Governance

Land and environmental approvals needed for faecal sludge treatment facilities

There is an urgent need for specific guidelines and rules for the selection of sites for setting up faecal sludge treatment facilities.

Author : Anju Dwivedi, Scaling City Institution for India (SCI-FI) - Centre for Policy Research, Shikha Shukla Chhabra

Despite an enabling framework for implementation of Faecal Sludge and Septage Management (FSSM) initiatives, there exists a vacuum concerning specific guidelines/rules for the selection of sites for setting up of Faecal Sludge Treatment Plants (FSTPs). In the absence of specific guidelines, the provisions of the Solid Waste Management Rules, 2016 – Schedule 1, which provide specifications for selection of the site for Sanitary Landfill Sites (SLFs), are being applied for selection of sites for setting up FSTPs.

Solid Waste Management Rules, 2016: Key provisions applicable for siting of FSTPs

Under Project Nirmal, for selection of the site for setting up of FSTPs in Angul and Dhenkanal, the following provisions of the Solid Waste Manage­ment Rules, 2016 – Schedule 1 have been applied:

  • The FSTP site should be at least 200 meters away from any water body. The site should not be liable to flooding and its elevation should permit the discharge of effluent by gravity to the receiving streams or the level of the irrigation area to be commanded, in case of reuse for ir­rigation.
  • In case the selected site is surrounded by resi­dences, adequate measures need to be taken to control odour from the FSTP.
  • The site should be accessible to personal and delivery persons at all times. Access to fire and other emergency vehicles must also be avail­able.
  • Sites with special natural features should be avoided. Development of areas designated as wild, scenic, or recreational has been prohibit­ed.
  • The site should be able to accommodate pres­ent and anticipated future requirements.
  • A site with a slight slope should be preferred to facilitate gravity flow of wastewater through treatment units and to minimize earthworks and associated construction costs.
  • A site with a low water table has been sug­gested as preferable to minimize difficulties in earthworks, prevent instability with in-ground structures and limit potential groundwater im­pacts.
  • The sites with soils that have high clay content has been suggested as preferable to provide clay material for the lining of any treatment units such as ponds or lagoons or bio-solids man­agement or re-claimed water storage.

Model Faecal Sludge and Septage Management Regulations, 2018: Provisions for treatment and disposal

Project Nirmal, provided technical assistance to the Housing and Urban Development Depart­ment (H&UDD), Government of Odisha (GoO), to prepare the “Model Faecal Sludge and Septage Man­agement (FSSM) Regulations, 2018”. Subsequently, all ULBs in the state has promulgated FSSM bye-laws based on the Model FSSM Regulations.

<p style="margin-bottom:13px">The Model FSSM Regulations contain specific rules for treatment and disposal of faecal sludge. While ULBs have been given the discretion to approve and notify how septage is to be processed and treated, the selected treatment mechanism has to be per relevant laws, notifications, or as per the provisions of the Odisha Urban Septage Management Guidelines, 2016 (OUSMG, 2016) or any good engineering practices. Further, the Model FSSM Regulations provide that septage or sludge cannot be treated or disposed of in any manner other than what has been specified and approved by the ULB. </p>

The operator of treatment facilities has been made responsible for ensuring that the disposal of treated septage complies with standards laid down by the Odisha State Pollution Control Board (OSPCB). Concerning the site for disposal, the Model FSSM Regulations provide that the treated septage is to be disposed only at the location which has been authorized and notified by the ULB and the same has to be chosen in compliance with the Envi­ronment (Protection) Act, 1986 and the Water (Pre­vention and Control of Pollution) Act, 1974 and the rules framed thereunder.

The process for finalising the location of the disposal site has to be consultative involving representatives of the ULB, OSPCB and the district administration.

OUSMG, 2016: Key provisions relating to treatment, disposal and siting of faecal sludge treatment facilities

As per the OUSMG, 2016 only ULB approved and designated treatment facilities are to be used for processing and treatment of septage. The guide­lines provide that septage can either be co-treat­ed with sewage at a Sewage Treatment Plant (STP) or in case STP is not available or the existing plant has insufficient capacity or its location is too far from the ULB, a treatment facility specially meant for septage treatment needs to be con­structed.

