Performance Audit of Water Pollution in India
Shri Kartikaye Mathur, IA&AS
"Every year, more people die from the consequences of unsafe water than from all forms of violence, including war"
The office of the Principal Director of Audit, Scientific Departments was established in April 1986 to have a unified audit of Scientific Departments/Bodies/Authorities having regard to their special features as suggested by Government on a recommendation of Science Advisory Committee to Cabinet (SACC).
This office was nominated in December 2002 as nodal office for activities relating to Environment Audit. Ever since it has published many all India reviews on environmental aspects like Ganga Action Plan (2000), Project Tiger (2006), Waste Management (2008) and Water Pollution (2011).
Since Environment was an emerging area for audit, we used an innovative approach for identifying the major environmental issues and also the audit concerns. In July 2009, the office of the Comptroller and Auditor General of India organised a Stakeholders’ Conference on Environment Audit to flag major environmental issues in India and to identify significant areas for audit enquiry which could be examined in the course of time. Experts from Civil Society organisations, Ministries of Environment & Forests and Urban Development, from the Indian Meteorology Department and representatives/corporate bodies working in the field of environment attended the Conference.
The areas of environmental concerns that emerged from the conference were:
- Biological diversity including forests and forest management, wetland, mangrove, etc.
- Air Pollution
- Water pollution
- Waste Management
- Climate Change
- Coastal Zone Management
Amongst the various concerns highlighted during the Conference, the following were considered significant from audit perspective:
- Ecological sustainability, equity in distribution of environmental resources and efficiency of environmental programs.
- Audits should be concurrent with the implementation of the programs so that inputs can be provided to improve performance.
- Need to evolve standards for involvement of public/public participation in agencies handling environment as well as in the audit of the environment.
- Need to emphasize on social audit where involvement of local communities in the audit process is important.
- Need to disseminate audit reports more widely.
Since Water pollution emerged as a significant area of environmental concern, we selected it as a topic for a performance audit. To frame the issues and to analyse the situation on the ground, identify criteria and to obtain international references, a two-day International Conference on Environment Audit-Concerns about Water Pollution was organised in March 2010. This conference was attended by members of various Civil Society Organisations, Government Agencies, International Agencies and Regulatory Bodies like Jheel Samrakshan Samity, Arghyam, Tarun Bharat Sangh, Water Aid India, Ministry of Environment and Forests, Central Pollution Control Board, Central Ground Water Board, Jammu & Kashmir Lakes & Waterways Development Authority, International Union for the Conservation of Nature, Food and Agriculture Organisation, GTZ etc. The Heads of Supreme Audit Institutions from Austria, Bhutan, Maldives and Bangladesh also shared their concerns about water pollution.
The Conference flagged important areas of concern with regard to river, lake and ground water pollution. Some of the issues raised during the Conference were:
- Lack of coordination and ownership between the different agencies that are involved in its implementation;
- Need for the government to review the low levels of budgetary priority given to environment programs in the country;
- Need to strengthen truly representative public participation in governmental programs;
- Need to co-relate the reality that the number of citizens dependent on water bodies for livelihood with the creation of programs for conservation;
- The imperatives of a comprehensive river basin approach for curbing river pollution as opposed to the extant town-based approach;
- The requirement of legislations for maintaining minimum amount of water/flow in lakes and setting standards for nitrogen and phosphorus as measures of water quality;
- Commitment from Supreme Audit Institutions to carry their mandate of environment audit forward and be more proactive in the field of environment audit.
Taking cognisance of the emphasis put in both the conferences on the need to engage the local communities in identifying environment concerns of the immediate population and assessing how well the environment maintenance and improvement initiatives of the Government addressed their concerns, we put out advertisements in various national and local newspapers all across India, inviting suggestions from the general public regarding the water pollution problems faced by them. Over 500 responses were received as e-mails and letters. All these inputs facilitated the framing of audit objectives, sub-objectives and questionnaires for the Performance Audit (PA) on water pollution.
Some of the issues raised by the public were:
- Awareness generation among the literate urban & implementation of the law.
