Suggestions by Save
Committee and Prakruti
2) Part 1
Initiatives undertaken in the Recent
o The Dattak
Vasti Yojana for achieving cleanliness in the slum areas through
financial assistance to Community Based Organizations (CBOs) which
currently covers (?) of slum areas.
Dattak Vasti Yogana can never bring about
cleanliness as local residents were not involved
and outside agencies foreign to the local residents were
sought to be brought on the scene The ideal strategy is
always to encourage resident slum dwellers to form
local resident associations for cleaning up after their
respective areas. This requires close contact with local
residents in slum areas. The MCGM should help
the formation of local associations which could
be motivated to look after cleanliness, health issues etc in
respective slums. The concept of `dattak' meaning
adopting has not and will never work. Local population
associations should be empowered by giving authority to
work and financial aid to develop their cleanliness.
This will provide jobs to the young within their locality. Slum
dwellers will themselves monitor effectively.
programme of construction of community/public, Pay & Use toilets
in slums (with the help of the World Bank) and other areas.
► The World Bank increased, at the suggestion
and insistence of Save Bombay Committee the loan for Bombay Sewage
Disposal Project from $ 500 to 550 million to enable the
MCGM to provide integral Public Sanitary Conveniences
comprising of Toilets and Washing Places connected to biogas plant
and vermiculture facilities. The SBC had suggested for
additional loan of $ 100 millions so that all the
slums are provided with such PSCs. We cannot understand as to
why the MCGM accepted 50 instead 100 million. The Bank had
insisted on covering all
slums to make the Bombay Sewage Disposal Project complete in every
► One would like to know whether all the slums
are covered and if not how many in number and percentage of
population are covered and reasons as to why all the slums are not
provided with comprehensive PSCs. Please state a fixed
date when the work would be completed 100%. What help
dopes the MCGM expect from NGOs in completing the programme on
schedule? IS MCGM ready to be totally transparent and work in total
partnership with the NGOs on formulating policies and
of Advance Locality Management Groups (neighbourhood residents’
groups) for promoting segregation of waste at source and vermi-composting
in the premises of housing societies and residential colonies.
► The ALM was and is the citizen idea
implemented by the NGOs and local populations. Hence the MCGM
should accept NGO statements and
clarifications. Segregation and vermiculite work was
expected to be done by individual waste generator with the local ALM
assisting where required. ALMs are meant for managing segregated
waste. Why is entire Mumbai not
covered through ward wise chains of ALMs? What are the
constraints? How many neighbourhood waste management units apart
from vermiculture units are set up wardwise to handle waste within
N.G.Os to set up de-centralized Waste Management Projects
(composting and bio-methanation) to serve as demonstration projects
on municipal plots.
► Neighbourhood vermiculture programmes
were meant to ensure that not a single ton of waste goes
out of the ward and to dumping yards. Neighbourhood facilities
are not demonstration units but actual medium and large scale
production units covering all quantum of organic waste
needed to stop hauling to dumping grounds altogether. What
is the position and when will entire Mumbai be covered by ALMs and
neighbourhood plants to be run by resident? Vermiculture does
not need any long term training and whatever is required minimum is
with the MCGM and concerned citizens. Unfortunate part is the MCBM
officers coming in charge do not appreciate this situation on the
► Is there any biomethanisation project
established anywhere and if so where is it
operating? Has any EIA been taken?
waste segregation activities of N.G.Os working with rag-pickers by
providing sites, vehicles etc.
► Where and how many? Quantum of waste for
hauling to dumping grounds reduced. Why is vermiculture facility not
set up with rag picker help throughout Mumbai?
o Setting up
a system of biomedical waste (BMW) collection, transport, treatment
► Details required on the quantum, transport,
safe disposal etc. How is biomedical waste generated by
General Practitioners, Surgeons in ht6eir clinics, Pharma labs
covered and to what extent of coverage already achieved? Our
submission is that these class of bio medical waste are not touched
at all along with many large and small hospitals. Please correct if
we are on the wrong.
the above initiatives, efforts were also made to set up large scale
Waste–to-Energy Plants, through private operators at the dumping
sites, which did not bear fruit due to reasons beyond the control of
the MCGM such as certain decisions by the Maharashtra Electricity
Regulatory Commission (MERC) and the Ministry of Non-Conventional
Energy Sources (MNES), all the other initiatives have achieved
varying degrees of success.
