAFT ENGINES OF THE DEVIL building projects this data has not been centrally compiled in a composite data bank in the government. 2008. May increase considerably. This indicates that the high end construction activities are expected to escalate in India. The construction industry in most states is growing fast at 10-17 percent annually. According to the Environmental Design Solutions Pvt Ltd. Delhi NCR. Low income group (LIG) — Rs 3300 to 7308 per month. Trend in Residential Space: Clearly.

this sums up to 101. Kms which is nearly 3 times (36 Sq km) of Panjim city of Goa. But in the future the government will concentrate more on EWS and LIG.7 percent as estimated by the Planning Commission in 2004-5 based on household consumer expenditure. Mumbai. Ahmedabad. Under the National Housing and Habitat Policy 1998 and 2006 the government is expected to build 2million dwelling units a year. This has also escalated demand for low cost housing – from 25 million housing units in 2007 to 38 million affordable housing units by 2030 (Mackenzie 2010) .098 million Sq. and Kolkata. In fact McKinsey 2010 projects that with unlocking of growth India will require to build 700 million to 900 million sq meters of residential and commercial space a year in the 2030 timeframe which is equivalent to adding two new Mumbai. This means for high end houses the governments’ role is going to diminish and that of the private construction industry will increase. Kochi and Goa too add a significant share of demand due to the governments’ initiatives to promote tourism in these cities (see fig 1: Building stock in cities). Under JNNURM it is a much smaller target 1-2 lakh units a year – one million units during eleventh plan – only 1 per cent of the housing shortage. Chennai. Pune is expected to be the third fastest growing city and Mumbai fourth. There is considerable scope of influencing the resource use parameters of the new housing stock – both at the government and private sector. CREDAI is the association of the builders and developers and have 3000 membership that covers 80 per cent of the real estate development in key 13 states of India. It is also important to note that urban poverty in India remains high at 25. Pune. The private sector real estate developers are expected to be very important players. this segment is expected to be an important driver for resource guzzling in cities. Alternatively. Besides other cities like Jaipur. The NCR will lead the pack followed by Bangalore and other major cities. These disparate data do not allow comprehensive assessment of the real estate development. Almost 80 percent of the projected demand will be in 7 major cities in India that include National Capital Region of Delhi. Yet again it is hard to get comparable and composite data for commercial space. Bangalore. Cushman & Wakefield’ also estimates that pan-India cumulative demand projection for real estate sector for 2008-2012 is 1. Hyderabad. ft (built-up area). According to the Indian Brand Equity Foundation the stock of commercial office space in India in 2006 was 45 million Sq ft and retail space was 19 million sq ft. Retail and Commercial Space: Even though the retail and commercial space is comparatively smaller than the residential space and stock. Various estimates exist that provide the indicative trends. NCR will witness such gregarious growth largely because of the emergence of the business districts like Gurgaon and NOIDA and concentration of corporate firms. For instance. It has also been pointed out by ‘Cushman & Wakefield’ that real estate development during 2008-2012 will also be very concentrated in just a few mega cities of India.THIRD DRAFT income categories. 8 . Even though these are not expected to be resource guzzlers the new housing stocks even at low and moderate income group have enormous potential for innovative housing designs to make it resource efficient for the poor and the government should shoulder that responsibility. There are also small time developers who need to be influenced as well. For the rest the market forces are expected to take over. 75 per cent of the urban population in India is in the bottom rung of income level.94 Sq.

There are disparate and fragmented indicative estimates of environmental impacts of buildings. retail expansion will be phenomenal. changing dynamics of Indian realty sector. For any regulatory instrument dealing with mitigation of environmental impact of buildings to be successful will need clarity about the nature of these impacts. and climate impacts. waste and pollution. as per the estimates of Ernst & Young.3 million sq ft until 31st December 2008 90 80 70 Area in million Sq ft 60 50 40 30 20 10 0 Bangalore NCR Chennai Mumbai Pune Hyderabad Kolkota Ahmedabad Commercial Retail Retail sector will see prolific growth. traffic related air pollution and congestion. In fact NCR will hog 20 per cent of the future demand and Mumbai about 16 per cent (see fig 2: Cumulative real estate demand). But the rate of increase will be very high in Hyderabad. The aggregated impacts of buildings have not been estimated for India. With the share of organized retail likely to increase to USD 30 billion by 2010. RESOURCE IMPACTS OF BUILDINGS Environment impact assessment will have to address widely divergent environmental concerns that have centered on buildings – energy and water guzzling. 2008. Cushman & Wakefield. Buildings are complex ecosystems that have many aspects of resource use and Fig 2: Cumulative real estate demand upto 2012 Cumulative real estate demand upto 2012 by sectors 120 Commercial 100 Area in million Sq ft 80 60 40 20 0 Bangalore NCR Chennai Mumbai Pune Hyderabad Kolkota Residential Retail Hospitality Source Anon.THIRD DRAFT Fig 1: Building stock in cities Buildings stock of 353. The metamorphosis. Chennai and Bangalore. May 9 .

bio diversity. At the same time it causes 40 per cent of carbon emissions. Globally. By 2030 cities will be consuming 73 per cent of world energy. There is still a big difference in CO2 emissions between big and small cities in India which is a reflection of the difference in energy consumption pattern (see Fig 4: Total CO2 equivalent emissions Fig 3: Burden of Built Environment Share of built environment in resource use 40 40 30 Percentage 30 20 20 10 0 Energy use Raw material use Water use Resources Land 20 Share of built environment in pollution emission 40 30 20 10 0 CO2 emission Solid waste generation ater effluents Source: Anon. June 2009. and 20 per cent of water effluents. 20 per cent of water use and 20 per cent of land use. water. energy demand is expected to grow more rapidly in cities due to growth in urban population. BUILDINGS AND ENERGY LINKAGES Building and energy linkages have drawn more attention of late given the raging global concerns over climate impacts of cities and energy security. lifestyle changes. Green Buildings – an overview. While we recognize that each of these aspects of buildings will require very careful impact assessment illustratively we have carried out a more detailed analysis of energy and water impacts of buildings to illustrate the regulatory challenge.THIRD DRAFT waste generation – energy. The World Energy Outlook 2009 states that already two-third of world’s energy is consumed in cities – by half of world’s population. Capacity Building Series (2008-2009). Limited evidence shows building can be responsible for 40 per cent of energy use. TARA Nirman Kendra. India mirrors this trend. New Delhi Percentage 10 . (Fig 3: Burden of built environment) Each of these will require clear assessment. 2008. air and so on. 30 per cent of solid waste. land. and increase in the level of economic activities. 30 per cent of raw material use.

08 3. IV (7 city) Cat.68 8. published by ICLEI. retail and hotels are high end users of energy. Pattern of energy use in Indian buildings: What is the general pattern of normal energy use in buildings in India? In India Bureau of Energy Efficiency that is responsible for energy regulations for buildings has come up with typical values for different climatic zones of the country and for different building usage. II (3 city) Cat.A. No Building of category was available in the buildings surveyed Source: Bureau of Energy Efficiency. This difference will get further accentuated with the future development of the real estates in cities and concentration of household demand.31 27. 11 . (million 8 tonnes) 6 4 2 0 Total CO2 equivalent emissions (million tons/ annum) classified according to different population classes of cities Cat. I (1 city) Cat. British High Commission and Census of India 2001 for city population data (million tons/ annum) classified according to different population classes of cities).THIRD DRAFT Fig 4: 10 Average CO2eqv.2 (324) (400) NA NA NA 11. Climatic conditions have a strong bearing on the usage of energy and therefore it is important to consider these factors (See table 2: Typical energy consumption in buildings – climatic zone-wise and building-use-wise).14 (199) (165) (93.55 15. BEE has not generated good data on residential buildings which is yet not in their regulatory focus. Table 2: Typical energy consumption in buildings – climatic zone-wise and building-use-wise Building Category Office Shopping Mall IT Park Hotel Hospital Residence Climatic Zone wise Typical Energy Consumption kWh/ft2/yr (In bracket in kWh/m2/yr) Temperate Warm & Humid Composite Hot & Dry 18.43 15. Shopping Mall is W&H zone was not full AC N. V (16 city) Cat. III (6 city) Cat.62 45. The typical values show that office.36 8. IT Park in temperate and W&H zone were not fully functional b.87 (306) (164) (301) (128) 10.13 NA 37. But residential buildings are expected to have a very broad bandwidth given the range of low cost housing to high income housing.39) (87) 28.96 11.7 (126) 15-30 Note: a.14 NA (108) (39) (485) NA 30. VI (7 city) Source: Based on data provided in ‘Energy and Carbon Emission Profile of 53 South Asian Cities’.

THIRD DRAFT According to BEE most commercial buildings in India have energy performance index (EPI) of 200 kwh/sqm/year or higher. and growing at the rate of 8 per cent per annum. Overall the residential sector in India is a significant user of primary energy. Fig 5: Primary Energy by User (including biomass) 2004 20. This poses serious challenge for both energy and climate security.000 0 10% 39% 5% Final 9% Primary 12% 37% 6% 34% Service Industry Transport Residential Agriculture Primary electricity is equal to the electricity consumed directly and the indirect energy use that was necessary to produce the electricity.000 16. It is possible to select materials and architectural designs that can help to improve thermal efficiency of the buildings and reduce energy use. Other estimates show that the share of residential sector can be as high as 33 per cent and the energy consumption may increase 10 percent annually in the future. With such high share of electricity consumption unfettered energy consumption in the building sector can have serious implications. Clearly therefore energy inefficiency is getting locked up in Indian building sector. The direct use of energy in building operations for instance varies between residential and commercial buildings (see fig 7: Energy consumption by usage in 12 .000 6% TJ 12. BEE considers 180 kwh/sqm/year as the typical national average and states that the buildings in North America and Europe have EPI of less than 150 kwh/sqm/year due to overall efficiency gains.000 4. If only electricity consumption is considered then the residential sector uses up 23 per cent of the electricity (see fig 6: India’s Primary Electricity Consumption). About the highest is consumed by the residential sector — 37 per cent (see fig 5: Primary Energy by User (including biomass) 2004). Fig 6: India’s Primary Electricity Consumption Agriculture (31%) Industrial (36%) Transportation (3%) Residential (23%) Comercial (7%) Source: EDS What affects energy consumption in buildings?: Energy consumption in buildings needs to be understood in terms of embedded energy that varies according to the building material as well as direct use of energy during building construction and operations phases.000 35% 8.

