A BANGALORE ENVIRONMENT TRUST PUBLICATION 07 Nov 2020 BET’s official submission to UDD, BDA, BBMP, BWSSB, KSPCB and NGT appointed monitoring committee CITIZEN’S AGENDA FOR BELLANDUR/VARTHUR CATCHMENT Team: Dr. Yellappa Reddy, Nirmala Gowda, Dr. Nidhi Paliwal 1 About Bangalore Environment Trust (BET) Bangalore Environment Trust was founded in 1987 by a group of enlightened citizens. Since then the trust has been working on multitude of environmental issues like lake restoration, urban tree protection, afforestation, pollution prevention, water rights and pollution related livelihood issues. We also dabble in art from time to time. We hold regular events to bring the nature’s touch to children. Working with various academic institutions and research organizations we continuously bring peer reviewed scientific data into policy and decision making. We take it to police and courts where necessary. We are practitioners of democracy. About the team: DR. A. N. YELLAPPA REDDY, CHAIRMAN Member of Indian Forest Services, Dr Reddy has served for four decades as an Administrator of Forests. He knows every inch of Western Ghats and its ecology. He retired as the Secretary of Department of Ecology and Environment, Government of Karnataka. He served as the member of Karnataka High Court Lok-Adalat. He is the founding member of Foundation for Ecological Security. It is under his expert and soulful guidance that BET has done numerous lake restorations and afforestation work, along with other organizations. MS. NIRMALA GOWDA, TRUSTEE Was a Software Engineer, who last worked for Novartis Pharmaceuticals in the US. Returned to India, after spending more than a decade in the US, with the intention of farming and working on environmental issues. She has volunteered with Environmental organizations like Sierra Club and Nature Conservancy in the US and has a M.sc in Environmental Management from University of San Francisco. She does natural farming and works on water pollution and livelihood related issues DR. NIDHI PALIWAL, TRUSTEE She has practiced dentistry for 15 years and has worked in various hospitals including Manipal. She works incessantly to leave a better planet for her children and resides next to Bellandur Lake. Postal Address: No.10, Sirur Park ‘B’ Street, Seshadripuram, Bangalore 560 020 Website: https://bngenvtrust.org/ Email: [email protected] 2 WHY THIS DOCUMENT? Following the trail of Bellandur and Varthur Rejuvenation, we discovered the rejuvenation process to be ad-hoc , illogical and not supported by well documented data and scientific facts. An opportunity to provide inputs was presented to BET’s chairman Dr. Yellappa Reddy, when he was nominated by BDA as a technical committee member to advise on rejuvenation of Bellandur and Varthur Lakes (15). BET team presented several critical recommendations supported by facts and figures, requesting the government to course correct. In Feb 2020, BET supported by citizen experts, along with other technical committee members, wrote an open letter to the government requesting it to pause and critically evaluate its actions (8). The same letter was sent to NGT. The Hon’ble NGT in its order dated 13 Aug 2020 (22), asked the monitoring committee to consider the letter. In pursuant of that order, the monitoring committee sent an official meeting request on 24 Sep 2020 and the virtual meeting took place on 28 Sep 2020 (23). The analysis presented by BET at that meeting is collated in this document, “Citizen’s Agenda for Bellandur/Varthur Catchment”. This document is BET’s official submission to government bodies and NGT appointed monitoring committee. We hope this also serves to inform the civil societies on the state of affairs. 3 EXECUTIVE SUMMARY Actions taken by the government to restore Bellandur, Varthur and Agara lake is found to be superficial and leaves the citizens wanting for more. In-depth analysis of the government’s submissions to National Green Tribunal over the past few years revealed continued wanton neglect of responsibilities, eluding courts with inaccurate facts and escaping public scrutiny with non-transparent operations. Treated wastewater is a precious commodity in today’s times. In the absence of treated wastewater policy and the necessary data to make informed decisions, injudicious allocation of treated wastewater to Minor irrigation can leave the Bellandur and Varthur lakes with scant or no water, turning these large lakes into small ponds. The government must prepare treated wastewater utilization plan for Bellandur/Varthur catchment, with a very clear policy decision to use the treated waste water to maintain the lakes of Bengaluru up to its brim. BWSSB is using the oldest trick in the book - Cherry picking data to show compliance to NGT. It must