► Foolproof and total managing and
realising zero waste at local levels would not require any
thinking of wasteful, polluting Waste to Energy (WTE) plants .
Information that the WTE plant did not materialise is a welcome
blessing to citizens. Hope that proposals for setting up
WTE plants are not revived in future without taking the pros and
cons of such technology into account and seeking citizen content and
support. It should be appreciated that vermi-processing is an
efficient WTE plant guaranteeing minimum environmental
quality and financial saving. What other initiatives were taken
and what was the quantity of waste handled?
The limited success of some initiatives
The ALM movement did not succeed in achieving the level of
success achieved by the ALMs in a few pockets due to the lack of a
dedicated formal mechanism that can take care of training,
monitoring, feedback and evaluation of
a large and growing number of ALMs and their activities and
an effective and sustainable model to incentivise local
residents to maximize segregation of garbage and do in-situ
composting of Bio-degradable Waste within the premises of Housing
Societies, colonies etc. The Dattak Vasti Yojana has been
constrained by the lack of funds and absence of arrangements for
training of CBOs as well as proper monitoring and evaluation of
► All this was MCGM responsibility and within
MCGM possibility. Why did the MCGM fail in achieving this
task? Lack of commitment by MCGM to the work ahead? Refusal to
accept the citizen initiative? Refusal to accept citizens and NGOs
as equal partners? Refusal to become transparent and accountable?
Reasons for failure or limited success unacceptable. Why did
the BMC not provide all that it mentions as essential for achieving
zero garbage condition?}
The Recent Initiatives
The following initiatives have been implemented by the MCGM
A scheme for engagement of CBOs and NGOs (mainly Mahila
Mandals) for sweeping and mopping of selected roads has been
established successfully despite severe opposition from employees’
unions. At present 142 Nos. of such units are in operation all over
Mumbai. A similar attempt in the area of transporting waste was
subverted due to the financial weakness of CBOs. It is being planned
to bolster this scheme with better supervision arrangements.
► With huge existing staff employed in SWM,
scavenging, sewage disposal, any new ideas for working cannot bring
any improvement. At best such attempt can increase
confrontation between the BMC and workers and within workers without
deriving any benefit. The need is to improve working and
efficiency by creating atmosphere of mutual respect. At present the
BMC looks to this very important class of labour with doubt and
suspicion hence is always looking to more mechanisation,
outsourcing. This situation cannot improve efficiency and
cleanliness better HRD with the existing staff that eats away all
resources is necessary.
o Under the
guidance of the National Environmental Engineering Research
Institute (NEERI) and the Dr. Maley Committee appointed by the
Hon’ble High Court, steps have been taken for collection and
treatment of leachate in a scientific manner at the dumping grounds.
► Citizens would like to receive full
details of specific arrangements put in place to stop
leaching from dumping of untreated mixed waste including abattoir
waste. All waste from municipal slaughter house is dumped in
Deonar Dumping Ground, the largest in Mumbai without any
treatment and after care. Studies show that leachate
continuously percolating underground on large
scale at Deonar has formed into a large lake
underground of toxic leachate. What arrangements are made to
retrieve leachate from the lake and to dispose off in an
environmentally acceptable manner? Give details.
► Dumping grounds, open gutters and
channels in the suburbs are the biggest threats to acquifers in
Mumbai. Is the MCGM aware that water taken out from overflowing open
gutters is used on large scale for preparing snacks, bhelpuri,
vadas, papad in slum and slum like areas. Water from wells
already existing or retrieved from deep holes dug near open
channels is the base of snacks and junk food sold all over Mumbai
including top notch hotels and restaurants.
What arrangements exists to provide adequate water in slums,
how much per capita in comparison to water supplied to flats
and chawls. Please give figures for different
o Under the
guidance of NEERI and the Dr. Maley Committee vents have also been
provided at the dumping grounds to release excess methane and this
has resulted in substantial reduction of fires occurring in the
► Please explain the system developed for
releasing and trapping methane, only excess and not all from dumping
grounds. Surprise incognito joint visits to dumping grounds
would show the extent of smoke and fires still going on in dumping
ground. Are MCGM senior officers ready for this venture.
programme for purchase and installation of litter bins and public
garbage collection bins of international standard in public places
along with manning of all garbage collection centres.