cooler. highest efficiency electric appliances energy consumption for heating. TV etc dominate. The energy audits of buildings so far carried out by the BEE shows that existing buildings have 30 to 50 percent energy savings potential. A/C. But detailed mapping of energy use by nature of appliances and building design will demand regulations that will drive quick uptake of energy efficient appliances and building design.THIRD DRAFT Fig 7: Energy consumption by usage in commercial and residential buildings Residential buildings 116 billion units Others (10%) TV (4%) Lighting (28%) Refrigeration (13%) HVAC (32%) Lighting (60%) EV Cooler (4%) Fans (34%) A/C (7%) Commercial buildings 33 billion units Others (8%) Source: Bureau of Energy Efficiency commercial and residential buildings). BEE found that energy use at an EPI of 605 kWh/m2/year in a typical new hospital can be brought down to 312 kWH/m2/year. One of the recent 2010 McKinsey estimates shows that the national power demand can be reduced by as much as 25 per cent in 2030 by improving energy efficiency of buildings and operations. The energy use of buildings can be indicated by the Energy Performance Index (EPI) in terms of energy used per unit area per year (kWh/m2/Year). In commercial buildings lighting. A/C is still a small contributor given the modest lifestyle and dominance of low cost housing stock. Energy saving potential in buildings: Regulatory tools need to maximize the energy savings potential of the buildings. More estimates from EDS shows significant potential of GHG savings from energy conservation measures in building usage – 24 per cent from lighting and 12 per cent from AC etc. The BEE assessment shows that over 50 percent improvement is possible in commercial buildings. in residential buildings lighting and fans use up the maximum energy. Similarly in a typical office building EPI can be reduced from 186 to 86 kWh/m2/Year. In fact. Studies have also begun to appear on the potential GHG savings from energy efficiency improvement in the building sector in India. Fans are the highest at 34 per cent followed by lighting at 28 per cent. fans. But in residential buildings lighting. heating. With improved and optimized insulation. and air conditioning dominate the energy consumption. Only lighting and air conditioning can account for 80 per cent of the energy consumption in typical commercial buildings. Range of use is more diverse in residential buildings. ventilation and air conditioning. refrigeration. energy 13 . It has now been fairly well demonstrated that significant energy saving is possible from building construction and operations. ventilation. For example. Assessment of the BEE data shows that various energy efficiency measures will help to improve energy performance of buildings (see fig 8: Impact of energy efficiency measures on the EPI of commercial buildings).

As surface water source is getting severely stressed dependence on ground water is increasing. Regulations need to target water usage both during the construction phase as well as operational phase. Water deficit will be a serious constraint in Indian cities that will also constrain the urban building sector. class-I and class-II cities are dependant on groundwater either fully or partially. 14 . Building and water linkages Yet another key resource impact of buildings is water both as intake and waste. The best known example is of Chennai where faced by severe constraints in supplying adequate water. Regulations will also have to ensure that energy saving action remains dynamic in post construction phase as well. Regulations will have to be designed to ensure maximum water savings and waste minimization in buildings. the agency has resorted to procure ground water from far off distant places. National Institute of Urban Affairs (NIUA) study of 2005 concludes that 56 per cent of metropolitan.THIRD DRAFT Fig 8: Impact of energy efficiency measures on the EPI of commercial buildings (office and hospital buildings) EPI = 186 kWh/m2 per annum Envelope optimisation EPI = 605 kWh/m2 per annum Envelope optimisation EPI = 593 kWh/m2 per annum Lighting optimisation EPI = 165 kWh/m2 per annum Lighting optimisation EPI = 120 kWh/m2 per annum HVAC optimisation EPI = 476 kWh/m2 per annum Efficient chiller EPI = 98 kWh/m2 per annum HVAC controls EPI = 346 kWh/m2 per annum Controls for HVAC system EPI = 92 kWh/m2 per annum Daylight integration EPI = 312 Source: EDS. But role of regulations becomes very important in ensuring adoption of these features to achieve best possible thermal efficiency and meet energy performance index. There are many ways a building can save energy – by adopting energy efficient building design and appropriate building material. Majority of urban areas are increasingly using groundwater to meet their water requirement (see fig 9: Dependence on ground water increasing in cities). innovative and energy saving operational features and energy efficient electrical appliances opt for in-situ renewable energy and so on. this is not adequate and in many cases irregular. It is within this reality that the future building sector will take shape in Indian cities. 2010 kWh/m2 per annum EPI = 86 kWh/m2 per annum consumption can be reduced by 55 per cent – this can cut 150 million tonnes of CO2 by 2030. If this trend continues it can have severe environmental consequences. Therefore. this paper will assess the effectiveness of the EIA regulations for the large buildings in achieving these objectives. Though a majority of households in major cities in India depend on the municipal water supply for their daily needs.

Jamia Millia Islamia.ii This demand can also be further reduced with the use of modern technologies like membrane curing and sprinkler techniques. A. brick-soaking. adding on to the strength of the structure. concreting. June 30July 19. (Table 3: Water Requirement for Various Grades of Concrete) Curing and mixing of concrete is one of the most water intensive phases in the building construction process. as soon as it has set which traps the moisture in it and prevents the erosion of moisture. Similarly. amount and quality of cement. sprinkler system can be used. Water demand is generally 10 to 20 percent of the total volume of brick and concrete used in a buildingi. masonry. The quality of water used during this stage is vital as contaminated water can affect the lifespan of the structures. 2008. A chemical application is done on all the exposed surfaces of concrete. This would help prevent loss of water by evaporation and avoid water reboundiii. In: UGC-Summer Programme. Concrete structures can also be covered with thin cloth or gunny bags and then water should be sprayed on them. water is primarily used in the concrete mix to start the hardening process through the hydration of cement. Similar to concrete. The total water requirement for the composition of concrete mix is dependent on the aggregate size and shapes. 2008. well graded versus gap graded mixes of concrete and admixtures. Instead of pouring water over concrete structures. Actual pattern of water use during construction phase will vary across building types. Water Poverty in Urban India: A Study of Major Cities. curing. Regulations will have to address both for maximum gains. Building construction phase: Water is a very essential element in the construction phase of any building which uses concrete and brick as its building materials. Also the quantity is an essential measure as excessive water can cause a loss of strength in the concrete. New Delhi What influences water usage in buildings? Water is intensely used during both construction as well as operational phase. to laying of roofs and flooring require intensive use of water. All stages in the construction industry starting from the foundation.THIRD DRAFT Fig 9: Dependence on ground water increasing in cities Source of water in households (per cent) in selected cities Dependence of household on various sources of water 120 Percentage dependence of household 100 80 60 40 20 0 All 7 cities Delhi Mumbai Kolkota Hyderabad Kanpur Ahmedabad Madurai Cities e e w en e se w e se e ete e w w se uo t e ete w e Source: Shaban. whitewashing. bricks are soaked in water for some time before laying to make the 15 .

Clearly. Part 6. Max M5 M7.5 M10 M15 M20 Generally 1:2 but subject to an upper limit of 1:1. (see table 4: Norms and Standards of Water Supply in India). laundry fixtures (washing machines) and kitchen facilities (such as sinks and dishwashing machines). which is collected through fixtures such as toilets and urinals. Bureau of Indian Standards. type of sewerage system etc.5 60 45 34 32 30 Source: National Building Code of India 2005. ranging from rural urban. blackwater and stormwater. Section 5A. 135 lpcd (litres per capita per day) is considered a standard norm in India for average water consumption prescribed by the Central Public Health and Environmental Engineering Organisation (CPHEEO). Norms for water usage has evolved in India. The average requirement has been calculated based on various parameters and for various categories. while. 16 . type of toilet. In UK for instance 80-100 lpcd is seen as the desirable target in residential buildings. Table 9. to be taken as the Sum of the Individual Masses of Fine and Coarse Aggregates. New Delhi walls for additional strength. Potable water is the drinking water. At present.THIRD DRAFT Table 3: Water Requirement for Various Grades of Concrete Grade of Concrete Total Quantity of Dry Aggregates by Mass per 50kg of cement. But in India often policy clarity on these targets is missing and policies often try to set higher consumption target contrary to goals of sustainability. showers and baths). Blackwater contains ‘waste discharges from the human body. Several organizations and agencies have attempted to estimate the average basic per capita water requirement per day for an individual. Building regulations will have to address all types of water and wastewater categories in buildings — greywater. Builders are advised to reuse and recycle the water in construction sites to reduce the fresh water use. Water use in building operation phase: A great part of water is used during the operational phase of the buildings as it is directly related with lifestyle of the occupants. kg. impervious surfaces and drainage systemsiv. while stormwater refers to runoff due to rainfall collected from roofs. Page 19. as global experience shows policies are designed to lower per capita usage of water without compromising the basic and hygienic requirements. size of the city. greywater is the domestic wastewater from bathroom fixtures (taps. regulations need to play an effective role in ensuring that sustainable water efficient practices are adopted in building construction. But the fundamental element that requires monitoring and evaluation is the per capita water usage in building to ensure that there is no water guzzling and at the same time enough water is available to meet the essential hygienic standards. It also provides a break up for 135 lpcd in a standard residential unit for various functions (see fig 10: Break-up of 135 lpcd Water) But clearly.5 and a lower limit of 1:2. Max 800 625 480 330 250 Proportion of Fine Aggregate to Coarse Aggregate (by mass) Quantity of water in litres per 50 kg of Cement.