- A separate department both at Central and States must be created to save water bodies. Political interference must be stopped in freeing water bodies from encroachments.
- Rainwater harvesting should be implemented.
- Initiative need to be taken for cleaning and filtration.
- Every panchayat should allot a particular place to throw the wastes. Parks should be maintained on the river bank. Action must be taken to remove all waste plants near the river.
- After the work is done there should be check about the maintenance of the canal.
- Organic parameters have yet to be clarified/defined by the State Pollution Board. Point Source Analyses thus becomes an essential part of pollution abatement strategy. The Research & Development (R&D) efforts should be directed towards assessing persistence of any hazardous chemical entity. Some of the techniques like BOD and COD, we still practice need to be updated or replaced. These tests need to be gradually superseded by standardized toxicity test Microtox.
Following should be carried out to save the rain water by PWD/ Civic bodies and road construction agencies:
- The side berms of the roads in cities should be sloped on the outer side of the road width at all places.
- Do not let the rain water enter into the side drains, but let it be absorbed by the earth in a natural process time.
- Remove all the paper/plastic/obstruction (like stones, unnecessary walls, pavements, cementing etc from the face of earth). Allow water to come in direct contact with earth with least flow to far of place.
- All trees should have a round dug place of about two feet bigger circumference then the tree circumference. Trees absorb lot of water and much faster. This will recharge the underground water
- Recycled water should be used in their own tannery instead of discharging that in the river. The lakes, ponds and tanks around this area should be renovated. A tribunal should be formed consisting of tannery owners, NGOs and general public and government. The resolutions made by the tribunal should be sent to the government as their recommendation.
- Priority should be given not to allow the deeper aquifers to get contaminated. In case of dug wells proper lining must be provided for the formations vulnerable to contamination. In case of bore wells a proper case must be used to avoid the entry of undesirable waste. Direct entry of surface water/recharge water, if contaminated, into dug wells or bore wells, must be protected by filtration. Salinated water either from deeper aquifers or from water logged areas should be carried on the high land areas and then used or spread. This will reduce the salt concentration, and also its use will recharge the upland areas and help in crop production.
- To check Pollution of Drinking Water Sources, the Pits in Fine Soils (Effective Size 0.2 mm or less) should be located at a minimum distance of 3 meters from Open Wells. Hand Pumps provided Ground Water Table throughout the year is 2 metre or more below the Bottom of Pit, if Water Table is higher, the distance should be increased to 10 metres. In Coarser Soils (Effective size more than 0.2 mm), the same safe distances can be maintained by providing 500 mm thick sand envelope of 0.2 mm sand all around the pit and sealing the pit bottom with some impervious material like puddled clay, polythene sheet, lean cement concrete or cement stabilised soil. Normally bacteria does not move beyond 3 metres horizontally in homogenous soil and vertically it does not permeates more than 1 metre, however there can be marginal deviations depending upon the types and compaction of the soil.
- Pollution penalty of a certain amount per day till the BOD load is brought back within the “minas” standard. All units must have a ground water monitoring system as per international standard. They must have monitoring wells and must have ground water analysis results.
- Check dam should be constructed by the industries at their discharge point. Sewage of the industry should be discharged in the river after sufficient treatment. A huge quantity of water is wasted every monsoon due to non-availability of adequate storage system.
- The rules governing pollution of water caused by factories should be rigorously implemented. The sewerage water should not be allowed to mix with ponds and rivers. Fast action should be taken by concerned bodies and NGOs to clean up lakes and rivers in their locality and erect more SHOUCHALAYAS for the masses. Planning is required to prevent slums, houses etc. from being constructed near the water bodies to stop the temptation on the part of their occupants to use them as easy outlets for rubbish. Dead animals and birds should not be allowed to be thrown into the seas, rivers, etc.
With the help of the inputs received during different engagements with the stakeholders, we proceeded to frame the areas of audit enquiry and audit questions. Audit methodology consisted of document analysis, responses to questionnaires, examination of reports & records at various levels to collect audit evidence. And the performance audit of “Water Pollution in India” was conducted during 2010-11.