<p style="margin-bottom:13px">The location of the treatment facility is to be authorized and notified by the ULB and the same has to comply with the provisions of the Environment (Protection) Act, 1986 and the Water (Prevention and Control of Pollution) Act, 1974. Further, the guidelines provide that the site for the treatment facility and disposal of treated wastewater and sludge must be selected in consultation with the District Collector, OSPCB and general public. </p>

Process of site selection for FSTPs: Experiences of Dhenkanal and Angul

The process of site selection for setting up of FSTPs in Dhenkanal and Angul has been protracted and complex. Further, in the absence of well-defined rules and lack of any precedent, the process has been time-consuming with inordinate delays. In Dhenkanal, the FSTP site selection process began in March 2016 with Practical Action (the implementing agency) send­ing a request to the Chairperson, Dhenkanal Mu­nicipality for allocation of land for the FSTP and it ended on 23rd May 2017 with the district adminis­tration issuing a letter in favour of the Dhenkanal Municipality with permission to establish the FSTP at Mahisapat Mauza.

In Angul, the process took almost two years, after the Odisha High Court made a ruling in favour of the Angul Municipality and gave them a go-ahead for the construction of FSTP at Panchmahala Mouza.

<p style="margin-bottom:13px">As per the OUSMG, 2016 the selection of the site for FSTPs must involve the District Collector, repre­sentatives of OSPCB and the general public. How­ever, in Dhenkanal and Angul, the site selection process has seen the involvement of many more government officials including those of the respective ULBs; district administration; the Regional Office (RO) of the OSPCB; and forest department. The involvement of these officials was consid­ered necessary to ensure that the site for setting up the FSTP did not cause any adverse impact on land, forests, water sources and the environment. Also, officials from the Police Department were involved to ensure safety and security during the land alienation/demarcation process. </p>

The provisions of the various Acts and Rules were adhered to while selecting the site for FSTPs. In both Angul and Dhenkanal, multiple sites were identified and parallelly processed for site selec­tion alienation and demarcation. In Dhenkanal, three different sites were identified while in Angul four sites were identified at different locations.

Lessons learnt

In the absence of specific guidelines for selec­tion of sites for setting up of FSTPs, the provi­sions of the Solid Waste Management Rules, 2016 – Schedule 1, which provide specifications for selection of the site for the Sanitary Landfill Sites (SLFs), are being applied for selection of the site for setting up Faecal Sludge Treatment Plants (FSTPs). There is, however, an urgent need for specific guidelines/rules for the selection of sites for setting up FSTPs to adequately ad­dress the differences in treatment and disposal facilities for faecal waste and solid waste.

<p style="margin-bottom:13px">The land allocation process for FSTPs, in both Angul and Dhenkanal, has been protracted and complex. While the OUSMG 2016 provides that the site for the treatment facility and dis­posal of treated wastewater and sludge must be selected in consultation with the District Collector, OSPCB and general public, in reality, the site selection process has required the in­volvement of many more state, district and local government officials. The involvement of so many officials has meant that the process has been long drawn out with numerous admin­istrative procedures to be followed resulting in inordinate delays.</p>

In Dhenkanal, the FSTP site selection process took around fourteen months (March 2016 – May 2017) while in Angul it took more than two years (March 2016 – Oc­tober 2018). There is a need to streamline the approval process for site allocation for creation of treatment and disposal facilities for faecal sludge.

<p style="margin-bottom:13px">The coordination mechanisms established under Project Nirmal at the state, district and town level, namely, the Project Steering Com­mittee (PSC), the District Co-ordination Com­mittee (DCC) and the City Sanitation Task Force (CSTF) played an active role in overseeing the process of land allocation for the FSTPs in both Angul and Dhenkanal. The Site Selection Com­mittee which exists at the sub-divisional level had all key officials as its members and played an oversight role in the land allocation process. This Committee ensured that there was regular follow up with the concerned officials. </p>

In both Angul and Dhenkanal, there were protests by residents regarding the sites being considered for setting up of the FSTP. Most of these were due to a lack of awareness regarding the functioning of an FSTP and miscon­ceptions regarding the same. The approach taken by Project Nirmal, which was aimed at building awareness among local communities through site visits to functioning wastewa­ter treatment facilities and showing videos documenting the functioning of wastewater treatment facilities, helped address many of the prevailing myths and misconceptions and paved the way for communities to become open about setting up a treatment facility in their neighbourhood.

The project was completed in 2020 and was implemented by Centre for Policy Research and Practical Action with support from Bill and Melinda Gates Foundation; Arghyam; Housing and Urban Development, Government of Odisha; and Municipalities of Angul and Dhenkanal. 

The article based on the research learning note 'Project Nirmal: Faecal Sludge Treatment Facilities – Land and Environmental Clearances Research’  is a part of the series demonstrating learning and outcomes of the Project Nirmal based on Scaling City Institution for India (SCI-FI)’s research on water and sanitation. More on the series: https://twitter.com/CPR_SCIFI

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