Environmental enforcement of industrial clusters in India is a daunting task for regulators. The clusters consist of micro-smallmedium enterprises (MSMEs) who do not have adequate technical capacity, capital and space to install individual pollution control plants. Consequently, common solutions are sought where a pollution control plant for the entire cluster is established and operated. Industries collect effluents and send them for treatment and disposal to this common plant after some pretreatment.
The concept of Common Effluent Treatment Plants (CETPs) for industrial clusters emerged in early 1977. Professor Nilay Choudhuri, the then Chairman of Central Pollution Control Board (CPCB) produced a landmark publication ‘Industrial Estate Planning’ after a consultative workshop. I still have a copy of the workshop proceedings. This publication is a must-read.
A scheme to finance CETPs was launched under the Central Loan Scheme. Later, between 1991-1999, the Scheme was supported by the World Bank under the credits lines – Industrial Pollution Control and Industrial Pollution Prevention & Control. Today, nearly 200 CETPs operate in India. These CETPs are owned by companies formed by the member MSMEs who employ or contract operational staff and collect effluent charges based on a formula.
Independent assessments have shown that on an overall basis, the performance of CETPs has not been satisfactory. The reasons have been several – lack of interest or commitment, technical difficulties in treating complex and variable effluents, unreasonable effluent standards (such as Total Dissolved Solids – (TDS) etc. This has led to public interest litigations and subsequent intervention by the judiciary. In the last two decades, cases of en masse closures have taken place under court directives especially in the states of Gujarat and Tamil Nadu. Negligence on environmental matters has thus led to significant economic (business) and social impacts (employment).
I met the Chief Secretary (CS) of one the troubled states where industrial clusters, CETP and judicial intervention had become a serious political issue. We were having dinner. The CS said that it is important that the Chief Minister (CM) of the State is briefed in a 3600 perspective to get a ‘balanced’ view on what should be done to address this problem. He asked me if I could give a presentation to the CM on my own assessment of one of the prominent industrial clusters. I generally avoid meeting with politicians but couldn’t resist the CS’s invite as the CM of the state was known to be one of the sharpest state rulers.
The CS asked me to come one day early, as he wanted to review my slides. When we met in a hotel, he seemed a bit worried. “Dr. Modak, I am not really sure how the tone of your presentation should be. I have been informed that the CM may be having a stake in one of the prominent industrial units in the cluster. So going too hard on the industries may not work and the CM may not like this approach. On the other hand, we have been also informed that the CM wants to show firmness and decisiveness towards environmental matters. En masse closure of industries was one way to demonstrate this intent”.
“What do you expect from me then?” I asked. I was not comfortable with this complex situation.
I suggest you make two sets of presentations – the CS said. One set will ‘defend’ the industries and come up with recommendations that will provide them some time, some concessions and technical guidance to reach the desired level of compliance. The second presentation set will present a case that is ‘hopeless’ and recommend strict punitive actions and even a mass closure if required.
You should start your presentation using the second set first. I will watch how the CM is reacting. If I see the CM perturbed then I will pass you a chit suggesting you need to switch the presentation. But you will have to do this rather smoothly.
I thought this was going to be challenging but it looked like there was no other option. I wished I was a theater actor.
In those days, we did not use PowerPoint projections. I had a stack of plastic foils or transparencies. I reviewed my slides, added more and split the presentation into two – giving two different points of view. This needed late-night work with a strong South Indian coffee. By 2 am, I had two stacks of slides – one comforting the industries while recognizing that non-compliance was a serious matter (stack A) and the other recommending strong punitive action to show the might of the state (stack B). I decided to put the slide deck B on the ‘left’ slide of the overhead projector (OHP) and deck A on the ‘right’.
When I reached the office of the CM in the morning, the CS was waiting for me. He had organized a trolley with an OHP. “Where your two slide are stacks?” he asked in anguish. “The CM is very busy today and as soon as the red light outside the door turns green, we will enter the room with this trolley and immediately start the presentation. The CM hates
wasting time on preliminaries. The Finance and Environment Secretaries are already inside discussing other matters.
I was tensed.
As soon as the red light turned green, we rushed inside. I was introduced. The CM spoke to me in Tamil (the State language). I being a Marathi, did not understand a single bit of what was said. When he realized that I don’t speak or understand Tamil, the CM asked the CS why someone from State of Maharashtra was called to advice. Wasn’t there a competent expert available in our state? This conversation took place in Tamil.
I was told later that the CM was really upset and had told the CS to simply pack me off and stop the presentation. “Next time the gentleman should come here to present in Tamil (i.e. he should learn Tamil) or else get me someone else from the State,” the CM scorned. The CS had somehow managed the situation by pleading my case and saying that now that I was there ….
In the bargain, my presentation time was reduced from 20 minutes to 15 minutes!
I had set up the two slide packs A and B on the left and right of the OHP. The presentation began from the ‘left’. I was going hard on the industries, the non-compliance, environmental, health and economic damage etc. I showed some statisticsand maps. The CS was watching CM’s face. I could sense some level of discomfort on his already-agitated face.
And as expected, a small chit came to me from the CS after 5 minutes that indicating the need for the switch. I paused and picked up the transparency from the ‘right’ side of the OHP now. I said “The situation is grim – however enforcement alone is not going to work. Closing of the industries is not the solution. You need to support and catalyze ecological modernization of the MSMEs”
I picked up the next “right” transparency. I spoke about carrot and stick approaches, market instruments and experiences from other countries.
We need to set up demonstration projects using cleaner technologies where we reduce pollution loads at the source itself rather than following conventional end-of-the-pipe approach. If TDS is the issue, then the solution is not to rely only on the Reverse Osmosis (RO) plants or Multiple Effect Evaporators (MEE). These solutions are both capital and energy intensive. Substitution or minimization of use of salt in the manufacturing processes itself, along with recovery, could be the way out.“What we need is a strategic
approach that blends compliance with competitiveness”
My last punch line seemed to have pleased the CM. I saw that increasing attention was given to my later slides. The presentation ended exactly in 15 minutes. The CM looked happy and so did the CS.
As we left the room, the Personal Secretary (PS) to the CM came rushing to me. “Good presentation, Sir. Thank you. Only one request from the CM. The CM wants copies of both the slide decks – the one on the left as well as on the right.”
My mouth turned dry. I looked at the PS and CS helplessly.
While handing over both the decks to the PS, I realized why this person was the CM of the State and indeed deserved to be! No details were missed despite my attempt at a smooth transition.
I asked the CS to book me on the next flight out of the State. (The other option was to learn Tamil in Mumbai in one of the Idli lanes of Matunga)
But fundamentally, left vs. right was the issue. And the issue still remains.
I very much cherish this experience
(Cover image sourced from https://www.dominie.com.au/products/YI-62634)