Govt. For example. 1973 Zakaria Committee (ZC on Augmentation of • Small: 45 Ipcd Financial Resources of Urban Local • Medium: 67. undertaken by researchers from Tata Consulting Engineering in Mumbai shows an average family of five in Mumbai consumes about 920 liters per day. Third Edition – Revised and Updated.5 Ipcd Bodies. 1963. Maintaining Gujarat Municipal Services A Long Range Perspective. 1983 • Public stand Posts: 25-70 lpcd (average 40 lpcd) Basic Minimum Services Under Minimum 100 per cent coverage by safe drinking water in urban areas. The average was derived on the basis of a small survey conducted in sample households in a posh Mumbai locality and the breakup of the household Fig 10: Break-up of 135 lpcd Water Consumption eny ko ele en ko eny ko en ko en xko Source: Anon. 1999. Needs Programme. 1981-90. Government of India. Ministry of Works & Housing. • With Sewerage: 125 lpcd Government of India. TCPO. No 1 Physical Standard • Small cities: 70-100 Ipcd” • Large cities: 150-200 Ipcd • Public stand Posts (PSP): 40 Ipcd National Master Plan (NMP). • Large : 157. Central Public Health and Environmental Engineering Organisation. 1974 Committee on Plan Projects for Industrial • 180-225 Ipcd Townships (COPP).0 Ipcd Operations Research Group (ORG). 2003 Source: Compiled from various sources Implementation of these norms is critical to modify the water consumption patterns in Indian household especially as there is wide variability in the actual water consumption pattern in Indian cities. 1987 • Super metropolitan: 270 lpcd • Small: 80 lpcd • Medium: 80-150 lpcd • Large: 180 lpcd • Small: 95-125 lpcd • Medium: with Industrial base . 1991 2 3 4 5 6 7 8 9. 9th Five Year Plan. 1997-2002 (1999) • Without Sewerage: 70 lpcd • With spot sources & public stand posts: 40 lpcd Report on Norms and Space Standards for Planning Public • 180 Ipcd Sector Project Towns.112.150 lpcd ■ Problem areas: 90 lpcd.THIRD DRAFT Table 4: Norms and Standards of Water Supply in India S. Ministry of Urban Development. 1989 National Institute of Urban Affairs (NIUA). New Delhi 17 . a study.5 . of India. Delivery and Financing of Urban Services. which amounts to 184 LPCDv. Manual on Water Supply and Treatment. World Health Organization (WHO). ■ Average: 80-150 lpcd • Large: With Industrial base 170-210 lpcd ■ Problem Areas: 120-125 lpcd ■ Average: 115-210 lpcd • no access (water available below 5 lpcd) • basic access (average approximately 20 lpcd) • inter-mediate access (average approximately 50 lpcd) • optimal access (average of 100-200 lpcd) Agency Manual on water supply and Urban Deve lopment.5-202. India. House connections: International Water Supply and Sanitation • 70-250 lpcd (average of 140 lpcd) Decade. MoUD.

Regulations will have to control guzzling and ensure more equitable distribution of water amongst households. taps and showers devouring more than 60-70 per cent of total water use. S.4 6. On an average. D. less than 10 per cent of the total water in a household is used for 18 . bathing consumes highest amount of water. S. Fig 11: Daily Water Use for an Indian household Daily water use for an Indian household 1000 Litres per day (household of 5 members) Water use (in litres) 800 600 400 400 212 200 0 Showers Running taps in Kitchen Laundry Purpose Source: Shah. Consumption in toilets (20 per cent). But together they help to illustrate a range (See box 1: Varying estimates of per capita water consumption in India). It is from this perspective that the environment impact assessment regulations for the high end buildings become important. it consumes about 28 per cent of the total water at household level (see fig 13: Average Domestic Water Consumption for Various Activities).4 28 135 27 Toilets 32. washing clothes (19 per cent) and washing utensils (16 per cent) follow the consumption in bathing. Broadly studies show that toilets and bathrooms are the biggest water guzzlers in a house. To a great extent building related water management strategies will play an important role. provides some sense of water use for various purposes. The study. Very few instutionalised attempts have been made to compile and analyse patterns of water use in buildings that can be brought within the policy focus. namely (i) high income group (HIG) areas with well planned buildings. laundry. Together. toilet and leaky fittings (see Fig 11: Daily Water Use for an Indian household ). building types and total water consumptionviii. (ii) middle income group (MIG) areas with well planned buildings. A study on Water Poverty in Urban India in 2008 by Abdul Shaban from Tata Institute of Social Science (TISS). categorized and surveyed the selected seven cities in five different areas. and Panda. Mumbai. and (v) the mixed areas.THIRD DRAFT consumption provides usage pattern for Basic Water Requirement (BWR) like showers. Water Audit – Need of the Hour. India 920 Litres per capita per day (LPCD) 80 140 42. Tata Consulting Engineering. with flushes. Pattern of water use in households: Regulations will have to address pattern of water usage by the nature of usage in households to promote water efficiency and conservation measures. (iii) low income group (LIG) areas with well planned buildings. Thakar. (iv) slum areas. It is very clear from the study that at the household level. involved survey of over 2500 households across seven major cities. 2009. faucets. It also brings out starkly the challenge of two extremes – very low water availability at one level and also water guzzling at another. There are varying estimates.48 184 Leaking fitting Total It is not easy to arrive at any clear baseline for per capita water consumption in Indian cities. in all the seven cities.

2 77.4 115. Kanpur. More data has come from individual research projects. the availability of water is even less than 100 liters per capita per day. Mumbai (191 lpcd). Vijaywada (158 lpcd) and Varanasi (147 lpcd). Similarly. The study further details the cities registering average per capita consumption as high as Jamshedpur (203 lpcd). A 2007 survey conducted by the National Institute of Public Finance and Policy (NIPFP) shows that in a sizeable number of urban centers. Delhi (78 lpcd). June 30.7 per cent of sample municipalities are reported to supply over 100 liters of water per capita per dayvi.56 377. This shows promotion of water efficiency standards for water appliances and the right pricing signals can help to reduce water usage. Local regulatory action in these cities will be critical in achieving targets. the average per capita water consumption in domestic households for seven cities – Delhi. Mumbai (90 lpcd). cities like Amristar.July 19.1 Per capita Source: Shaban. followed by Hyderabad (96 lpcd).7 406. The highest consumption is in Kolkata (116 lpcd). On the other hand. as only 2.2 391.1 95 88.THIRD DRAFT BOX 1: VARYING ESTIMATES OF PER CAPITA WATER CONSUMPTION IN INDIA Many estimates exist on the average per capita water consumption across India. which also displays a similar picture. A. Madurai (88 lpcd). New Delhi drinking and cooking. 2008.8 383.6 96. Ahmedabad (95 lpcd). The figure Per Capita Supply to the Total Population in Various Indian Cities reiterates that different estimates per capita water consumption are made by different agencies. and Kanpur (77 lpcd) (see Fig 12: Domestic Water Consumption Per Household and Per Capita). the study provides a cross section of activity wise water consumption across the seven surveyed cities (see Fig 14: Activity-wise Distribution of Water Consumption in Seven Indian Cities ). Domestic water 398. 15: Per Capita Supply to the Total Population in Various Indian Cities).3 19 .7 410. Water Poverty in Urban India: A Study of Major Cities. Indore.9 363. In: UGC-Summer Programme. with bathing.2 91. According to Ministry of Urban Development (MoUD) and Asian Development Bank’s (ADB) study titled. Chennai registered figures between 85-90 lpcd and Bhopal’s per capita was lowest at 72 lpcd. washing clothes. is about 92 lpcd. Jamia Millia Islamia. Ahmedabad. toilets and kitchen activities (excluding cooking) consuming the majority of water. 2008. The variation in per capita household water usage also shows up as a pattern across cities and shows wide variation across cities (see Fig. Benchmarking and Data Book of Water Utilities in India in 2007vii states that the average daily per capita water consumption is about 123 lpcd. and Madurai. Fig 12: Domestic Water Consumption Per Household and Per Capita Domestic water consumption per household and per capita Per household consumption (in litres) 500 400 300 200 100 0 Delhi Mumbai Kolkata Hyderabad Kanpur Ahmedabad Madurai Cities Total 78 90.8 443. Kolkata. Hyderabad. Mumbai. According to the survey by Abdul Shaban of Jamia Millia Islamia in 2008.

2008. Jamia Millia Islamia. Government of India 20 Kanpur Kochi 0 171 176 160 . New Delhi Fig 14: Activity-wise Distribution of Water Consumption in Seven Indian Cities Activity wise distribution of water consumption in cities e Percentage of total consumption by 40 e e 30 households/day 20 10 0 All 7 cities Derlhi Mumbai Kolkata Hyderabad Cities Kanpur Ahmedabad Madurai Source: Shaban. 2008. In: UGC-Summer Programme. Water Poverty in Urban India: A Study of Major Cities.THIRD DRAFT Fig 13 : Average Domestic Water Consumption for Various Activities Water consumption in domestic activities Percentage of water 30 consumed 20 10 0 Bathing Toilet Washing clothes Washing House utensils cleaning Activity Drinking Cooking Others 28 20 19 16 7 4 3 2 Source: Shaban.July 19. 2005. June 30July 19. Jamia Millia Islamia. Status of Water Supply. New Delhi Fig 15: Per Capita Supply to the Total Population in Various Indian Cities Water supply in cities Own norms (LPCD) Litres per capita per day (LPCD) 300 227 225 218 240 268 250 Water supplied (LPCD) 283 270 140 139 180 171 191 Varanasi Visakhapatnam 65 Pune Nagpur Surat Vadodara 131 200 149 180 170 200 124 150 124 170 139 140 141 150 180 173 200 150 160 164 164 200 110 106 108 114 110 Lucknow Ludhina Madurai 88 100 Greater Mumbai Kolkata Bangalore Chennai Bhopal Indore Ahmedabad Hyderabad Jaipur Derlhi Coimbatore Cities Source: Anon. Water Poverty in Urban India: A Study of Major Cities. June 30. 2008. In: UGC-Summer Programme. 2008. Sanitation and Solid Waste Management in Urban. A. A. Ministry of Urban Development. National Institute of Urban Affairs for Central Public Health and Environmental Engineering Organisation (CPHEEO).

residential buildings in India. Table 5: Average Water Consumption by Various Building Types Category Residences (population) • <20000 • 20000 – 100000 • >100000 Hospitals • < 100 beds • >100 beds Hotels Offices Restaurants Cinemas/ theatres/recreation Centre Schools Day school Boarding school Quantity (lpcd) 70-100 100-150 150-200 340 450 180 45 70 15* 45 135 * Indicates water consumption/ seat Source. institutional and commercial purposes the nature and extent of The National Building Code (NBC) for India enlists the water supply requirement for various building types (see Table 5: Average Water Consumption by Various Building Types ). The National Building Code prepared by BIS provides water requirements for residential buildings (see Table 6: Water Requirement in Buildings (Residences). .National Building Code of India 2005. Water saving potential in buildings: There are very few studies on the potential of water use reduction and conservation in commercial. 1 Population upto 20000 without flushing system Water Supply a) through stand post: 40 lphd. These figures are crucial since NBC is followed across India and provision of basic amenities is provided accordingly. Type of building usage will also determine the nature of interventions. residential etc. The fig 16 demonstrates the nature of activities in building or building types (commercial. Litres per head per day (lphd) can be equated to litres per capita per day (lpcd) Source.THIRD DRAFT In buildings meant for residential. states that hotels use considerable quantity of the water drawing mainly from the deep tube wells or from municipal supply. A case example from hotels.) is central to the quantum and categories of water useix. Min b) through hourly service connection : 70 to 100 lphd 100 – 150 lphd 150 – 200 lphd* 2 3 population 20000 to 100000 together with full flushing system for communities with population above 100000 together with full flushing system Note: * the value of water supply given as 150-299 LPHD (litres per head per day) may be reduced to 135 LPHD for LIG & EWS houses depending on the prevailing condition. New Delhi Table 6: Water Requirement in Buildings (Residences) S. New Delhi 21 . Bureau of Indian Standards. Regulations will also have to respond to these diverse patterns to influence decision of water usage by type of buildings.National Building Code of India 2005.No. Bureau of Indian Standards.