An innovative approach was used fixing the criteria for the Performance Audit and secondary sources of criteria like certain non-conventional sources were used, these included:
- the Agenda 21 document of the World Commission on Sustainable Development of the United Nations Conference on Environment and Development, held in Rio in June 1992,
- Guidelines of United Nations Environment Programme (UNEP) on water pollution, etc.
These criteria had to be adopted because there was no standard on bio-monitoring, non-point sources of pollution of rivers and lakes.
Taking into account that in order to set the standard for the desired quality of a water body, it is essential to identify the uses of water in that water body. In India, Central Pollution Control Board has developed a concept of designated best use. Five designated best uses have been identified:
- Drinking water source without conventional treatment but after disinfection
- Outdoor bathing (Organised)
- Drinking water source after conventional treatment and disinfection
- Propagation of Wildlife and Fisheries
- Irrigation, Industrial Cooling, Controlled Waste disposal
This classification helps the water quality managers and planners to set water quality targets and design suitable restoration programs for various water bodies. We used these targets as benchmarks in evaluating the quality of the water.
A conscious decision was taken to allocate substantial time for audit planning which is not common in our Performance Audit (PAs). Hence six months were allotted for audit planning and six months for field audit.
An Entry Conference with the Ministry of Environment & Forests (MoEF) was held on 30 July 2010 wherein the audit objectives, scope of audit, audit criteria and audit methodology were discussed. Exit Conference on 6 June, 2011 was held with MoEF where audit findings were discussed.
At the Centre, audit scope covered the programs and schemes for control of pollution of rivers, lakes and ground water in MoEF/MoWR. It also covered functioning of NRCD, its role in planning, implementation/monitoring and monitoring activities of CPCB/CGWB, relating to river, lake and ground water pollution relating to the period 2006-07 and 2010-11. Records of Water Quality Assessment Authority (WQAA) were also examined in light of the responsibilities allocated to them.
In the States, audit scope covered adequacy of data relating to river, lake and ground water pollution. It also extended to the study of the implementation and monitoring of programs (NRCP and NLCP) for the control of pollution of rivers and lakes by the designated agencies. Audit scope related to the States also covered implementation and monitoring of schemes, if any, for the control of pollution of ground water.
For this we test-checked records of the State Governments, implementing agencies (mainly municipalities and lake development authorities), State Pollution Control Boards and WQRC in the States covering the period 2006-07 to 2010-11.
The review was undertaken to ascertain whether:
- Inventory of water sources has been prepared and whether the overall status of quality of water in rivers, lakes and groundwater has been adequately assessed in India;
- Risks of polluted water to health of living organisms and the impact on environment have been adequately assessed;
- Adequate policies, legislations and programs have been formulated and effective institutions been put into place for pollution prevention, treatment and restoration of polluted water in rivers, lakes and ground water;
- Programs for pollution prevention, treatment and restoration of polluted water in rivers, lakes and ground water have been planned, implemented and monitored efficiently and effectively;
- Funds were utilised in an efficient and economic manner to further the aim of reduction of water pollution;
- Adequate mechanisms have been put in place by the government to sustain measures to tackle water pollution and
- Programs for the control of pollution had succeeded in reducing pollution levels in ground water and surface water and restoring water quality.
We selected the audit sample on the basis of assessment of risks like expenditure, criticality of the project in pollution control and feedback received from the public to the advertisement placed in newspapers.
- Out of 1079 projects for pollution control of 24 rivers across 19 States being implemented, we scrutinized 140 projects being implemented for control of pollution for 24 rivers.
- Out of projects for conservation of 58 lakes in 14 States, we studied 22 projects for conservation of lakes across 14 States.
- Out of a total of 6053 blocks across India, we examined 116 blocks for implementation and monitoring programs relating to ground water pollution.
- Audit also studied the administrative structures and activities related to water pollution in 25 States of India.
Our recommendations to MoEF were:
- MoEF/States need to set out a clear policy on water pollution which takes into account prevention and control of water pollution as well as ecological restoration of degraded water bodies.