► The present practice of keeping the bins in
public places has increased littering and should be discarded
immediately. The bins, whether international or improvised are
open invitation to more littering and should be taken
off from public places. There is no need to spend on internationally
acclaimed bins because our dumping places within crowded
areas always overflowing with garbage.
o The MPCB
has finalized a proposal for setting up additional facilities for
treatment of bio-medical waste and stricter implementation of
bio-medical waste handling and management rules in the city of
which requires the MCGM to make additional sites for setting up the
► How is the MCGM looking after bio-medical
waste generated by General Practitioners,
Surgeons, Pharma labs scattered throughout Mumbai?
o A decision
has been taken to strengthen the Dattak Vasti Yojana and provide
adequate financial support to extend its coverage of slum areas.
► The concept of Dattak Vasti Yojana is improper
and unrealistic. Cleanliness work should be managed by local
resident associations of slum colonies that would provide
jobs to the local youth and monitoring to residents
of specific slum areas.
The Municipal Corporation faces several
challenges on the path to a cleaner Mumbai.
Resistance to Change
► It must be accepted that resistance to
change is highest amongst the chief and senior municipal officers.
To ensure maximum citizen support, it is essential
that citizens are involved in planning and implementation
of programmes. Once citizen involvement is realised, participation
by residents, the stakeholders, in the entire exercise will be
achieved. This involvement would ensure and has ensured smooth
change over better practices.
o A large
workforce and unions of workers who resist necessary measures such
as night sweeping, outsourcing, mechanization etc.
► Resistance is normal and understandable. No
joint evolution of programmes that guarantee better conditions.
Night sweeping may look attractive but is not practical. Night
sweeping was undertaken in selected areas some 10 years ago. It
turned out to be a failure for many reasons including the fact that
most of the waste generated during last 24 hours is dumped in the
early morning by generators. In case of night sweeping this waste
would remain in public places during the better part of the day.
Shops and offices dump their waste on opening of the establishments
in the morning. Luminosity on streets is poor to too poor
for efficient night sweeping. Under the rules, labour will have to
be paid higher emoluments for reporting on duty for
night sweeping. Their coming and return to homes at late
night hours would cause serious problems.
It is natural
that mechanisation is opposed by the labour because of the
fear of losing their jobs. The municipal work can be
carried out more efficiently by manual labour. The
character of the work force will also change due to
mechanisation and this will increase the cost substantially with no
benefit. The fear of unionised work force can be suitably
managed through innovative HRD. These are not
insurmountable blocks yet never tried. Senior MCGM officers
have always viewed low ranking employees with suspicion. This
has to go for better efficiency. }
lobbies of contractors engaged in the business of transport of solid
waste who operate at various levels and stall any move to bring
about radical changes in the nature of contracts for collection and
transport of solid waste.
► It is natural for human beings including
ourselves at different levels of life to protect ourselves and to
usurp the advantageous position of others.
to any move to introduce user charges for waste collection and
transport services on the basis of the “polluter pays” principle
to be able to expand, upgrade and modernize the solid waste
management services and practices.
► We have not come across any honest and
concerted effort of the MCGM to introduce programmes for user
charges or for getting resident support in initiate innovative
programmes that provide better facilities to residents. Resistance
is natural to any proposal that will increase the cost of a house
holder, however this being a very important aspect, one has to try
with support from users by involving them in the process. The way
citizens are gulping and accepting higher prices for essentials
shows that they would readily pay for better service. The program
should be such that the entire cost of the SWM Dept, as also of
other services like road construction and maintenance costs from
vehicle owners, is recouped through user charges. Of
course one will have to be objective as well as transparent and
accountable. MCGM efforts in the past have been to
protect senior officers and powerful citizens. This is a
Lack of Coordination amongst various agencies
► The MCGM is the main party in the pivotal
position and therefore has the last word in laying down terms to be
observed by various agencies. On the contrary we observe that the
MCGM does not work adequately to get co-operation from other
o Lack of
proper coordination in waste management activities between M.C.G.M
and other organizations who own/occupy large layouts such as the
railways, the Mumbai port trust, MHADA etc.