Several water uses may be discontinued or reduced in response to the 22 . In India there is considerable scope for efficiency improvement and conserving water through efficiency measures in buildings. Water efficiency also involves conserving water by operationalising water saving technologies and actions (see fig 17: Potential water savings in an Indian household by installing water efficient fixtures). dishwashing. cooling towers and landscape irrigation can reduce water consumption by installing water efficient fixtures. cost savings on water bills. Low availability of water or shrinking supplies is a strong determinant of water use in buildings. helps to prioritise areas for subsequent actions and strategies required within the building. Saleem India Blog Countries like Australia. For instance. end use pattern and amount etc. and that change in human behaviour or production patterns could increase those savings further. TCE’s household survey in Mumbai also provided a rough estimate of amount of water saving that can be achieved if simple replacement or installation of water efficient fixtures is adopted (see table 7: Average water savings in an Indian household by installing water efficient fixtures). According to the American Water Works Association. A study on European water saving potential commissioned by the EU executive and published in August 2007 estimates that water efficiency could be improved by nearly 40 per cent via technological improvements alone. S.THIRD DRAFT Fig 16: Water Consumption and Waste Generation in Hotels Kiololitres/day (KL/day) 300 200 100 0 Drinking water Toilets Kitchen Laundry Air Garden Swimming Fire conditioners pool fighting Various processes Boiler Consumption (KL/day from municipality & deep tubewells) Distance (KL/day into municipal sewers & drains) Source: Imdaadullah. water efficient appliances can play an important role. Commercial buildings with very high water usage in commercial laundry. In the Indian context. But each of these strategies will have to be clearly assessed to design interventions. The benefits of implementing water efficiency initiatives in buildings may include. 2008. But. households can reduce daily per capita water use by about 35 per cent by installing more efficient water fixtures and regularly checking them for leaks. Environmental Management in Hotel Industry. water efficient fixtures are just one of the many aspects in building’s water conservation and efficiency improvement. Singapore and USA have assessed water use and its patterns for effective strategies. This is important since information and data on total consumption. Regulations can also help to influence a range of decisions on water usage. water conservation and improving the image of the a business/building as a water efficient facility.

high pressure or corrosion. water consumption can be efficient even if the water supply is regular and adequate. if the building has undertaken water conservation and efficient designs. For examples. Water use in Commercial Buildings-where does it all go?.000 litres annually. Certain areas in the building generally have high leakages which include cooling towers. Central to water conservation and efficiency improvement is that freshwater withdrawal and consumption is reduced that is.3 Source: Tata Consulting Engineering 2009 * Family size considered is five Fig 17: Potential Water Savings from Installed Efficiency Devices Landscape irrigation Cooling tower conductivity controller Low flow faucet aerator Low flow shower head High efficiency toilet Water efficient commercial dish washer Water efficient pre rinse spray valve X ray recycling system Stream sterilizer High efficiency cloths washer (common-area laundry) Tunnel washer (industrial laundry) Efficient washer extractor (on-premise laundries) Efficiency device 0 20 9 31 61 35 21 26 26 61 36 31 41 20 40 60 Potential savings Source: Ezell. faulty washers/handles. Often leakages go undetected either due to lack of maintenance. For example. doing more with less.THIRD DRAFT Table 7: Average water savings in an Indian household by installing water efficient fixtures Purpose Showers Running taps Laundry Toilets Fittings Total Water that can be saved in liters/day* 200 106 14 60 32 415 Water that can be saved in liters/Week 1400 742. which is a very significant amount. On the other hand. taps. a modest leak figure of 3 litres/hour on a 24*7 basis can lead to water loss in the tune of 26. insensitivity or/and sheer ignorance. waterscapes. waning. C. 2009 51 80 51 75 68 80 108 51 61 80 100 120 declining supplies. So essentially. cistern flapper. Leakages generally occur in old fixtures and fittings due to aging. in buildings may be suspended during summer months when water is in severe shortage. hose reels.8 2889. building’s water consumption is subject to supply and demand management measures.5 100 420 226. urinals. There are 23 . This amount is equivalent to the average Canadian household water use for a monthx. underground pipes and control valves. Often water loss due to leakage can be in the range of 10-30 per cent and may gradually increase over time. Fix leakages in buildings to cut losses: Another important component that is generally overlooked is fixing leakages in the buildings. fountains etc.

Finally.2 15. A. Jamia Millia Islamia.3 20 15 10 5 0 Below 50 50 to 75 75 to 100 100 to 135 17.3 4. Some of the activities that become a way of life as individuals/households climb on the income level. with increase in family members in a household. Second.8 2.4 21.5 23. This rapid review of the building and water linkage brings out the gamut of complexity that the environment impact assessment rules will have to address. Need efficiency signals for rich households: Another key big challenge for the regulators is to push for efficiency measures in rich households where life style is responsible for water guzzling. uses which would have otherwise used freshwater.3 135 to175 Above 200 Litres/capita/day Source: Shaban. Water Poverty in Urban India: A Study of Major Cities.2 26. These sources of freshwater if harvested and captured can provide ample water for a variety of purposes. 2008.July 19. bath tubs etc. with lower levels of water supply and consumption including due to basic lifestyle.1 1.THIRD DRAFT three ways generally to achieve this ultimate goal in water conservation.4 6. Besides this per capita consumption of water is also dependent on the household size.9 7.2 30 25 19.5 8.5 19. Generally. swimming pools etc.9 2 2. horticulture. household size of a slum and a low income family would be higher.5 35 Percentage distribution of household 26. New Delhi 24 24 . The TISS study on water in seven cities concludes that the richer households and households with higher education level have higher consumption of water.7 3. flushing etc. is to augment the water supply through measures like rainwater harvesting and storm water management.4 175 to 200 1.7 20.8 21.2 20 12.4 22. June 30. is to improve efficiency by installing and retrofitting water efficient fixtures in place of the high water consuming ones. water conservation measures and techniques including both technical and behaviourial. which fall under these three broad aspects can improve water saving potential of a building. In: UGC-Summer Programme. dishwashers.8 16. per capita water consumption tends to declines. First. landscape irrigation. which includes multiple toilets with showers. (see fig 18: Area and Water Consumption Category-wise Distribution of Household in Percentage).. Thus.6 8. car washing. recycling and reusing wastewater for construction. washing machines. 2008. Fig 18: Area and Water Consumption Category-wise Distribution of Household in Percentage Area and water consumption category-wise distribution of household High income group area with well planned buildingf Middle income group area with well planned building Low income group area with well planned building Others (amixed area) 23.4 31 13.

mining and big infrastructure projects. the impact on land. Such conflicts and adverse consequences will only multiply in the future if not addressed with appropriate impact assessments tools. This regulation is expected to internalize the country’s resource management and development planning to reduce the impact on environment. While all these aspects will require very diligent impact assessment this paper intends to highlight a very new area of impact that has not got much attention so far – traffic impacts of buildings. high impact buildings that are more gregarious in their resource needs and use. cycling and walking. Following this classification buildings have come under Category B that includes all building and township projects whereas Category A includes industry. and traffic for resource conservation and for reducing developmental impact on the environment. and are expected to influence a large part of the building sector (See Annex 1 on key green building regulations). and adding to congestion has added this very serious dimension to the impact assessment of buildings in cities. energy waste. water and waste. This report examines the key question if EIA is effectively addressing the concern? The EIA. EIA presents that opportunity.THIRD DRAFT ADDRESSING OTHER IMPACTS OF BUILDINGS Buildings are now microcosm of the urban ecosystem. has been amended from time to time and in 2004 EIA ambit was extended to cover buildings. This is especially true for large commercial buildings that induce additional traffic in the neighbourhood. if designed well. Multiple policy tools have begun to take shape in different resource sectors of water. new townships and industrial estates. ENVIRONMENT IMPACT ASSESSMENT FOR BUILDINGS: IS IT DELIVERING? In view of the big picture challenge of the building sector an attempt has been made to assess the policy drivers that can influence resource use in buildings. This has already resulted in tension and conflicts.000 sqm and less than 1.xi After 2006 amendment all projects and activities covered under EIA are broadly categorized into two categories – category A and category B. The EIA comprehensively addresses all aspects of resource use and waste generation in buildings and targets the most high end. air quality and the surrounding neighbourhoods can be drastic if not modified with regulatory discipline.50. introduced as an administrative measure in 1994 under the Environment (Protection) Act. The growing motorization and the ever worsening mobility crisis in which personal vehicle usage is marginalizing the public transport. This is already becoming a serious cause of tension in many localities of our cities. Within Category B all building and construction projects equal to or more than 20. Their impact of urban environment is intense and complex. based on the potential impacts on human health and natural and man made resources. One illustrative case is the law suit filed by the resident welfare association of one of the posh colony in Delhi – Greater Kailash against the Savitri commercial complex on grounds of its congestion effect.50. But this report examines only the Environment Impact Assessment (EIA) tool for the building sector. In addition to energy.000 sqm of built up area are further classified as B1 and townships covering a area of 50 ha or more and or built up area of more than 1. The large commercial buildings especially the mega shopping malls induce and attract huge amount of traffic on its access roads that can have serious detrimental impact on the surrounding neighbourhoods and also contribute hugely to the local air pollution and congestion. biodiversity. 25 .000 sqmeters are B2. substantially.

