To: The Chairman, BWSSB 1st Floor, Cauvery Bhavan,K.G.Road Bangalore-560009
Dear Sir/Madam,
Loksatta Party welcomes the recent amendment to the BWSSB act making rainwater harvesting mandatory in Bangalore. The legislature must be commended for passing the legislation which will help in recharging depleting ground water table as well as help storm water drainage system to cope with heavy rainfall. The BWSSB circulated rules for this amendment last week and invited feedback from public.
Loksatta party strongly feels that in order for active public participation in review of draft regulations, more time is necessary and requests the deadline to be extended by 2 weeks.
Loksatta party has the following suggestions to the draft regulations:
1. We think the amendment has a serious short coming. Existing buildings built on sites of more than 2400 square feet are expected to implement rainwater harvesting within a time period of 9 months from the commencement of the act. Similarly, all new constructions on a sital area of more than 1200 sq. feet are expected to implement rain water harvesting. Loksatta Party is of the opinion that 9 months is too short a time for completing installation of water harvesting in all applicable buildings in Bangalore because
a. Licensed plumbing contractors and their staff need to be trained in the scientific implementation and best practices
Loksatta party has the following suggestions to the draft regulations:
1. We think the amendment has a serious short coming. Existing buildings built on sites of more than 2400 square feet are expected to implement rainwater harvesting within a time period of 9 months from the commencement of the act. Similarly, all new constructions on a sital area of more than 1200 sq. feet are expected to implement rain water harvesting. Loksatta Party is of the opinion that 9 months is too short a time for completing installation of water harvesting in all applicable buildings in Bangalore because
a. Licensed plumbing contractors and their staff need to be trained in the scientific implementation and best practices
b. Public awareness and education program must be part of the implementation so that implementation is done effectively.
2. The rule makes no distinction between small and large consumers of water. The current draft rules require a RWH storage or recharge capacity of 20 liters per square meter of building roof area. It would be advisable to put a larger burden on bigger consumers. A larger requirement could be placed on multi family dwellings or multi storey buildings. Similarly, large consumers of water could be asked to provide a higher provision for rain water storage and ground water recharge.
3. Loksatta Party suggests that government reconsider the enforcement authority being vested on BWSSB. BWSSB may not be appropriately staffed and capable of effectively enforcing the rapid addition of rain water harvesting systems across the city in comprehensive manner with fairness and transparency. The current amendment puts the onus on the BWSSB to enforce the implementation of systems in non-compliant buildings and to recover costs through the land revenue department. The government should ask itself on whether this idea is really practical.
4. Finally, since the rules envisage the recharge of ground water through open wells and borewells, it is imperative to have clearly defined standards as well as inspection to ensure that surface pollution does not contaminate ground water through poor design. In the normal course, water percolates through the soil and has a chance to be cleaned off many of its contaminants through this process before hitting the ground water table. The direct recharge process poses a danger of ground water pollution if not implemented properly. All these issues must be carefully considered. Proper training of the implementing plumbers and contractors as well as inspection and monitoring is vital for the safety and enhancement of our ground water supplies through rain water harvesting.
The government and the BWSSB would be well advised to give some more thought to the aforementioned aspects of the new rain water harvesting law. The Lok Satta party looks forward to the opportunity to work with the administration to promote the successful implementation of rain water harvesting in Bangalore and shortly and the whole state in the future.
sincerely,
K.Rama Lakshmi
Convenor,
Loksatta Party Karnataka State Unit
Phone: 94499 94499
E-Mail: info@loksattakarnataka.org
Web: www.loksattakarnataka.org
2. The rule makes no distinction between small and large consumers of water. The current draft rules require a RWH storage or recharge capacity of 20 liters per square meter of building roof area. It would be advisable to put a larger burden on bigger consumers. A larger requirement could be placed on multi family dwellings or multi storey buildings. Similarly, large consumers of water could be asked to provide a higher provision for rain water storage and ground water recharge.
3. Loksatta Party suggests that government reconsider the enforcement authority being vested on BWSSB. BWSSB may not be appropriately staffed and capable of effectively enforcing the rapid addition of rain water harvesting systems across the city in comprehensive manner with fairness and transparency. The current amendment puts the onus on the BWSSB to enforce the implementation of systems in non-compliant buildings and to recover costs through the land revenue department. The government should ask itself on whether this idea is really practical.
4. Finally, since the rules envisage the recharge of ground water through open wells and borewells, it is imperative to have clearly defined standards as well as inspection to ensure that surface pollution does not contaminate ground water through poor design. In the normal course, water percolates through the soil and has a chance to be cleaned off many of its contaminants through this process before hitting the ground water table. The direct recharge process poses a danger of ground water pollution if not implemented properly. All these issues must be carefully considered. Proper training of the implementing plumbers and contractors as well as inspection and monitoring is vital for the safety and enhancement of our ground water supplies through rain water harvesting.
The government and the BWSSB would be well advised to give some more thought to the aforementioned aspects of the new rain water harvesting law. The Lok Satta party looks forward to the opportunity to work with the administration to promote the successful implementation of rain water harvesting in Bangalore and shortly and the whole state in the future.
sincerely,
K.Rama Lakshmi
Convenor,
Loksatta Party Karnataka State Unit
Phone: 94499 94499
E-Mail: info@loksattakarnataka.org
Web: www.loksattakarnataka.org
