Proposed new solid waste management rules – comments

The Ministry of Environment and Forests has come up with draft Municipal Solid Waste (Management and Handling) Rules, 2013. The rules will overrule the existing rules which were framed in 2000 here. The Ministry has given a period of 60 days (from 29.08.2013) for public to respond with their views and suggestions.

It is important that everybody concerned with the issue of a clean city to engage with this process. The issue is not just one of a clean city but the philosophy towards waste management and the processes that will be followed. A number of activists have been carrying out efforts over the years without broad based public involvement. Please do consider organising programs around this issue where some of the members involved with the issue for long would love to come and speak.

The rules seem to have been put together in a hurry with incorporating the learnings from a number of developments since the 2000 Rules.

The proposed rules have a number of flaws, which I am highlighting below.

  1. The Ministry must share what necessitated the need for a new set of rules. Whether a note on the same is prepared and should share the same.
  2. The rules lack commentary on the serious constraints involved with developing new landfill sites. Competing demands for land are now stronger than they were when the rules were last formed in 2000. Land is needed to housing, infrastructure, farming and recreation and hence needs to be low in the priority of solid waste management.
  3. The rules do not adequately stress on the need for municipal corporations to go beyond the call of duty in sensitizing the citizens about not mixing wet and dry waste at source and hence minimising the need for centralised collection and transport of waste and landfill requirements.
    1. If in MSW 2000 this need was felt and appreciated adequately the developments since then have only increased the importance of reducing as much waste at source as possible. MSW 2013 Rules need to in fact start getting stringent about not accepting any mixed waste at source and levying fines for the same.
    2. The Rules should adequately acknowledge the services provided by rag pickers, the significant self-employment generated as a result and the need for municipal corporations to formally recognize the contribution by them.
    3. The Ministry should be abundantly aware that a lot of the requirements expected in the MSW 2000 Rules have been violated with gross impunity.
  4. The Rules should comment that due to the following important considerations there will be a strong focus on the minimisation of transport of waste over long distance. The transport of waste over long distance leads to
    1.  Use of fossil fuels which leads to release of GHG emissions which leads to long term environmental damage. India has a National Acton Plan on Climate Change and is a participant in global talks on mitigating climate change. The municipal waste management rules need to clearly be compliant with these efforts in letter and spirit.
    2. Air pollution from emissions which lead to immediate health impacts to the residents of the city.
    3. Loss of foreign exchange and hence economically harms the country. This is important in years like 2013, when we are facing a crisis.
    4. Expenditure on expensive machinery and
    5. Overall puts a strain on the municipal budget of the respective city.
  5. MSW 2013 Rules need to give very explicit guidance/instructions to the municipal corporations for engaging substantially in activities towards creating awareness about segregation of garbage and all other measures to treat biodegradable waste at source through various means. This creating of awareness will be through (and not limited to) advertisements in papers, television, schools, colleges, cinema halls, funding civil society organisations for road shows and all other means.
  6. MSW Rules 2013 should stress on very high standards of financial reporting about the complete costs involved in waste management.
  7. MSW Rules 2013 should stress on detailed disclosure on all the kinds of waste being generated in the city.
  8. MSW Rules 2013 do not adequately address the issue of electronic waste. Electronic waste generation is now huge in India and significant amount like batteries etc. are being disposed in the normal stream of waste disposal. The municipal corporations have to cover the whole gamut of awareness creation, strict segregation at source and final disposal in detail and with seriousness.
  9. MSW Rules 2013 need to be explicit and stringent on the need to strictly control the distribution of plastic carry bags in various kinds of shopping, a very large proportion of which end up in the garbage stream and are posing very serious environmental challenges. In Mumbai, all waterways like nullahs, creeks and the sea are choked with such plastic bags. During monsoons the sea throws all the plastic and other refuse out and makes a complete mess of the beaches.

The Waste to Energy part has been added new and one wonders whether that is the sole purpose of the new set of rules.

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4 thoughts on “Proposed new solid waste management rules – comments

  1. We are also suggesting that there should be a process defined for the selection of a waste processing option. So instead of first jumping to incineration (for e.g.) one must first start with segregation and local processing (bio-meth, composting etc) and go up the chain in this manner until you get to large centralized processing/land filing options. And the public authority has to show how it has gone through this step by step.
    A framework for Cost-Benefit Analysis should also be recommended
    Finally cities should make a Comprehensive SWM Plan, just as JNNURM mandated that cities prepare a Comprehensive Mobility Plan. In some ways making a 20 year plan for SWM has got to be easier than a mobility (transport) plan, since it is perhaps more predictable.

    • Hi Ranjit, I think the idea for the public authority to show step by step the efforts they made is a great idea – there should be full disclosure. A CSWMP is clearly more doable than CMP. Do keep informed about your and other efforts in Pune. Thanks.

  2. e-waste is seperately dealt ,see E-waste management guidelines issued by Central Pollution control Board and common facilty has been established to segregate and recycle plastics,copper strips,recovery of precious and base metals from printed circuit board and leadn from crt.

  3. Hello Rishi and others, I think the suggestions put forth by you all make a lot of sense…’segregation at source’, getting informal recyclers into the Municipal fold and giving them training, and the basic emphasis on waste reduction should be the base of CSWMP (as suggested by Ranjit) – This way, principle of reduce, reuse and recycle comes into practice. Waste recovery can be side by side practiced through composting, anaerobic digestion rather than controversial Incineration as Ranjit suggested.

    Also e-waste segregation becomes an important element of ‘segregation at source’…Municipality and market need to create more linkages between generators of e-waste and its recyclers

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