Typically. which determines whether the proposed project.’ 26 . The Buildings and township projects in category B have been exempted from the need of such detailed EIAs. carried out investigation. CSE has assessed available literature.000 sqm. thermal/nuclear plant projects.THIRD DRAFT WHAT AILS EIA FOR BUILDINGS? CSE has reviewed the EIA procedure for buildings especially for energy and water and have also examined the official information for the buildings in the National Capital Region (NCR) that have undergone the EIA process. This stage also defines the boundary and time limit of the study. officials minutes of meetings. public consultation/hearing and appraisal. Thus. mining. The process for the grant of environmental clearance for these projects is relatively less intensive and rigorous than for category A projects. The third stage involves consultations with the affected people and communities and integration of their concerns. The next stage of scoping identifies the key issues and impacts that should be further investigated. The screening procedure is also based on information provided by the applicant in an application (Form 1. But for B1 projects the Ministry of Environment and Forests is expected to issue appropriate guidelines from time to time regarding which project may require EIA. These are required to be cleared on the basis of information to be furnished in Form 1/Form 1A prescribed under the EIA rules. The four stages namely screening. no public hearing is required for buildings. B1 refer to the township projects with more than 50 ha and B2 refer to the building construction within 20. However. scoping. 1A and conceptual plan in case of construction projects. are not applied to the building sector. there is a finer division in the category B projects. requires an EIA and if it does.00. then the level of assessment required. The review of the EIA process for buildings expose systemic weaknesses as well as specific concerns related to each sector that is appraised for the environmental clearance. the detailed EIA needed for industry and mining begins with screening. Environmental clearance for buildings is different and less rigorous: The requirements for environmental clearance for buildings are different from those meant for industrial. But this has not been done so far. According to rules B1 projects – townships — may require detailed Environmental Impact Assessment report whereas ‘B2’ projects (buildings) will not. Appraisal of the EIA by various agencies like Kalpavriksh and others has also been considered. it is much simplified for the category B projects (see Annex 2. This stage is basically is to differentiate between projects belonging to category B and further B1 or B2 to be cleared by State Environment Impact Assessment Authority (SEIAA).000 sqm to 15. port. fig 3 and 4). scoping. The final stage is the appraisal stage which examines the adequacy and effectiveness of the EIA report and provides the information necessary for decision-making. public consultation and appraisal instrumental in assessing and granting of environmental clearance to the A category projects.). interacted with the key stakeholders and analyzed case studies to identify the key limiting factors that constrain the resource saving potential of this regulatory tool. Comparison shows that the EIA requirements for buildings are not as rigorous and detailed as those required for the category A or industrial projects. While the category A projects have to undergo all the four stages of EIA including screening. The category B projects only have to undergo stage 1 of screening.

Therefore. Instead of relaxing the conditions. But the concern is that even if a single unit of building has a relatively low impact compared to an industrial project. Although in the face of strong public criticism and also protests from the state governments the environment ministry had to back track and eventually drop this recommendation. In fact. mt. the building projects are constructed in multiples in an area. wastewater treatment etc. This was an attempt to extend the limit of 20. therefore the cumulative impact of the entire lot of buildings would be grave.000 sq meter meant that virtually the entire building sector would move out of the pale of the EIA regulations. A case in point is the MoEF’s January 19. Confederation of Real Estate Developers Association of India (CREDAI) an association comprising all big players of India like Reliance. mts were brought within the net of EIA. Also the successive dilution of the EIA provision for buildings over time has further reduced the system to a mere formality of forms that requires submission of minimal details on resource consumption and conservation practices. The government and the developers in the past have made continuous attempts to dilute the already weak EIA process for building and construction projects.000 sq. Weak mandate: Building industry is not required to conduct an extensive detailed EIA but instead fulfill certain requirements of furnishing basic information about their resource use according to the items listed in the Form 1 & Form 1A of the EIA rules for the clearance from the ministry or the ministry appointed state level authorities like the SEAC for each state. The association has submitted their memorandum to the Prime Minister’s Office (PMO). The municipal authorities/ town planning departments in most cities are ignoring these issues while granting the building/ site clearance.000 sq m to 50. on new projects.000 sq meters to more than 50.000 sq. Godrej. The real estate industry put their weight behind the environment ministry proposal to relax the area criteria from 20. nearly 90 per cent of the building plans sanctioned could go off the list thus numbing the effect of the regulations. Till then. This renders it as very ineffective and weak. The builders association and federation have continued to claim that buildings are low impact and that the EIA process for building projects therefore should be lenient. waste management.000 sq meters and thus make the EIA process ineffectual for buildings. of built-up area from the ambit of the Environment Impact Assessment and the Environment Protection Act 1986. DLF etc has taken up cudgels against EIA rules on buildings since the 2006 amendments when all the projects which were between the range of 20. since they are considered to have a low impact on the environment. 2009 draft notification of Environment Impact Assessment rules which suggested exclusion of construction projects that includes the housing projects.000 sq. Tata. Currently. Bharti. water harvesting.50. 27 . As there are very few projects that have area above 50. there is a need to revisit the EIA process for buildings and construction projects to make it into a stronger regulatory tool to reduce its impact on the environment. there is a need to strengthen the conditions and the clearance process to make it better. environmental clearance is the only process in which the regulator can put conditions on water and energy efficiency. The real estate development should be evaluated with respect to its cumulative impact on the environment. In fact. commercial and retail construction that are less than 50. it would remain a category in the notification purely for cosmetic reasons.000 sqm.THIRD DRAFT According to the ministry official buildings have not been included in the detailed EIA process and are limited to form 1 and 1A. mts to 1.

NGOs etc. Weak appraisal: The indicators and norms for evaluating the projects have not been properly laid down for the State Expert Appraisal Committee to perform the task.THIRD DRAFT While all this criticism helped to stop the amendment from going through the general provision on the buildings remained weak. Only. One of the most 28 . EIA in its current form is only a feeble check. this tends to be a rare or special scenario in which the committee undertakes site visits to ascertain facts.). Only basic and broad information are provided which are often not sufficient for rigorous evaluation. In 2008 the Haryana State Pollution Control Board (HSPCB) has served notices to 147 builders for failing to get environmental clearance for their housing and commercial projects before executing them. Even though a more decentralized institutional mechanism has been set up for evaluation of the projects the system is not rigorous enough to make a difference. Loopholes in the EIA notification 2006 slackens scrutiny of buildings in townships: If township projects are effectively brought under the detailed EIA requirements like the industry and as originally envisaged this will have effective impact on the individual building projects within the township. This is not possible unless some secondary information source is available (local resident. who can expose the anomalies. Escape Route: The area criteria for the buildings are not sufficient to identify the high impact buildings besides it also creates loopholes for evasion. Builders and developers tend to hide the facts in order to receive the environmental clearance and prevent derailment of their projects. This provision seems very superficial at the outset since it is purely resting on the information provided by the project proponent. Despite EIA scrutiny therefore resource intensive construction projects are proliferating in the cities in complete disregard of the carrying capacity of the neighborhoods and often without the proper permissions from the regulatory authority. But this has not been done. The project appraisal has not been legally or explicitly aligned with the established norms in the respective resource sectors like the per capita water consumption norms or the energy code for buildings etc. But due to the current confusion and lack of proper guidelines from the ministry of environment and forests there is nothing yet in the notification or the Form 1 or 1A that could stop the SEIAA from transferring all township projects to category B 2 and therefore doing away with the need for EIAs and public hearings. But. But there is no effective mechanism with the Committee to ascertain whether actual construction has started before consent has been granted. if the committee has certain doubts or can sense foul with respect to the information provided by the project proponent and ground realities. If this loophole is plugged then individual building projects in new township areas can benefit from more robust and rigorous EIA. Construction precedes consent and weakens the effect: Construction activities cannot be initiated prior to environment clearance. The only source of information for environment clearance remains to be the project proponent. the committee can ask for a site visit. The notification only vaguely states that the Ministry will issue guidelines from time to time for the categorization of B 1 and B 2 projects. Also the important issue to be highlighted over here is that all the information in the application is primarily secondary data. with little scope for the SEACC to have detailed probing in the key areas. Similarly. there is barely any attempt to get environment management plan for post construction monitoring.

Land acquisition should be permitted only after the environmental clearance has been obtained. or preparation of land by the project management except for securing the land. Thus. with project proponents producing a certificate from the relevant land development authorities.” before any construction work. even when the project has not been cleared. Paragraph 2. Monitoring. But the land acquired and proposed development should be in accordance with the master plan and as per the zones prescribed under it. This provision suggests that the applicant would have to identify ‘prospective sites’ for the project / activity before applying for prior environmental clearance. the Vasant Kunj Square Mall.THIRD DRAFT critiqued criteria of EIA 8 (a) is that buildings and construction projects with built up area of less than 20. non adherence to proposed measures would be extremely detrimental to the environment and public health. is started on the project or activity”. It is generally a prerogative of the land development authority but occasionally EC committee also refers it to the project proponents for doubts. For example. Paragraph 6 of the EIA notification -2006 states that ”prior environmental clearance in all cases shall be made ……. This is a soft spot that is often exploited by the builders and developers who may manipulate the area or create parcels to avoid environmental clearance altogether. 29 . This needs to be addressed in the wake of unprecedented building and construction projects across India. the lack of clarity and the possible implications. The actual scope of this provision is grossly undermined because paragraph 2 of the notification categorically allows for land acquisition to commence through the use of the word ‘securing the land’ as has been detailed above). It thereby suggests that in processing the application for the grant of clearances. even when no application has been made for prior environmental clearance of the projectxiii. Land acquisition in building and construction projects is generally between private parties therefore often off the purview of the land acquisition act. at the site by the applicant”.The weakest link: Without adequate provision and mechanism for monitoring and compliance the entire environmental clearance process is of little value. Land Acquisition– Prior or post environmental clearance? A serious weakness of the environmental clearance is that land is committed for the project even before the site assessment.108 sq mtrsxii. various project sites would be evaluated before one of the actually confirmed.after the identification of prospective site(s) for the project and/or activities to which the application relates.000 sq. recharge and treatment as well as the proposals for energy conservation. This is again particularly problematic in terms of the wording. The project proponents will have to be made liable to the stated targets for withdraw of water. It does not account for the fact that environmental assessment may bring out the unsuitability of the land and the site. in Delhi required no clearance since in its report (June 2006 Rapid EIA report) the total built up area was shown to be 19021. A major flaw of this provision is that a project proponent can actually start the process of land acquisition. the EIA notification -2006 requires prior environmental clearance.mtrs that are exempted from Environmental clearance may have several large capacity projects with potentially larger environmental impacts. There are no other criteria to establish the high impact of the buildings even with minor variation in area criteria. or preparation of land. before commencing any construction activity. But these are left out of the purview of environmental impact assessment process altogether.

