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  Home >> Cleanliness >> Suggestions by Save Bombay Committee and Prakruti (part 2)


Suggestions by Save Bombay Committee and Prakruti (part 2)                                        Part 1

Initiatives undertaken in the Recent Past

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.

o       A 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 Bombay 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 Bombay slums to make the Bombay Sewage Disposal Project complete in every sense. 

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 implementation?        

o       Involvement 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 respective wards?  

o       Supporting 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 ground. 

Is there any biomethanisation project established anywhere and if so where is it operating? Has any EIA been taken?

o       Supporting 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 and disposal.

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. 

o       Besides 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? 

o       The limited success of some initiatives
o       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 their activities.

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?}

o       The Recent Initiatives
o       The following initiatives have been implemented by the MCGM recently 
o       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 users.   

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 dumping grounds.

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.

o       A 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 Mumbai which requires the MCGM to make additional sites for setting up the treatment plants.

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 Roadblocks

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. } 

o       Entrenched 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.

o       Resistance 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 hurdle.

o        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 agencies.

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 MCGM officers.

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 activities.

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.

o       Different 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.

Citizens are ready to help provided they are treated as equals. 

o         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?

o       The ‘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. } 

o        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).

o       Cleaning 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 Co. 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;

o       An 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 floods.

·        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.

·        International 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 organized  conveniently through authorized workers employed by   N.G.Os.

·        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 contemplated.

·        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 

Does 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 infrastructure.

·                     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.

Vinaybhai, we 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. 

Kisan Mehta        Priya Salvi      

620, Jame Jamshed Road, Dadar East,
Mumbai - 400 014
Tel: 0091 22 24149688
Kisan Mehta - Mobile 92234 48857
Priya Salvi    - Mobile 93231 96420 

Part 1

It is one of the beautiful compensations of this life that no one can sincerely try to help another without helping himself. --Charles Dudley Warner