stop doing that. The existence of four MLD Madivala STP, so far hidden from NGT, must be included. Important transparency and accountability metrics like STP operating capacities, wastewater treatment efficiencies, flow levels in the raja kaluves and sewer trunk lines, sewage transportation efficiencies, most of which is generated, is not used adequately and must be used for decision making and compliance monitoring. BBMP’s epic negligence is palpable from its inability in putting simple interventions like waste and silt trapping structures in the drains. Despite being flogged from many sides – high court, NGT, public – it is unable to clean up solid waste in the drains and clear encrochments. Appropriate silt and waste trapping structures at regular distances, with daily removal and disposal of solid waste, must be immediately done in accordance with 4 law. Exact area and location of buffer zones, available for bio-diversity park plantation must be immediately determined and plantation must start as soon as possible. KSPCB has self-diminished its role to issuing notices. The debate on hazardous nature of the slush and silt has continued for years till today while KSPCB should have put that to rest a long time ago. The real time monitors show wide fluctuations in water quality, which are unequivocally indicators of frequent episodic industrial discharges. KSPCB must wake up from slumber, investigate and find the sources. The issue of illegal industries is far from over. There is a need for speed in stopping the operations of illegal industries. BDA’s one-time rejuvenation is a complete mess. It’s ad-hoc , piecemeal and impractical nature of work has worsened pollution of the lakebed and resulted in infructuous expenses. Ground truthing reveals that dredged muck dumped in mounds is rotting on the lakebed creating a hazard to the people around and also polluting the lake. Until the disposal plan is finalized, the dredging must stop. In terms of silt disposal, an astounding 77% of the desilting cost (i.e. 131 crores) is allocated for disposal of silt to a quarry 25 kms away. A cost-benefit analysis must be done to determine if the disposal costs are justified. Perhaps desilting the drains leading to the lakes, is a better alternative. More important than the one-time rejuvenation is the lake specific maintenance policy. Maintenance plan for Bellandur, Varthur and Agara must be developed at the earliest, clearly documenting the execution of maintenance activities with proper timing and with adequate resources esp. budget. Several court orders -- NGT O.A No 593/2017 , NGT O.A. No 804/2017, NGT O.A No 111/2020 , High Court W.P No. 817/2008, High Court W.P No. 24739/2012 , High Court W.P No. 38401/2014 -- are relevant and those orders must be followed. Our analysis has identified 31 agenda points on which government action is needed. We earnestly request the government to wake-up from its slumber and get into meaningful action. 5 CONTENTS 1. CONTROVERSIAL ALLOCATIONS: WHO GETS TREATED WASTEWATER – BENGALURU LAKES OR MINOR IRRIGATION? 2. BENGALURU WATER SUPPLY AND SEWERAGE BOARD (BWSSB) 2.1 NOT ACCOUNTED: 4 MLD MADIVALA STP 2.2 CHERRY PICKING: STP INFLOW DATA 2.3 FLAWED ACCOUNTING: HOW MUCH WASTEWATER AND RAW SEWAGE IS THERE? 2.4 MISSING TIME-SERIES DATA ON TREATED WATER QUALITY 2.5 INADEQUATE: ONLINE REAL TIME MONITORING OF TREATED WASTEWATER QUALITY 2.6 ADDRESS POWER OUTAGES ISSUE 2.7 THE FALSITY OF AERATORS AND FLOATING ISLANDS 2.8 BWSSB STP LABS: NOT RECOGNIZED BY GOI UNDER THE EPA ACT/AIR ACT/WATER ACT 3. BRUHAT BENGALURU MAHANAGARA PALIKE (BBMP) 3.1 WHERE ARE THE SILT AND WASTE TRAPPING STRUCTURES? 3.2 HOW MUCH AREA IN SQ-FT IS AVAILABLE FOR BIO-DIVERSITY PARKS? 6 4. KARNATAKA STATE POLLUTION CONTROL BOARD (KSPCB) 4.1 INCONCLUSIVE: HAZARDOUS NATURE OF THE MUCK ON THE LAKEBED 4.2 UNBATED POLLUTION FROM ILLEGAL INDUSTRIES 4.3 COMPLIANCE TO O.A 593/2017- STP/CETP/ETP 4.4 DISREGARDING REAL TIME WASTEWATER QUALITY MONITORING DATA 4.5 THERE IS NO ROBUST WATER QUALITY MONITORING PROGRAM 4.6 TRANSPARENCY AND ACCOUNTABILITY 5. BANGALORE DEVELOPMENT AUTHORITY (BDA) 5.1 WHEN THERE IS NO PLAN 5.2 THE DEDGING DEBACLE 5.3 IS IT MERELY ABOUT ONE-TIME REJUVENATION? 6. NO END IN SIGHT AS THE POLLUTION CONTINUES UNBATED 6.1 DIVERSION CHANNEL BREACH POLLUTING THE LAKE 6.2 KC VALLEY STP POLLUTING THE LAKE 6.3 FIRE AGAIN. 7. CONCLUSION 8. REFERENCES 7 FIGURES IN THE DOCUMENT Figure 1: Allocations of Treated Wastewater as per BWSSB Figure 2: STP inflow data as submitted to NGT (10),(21) Figure 3: Representative Locations for measuring sewage flow Figure 4: Misleading Storm Water Drain Flow data submitted to NGT by BWSSB Figure 5: Effect of floating islands and aerators on wastewater quality Figure 6: Representative locations for