over 2000 projects have been granted clearance across India. not of the EC committee. Since the committee has been constituted only recently in 2008 the impacts on monitoring (or rather its absence) is yet to be seen. According to Kanchi Kohli and Manju Menon’s report titled ’Calling the Bluff— “the State of Monitoring and Compliance of Environmental Clearance Conditions’ monitoring of projects is dismal and very weak”xiv. once the environmental clearance is granted the project proponent is least liable to the committee. technical resources and ever-increasing workloads. Monitoring reports – poor track record: Very few projects proponents/authorities actually submit the mandated bi annual compliance reports. south and west which have the maximum number of cleared projects have the least monitoring reports 187 (monitoring reports as of 2008) of 1255 projects (cleared between 1986-2006) and 180 (number of MRs as of 2008) of 1219 (cleared between 1986-2006) respectively. They are not responsible for monitoring it. According to a member of the Delhi State Environment Appraisal Committee. The offices have to undertake site visits. The MoEF has six regional offices in Chandigarh (north). maintain records of the violations by the projects and receive the six monthly compliance reports from the project proponents. if any NGO. 23 projects in southern region have no monitoring report. thus adding to the load of understaffed and under-resourced regional offices. According to the Kalpvriksh analysis of all the EIA projects -.not just builidings -. The officials have further added that it should be the responsibility of the regulatory authority to monitor compliance. In case of violation or non compliance. And. since the project proponents have to state compliance or non compliance with the environmental conditions. Thus. non-compliance is barely reported. Therefore. After the enforcement of the EIA notification 2006. in west only 16 of the 111 projects cleared have monitoring reports. Clearly. The report states that on an average every regional office is able to monitor a project once in every three or four years. Stating non compliance can make them liable for legal action. only 91 could be assessed for non compliance since only those had monitoring reports. to carry out a purposeful monitoring. a project proponent will not submit a non compliance report. of the total 223. the extent of non compliance is considerable. There are also discrepancies between the information provided in the monitoring and compliance reports. This is dependent on the number of projects to be scrutinized in the particular region. it would not be directed to the committee but the regulatory agencies or the regional MoEF offices.that have been granted clearance in 2003 and monitored by six regional offices. the committee is only responsible to clear or object to the projects.THIRD DRAFT The project proponent is expected to submit bi annual compliance reports. Bhopal (western). resident/s complainant register complain. Besides weak enforcement is another important factor. Shillong (north eastern). 30 . Agencies like Jal board should take the onus of regulating the project’s water withdrawal and disposal quantities and quality. Information obtained through RTI by Kalpvriksh show that there are wide gaps between what is reported and what exists on ground. show cause notices etc. The powers with respect to monitoring are much diluted. Bhubaneshwar (eastern) and Bangalore (south). Overall this seems to be the weakest link in the EIA process. There has to be an independent regulatory check. Monitoring seems to be a simple formality with project proponent monitoring themselves and submitting bi-annual compliance report based on self monitoring. It is observed that regulatory authorities have their own limitations in regards to manpower. Lucknow (central).

It is also not commensurate with the consent of establish and consent to operate certificates. therefore. The significance of public consultation is illustrated by a case example of Vasant Kunj ridge case. But the issue is that no time is specified in terms of tests/readings. There is also a requirement to ensure that all information regarding the process of EIA – from the time the application is made. There should be initiation of discussion on the inclusion of Public consultation in the environmental clearance process for the building and construction projects. This is a way that the PP seems to have found to save themselves of legalities. The speed at which land acquisitions and development of building projects is occurring across the country there needs to be a way to ascertain local needs and issues. Project proponents and the committees generally agree on a penalty amount and a bank guarantee that according to the committee compensates for the environmental 31 . Public Consultations: Public consultations. to enable research on regional and cumulative environmental impact and finally. No follow up on compliance report: There is no mechanism to make project proponents to submit compliance report to the regulatory body every six months. data gathered through different agencies is not available to public. to develop baseline data on environmental and social parameters for different parts of the country (since a good EIA report can be a good source of primary data). No periodicity is mentioned to ascertain the actual ground realities. in case of violations and non compliance. decisions and final decision and conditions/safeguards for granting clearance. All EIA documents must be available online.THIRD DRAFT Often. There should be increased public disclosure of all documents. till the final clearance. Post Facto clearances: It is almost becoming a trend that projects that never took clearance before project initiation are continuously being granted post facto environmental clearance after construction and even operation. The sub standard and inadequate information provided by the project proponents needs to be addressed since the information provided by them in the application is the basis for clearance. to improve decision-making. The database must be centrally organized. Lack of sampling networks and ill-defined sampling and analysis procedures also adds to the problem of inconsistency. Quality assurance and quality control on existing data is also negligible. the project proponents instead of mentioning non compliance to the conditions. For example project proponents may avoid data reading during the time when site clearance in ongoing Quality of Information and disclosure: Good quality data is a major concern while preparing any EIA report. which are a crucial component of the EIA for category A projects are not included in category B. is available on a web –enabled system. citizen’s perspective was ignored and mass scale construction was promoted and is continuing till date. Since there is no formal procedure of public hearing and consultation in the case of EIA for building and construction process. There is a need to have a centralized repository of all EIA reports in the country to track the performance of the environmental clearance process in the long run. would refer it as ‘agreed to comply’ or ‘will be complied’. There is no central data bank. to improve public access and scrutiny. even if the data is fed through state agencies. So there may be mismatch between the report prepared by the project proponents and the ground situation. wherein the local residents and civil society initiated a campaign against the malls and hotels that were constructed on the ridge. proceedings of meetings.

but is only an administrative action has become common and is widely accepted. Unless and until. No protocols for Inspection. Central Business Shahdara. the 2006 notification includes a provision (8.9B & 9 C.vi) that action will be taken against the applicant for deliberate concealment and/or submission of false or misleading information. No powers to regional office: Even in cases where regional office take notice of violations and issue show cause notices. Location. New Delhi Irregular monitoring. The regional offices of the MoEF are increasingly been pressured with growing number of projects and lack capacity and manpower. 32 . the project will go unchecked and will continue to operate as per the earlier agreed conditions with on-site changes (ranging from small to dramatic) without the knowledge of Environment clearance committee and revised Environment clearance. This was also confirmed by the senior MoEF official. Maharaja Ranjit Singh Marg. the regional offices issue show-cause notice. MoEF has also over the years failed to initiate relevant action except in very few cases. Since the cases drag on for long without final orders. ex-Hotel Ranjit Site. Further. while there is no fixed frequency followed for project monitoring in southern regional office. Like the central regional office monitors depending on the nature of project. which provides impetus to the project proponents to continue with violations. Post facto clearance is fast emerging as a clear and convenient alternative for the offenders and violators to receive environmental clearance after initiating or completing construction. Cross River Mall. Jackson Buildwell developed by Jackson Buildwell Pvt. Since the Environment clearance is valid till five years and the project proponents should initiate construction within 5 years. at 1B-3.THIRD DRAFT damages and impact caused by the projects. Post Facto clearance is not even part of the legal provision in the EIA. V3S Ring Road Mall.According to the Kalpvriskh study there the MoEF ha not recommended norms and protocols for inspection of projects to monitor environmental compliance conditions for northern and southern offices.The frequency of monitoring the projects is also not uniform across al regional offices. Rohini. It can be extended to another 5 years upon submission of application in Form-1 within validity period. But if there are any changes in the conditions for Environment clearance at that time the project proponent has to come back to the committee. The increased instances in the grant of post facto clearance after monetary penalty are clearly a worrying signal. Validity of environment clearance is unlimited: Environment clearance’s validity is for a limited period for area development projects till the developer is responsible. but the MoEF does not even maintain records of show cause notices and further no specific guidelines have been issued by central ministry for issuance of show-cause notices by regional offices. monitoring will not be effective in improving the compliance of the environmental conditions. much of official’s time in regional offices is spent on the cases. Therefore this trend needs to be halted to make it as an exception rather than practice. the regional offices do not have any authority to take punitive action against the violators. This provision is rarely implemented and as a result is leading to fraudulent practices and delays in project clearancesxv. New Delhi. Sector -10. we strengthen the regulatory capacity. Ltd. Also there are growing incidences where cases are filed against the company caught violating environmental conditions in the local courts. In case project proponents change conditions and the verification/ monitoring system is inefficient or weak. Cases filed to buy time: Further. if there is non compliance in particular project. Some of these examples include Shopping Centre developed by Campion Properties Ltd.

33 .THIRD DRAFT Need stronger role for State Pollution Control Boards: The state pollution control boards are responsible for the issuance of consent certificates to the industries/projects falling in confirming areas under green and orange categories.62 crores have been realized till 2008. The project related reports by the proponent are poorly drafted and its management is also weak at the end of DPCC. Other functions include inspecting wastewater treatment installations. to set an example Consent Management Committee (CMC) has taken stringent action such as imposition of bank guarantees and environmental damages. The website mentions that the ‘construction work by most of these projects was undertaken in blatant violations of the environmental laws. Ground realities however indicate to the fact that not everything is all right. grant environmental and other critical clearances but their coordination leaves much to desire. grant NOC. It also prepares and enforces standards for the treatment of sewage and trade effluents etc. Although the units submit and are often directed to submit six monthly monitoring reports. From September 2006 – August 2008 MoEF has granted clearance to 2016 projects. during or before the preparation of the monitoring reports. There is no systematic manner in which inspection and checks are conducted. control and abatement of air and water pollution. The official from DPCC also agreed that the degree of compliance in the reports and on site is also questionable and not to the desired level. Inadequate resources and staff in regional offices: It cannot be taken as granted that monitoring reports have been verified by site visits by the officers from the regional offices. directions for closure/stopping construction have been issued to 5 shopping malls/construction projects up till 2008. although there are some common areas of work and coordination. DPCC has been forced to impose bank guarantees /penalties on shopping malls & construction projects. the six regional offices have about two to three scientists who have to monitor about 6000 projects that are either in construction or operational stage. The organizational capacity and human resources available with the regional offices pose a big challenge to environmental compliance. There is a obvious lack of communication between SEAC and the regulatory bodies. air pollution control equipment.60 crores in lieu of environmental damages and bank guarantees of Rs 17. This has placed huge burden on the regional offices to monitor these projects. Coordination Missing: There are various authorities and agencies which do independent monitoring. Delhi Pollution Control Committee (DPCC) the prime authority responsible for controlling pollution in the national capital territory of Delhi agrees to large scale violations by various building projects. The bi annual compliance goes to MoEF or regional offices and not the EC committee. Even if the conditions demand the coordination is non existent therefore violations and non compliance go unattended and uninformed due to poor coordination. Further. On its website it is mentioned that shopping malls and commercial complexes have violated environmental laws. But according to the officials from DPCC the inspection by the officials are not regular but rather random. and to take steps for the prevention. At present. In addition. As a result.’ According to DPCC. the record maintenance is poor. An amount of Rs 12. Further the shortage of staff also creates problems in streamlining inspection. 18 notices for closure/ stopping construction have been issued to shopping malls/ construction projects. since monitoring is not environmental clearance committee’s responsibility. besides undertaking assessment of the quality of ambient water and air. lack of sharing and sometimes ignorance.

