In mid December 2018, the report of the Comptroller and Auditor General’s performance audit on Solid Waste Management (SWM) in 35 test-checked Urban Local Bodies (ULBs) in Karnataka was tabled at the state assembly. The report painted a rather sorry picture of the way these civic bodies had been going about the task of solid waste management in their municipalities and called out instances of flawed collection, ineffectual bans on plastic, faulty handling of e-waste and unauthorised slaughter houses among various other gaps.

However, that is not where the CAG indictment of the ULBs ended.

As per Paragraph 7.2 of the Swachch Bharat Mission guidelines, ULBs were to prepare Detailed Project Reports for Solid Waste Management in their jurisdiction in consultation with the State Government. These DPRs were supposed to provide the very base for the planning and implementation of waste management in the different ULBs.

As per SBM Urban guidelines, street sweeping, litter control intervention and dumpsite remediation were all to be part of such DPRs, created with the final aim of ensuring a clean city. The guidelines also provided scope for handholding by the state government, if needed for quick preparation of such DPRs.

Auditors observed that District Urban Development Cells had invited tenders in November – December 2015 from agencies empaneled by Government of India and entrusted work under the Terms of Reference provided by the state government. But a major factor that led to deficiencies in DPRs on SWM is that the state government had stipulated a time frame of 50 days for completion and finalization of each DPR.

The CAG report states that “As of March 2018, the DPRs of 223 out of 281 ULBs (except BBMP) were prepared; of which, the High Powered Committee approved 218. In 58 ULBs, preparation of DPRs did not commence at all, even after a lapse of more than two years”. The State Level High Powered Committee has pressed for the speedy preparation of these remaining DPRs in their 7th and 8th meeting.

It would of course have helped citizens if the CAG report mentioned the names of these 58 ULBs, and also clarified whether the Department of Municipal Administration has already accorded the work of preparing these DPRs to consultants after issuing tenders and proper scrutiny of the same. But these details are missing in this otherwise detailed CAG Audit Report. It is now up to the curious citizen to seek these details by filing an RTI application with the Public Information Officer at the Department of Municipal Administration..

CAG auditors have not disclosed the reasons behind the High Power Committee (HPC) withholding approval to the DPRs of the five remaining ULBs. Readers are left wondering whether these DPRs were not discussed by the HPC, or whether the audited entity merely didn’t furnish the reasons cited by HPC for not granting approval. The report doesn’t mention the names of these five ULBs either.

Next, the CAG audit elaborates on the deficiencies that were found in the DPRs pertaining to 30 of the test-checked ULBs.

The other five sampled ULBs (Kakkera, Mugalkhod and Ugar Khurd TMCs as well as Ainapura and Chinchli Town Panchayats) were upgraded from Gram Panchayat status only in the year 2015-16 and DPR preparation was not yet taken up there.

Non-involvement of stakeholders in planning

The CAG has strongly criticized ULBs for failing to engage RWAs, co-operative societies, sanitation workers, NGOs working in the field and many other important external stakeholders,  whose inputs would have provided crucial insight to aid the planning process as well as implementation.

The audit pointed out that the civic bodies neither constituted a core/advisory team (internal stakeholders) nor a stakeholder committee (external stakeholders) in any of the test checked ULBs. Only one ULB (Bagalkote CMC) had made a beginning in January 2013 by identifying ragpickers and issuing 85 identity cards (as of September 2017).

Similarly CAG also indicted ULBs for failing to acknowledge the primary role played by informal sector waste pickers, waste collectors and recyclers, stating that, “It is the duty of (an) ULB to establish a system to recognize organisations of informal waste collectors and establish a system to facilitate their participation in SWM”.

Inadequate estimation of waste generated

The audit observed that none of the 30 test-checked ULBs adhered to the methodology as prescribed in the Manual on Municipal Solid Waste Management (2016). This manual stipulated that for the purpose of long term planning, the average amount of waste disposed by a specific class of generators may be estimated only by averaging data from several samples. These samples were to be collected continuously for a period of seven days at multiple representative locations, in each of the three main seasons.

