Damodar V Pujari,
Date- 28th October 2013
To,
The Secretary,
Ministry of Environment and Forests,
New Delhi
Subject- Comments on Draft Solid Waste Management Rules 2013
Dear sir/ madam,
With respect to the proposed Municipal Solid Waste (Management and Handling) Rules 2013, posted on the website of Ministry of Environment and Forests, I hereby submit following concerns for due consideration which are born out of my research work in the field of Municipal Solid Waste Management in Mumbai. The proposed rules have scope for improvement subjected to following points-
- Efforts for reduction of waste generation are required more than managing the waste in the first place- It is quite strange that the ministry has been periodically coming out with slew of rules for waste management under the title of “Management and Handling”. Waste is a kind of pollution and therefore needs to be dealt with like other pollutants. The ministry’s other acts which derive administrative powers from the same Environment Protection Act, are always aimed at “Prevention and Control” of the particular kind of pollution in question e.g. Water (Prevention and Control of Pollution) Act, 1974, Air(Prevention and Control of Pollution) 1981 Act. Etc. But, the very spirit of the MSWM rules seem to be aimed at assumingwaste generation de facto and gearing all the public machinery towards managing the produced waste. Waste is one of the pollutants or even a congregation of many such products and hence should be dealt in a similar manner as other kind so pollutants. Therefore, please make waste management steps mandatory to all the concerned stake holders before plunging into management aspects of it.
- . Understand the waste profile of the region before making dumping grounds- In the waste management rules, all the urban local bodies are asked to prepare a waste dumping facility for safe disposal of waste. However, in Indian households, many organic and non-organic wastes are discarded which could be easily recycled and reused. Such a scenario occurs because of the two reasons, one because we discard all that is useless and second our waste handling machinery (urban local body) doesn’t know what is produced in what quantity and where. Waste also carries the socio-economic profiles of the places where it is produced. Therefore, areas where organic waste component is more, manure making and/or bio-methanation units could be set up at ward levels or any suitable place near waste generation points. The point here is to understand the waste dynamics of the habitat before plunging into recommending a dumping ground. Moreover, rural areas will also carry agricultural residues and at times animal wastes. Such a material could be of high calorific value and therefore would need different sets of waste treatment set ups. Ditto for hilly regions where the waste management is a completely different ball game.
- . Based on waste profiles, make tailor-made waste management options- Once a comprehensive set of profiling of waste generation is done for the region in question, roll out suitable waste management and disposal remedies. It is not a worthwhile to ferry all the waste for 10-30 km from the city into the dumping grounds and then treat them for waste-to-energy operations. If such energy is produced, it becomes further cost consuming to transport that energy back to the consumers residing in the urban area. Such plants could safely be established at ward levels considering waste generation profiles. It would save public expenditure on two fronts- on transporting such waste which could be locally treated and at second, by reducing the energy demands of various sources viz. cooking gas, electricity etc.
- . Please make realistic and honest reporting of the waste management- The waste management wings of the urban local bodies, must make honest and realistic waste management reports. The current system of reporting waste management only deals with “dumping the waste into dumping grounds” without any regard for scientific methodologies. The data are collected only at the dumping grounds without any representativeness and reported with similar errors each year. If these new rules are making those urban local bodies to submit the report of waste management to the state environment departments each year, please specify the scientific, representative methodologies for reporting such facts without any errors.
- . Recognize the social angle associated with waste management- Today, we have millions of waste pickers/ rag pickers across our towns who earn their livelihoods on waste but are not accounted for in any government records. Waste management is as much a social issue as a scientific and administrative issue. Therefore, please make it mandatory for the municipal bodies to register the waste pickers who help the nation save its resources by assisting the waste management industry. When it comes to the battle against waste, rag-pickers are the first line of defense a municipal body has. Please don’t ignore them
- Treat dumping ground only as a last resort- The dumping grounds-by definition- are to be used only for that waste which can’t be treated in any possible way. Inert waste, in short. Please use them like just that. Otherwise, no city will ever have enough space for safely disposing its waste. Organic material and recyclable components could easily be dealt with at local level with respective waste management modalities.
After adopting such measures, it is my sincere belief that the waste management in India would become a sustainable practice and even a possible business opportunity for entrepreneurs to venture in.
If needed, I’d be happy to elaborate the points with a brief presentation and reasons behind these points.
Thanks
Damodar V Pujari
Fellow- South Asia Network on Dams, Rivers and Peopple.