► Why is the MCGM the duly constituted and
authorised agency for Mumbai does not lay down and exercise
co-ordination in Mumbai? No other agency is more authorised and
qualified in this area. This is possible yet not tried by the senior
o A large
informal sector consisting of rag-pickers, ‘raddi-wallahs’,
scrap dealers and waste, recyclers whose role needs to be recognized
and who need to be made an integral part of the overall system of
solid waste management by a suitable method of compulsory
registration/licensing and concessions to promote waste recycling
► Let the MCGM initiate in this area, trust in
the informal sector for specific areas to see the response. Informal
sector cannot be wished away till the time the governments at
different levels cannot provide for minimum sustenance to be earned
through normal means. Again the MCGM has failed in this area. What
support does it need from NGO. The first requirement is that the
NCGM should take NGOs as equal partners sharing all information and
decision making with them.
departments and agencies responsible for removal of garbage,
cleaning of storm water drains, regulation of hawkers, regulation of
slaughter of animals and sale and pest control respectively
resulting in divided and diffused accountability.
► Again MCGM is the only agency
that can mobilize all the dept. to work in cohesion.
ready to help provided they are treated as equals.
Apathy to the Problem
o A very
large and growing slum population (65% of the total population)
living in congested areas, most of which have poor drainage,
practically no sanitation whether in terms of sewerage lines,
sanitary toilet seats or regular conservancy services resulting in
open nallahs and open plots serving as sewers and garbage dumps –
both household and commercial.
► If the MCGM had provided adequate number of
Public Sanitary Conveniences (PSC) along with biogas and
vermiculture facilities as has been laid down by the World
Bank the issues raised here would have disappeared. The bank
loan provides the opportunity to still do it. When does the MCGM
start the intensive work? What cooperation needed from NGOS?
‘NIMBY’ syndrome and the lack of appreciation about the dire
necessity of obtaining sites urgently for setting up waste
processing facilities and sanitary land fill sites.
► If there is any NIMBY approach, it is on the
MCGM site. Implementation by the MCGM of Integrated Solid
Waste Management Programme accepted by the MCGM in public will
eliminate the need for sites for land filling, sanitary or
otherwise. Land filling itself is a hazardous process causing
illhealth and pollution. This has no place in a clean city. }
Outdated Means & Methods
o The lack
of a strong regulatory regime governing nuisances and waste
management practices with adequately deterrent penalties for
non-compliance with rules.
► The MCGM will be able to discipline more
forcefully if the MCGM itself implements the Central Government
norms for handling municipal solid waste (MSW).
of open storm-water drains and nallahs before the monsoons instead
of keeping them clear of garbage round the year.
► This is a responsibility of the MCGM. It is
upto MCGM to look after this area satisfactorily. The
suffering that followed came up after 26 July deluge shows
that the MCGM had not done its duty of cleaning up of nallah, storm
water drains. MCGM road excavation work continued till 26 and
resumed from 29 with debri lying everywhere. This is the situation
even today. After perpetrating so much hardship on
citizens, open nallahs are still full of paper plastics, dust,
filth and what not. Senior MCGM officials should visit these areas
with concerned citizens to see the extent of callousness on the part
of the Chief and senior MCGM officers. River and nallahs that cause
so much pain and loss of life in Kurla, Kalina areas are still full
of everything that the MCGM declares should not be present. Are the
MCGM seniors ready to take joint surprise incognito visit?