On the other hand MoEF in case of non compliance can refer to its own committee or constituted committee of regulators under EPA act. of the appointed members only a few may be present during the meetings. disposal. the monitoring and regulatory 34 . Therefore. Environment clearance Timing: The preamble of the Environment clearance given to the project proponents mentions the condition (e. There are both new projects and old projects that are either reviewed or cleared in each meeting. In the 48 minutes of meetings reviewed a total of 927 projects were reviewed of which 267 projects that were granted EC (see fig 30).THIRD DRAFT In cases where the regulatory agencies is unable to competently do the monitoring task to check project’s compliance with environmental clearance and other environmental laws/ notifications. There were significant variations in the number of the projects that were discussed in the meetings ranging from 12 to 52 projects in the 48th and 15th meeting of Haryana SEAC respectively. these small committees are more often than not over burdened with project clearance applications and EIA process. Often procurement of certificates from various authorities may take time. in case the project proponent doesn’t get the NOC thereafter or flounders with the mentioned conditions there is absolutely no way for counter checks. The large number of projects and the pressure to review these projects in limited time is often a constraint in detailed discussions and its comprehensive review. But. to reduce the pressure on the committee members the member secretary of the Haryana SEAC in the 16th meeting decided that only six new projects for appraisal or twelve projects for grading or in combination thereof in one sitting would be taken. for water withdrawal. the environmental clearance committee’s hands are tied. They can just be silent spectators to a scenario where the project proponents is violating and not complying with the environmental clearance conditions specified by the committee. The members often have little time to go through a number of new cases that are received every month apart from old cases that may apply for re-clearance. The key reasons for reduced membership are generally cost cutting. Often it is seen that a committee may have just 5-6 members not representing all the essential fields for environment clearance. They are required to meet atleast once a month and with an average of 15-20 projects applying for environment clearance every month. On an average 6 projects are granted clearance in each meeting by the committee. generally the discussions may not reflect the real issues and leaving less or no time for detailed appraisal on the key project components that can potentially have significant impact on the environment. Further. which scheduled for 2 days. As a result. There may be significant variation in the average time spent by the committee members on reviewing the projects and granting them EC. In some cases committee may provide EC before PP receives NOCs from the relevant authorities. according to a few committee members that CSE met. Infact. lack or non availability of experts amongst others. However. Unless.). Committee Complexities: The upper limit for members in the State Environmental Appraisal Committee (SEAC) is 15 but there is no mention of minimum members required for the committee to function. The analyses of the number of projects that were reviewed and cleared shows that the committee reviews on an average 19 projects in each of its meetings. presentation by the proponent is probably the only effective time that the members are able to accord to each project. which is generally a constraining factor for the committee. stressed with multiple projects for clearance. there could be a real possibility of project proponent taking advantage of the genuine time constraint and avoid discussion on key and significant issues. Hence. etc.g.

the ratings were accorded to projects on the basis of environmental information and inputs incorporated in the project proposal. For example in the 3rd meeting of Haryana SEAC held on 26 & 27 August 2008. jal boards or municipalities) become rigorous and regular. Besides. Sector-59. (Construction of Commercial complex at Sector 67. (Construction of Commercial Complex at Sector 66.has silver rating and environmental clearance granted M/s Parsvnath Developers Limited. Since the committee is reviewing very large number of projects in each meeting.has gold rating. silver etc. Ltd.gold rating. if the regulators intend to take appropriate action they can book the non complying PP as per the EPA act. (Construction of Commercial complex at sector 66. gold. Sonepat. Gurgaon. some SEACs like in this case for Haryana continue to use it. (Construction of Commercial complex at sector 73. The issue is that the project proponents may project these ratings for their building projects and use it on the ground that the project as a whole is gold or platinum rated. Ltd. etc 35 . & Others (Construction of Commercial Complex at Sector 84. Gurgaon. Near Tau Devilal Park. (Construction of Commercial complex at Sector 74. these ratings are not on the project construction and operation process and performance. But these ratings were not for the project. 86. Proposed Parsvnath Mall Sector-8. Gurgaon. Haryana. incorrect or unclear information needs to be eliminated as far as possible. Gurgaon. Gurgaon among others. Ltd. Gurgaon. Even though their built up areas are different ranging from 19. M/S Afresh Builders Pvt. But. air and water pollution act or other relevant state acts. the PP can have their own will at the expense of environment. (Construction of Commercial complex at Sector 62. the following projects have absolute similar water requirements and wastewater generation. Ltd. (Group Housing Project “Raisina Residency. M/S Lavish Build Mart Pvt. Some examples include: M/S M3M India Ltd.S Infrastructure Pvt. The official added this process even though was adopted few years back has been discontinued because of it was impractical. But are only indicative of the information provided and the quality of report (conceptual plan) submitted to the ministry. According to the MoEF official. Subjective Rating for Proposals: In the minutes of the meeting of the Haryana SEAC several projects when they are granted environmental clearance are awarded ratings ranging from platinum. District Gurgaon”. Thus. Ullahwas. Ltd. Sohna. Errors in Documentation: As far as documentation of the minutes of the meeting are concerned there are glaring mistakes that have been made by the concerned authorities which in this case is the SEAC and SEIAA. project proponents could conveniently conceal the fact that the rating is only for project report/proposal submitted to SEAC and not for the project (construction and operation phase). there is hardly enough time spent on reviewing it in depth and to objectively awards points on each aspects which would contribute to the project’s (report) overall rating.000 sq meters. But.THIRD DRAFT mechanisms (e. Ltd. Since these minutes are the most crucial source of information for public. Prompt Engineering Pvt.48. Haryana. M/S Gental Realotors Pvt. M/s Standard Farms Pvt.000 to 1. Vill. Some states have also issues local guidelines to be adhered by the developers and builders. Even their environmental conditions are exactly similar and match word to word. M/S R. Gurgaon. Teh.g. NH-1. Gurgaon. DLF New Town Heights at Sec. Ltd. M/S Martial Buildcon Pvt. The ratings originally in the manual on norms and standards for environment clearances of large construction projects in 2007 were highly subjective and several SEAC’s have discontinued its use.

The ministry has accepted the committee’s recommendation which was headed by the senior ministry official JM Mauskar. No official assessment of the benefits of environment clearance for buildings: The CSE review also reveals that so far no official effort has been made to assess the resource savings from the EIA intervention in the building sector. 36 . waste and traffic they are very loose. applicable for new construction and area development activities. Some of its other recommendations included removing the ceiling from the penalty for the violators and strengthening the central /state pollution boards and regional offices. The reforms must accompany stricter approaches in the targeted resource use areas. With builders/developers making huge profits in real estate this is an easy let off for activity 8A projects. Recently. This is unacceptable that one arm of the government should ignore what the other arm is doing. It may be recalled that when BEE had introduced ECBC in 2007 it had estimated that with ECBC can save 1. Other recommendations included increasing the penalty amount for the violators. But after several years of EIA Notification 2006. the MoEF’s appointed committee recommended making environmental violations as a non bailable offence. or builders any investment on environment management and conservation would imply increased cost and more importantly capital cost. The review has also shown that in the same sectors norms and standards already exists in the country but the environment clearance rules remain vague about them and not take them on board explicitly to set the terms for clearance. waste and traffic are not guided by clear targets and benchmarks. For instance. — in isolation and without clear benchmarks and targets can seriously compromise the process and delivery. water.THIRD DRAFT Environment. water. elaborate energy code for buildings (ECBC) has been adopted by the government for energy conservation in buildings but this is not integrated with the EIA tool. adhoc and not governed by clear targets and benchmarks. or energy efficiency measure. These are also not aligned with the existing norms and standards. energy. This therefore demands setting of clear mechanism for each sectoral appraisal of buildings to assess the impacts and monitoring with clear benchmarks. Adoption of any sustainable practices – rain water harvesting system. there are no sound provisions for assessment of resource savings potential of the new building stocks.7 billion units in the first year of code implementation in India. The fragmented approach towards managing environmental impacts of buildings has led to partial and segmented application of green elements in buildings. At present. the punishment for violations is limited to three years’ imprisonment and 1 lakh fine. waste and traffic: The review of the environmental clearance process has also brought out that the current mechanism of assessing the vital impacts on water. missing link in builder’s agenda: At present the industries are supposed to reserve 5 per cent of the project share to CSR according to MoEF. Same is the case with water.xvi Weak sectoral approaches on energy. Such exercise is critical to drive policy action and build public support.xvii. solar water heating systems. These could lead to effective and improved monitoring of implementation of environmental clearance conditions. The main objective behind these recommendations was to provide more powers to the environmental laws and regulators. with no compulsion on investing in environment management and monitoring on a regular basis. Even though guidelines have been prepared to minimize impacts in critical areas of energy.

time to set the terms of the policy discussion and action on the ways to reform the environmental clearance process for the buildings. It is clear that these saving measures will have to be integrated at the early stages of the project planning. Even if it is accepted that the building sector has its unique features — prolific. • Strengthen site screeing: It is important to plug the major flaw that a project proponent can actually start the process of land acquisition. STEPS TO STRENGTHEN THE OVERALL EIA APPROACH TO BUILDINGS • Revisit EIA rule for buildings to identify key elements for stronger application: While it may not be practical for the building sector to adopt the detailed EIA prescribed for the industrial sector given its numerous nature. But that is not 37 . The review makes it very clear that in view of the emerging environmental concerns in the building sector. But this tool will have to be strengthened substantially for effective improvement in energy savings in buildings. widespread and numerous and of varying impacts. and cannot be directly compared with the industrial and mining sites. Land should be acquired only after the suitability of the site has been established. a few essential elements may be identified for inclusion in building EIA. This is needed to deepen the policy understanding on how other policy instruments that are emerging for resource conservation in buildings can work effectively and synergistically. EIA provides that opportunity to bind them together to bring greater precision in targets and action. cumulatively they can be a very heavy draw on key resources including energy and water. While individually they can aggravate local pollution and resource impacts. As there is no formal procedure of public consultation citizen’s perspective was ignored and mass scale construction was promoted and is continuing till date. One such crucial element can be public Consultations or prior informed consent and decision. per capita water consumption norm for water management among others. As is evident from the cases in Vasant Kunj and Greater Kailash in Delhi citizen’s concern will have to be integrated.THIRD DRAFT THE WAY AHEAD The review of the environment clearance process for buildings expose systemic weaknesses as well as specific concerns related to each aspect of building appraisal that blunt the effectiveness of the policy. This in fact has to flow from the master plan of a city. the local residents and civil society had campaigned against the malls and hotels that were constructed on the ridge. even when the project has not been cleared. the alternative model for them will still need to be carefully designed for effective impacts. Both zonal plans and master plans require environmental clearance. buildings cannot be treated as a low impact sector. It is therefore. Building plan needs an explict link with an environmental plan. The environment clearance tool requires special attention for the simple reason that this is a holistic appraisal of the overall impact of the buildings and addresses the most high impact large building categories that are expected to emerge as major resource guzzlers. India has already adopted energy codes for buildings. There is yet another reason why it is important to take stock and refocus on the learning from the EIA experience. In Vasant Kunj ridge case.

