Comments 1 - MSW Littering / Segregation Rules ---comments by
Proposed MSW Littering, Segregation,
Storage, Delivery & Collection Rules 2005
1. MCGM or MCBM?
2. Cl (1) Title:
Should be 2006.
3. Cl 4(b):
How can one ensure that others will not do it?
4. Cl 5 (1). fish /
5. Cl 6. Rs. 1000
is too much for minor infringement. An entire schedule of
penalties is needed depending on quantity of waste, and category
of waste thrower. Also an escalation of penalties upon repeated
violation to be fined as follows:
Small amounts (Rs. 10 – Rs. 50) as deterrent
Small amounts (Rs. 250 – Rs. 1000) as deterrent
Increasing amounts (Rs. 500 – upwards) till punitive.
violations: Large amounts as penalty / punitive
6. Cl 6. Schedule - I A. To
be made as comprehensive as possible.
7. Cl 6 B 1 ii. .....
also commercial organisation.
8. Cl 6 B 2. What
are 'recyclable bags'?
9. Cl 6 B 3. Why
does non-recyclable waste to be stored only in 'recyclable
10. Schedule V:
Composting - a 'process' can not be a 'rule'. This entire
section should be removed. Only the last para under "other
methods of composting" is ok.
The following should be
(mostly from the Policy
Framework Recommendations by the NGO Council)
11. MCGM to pay for savings of
transport costs due to composting. MCGM to provide for purchase
of compost. MCGM to reduce trade refuse charges for hotels and
restaurants. All this will also help to pay for capital and
operating costs incurred by the waste generator to treat waste.
Else this is an indirect way of creating more fund
availability for MCGM while increasing the financial burden on
12. Option of handling leaves, etc.
differently than food should be mentioned. Education is
required for this. Burning of leaves and other waste should be
13. MCGM should also pick-up
unsegregated waste at a cost (daily fine) for some more time.
Else the laws will not work. No time is being given for
people to become aware of how to compost, and to buy / build
bio-bins. It will become a very ham-handed approach. MCGM will
say to courts and environmentalists that we have done our job,
but the citizens are not following it, what can we do. But the responsibility
of bringing out a law does not end with promulgating it.
It has to be combined with education and awareness initiatives
of different stakeholders, a phase-in period, infrastructural
facilities, creating resource cells, incentives and
disincentives, small fines escalating into punitive ones in due
course, citizen organisation's involvement in monitoring and
MCGM needs to move away from a mode
of thinking which is to promulgate laws and either ensure
compliance by force, or let the system fail. This also breeds
lethargy and corruption. The need is to involve citizen groups
to ensure citizen participation and to move to a mode of
thinking where the implementation process is equally, if not
more, important as the law itself. The means is as important as
the end. So instead of trying to achieve the desired objective
overnight and thus virtually guaranteeing frustration and
failure, it should be achieved over a well-thought out period
thereby assuring co-operation and success.
The objective is a 'Chakachak
Mumbai'. The objective is not 'it's not MCGM's fault'.
14. Hawkers to have basket / gunny
bag slung beneath to prevent littering.
15. Specific provision for temples
to handle pooja offerings should be made.
16. Cow-dung to be bio-composted.
MCGM to stop buying cow dung.
17. Nursing homes, doctor clinics,
pathological labs should have to deposit their waste to nearby
hospital or designated containers nearby.
18. Throwing anything into water
bodies -- sea, lakes, rivers -- to be banned. This to include
pooja items. Special exceptions during Ganesh Visarjan, etc.
Special exceptions after certain religious rites ok.
But throwing of daily pooja items to be stopped. Kalashes to be
provided with an assurance that Pooja articles will be dealt
with in an appopriate religious manner.
19. MCGM's responsibility of
providing litter bins is a must. Without that to impose a fine
on littering is incorrect and onerous. e.g. If someone is
eating a banana while walking in a recreation area and no bins
are there, where is the person supposed to deposit the banana
20. 'Saaf Aangan' concept of "I
Clean Mumbai" must be introduced explicitly via these
Rules. Essentially that every housing society, shop,
establishment to be responsible for keeping its area and
surrounding footpath and drain / road gutter clean. ALMs to have
the responsibility of ensuring compliance, and the authority to
fine the offender and use the fine money for ALM activities. If
ALMs fail, then both the ALM and the offender to be fined by
21. An explicit role and
responsibility of ALMs should be planned in these rules. It will
strengthen the ALM concept, reduce workload on MCGM, and bring
out greater compliance.
22. Sanitation is left out. Are
people going to be penalised when there are insufficient toilets
in the first place?
23. The "Cleanliness Task
Force" concept should be institutionalised via these Rules
i.e. Reports of such teams should be taken cognisance of in
imposing penalties, etc.
24. Paan spitting, other spitting,
urinating --- shouldn't there be minor fines for these e.g. Rs.
10. These could be collected by Resident Orgs / ALMs / Home
Guards or some such mechanism and be kept by them to cover
their overheads. Again, the objective is of a Clean Mumbai.
25. MCGM to provide support via
special teams of their conservancy staff to help in
cleanliness drives organised by citizen groups.
26. MCGM should also specify what
will be done with the inorganic recyclable and inorganic
non-recyclable wastes by them to inspire citizen support in
making the program a success.
Please give your comments too at the
earliest for discussing with MCGM.
If you are interested in
participating in such meetings, please inform.
One such meeting is on Sat, Dec 10,
at 11 am.
thanks and regards
22000004 / 22000478
Dec 8, 2005