Initiatives Currently Undertaken
· IL&FS Eco Smart
have been selected and appointed as Consultants to study the
condition of the dumping grounds, and the characteristics and
patterns of the solid waste generated in the City and to make short
term and long term recommendations regarding:
► Citizens are not ready to go on this path of
extremely high cost with no satisfying results. The MCGM has
accepted the Integrated Solid Waste Management Programne (ISWMP)
long back but has not implemented it. It would be serious blunder if
the MCGM goes on the new wasteful and useless path without
fully exhausting the opportunities of the ISWMP. The Save Bombay
Committee is willing nd anxious to help the MCGM for implementation
of the ISWMP for the perennial benefit of the Mumbai citizens. We
are prepared to point out the inappropriate recommendations of the
IL&FS. Information on Eco Smart recommendations and their
qualification to advise the MCGM would be appreciated. Who are
Ecosmart? Citizens are totally unaware IL&FS
EcoSmart Co. recommendations hence it is improper to
react without fully understanding their programmes. We are
reserving our response till the MCGM is ready to discuss frankly
with citizens. Citizens recommend that no action should be taken or
money spent on the following unrealistic programmes.
o The most
economically viable and sustainable waste processing technologies;
integrated waste disposal system including sanitary land-filling and
proper management of existing disposal sites as well as the
development of new waste disposal sites on lands expected to be made
available by the state government.
o They will
also advise and assist the MCGM to float tenders for selection of
developers who will build, maintain, manage and operate the
facilities in an integrated manner based on the recommended
technologies on a long term sustainable basis.
· Various proposals
for waste processing which have been received by M.C.G.M. including
composting, R.D.F. and waste-to-energy and the NEERI-Maley Committee
recommendations submitted to the Hon. High Court are being
scrutinized by the Consultants and their recommendations are
expected to be received by the end of September.
The short term and long term implementation processes will
begin thereafter including the bidding process for selection of
private developers of waste processing facilities.
· Draft guidelines for
integrated management and disposal of construction and demolition
waste and silt have been prepared and will be finalized shortly
after discussion with all concerned agencies. This will include
charges to be collected from generators to meet the costs of
containerized collection, storage and transport, tipping fees /gate
fees to be charged at waste disposal sites etc.
· Tenders have been
invited for engagement of contractors for cleaning the Western and
Eastern Express highways and major arterial roads with the help of
power sweeping machines.
· A programme for
up-gradation of uniforms, implements and chowkies used by Solid
Waste Management staff is being finalized.
· The Dattak Vasti
Yojana for slum areas has been strengthened with a revised scheme
for greater financial support, and stricter norms of performance to
increase the coverage and effectiveness of the programme.
· We are considering
involving N.G.Os. in the training of CBOs and monitoring and
evaluation of the their work on a sustainable basis. Discussions are
on with the UNICEF to collaborate with for this purpose in ten
wards. A pilot project is already initiated in H-east ward after the
· A model area based
contract for Municipal solid waste handling and transport including
street cleaning other than construction and demolition waste and
silt is being drafted which will ensure that payment and penalties
are linked to strict adherence to collection and transport schedules
and maintenance of cleanliness in the allotted areas while promoting
reduction and segregation of waste at source and increased recycling
through a system of separate waste collection streams, collection of
user charges, incentives and concessions. Distinct operation areas
will be carved out for Municipal and contractual operations
respectively to ensure accountability.
· Since the SWM
operations in most of the areas have to be carried out
departmentally due to the huge existing staff and establishment, a
suitable management structure and procedures which will ensure
economy, efficiency, service standards and accountability on
corporate lines are being worked out. While retrenchment of existing
staff is not envisaged the additional requirement of manpower and
machinery will be outsourced.
· An agency is being
appointed for third party monitoring of visible solid waste in the
form of cleanliness indices for all wards, congested areas
· A programme for
up-gradation and improvement of existing public toilet blocks on the
basis of a new set of guidelines and standards is being drawn up
along alongwith a plan to increase the availability of public
toilets at all locations where they are required. A proposal for the
second phase of the World Bank aided slum sanitation programme has
been submitted to the Govt. of India.
· A time-bound
programme for elimination of waste collection bins from public roads
(to be replaced by house-to-house / door-step collection) will now
be launched in all the Wards after successful pilot projects in
H/West and G/South Wards.
· A concept paper for
introducing user charges for providing door-step segregated waste
collection services and /or conservancy services in large sized
residential / non-residential internal layouts with a system of
penalties and incentives for segregation and waste reduction /
recycling is proposed be prepared after discussions with the MPCB
and all concerned agencies /entities such as the Railways, the
Mumbai Port Trust, the MHADA, the Central and State P.W.Ds. etc who
have large estates and private entities involved /interested in
trade and recycling of waste materials.
standard community garbage bins and wheeled bins of different sizes
have been introduced in some parts of the City resulting in better
storage and collection practices. Such bins will be provided in a
phased manner all over the City after ensuring compatibility with
garbage collection vehicles along with high quality street litter
bins this year and arrangements will be made for such bins to be
cleaned and manned properly.
