core sector communique

CSE warns against environmental debacle in Indian cities if resource guzzling and wastes in the building construction sector is not minimised

· 70 per cent of the building stock that will be there in 2030 is yet to be built in India. Without resource efficiency measures this will severely affect liveability of cities

· The environment impact of this construction boom will be severe as less than 3 per cent of the built-up area today is certified green.

· Power and water crisis in our cities this summer is a lasting reminder -- either we build energy and water prudent green buildings or perish

New Delhi, June 28, 2012: It is shocking that Indian cities are extremely ill prepared to address the environmental fallouts of the aggressive building construction that is underway. Both residential and commercial buildings will increase several fold in the coming decade. Nearly 70 per cent of the building stock that will be there in 2030 is yet to be built in India. This will have enormous impact on the quality of urban space; water and energy resources in cities; and waste generation. Unless guided with right principles for location choices, architectural design, appropriate choices of building material, and operational management, the building sector can make cities unliveable.

This concern emerged from a national media briefing – titled ‘Build them green: Deconstructing the building sector in India’ -- conducted today by the New Delhi-based research and advocacy organisation, Centre for Science and Environment (CSE). The briefing’s focus was the environmental challenges and solutions for the building construction sector; leading experts addressed the assembled media persons who had come from all over the country.

CSE researchers point out that in India, buildings are responsible for 40 per cent of the energy use, 30 per cent of the raw material use, 20 per cent of water use, and 20 per cent of land use in cities. At the same time, they cause 40 per cent of the carbon emissions, 30 per cent of solid waste generation, and 20 per cent of water effluents.

Said Anumita Roychowdhury, executive director-research and advocacy, CSE: “Despite being a major resource predator, the building construction sector is poorly regulated. Buildings cannot be treated as a low-impact sector.”

There is potential for resource savings in buildings if appropriate policies are in place. With more efficient lighting, ventilation, air conditioning, refrigeration and architectural design, it is possible to save 30-70 per cent of energy. The 2010 McKinsey estimates confirm that the national power demand can be reduced by as much as 25 per cent in 2030 by improving energy efficiency of buildings and operations. The Bureau of Energy Efficiency has also stated that even existing buildings have the potential to save 30-50 per cent of energy.

Similarly, substantial water savings is possible. Only by improving the water efficiency of the water fixtures the water demand can be reduced by more than 30 per cent.

Need performance monitoring and reporting

The problem is the sheer lack of information, say CSE researchers. There is barely any information and data on buildings in the public domain. Even in cases where green rating systems have been promoted with government back-up and incentives, there is no record of the actual performance of buildings and the nature of resource efficiency measures applied.

Cities such as NOIDA are allowing extra built-up areas, tax concessions etc to incentivise green rating of buildings. But these incentives are not linked with actual performance of the buildings. This has made evaluation of the performance of the rated buildings almost next to impossible. Any programme that is built with official backing must be transparent and accountable. Without proper performance monitoring green rated buildings can actual perform worse than standard buildings, as is evident in the US and other countries.

Many gaffes in environmental clearance process for buildings

Environment Impact assessment rules -- the only regulatory tool that requires holistic appraisal of overall impacts of buildings -- cover only the high impact buildings with more than 20,000 sq meters of area, There are many loopholes in the system that weaken it further, says Roychowdhury:

· Glaring loopholes: The builders have found an easy route of dodging the requirement of EIA by showing smaller parcels of land than the minimum limit of 20,000 sq meters. Plug this loophole.

· No clear benchmarking for assessing resource use, waste generation and mitigation strategies provided by the project proponents for approval: The current mechanism of assessing the vital impacts on water, energy, waste, and traffic are not guided by clear targets and benchmarks. These are also not aligned with the existing norms and standards in the specific resource sector. For example, India has already adopted the energy conservation building code (ECBC) for commercial buildings in different climatic zone. But EIA clearance and approval do not formally align with this code. EIA should formally demand compliance with the ECBC, and demand periodic energy and water audits in the post construction phase etc. The CSE analysis of energy and water data provided by the project proponents show that the EIA committees have no clear process of verification and assessment and do not relate to prescribed norms for resource use. The EIA appraisal should work synergistically with the norms and standards in the relevant sectors.