- MoEF/CPCB should initiate steps, along with Ministry of Water Resources and all the States to draw up a comprehensive inventory of all rivers, lakes and ground water sources in India. It should also undertake a survey to list the entire keystone species associated with each river and lake in India. This should also be placed in the public domain.
- MoEF/CPCB should intensify its efforts in developing biological indicators which would shed light on whether the functional integrity of aquatic ecosystems is safeguarded.
- MoEF should take into account the basin approach while planning for reduction of pollution of all rivers and lakes in the country.
- With respect to lakes, all three attributes i.e. the basin, the water body and the command area need to be conserved instead of the present focus of NLCP on the water body only.
- MoEF needs to establish enforceable water quality standards for lakes, rivers and ground water that would help protect human and ecosystem health. Penalties need to be levied for violations of water quality standards. Further, MoEF, in conjunction with Ministry of Agriculture, needs to develop standards for pollutants like nitrogen, phosphorus etc., which arise from agricultural practices, use of pesticides and fertilisers as pollution from agricultural sources is one of the biggest non-point source of pollution.
- The Jawaharlal Nehru National Urban Renewal Mission is already funding sewerage projects in some of the same States where funds are being provided by MoEF for the same purpose. It needs to focus on projects which seek to regenerate and conserve the river instead of those which focus largely on treatment of sewage. MoEF/States should conceive programs which address different sources of pollution flowing into rivers, lakes and ground water with focus being not only on prevention of pollution but also conservation and ecological restoration of our water bodies.
- Right now, there are multiple agencies involved in river and lake conservation, right from planning to implementation and monitoring. There is a need to consolidate all these functions for better coordination and accountability.
- In conjunction with the Ministry of Urban Development (MoUD), MoEF and the State should plan drainage for the city as a whole instead of piecemeal approval of random STPs and I&Ds. Further, funding for these projects should come from MoUD as the implementing agencies work under the control of MoUD. MoEF should be involved in the design stage and in monitoring the treated effluents if they are being discharged into the river.
- MoEF/States need to ensure that projects for source control of all kind of pollutants entering the lakes is included in projects for conservation and restoration of lakes, especially sewage and agriculture runoff which leads to nutrient over-loading of the lake.
- MoEF should ensure that all lakes facing encroachment and resultant filling up are included in NLCP. Further, all State Governments should declare bio-conservation zones around lakes so that encroachment of shoreline is prevented.
- The Water Quality Assessment Authority at the central level and the Water Quality Review Committee in the States should be revitalized and strengthened so that it can act as a cross-sectoral nodal body for water pollution issues.
- States should involve citizens in proposing and monitoring programs to control pollution of rivers and lakes. This will help in mobilizing support in civil society for the proposed projects and thus the projects will face less resistance from local people. Citizens Monitoring Committee and Local Level Lake Monitoring Committees need to be constituted to provide feedback for more effective implementation.
- MoEF/CPCB, in conjunction with the States, should conduct a city-wise assessment of the levels of pollution in our rivers and lakes. They should also evaluate the success of projects undertaken under NRCP in terms of pre-defined indicators developed by MoEF/CPCB. Such impact assessment should be done in a continuous manner so that data is generated to judge whether the programme is meeting its stated objectives.
For the Performance Review we received written replies from MoEF, MoWR, CPCB, CGWB. An issue which even the peer review had spoken about. To consider the recommendations/ observations contained in the audit report for implementation, MoEF constituted a committee, which brought out a Road Map for Management of “Water Pollution in India" (March 2012) comprising its recommendations on policy framework, programs/ activities of MoEF, infrastructure, monitoring aspects and financial management for better control over prevention of water pollution in India. The Audit Report was also discussed by the PAC in its meeting held on 17 July 2012
The PAC discussed the issue of water pollution at length with the senior officers of the Ministry. After collecting the oral evidence of MoEF, the PAC issued an exhaustive questionnaire to MoEF on various issues such as the adequacy of the legislative framework in enforcing pollution of water bodies as an offence, integrated approach involving various stakeholders towards management of the concerns surrounding water pollution, measures taken by MoEF to strengthen its resources handling water pollution issues etc. The Ministry has submitted its response to the questionnaire which is under vetting by audit.