Meeting with Environmental Regulators on Status and strategy for CEMS implementation to expedite compliance with the new monitoring requirements

Centre for Science and Environment (CSE) organized a meeting with senior officials from various State Pollution Control Boards (SPCBs) on continuous emission monitoring system (CEMS) - its implementation status and strategy in India.  In this meeting, the current status of CEMS implementation in India, challenges being faced by stakeholders and findings of CSE’s CEMS implementation survey in Karnataka (with Karnataka State Pollution Control Board) and Madhya Pradesh (with Madhya Pradesh Pollution Control Board) was shared. CSE also shared the learnings from “Regulators‘ Training cum Exposure Visit on CEMS in Germany” which was organized by CSE towards regulator’s capacity building for CEMS implementation in India.

This event named “Regulator’s Workshop on Power Sector – Compliance and Enforcement” also involved discussion on implementation of new norms mandated for coal- based power sector and capacity building programme for environmental regulators. The event was organized on 24th November 2016, at the India Habitat Centre, Lodhi Road, New Delhi. 

The details of the workshop are given below.

Background

In the last one year, MoEF&CC and CPCB have announced comprehensive measures to improve power sector’s environmental performance. However, Centre for Science and Environment (CSE’s) recent study of the sector shows lack of progress that could result in potential delays in compliance. We believe implementing the norms in a timely fashion will require a concerted effort. 

To discuss on this, CSE organized a workshop: “Power Sector – Compliance and Enforcement” on 24 November 2016, at the India Habitat Centre, Lodhi Road, New Delhi. The workshop covered the following areas:

• Understanding potential impediments faced by the industry and share our findings about appropriate pollution control technology

• Ensuring track of progress by the coal based power sector to comply with the new environmental norms and arrive at a roadmap for implementation.

• Status and strategy for continuous emission monitoring systems (CEMS) implementation to expedite compliance with the new monitoring requirements.

• Modifications in CSE’s Regulators training programme to improve its quality and focus. 

The workshop was attended by senior representatives of Pollution Control Boards of states where nearly 60 percent of coal-based capacity is located.

The key points discussed in the Workshop and the agreed action steps are summarized below:

A. The roundtable began with an overview of the of the new environment standards by Priyavrat Bhati, Programme Director, CSE.  The overview covered the rationale for new standards, the basis on which the new levels were arrived at and the environmental benefits from implementing the norms.  

a. The presentation clarified that pollution control technology to achieve proposed standards is mature and widely available and will work for Indian coal characteristics. Moreover the costs are manageable.
b. Survey of plants showed very little progress has been made.  While the timelines were initially achievable, now they are challenging for many plants. It was suggested that progress needs to be tracked closely to ensure compliance.
c. Tariff applications need to be expedited to ensure cost recovery by plants and also to enable companies to raise financing.  CEA and CERC need to establish benchmark technology and costs; CSE will give inputs to CEA/CERC to expedite these guidance reports.

The overview was followed by a presentation by Mr. RP Sharma, CSE - “Technologies to meet new emission norms” - which gave various pollution control technologies for PM, SO2 and NOx control.

B. A round table discussion among the officials of various SPCBs discussed the reasons for delay in implementation and possible solutions. The discussions resulted in the following plan of action:

a. State PCBs will ask coal-based power plants about the implementation status. CSE will circulate a template document for data collection, which was reviewed by the participating SPCB officials, to all the state PCB for ease of data collection.
b. CSE will collect the data from the PCBs, collate the information and prepare a report that will be shared with PCBs. The report will help policy makers take proactive steps, if required and also to fine tune timelines on a plant-by-plant basis. 
c. CSE will organize workshop (s) for SPCB officials to build capacity. This would encompass, at the minimum, various pollution control technologies to enable PCBs to guide/advise plants. Member Secretary of Madhya Pradesh Pollution Control Board offered to organize plant visit for regulators to view installation of pollution control technologies. Other pollution control boards – Maharashtra, Jharkhand, etc., also offered that they could help to organize workshops in their states.
d. Based on the implementation report and inputs from SPCBs, CSE will attempt to compile action steps, penalties/incentives to enforce compliance.

C. The round table was followed by discussions on continuous emissions monitoring system (CEMS). Sanjeev. K. Kanchan, Programme Manager, CSE made a presentation on the status of CEMS implementation in India. The presentation covered the findings of CSE’s survey on CEMs installation and learning’s from regulators' exposure visit to Germany. Post presentation, the discussion highlighted the following points:

a. Capacity building of regulators and industries is crucial for CEMS implementation. The SPCB representatives requested CSE to organise short training programmes in their states. It was agreed that CSE will discuss with the interested boards and will organise the training programmes on mutually agreed dates. The logistics of the training will be managed by the boards.
b. The certification and laboratory accreditation system is a must for quality assurance and quality control of CEMS installations. The SPCB officials agreed that development of such systems must be initiated on urgent basis. 
c. The participants shared that data manipulation has been noticed even with CEMS installations. Therefore data validation system needs to be adopted. CSE shared the example of Germany, how the CEMS data is assessed in conjugation with key operational data that automatically verifies the data quality. 
d. The participants were informed that draft guidelines of CEMS have been put on CPCB website for public comment. The participants should provide the feedback on the same. The participants shared that if the new guidelines/documents/notices etc. are introduced by CPCB with prior involvement of SPCBs, it will be easy for them to implement those in their states. 
e. CSE shared that it is developing a broader guidance manual with the help of European experts which will be used for capacity building of stakeholders.

D. At the end, Nivit Kumar Yadav, Senior Programme Manager, CSE summarized the highlights of the decade old association of CSE with regulators starting from the publication “TURNAROUND: Reform Agenda for India's Environmental Regulators”. Followed by discussions with the below key action points

a. The boards are interested in short term training programme (2-3 days) in their states. 
b. They want to collaborate with CSE to do research and find solutions to manage the emerging environmental issues and challenges. 
c. Himachal Pradesh Pollution Control Board will be signing an MoU with CSE on waste management training programme.
d. There is lots of confusion with respect to new waste rule notified in 2016. Participants want short term training programmes either in their state or in Delhi on the five new waste rules.