• Ensure strong enforcement to prevent construction without consent or post facto clearances: Institutional reforms are needed to plug loopholes and discipline and enforcement. As buildings are seen in isolation they are seen as low impact projects. urban water bodies. proceedings of meetings. • Need strong benchmarks: As we will see in the sectoral discussions the environmental clearance process is not linked with efefctive benchmarkes for resources consumtion and waste management. decisions and final decision and conditions/safeguards for granting clearance. The only legal instrument that is explictly taken note of is the forest conservation act etc. Also the environemntal clearance for buildings should not be for ever but be time bound. Reforms are needed for stronger penalty and deterrents and more effective use of the closure clause permitted under the law. All EIA documents must be available online. Enforce the proposal of the MoEF’s appointed committee to make environmental violations a non bailable offence. capacity and compliance strategy: In addition to the self assessment and self reporting by the project proponent independent third party audits are essential to prevent escalation in resource use and neglect of waste management. In most cases therefore land is already allotted to the developers without any environmental screening.THIRD DRAFT followed. Regional offices should be suitably empowered and aligned with other line departments to monitor the on ground reality and take corrective action. Site screening will also help in cumulative impact assessment. The current area criteria of 20. Also integrate the data generated by other concerned departments to take the performance of the projects. Technically it is said that if compliance report is not submitted the project proponent is liable to be punished.000 sq meter to 150000 sq meter need additional indicators to identify the high impact buildings to address the deviation. This will help to put brakes if the overall efficiency of the building deteriorates during the post construction phase. • • Quality of Information and disclosure: Develop and implement protocol for quality assurance and quality control on existing data. But site clearance is needed to understand the boundaries of influence. But this is rarely done. There should be increased public disclosure of all documents. This will help to address time delays in clearing projects. energy efficiency codes. Also develop clear protocol for inspection by the regional offices and ensure that these are adhered to. Developers get away with very low benchmarks. • Adopt enforceable post construction monitoring protocol. All compliance reports are expected to be on the website of the project proponents. The central environment ministry should also be made liable for ensuring that independent monitoring is being carried out in a transparent manner. enable research on regional and cumulative environmental impact and develop baseline data on environmental and social parameters for different parts of the country.To improve decision-making improve public access and scrutiny. 38 . But their cumulative impacts will have to be addressed not only through individual project clearance but also through zonal planning and cumulative ijmpact assesment. For instance. the clearance is not aligned with the regulatory requirements related to extraction of ground water and usage.

There is a system for benchmarking of the post-project monitoring as well. the project proponent considers various per capita water consumption estimates to determine the total water requirement for the projects. • Availability vs Allocation. • Undercover Exploitation: It is important to tighten the provision regarding water use and to increase the vigilance and stricter action by the Central Groundwater Board/Authority in the clearances. grant environmental and other critical clearances. The project proponent often underestimates or randomly takes the per person water requirement to get the project cleared and to prove low impact of the projects on water resources in the area. grant NOC. STRENGTHEN SECTORAL INTERVENTIONS Reforms for redu. Licenses are being issued indiscriminately in Gurgaon without such checks in place.THIRD DRAFT • Issue guidelines for EIA for township projects: This ambiguity must be immediately plugged to ensure that the high impact township projects follow the EIA guidelines similar to those for catergory A projects. often in water stressed areas authorities grant permission and allocate water based on the demand made by the project proponent without much reference to the water availability – both surface and ground water. At the same time for effective appraisal and monitoring create institutional arrangement for better coordination with other authorities and agencies that do independent monitoring. environmental clearance should be linked with assessments of resource availability. and precision with regard to resource use.Even a cursory review of the project proposals show that the project proponents only mention the water needs of the buildings. There are no mandatory norms on the basis of which per capita consumption can be benchmarked for environmental clearance or to review the project’s water requirement. The township approach will ensure uptake of strong efficiency measures even for new individual buildings within the township and maximize benefits. Improve communication between SEAC and the regulatory bodies. Civil structures for rain water harvesting is made without any assessment of the existing water table and quality and the change possible with rain water harvesting. For estimating they follow the basic principles of the guidelines of the Bureau of Indian Standards/ CPHEEO/UDPFI that helps to estimate the water demand based on per capita consumption. and responsible for allocation of resources. Sheer number of projects place huge burden on the regional offices to monitor these projects.cing water and waste water impacts of buildings • Introduce benchmarking of water consumption for environmental clearance of buildings: While stating water consumption. Therefore. • Build capacity for enforcement and also promote more coordinated action: The organizational capacity and human resources available with the regional offices will have to be strengthened. But this is not backed up by any assessment from the water providers to show if they can supply the requirement. there is a need to adopt and align the standards and norms for water consumption and waste to bring clarity. Therefore. Rainwater harvesting in buildings is currently being used as an excuse to exploit groundwater in critical 39 . Often rain water harvesting is used as a panacea for all. Therefore.

As of now there is no clear process or methodology for assessing or challenging the energy conservation data provided by the project proponents. Validity of environment assessment will depend on quality of inputs and methodology. there is only one time permission that the developer has to seek and can continue to exploit the groundwater forever without its renewal. Currently. These extensive guidelines can be incorporated in the EIA rules for building to further streamline the ECBC requirements for optimum energy performance. water conservation measures that find mention in the proponent’s reports are stereotypical and are there to satisfy the conditions. The current institutional and monitoring mechanisms in place for ECBC would then have to be merged with the monitoring process of the EC cleared building projects. But. • Drive conservation methods: There is need to diversify and increase water conservation measures. roof. • Align with National Habitat Standards for energy efficiency: Already under the National Habitat Mission the Ministry of Urban Development along with the Bureau of Energy Efficiency is developing guidelines for energy efficiency that are being integrated in the existing building bye-laws framework taking into account the wide variation in climatic conditions in the country. This data set should be properly reviewed. At present the EIA clearance process in the Ministry of Environment and Forests does not have any representation from BEE for the energy impact assessment. Only stricter benchmarking can force diverse and more innovative approaches. • Data management for proper impact assessment and monitoring mechanism: Both data and methodology for energy efficiency applied in buildings should be made more transparent. It is often not 40 . These guidelines also based on ECBC extensively deal with lighting. BEE informs that in 2007 it was communicated to GRIHA and LEED that buildings rated by them would have to be minimum 3 star. HVAC systems. The order from CGWA of discontinuing the renewal groundwater permission after two years should also be suspended. But in the case of EIA compliant buildings may be a higehr star rating should prescribed as these are high impact capital intensive buildings. energy efficiency in lighting. • Establish minimum energy benchmark for environmental clearance: Currently. Reforms for reducing energy impacts of buildings: • Align with ECBC: If ECBC has already been adopted officially as the key regulatory tool for guiding energy conservation in buildings it is important that this is also formally adopted and integrated with the EIA process. Currently. there are several other ways and measures that can be adopted to reduce water use and increase efficiency of water use in the buildings and construction projects. windows. skylight etc. Otherwise.THIRD DRAFT areas. These include guidance on thermo physical properties associated with various envelope elements such as wall. for effective implementation of the ECBC code minimum 3 star rating is being considered the minimum benchmark. The committees or authorities monitoring the EIA projects at the regional level would have to be aware and adequately trained and informed to understand the ECBC process and its monitoring requirements. renewable energy utilization etc. This would act as a check and regulate the developers exploiting groundwater resources. the EIA tool the way it is currently designed for energy efficiency is not at all sufficient to address energy conservation in the high impact buildings. ventilation requirements.

and ECBC with National Building Code that is much broader than the ECBC and is followed by all building developers.48. Initiate public action at national and state level to get the local byelaws modified accordingly.000 sq meters • Energy audits: Energy audits must be made mandatory for the bi-annual reports that the project proponents are expected to file.000 to 1. But this will have to be formally broad based in urban local bodies. There is now an opportunity to influence NBC to get more broad based sustainability indicators included. The system will have to be revamped to create incentive for best practice models. This largely focuses on daylight integration for lighting. Sometime the discussion and assessment seem over simplified. ULBs need capacity to do audits. surrounding public spaces and roads. BIS is coordinating this effort. 5. But this demands clear indicators for projection as well as operating performance of the buildings. For instance.4. This will also require clear protocol for data generation.THIRD DRAFT clear how clearances are given based on the information provided and how the information and data sets are assessed and used by the EIA authorities. BEE has begun the system of creating a small group of certifiers for energy audits. However as a matter of policy advocacy both.7. consistency and reliability. The NBC 2005. and changes in operations. The urban local bodies have very limited capacity to do energy audits to verify the improvements and savings. ventilation standards etc.1). The Energy Conservation Building Code aligns with the mandatory requirement for the natural ventilation compliance in the NBC 2005 (Part 8. There will always be a big dilemma between the modeled and actual energy performance of the buildings. The system will need specific benchmark that tracks building performance overtime. Even erroneous documentation happens. For example in the 3rd meeting of Haryana SEAC held on several projects had absolute similar water requirements and wastewater generation. guidelines for transit 41 .3 and 5. include some aspects of energy conservation but it is not elaborate enough. Reforms to reduce traffic impacts of buildings • Make traffic related clearances from competent authorities mandatory: The EIA authorities will have to accord priority to this dimension of impact of buildings and ensure that buildings obtain consent from the designated authorities in the city and also develop and implement a traffic management plan that obviates pressure on the neighbourhood. It is important to influence this deliberation for the big picture planning and effective local interventions. NBC and ECBC will need to form “Plug and Socket” to bring better result oriented integrated norms that are workable to form good practice of energy conservation. Even though their built up areas are different ranging from 19. These should fulfill the criteria of street design guidelines. The Bureau of Indian standards (BIS) that has framed NBC is now deliberating on a detailed draft chapter focused on “sustainability” that is expected to include many of the energy conservation and resource management issues. Even their environmental conditions are exactly similar and match word to word. • Harmonise EIA. in Delhi all projects should be routed through UTTIPEC and traffic police to clearly asses the traffic impacts of the proposed projects.1. data quality.

——. non-motorised transport approaches and so forth. fulfill the requirements of public transport connectivity.THIRD DRAFT oriented development.Sustainable building programme team 42 . These should also align with the parking policy of the city and prevent parking spill over on the public spaces surrounding the project area.