For example, if the municipality wants to assess the average amount of waste disposed of by bulk-generating apartments, samples should be collected from multiple such apartment complexes for seven days at a stretch in summer, winter and the rainy season. This waste should then be aggregated over the seven-day period, weighed and averaged. These quantities could be extrapolated to the entire ULB and per capita generation assessed.

The audit scrutiny revealed that 20 ULBs had assessed waste generated by conducting a sample survey for three consecutive days in one season only. T. Narsipura assessed waste generation by conducting a sample survey for seven days in a single season. Hubballi – Dharwad did not conduct any survey but adopted population estimation/per capita method to arrive at the average waste generated.

The remaining eight ULBs claimed to have quantified waste generation by collecting samples, but couldn’t furnish any documentary evidence for the same.

Replying to this audit objection, the state government stated in May 2018 that “Due to lack of time, 3 to 7 days sampling period for short term planning was followed and uniformity could not be ensured.” CAG found this reply untenable since it doesn’t address the issue of estimation of waste for long term planning.

Incomplete coverage of waste generators

The audit observed that none of the DPRs included generation of solid waste from public buildings, such as places of worship (except Udupi and Maddur), industrial buildings (except HDMC and Sagar) etc. CAG also raised objections on the failure to capture and include temporal fluctuation (due to festivals, functions etc).

As for other classes of waste generators, public buildings would also vary largely in the amount and nature of waste they generate. To arrive at an average, these variations must be captured through a well-designed sample survey.

It was also found that 21 out of 30 DPRs had failed to mention the quantum of unprocessed waste dumped at landfill sites. While the remaining nine DPRs had mentioned it, in case of eight ULBs, CAG auditors couldn’t establish authenticity since these ULBs either didn’t have a weighbridge facility at the landfill sites or it was not in working condition.

In one DPR (Sira CMC), when auditors compared the assumption of accumulated waste (i.e. 3070 tons), they found the assumption to be a significant under-estimate. The quantum of waste accumulated, based on a topographical survey in July 2016 with weighbridge entries for 15 months (April 2015 to July 2016), gave CAG auditors a figure of 7647 tons, almost twice the assumption in DPR!

Thus a complete and reliable database as desired by the Manual of Municipal Solid Waste Management, 2016 was not found in any of the DPRs test checked.

Non-coverage of special waste

The state level technical committee (constituted in January 2016 to accord technical approval to DPRs) had put forward an opinion in its very first meeting (February 2016) that measures to manage other waste like e-waste, hazardous waste, hospital waste, industrial waste etc.should be addressed in the DPRs.

None of the 30 DPRs that CAG auditors examined, however, addressed measures to manage these special categories as desired by the technical committee.

The state government, in its reply (May 2018) tried to justify this, stating that this issue had been considered in DPRs prepared in the year 2017-18. The reply also argued that assessment of special waste was not attempted earlier since the quantity of such waste in comparison to MSW generation was very little for these ULBs. CAG auditors have not found this reply convincing and state:

“The fact remains that the directives of (the) State Level Technical Committee were not complied with and documentary evidence in support of the reply was not furnished”.

Lack of contingency plans

The MSWM Manual (2000 and 2016) stipulated that ULBs should prepare contingency plans for appropriate storage of waste, to tide over situations when the processing/ treatment/disposal facilities were interrupted for some reason or not working. Despite this, auditors noticed that such plans were not prepared by any of the test-checked ULBs.

Thus, when there were public protests in Tumakuru and the villagers didn’t allow passage of waste transportation vehicles (2014), or when fire broke out at landfill sites in Ballari, Hubballi-Dharwad, Bidar, Dandeli etc, ULBs were caught unprepared to tackle any of these unforeseen situations.

Absence of waste minimization strategy

The principle of creating public awareness regarding minimization of waste was mentioned in the State SWM Policy (2004). However, the Karnataka government failed to operationalize a focused waste minimization strategy in its urban centres, even by December 2017 (when the CAG finalized its performance audit report).

Lapses pointed out by CAG auditors reveal the lack of basic monitoring by municipalities and district/ state level authorities to ensure compliance to statutory requirements. It seems that in a rush to carry out programme execution under the Swachh Bharat Mission (Urban), the authorities failed to ensure that DPRs on SWM captured the ground realities.