· Discussions are
being held with NGOs for providing them with manned neighbourhood
dry waste collection centers / kiosks which will be designed
aesthetically and can be located near public toilets, existing
public waste collection centers, sites from which collection bins
have been eliminated and other convenient places
where citizens /rag pickers can deposit /sell dry waste for
recycling or from where door-step collection of dry-waste can be
through authorized workers employed by
· A system of
compulsory registration in collaboration with the MPCB of all N.G.Os.,
individuals and firms engaged in the cleaning services, collection,
transport, segregation or recycling of waste of all kinds is being
· Discussions are
being held with employees’ Unions with regard to, work and
productivity norms and re-deployment of staff which will be required
to affect some of the changes which are planned along with better
uniforms, safety gear, tools and working conditions for them.
· M/s McKinsey &
Co. and IL&FS Eco-Smart are working very closely with the Solid
Waste Management Department of MCGM on day-to-day basis for the
preparation of time-bound plans for developing a sustainable and
integrated solid waste management system covering all the above
initiatives / programmes along with the necessary structural and
procedural changes required in the Solid Waste Management Department
for this purpose.
· A public awareness
programme along with a massive cleanliness drive was planned for
launch in October this year by which time the preparatory work for
all the new initiatives listed above would have been over and
comprehensive strategy and plan for Solid Waste Management would
have been announced. However in view of the concerns regarding
cleanliness and health which have been generated due to the recent
flooding of the city it is felt that the cleanliness drive and
awareness campaign should be launched immediately.
· A massive
cleanliness drive has been launched already by the MCGM after the
recent flooding of the city by pumping in additional manpower and
machinery and the results are evident in many areas already.
However, to sustain the drive the creation of a supporting
environment through public awareness and participation is a must.
The participation of the corporate sector, educational institutions,
celebrities, experts, mass media, creative and communication
agencies and N.G.Os is crucial for creating public awareness. For
this purpose it is proposed to quickly establish a core group of
advisors who can provide direction and co-ordination and help to
take forward this process as a public- private-citizen partnership.
The Tough Decisions Required
the MCGM want citizen articulation in the following areas to achive
success and overcome hurdles? Open discussions with citizens
treating citizens and NGOs are equal partners and the equal stakeholders!
We are reserving our submissions till that atmosphere is created.
End of response.
The political establishment has to be
prevailed upon to take some bold decisions such as:
· Banning the use of
plastic / Stern enforcement of regulations for the manufacture and
use of plastic
· Involvement of the
police in nuisance detection and enforcement
· Dealing firmly with
employee unions who oppose changes which are required in the
interests of economy and efficiency and do not involve any loss of
wages or retrenchment of existing employees.
· Making land
available at the earliest for developing sanitary landfill sites and
making finances available for developing waste management
Allowing reasonable user charges to be levied for
provision of doorstep services and heavy penalties to be imposed for
nuisances with nuisance detectors being allowed to keep a part of
the collections as an incentive.
Banning of tabelas within the city limits and shifting
of slaughter houses away from Mumbai city so that the entry of
cattle, sheep and chicken into Mumbai can be restricted.
► Who will do this? If MCGM wants the citizens
to initiate and support it will be necessary for MCGM to first
take citizens in confidence by allowing them to prepare the plans in
collaboration with the MCGM and to help in its implementation.
must admit that we cannot complete our work as you and our friends
expected and expect. Here is a part reply to some issues that you
posed. Replies to other issues are being churned out. In
the meantime, please call for responses, replies and comments on
what is submitted. Debate on a fairly good scale is necessary for
realising our goal for cleanliness.
COMMITTEE & PRAKRUTI
620, Jame Jamshed Road, Dadar East,
Mumbai - 400 014
Tel: 0091 22 24149688
Kisan Mehta - Mobile 92234 48857
Priya Salvi - Mobile 93231 96420