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“Dilution is the Solution” – A de-facto understanding of MoEF & CC.




Let us fight back the dilution of COD norms from 250 mg/l to 500 mg/l for sea discharge by Ministry of Environment, Forest and Climate Change not based on study but based on the discharged norms which industries might be able to achieve.

The MoEF & CC is waiting for “right-time” to make an announcement.

Rohit Prajapati

[email protected],

“Achievable” environmental norms—rather than the “caring capacity” of the environment—are the criteria for the prescribed norms for India’s MoEF & CC. Let us fight back the dilution of COD norms from 250 mg/l to 500 mg/l for sea discharge by Ministry of Environment, Forest and Climate Change; the proposed changes are not based on study but based on the discharged norms which industries might be able to achieve. The MoEF & CC is waiting for “right-time” to make an announcement. This approach of “dilution as the solution” to deal with violations of norms by the present MoEF & CC has been carried over since the former MoEF and continues to deteriorate and deplete the environment at irreversible levels in industrial clusters of India. It is a shameless attempt to condone industrial expansion even in areas where there is evidence that the environment is already ‘critically polluted’.

Now we are in an era where the three ministries of environment, labour and industry, individually and collectively, are increasingly concerned about “improving environment” from the perspective of industry and its profitability, industrial-friendly labour laws and prosperity of industry; this is aimed an accelerating production and profits of industrialists in the “interest of gross domestic product (GDP)”.

Keeping in mind the above objective of these three ministries in practice, time has come to merge these ministries in one which can be named as ‘The Ministry of Industry, Investment, Industrial-friendly Environment and Labour’. By merging the three ministries, the government will be more transparent to overtly express its real concern and commitment to industry, profit and GDP.

Following consistent struggle by pollution-affected people, people’s organisations, and NGOs regarding increasing pollution levels in industrial areas of India, the Central Pollution Control Board (CPCB) and the State Pollution Control Boards (SPCBs) in 1989 initiated the process of indexing critically polluted areas. At that time, 24 industrial areas including Vapi, Ankleshwar, Ludhiana etc. were declared “critically polluted”.

Thereafter, in several meetings of CPCB and SPCBs serious debates on the pollution status of these areas were undertaken. Even after formulation of “action plans” for the said industrial areas no substantial or qualitative change was observed in these industrial areas. For this reason, in 2009 the CPCB and IIT-Delhi, listening to the demands of the people’s organisation’s working on environmental issues decided to use a new method of “indexing the pollution levels” of these areas, which is now known as the “Comprehensive Environmental Pollution Index” (CEPI). The CEPI includes air, water, land pollution and health risks to the people living in the area. However, our demand has been to include the health of the workers, productivity of land and quality of food / agriculture produce in the index since contamination of the food supply and environmental impacts on population health should be indicators of environmental pollutants. Pollution is affecting not only people living around the industrial area but anyone consuming it – hence not restricting the impact to the particular industrial area.

As per the agreed upon measures, industrial areas with a CEPI of 70 and above are considered “critically polluted” areas while those with a CEPI between 60-70 are considered “severely polluted” areas. In our opinion, those industrial areas with CEPI between 40-60 ought to be labelled as “polluted areas”.

In December 2009 the CEPI of 88 polluted industrial estates was measured; it was then that the CPCB and the Ministry of Environment and Forest (MoEF) of Government of India were forced to declare 43 of those as “critically polluted areas” and another 32 industrial areas as “severely polluted” areas. Following this study the MoEF on 13 January 2010 was forced to issue a moratorium (prohibition on opening new industries and/or increasing the production capacity of the existing industries) on the 43 critically polluted areas. At that time, Paryavaran Suraksha Samiti (PSS) and other environment protection groups had asked for a moratorium on all the 75 (43+32) polluting areas, but the powerful industrial lobby and state governments working in tandem prevailed to prevent such a moratorium. The mucky politics and economics of “GDP growth” prevailed over the cause of ‘life and livelihood’ of ordinary people and ‘environment & conservation’.

In 2009, the Ankleswar’s industrial area, with 88.50 CEPI, topped the list of “critically polluted areas” of India.

In 2011 and 2013, Vapi industrial area, with CEPI of 85.31, topped this list.

Thus ‘Development Model of Government of Gujarat’ has led to the toppers in “critically polluted areas” in India in 2009 and continues to maintain its position in 2011 & 2013. Then after undue pressure from the industrial lobby, moratoriums on some of the clusters were lifted ignoring the overwhelming evidence of damage to environment and agriculture.

This clearly indicates that central government is not concerned about the environment but it is working under the pressure of Industrial lobby and central government is involved in reversing the past decisions of the Ministry of Environment, Forests & Climate Change to please the industrial lobby.

Let me also make it very clear that when any government and its concerned authorities talk about “prescribed norms” for the chemicals, we should keep in mind that it only means that government is “OK” with that much pollution load and not that there will be no impact at all on environment and health of the people. The “prescribed norms” calculations are not based on carrying capacity of the environment and the people but bearing capacity of the industries to keep up their profitability. The “prescribed norms” of a chemical substance is an exposure level to which it is believed an environment and people can be exposed day after day for a lifetime without adverse effects. Same is the case with the Threshold Limit Value (TLV) concept for the working condition inside the industries.

When we design the “norms” the fundamental question we should ask to ourselves that are we designing the “norms” based on carrying capacity of the area i.e. keeping in mind existing pollution load of the area? Are we considered the facts that many people staying in nearby industrial clusters are living below poverty line and are not able to take required calories in their diets and many of them are malnourished? Are we designing the “norms” for particular cluster or designing the “norms” for an area in general? Can we design just general “norms” or we should design area specific “norms”? Same is the case with calculation of TLV. Today very few people have information and knowledge about the data based used for the design of “environment norms” and “TLV”. We do not debate the authenticity of data base itself.

This is a result of the economic and political decision that decides the central and state government’s industrial policy to ensure the profitability of the industries.

It is time to oppose the dilution of COD norms from 250 mg/l to 500 mg/l by MoEF & CC. Raising the norms will artificially reduce the number of the critically and severely polluted areas on paper, while more industrial clusters will join the list of critically and severally polluted areas in reality. This will only lead to further deterioration of the environment.

Now it is crystal clear that for ‘Modi Government’ the word ‘Environment’ means only “Environment For Investment”.


Rohit Prajapati / Trupti Shah
37, Patrakar Colony, Tandalja Road,
Post-Akota, Vadodara – 390 020
Phone No. (O) + 91 – 265 – 2320399
Email No: [email protected]

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