· Strengthen screening of sites for construction: Land should be acquired only after the suitability of site has been established. Even the global best practice is to assess alternative locations to identify the most appropriate site. Site appraisal should be aligned with the provision of the Master Plan and zonal plans of the city. In most cases the land is already allotted to the developers without site screening and environmental appraisal. A large number of projects have come up in the water stressed part of Haryana, for instance, that has been marked by the Central Ground Water Board as a dark zone, as the groundwater table has dwindled drastically. EIA should assess boundaries of influence and sensitivity of sites before decisions on sites are taken.

· Need to stop construction before granting of consent and also post facto clearances: In many cases we have noticed that actual construction of buildings have progressed without getting the requisite consent from the authorities. This weakens the scrutiny. In 2008, the Haryana State Pollution Control Board had served notices to as many as 147 buildings that had started construction without environmental clearance. Similar cases have been observed in Delhi. Project proponents then agree to pay a penalty and bank guarantee to obtain post-facto environmental clearances. But there is no such legal provision under the EIA. This is becoming a convenient tool for the offenders and violators.

· Strengthen post-construction monitoring: This is the weakest link in the current EIA system for buildings. Project proponents are expected to submit bi-annual compliance report based on self monitoring. This is rarely done. There is also no independent check. There is no record of post project monitoring that might have been carried out by the regional offices responsible for monitoring. Rapid review of projects in and around Delhi has shown deviation from the prescribed conditions.

· Need public consultation: In contrast to the EIA rules for mining and industry sector that requires formal public hearing, the simplified procedures for the building sector have no scope of soliciting public comments on impact and mitigation. Citizen’s perspective is completely ignored. As a result, we are beginning to see strong public reaction and anger in cities against construction projects.

· Strengthen traffic impact assessment of buildings: The expansion of high impact buildings especially commercial and retail will induce heavy traffic in cities with serious pollution, public health and congestion impacts. Developers will have to provide area management plan for traffic mitigation in and around the project area. Currently, the information sought on traffic management in the project area is minimal. There is also no designated body authorised to give no-objection certificate for traffic clearance like the way it is done for water and electricity. This is needed to reduce induced traffic because of the project. Such reforms have happened in other countries like China.

· Systemic weakness in the institutional arrangement and capacity need attention: The gamut of challenges that plague the environmental clearance process is staggering – the regional offices do not have adequate authority for effective monitoring; resources and staff strength and capacity for appraisal and monitoring is very poor; institutional coordination for clearances is missing; the state environment appraisal committees are heavily burdened to do justice to each project; there are errors in documentation; quality of data and information provided by the project proponents is of poor quality.

New development will occur in suburbs and new towns without any integrated vision

More than half to 95 per cent of the new buildings will come up in resource stressed suburbs and new townships. IDFC’s India Infrastructure Report 2009 states that the size of private ‘integrated’ townships ranges from 100 to over 1000 acres and more than 200 such townships covering more than 200,000 acres are under approval for planning and construction especially around the four metros. On Delhi Mumbai Industrial Corridor (DMIC), several private towns and cities are on the cards. Touted as Walk to Work Green Towns, the new towns are sprouting without clear benchmarks, implementation strategies or strong regulatory safeguards. .

Said Roychowdhury: “Green measures are needed not only to reduce resource impacts of rich person’s home but also to improve thermal comfort of poor people’s home as well.”

CSE researchers call for building public support and acceptance of green building programmes. Tell people what “works” and what “doesn’t work” in terms of energy-efficient and water-saving strategies for homes. Inform people about the rate of return on costs for energy-efficiency and water-conservation products and appliances.

“Build support for green buildings. Not reduce it to a green coat and a sham to protect realty profits,” said Roychowdhury.