“KSPCB’s steep hike in CFO charges, unreasonable and unjust”

The hike in the annual Consent for Operation fee is arbitrary and, worse, could discourage people from treating their sewage. It is especially unfair to law-abiding citizens.

On November 20, 2020, the Karnataka State Pollution Control Board (KSPCB) issued a notification to increase the annual CFO (Consent For Operation) charges steeply. 

This notification is applicable to all Sewage Treatment Plants (STPs), including the ones operated by Bangalore Water Supply and Sewerage Board (BWSSB) and the private ones operated by the apartments, hospitals, malls, office complexes, IT parks, and others. 

There are major issues with increasing the annual CFO charges. Here are some of the issues listed:

1. KSPCB levies CFO charges only from 40 per cent of the public who treat their sewage in their own STP or BWSSB-run STPs. It does not levy anything on the whopping 60 per cent of the population — They are left free to pollute the environment.

This is highly unfair and violates the polluter pays, cost minimisation and equity principles enshrined in the National Environment Policy (NEP), 2006.

2. KSPCB applies very high Consent For Establishment (CFE) fees to domestic STPs because it holds that domestic STPs cause hazardous pollution that is at par with nuclear power plants, refineries, tanneries, steel foundries, etc (see appendix-B).

Read more: Why sewage treatment plants in apartments are messed up, and how this can change

This is a ridiculous stand. Even if domestic sewage is left untreated, it does not pose a danger that is comparable to the pollution from the other entities. 

Well, if we compare the day-to-day pollution, no apartment will match a refinery or a tannery. On the other hand, if we compare the pollution caused when the plant fails, no apartment can match a nuclear plant or a refinery.

3. KSPCB has no logic in hiking the CFO charges

  • The charges are arbitrarily set: They are not structured like a fee, fine, tax or fund. (see appendix-C)
  • The charges are not designed to nudge or encourage people to treat their own pollution. In fact, law-abiding citizens are given step-motherly treatment. (see appendix-D)

4. The original idea was to create a corpus for KSPCB, so that it can fulfil its duties that are defined in various Acts, such as the Water Pollution Act, 1974, and the Air Pollution Act, 1981.

According to the Water Act, this corpus was supposed to be utilised to arrest the degradation of the environment, as follows:

  • City-wide planning of sewage treatment infrastructure
  • Introduce new technologies (sponsor research)
  • Encourage industries (provide subsidies)
  • Educate builders about new technologies in STPs, bioremediation, etc
  • Educate users about water conservation, recycle and reuse
  • Monitor compliance with policies through audits

But in reality, KSPCB fails to fulfill almost all of its official duties.

Why should KSPCB be allowed to amass money if it is not spent to fulfil KSPCB’s duties?

Read more: How a dysfunctional pollution watchdog is affecting Bengaluru’s water scene

5. KSPCB refuses to accept that the CFE-CFO are given only if the STP passes rigorous checks and tests, and therefore they represent a certificate of guaranteed performance to the users.

6. In fact, KSPCB tends to raise even fundamental design flaws in STPs that have been running for years. Thus having CFE-CFO has no value. If so, why do we have to pay such a high price for these certificates if they are so worthless?

7. If an STP has CFE-CFO and yet it is found to pollute the environment, then KSPCB inspector must be held responsible for dereliction of duty, and KSPCB must compensate the STP owner under the law of torts.

Even the NEP enshrines the principle of “legal liability”, which further defines “fault-based liability” and “strict liability”. However, KSPCB refuses to accept any liabilities. 

In that case, KSPCB has no purpose left to amass wealth.

A file picture of Bellandur lake receiving untreated water. The lake has received toxic wastewater for 50 years. Pic: Sankar C G

Suggested remedies

1. All apartments, regardless of size, should be considered as “white category

2. Restructure the CFE-CFO fees to nudge people to follow NEP principles

Specifically, differential treatment must be given to the three classes of populations described in the appendix-D, so that the self-treaters get incentives, while the polluters get punished

Further, the cost of pollution treatment must be distributed equitably. That means STP-owners must be compensated. 

3. KSPCB should start fulfilling all its duties listed in the Water Act, 1974; which are neglected for the last 15 years, since its inception (a short list is given in point number 4 of the major issues listed).

[Read Part 1 and Part 2 of the series.]

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  1. George Abraham says:

    The cost of electricity to operate an STP is a big source of worry for Residential Welfare Associations. In most cases they make up more than 50% of the electricity bill every month. An extra burden from KSPCB will only increase the frustration.

  2. UMESH C J says:

    Maintenance of STP should be the responsibility of Bwssb/Kspcb. No Apartments should maintain STP as it is a skilled work and residents are not ment for maintaining the same.

  3. umesh C j says:

    When entire Sewage water of all individual houses etc are treated at STP maintained by Bwssb why residents of Apartments are burdened with maintenance of STP at huge cost, responsibility and ill effects of it.

  4. UMESH C J says:

    Now Apartments are being soft target for all Departments like Bwssb, kspcb, Bbmp, Bescom simply shifting their responsibility has become a fashion.
    Ex: STP is the responsibility of Bwssb/kspcb
    ///ly Transformers maintenance is the responsibility of Bescom
    ///ly Garbage collection is the responsibility of Bbmp
    Where as all the above Dept have shifted their responsibility to Residents of Apartments. A day is not far away other Dept like Fire Dept, Medical Dept,Banks and Insurance Dept may force Apartment residents to manage all administration and carry risk of Fire, Phc, Banking facilities and Insurance. Being a resident of Apartment seems to be a hell.

  5. Rajinder Verma says:

    Dear Mr Member Secretary KSPCB
    1. The recent hike in the CFO Rates are most unreasonable and the entire process is extremely unthoughtful and detrimental to encouraging citizen’s participation in keeping Karnataka, clean, green & water neutral. Let me list my objections:-
    a) Provision of Basic Municipal Services is the responsibility of the State forwhich the State can & does change Property Tax. Thus imposing a huge CFO Charges is a double whammy.
    b) Most STPs in residential areas are setup by the RWA/ Community and are also operated & maintained by the RWAs themselves without any state support whatsoever.
    c) STP operations are extremely expensive in terms of labour effort & electricity consumption, but the residents happily bear the cost since they want to live in a clean green environment and thus bear these costs.
    d) Equating the Residential STPs with those in Industrial Areas is being extremely incentive. While there is no denying that industrial units may discharge untreated affluent into public water bodies such is NOT the case with RWA run STPs. More often than not the RWAs use 100% of the treated RWA water and are infact helping recharge the Ground water within the community.
    2. A better alternative to this unthoughtful steep hike in CFO charges is to establish a graded system of incentives to those in compliance of standards & steep penalties to those in violation of the KSPCB norms. In fact I would go so far as to suggest that RWAs should all be encouraged to establish STPs and use the treated water and there should be absolutely no CFO fees charged to RWAs.
    3. We expect a favorable revision of your policies which seem to have missed the essence of public good in misplaced bureaucratic enthusiasm to increase Revenue.
    With best wishes,
    Colonel Rajinder Verma, (Retd)

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