Consent for Operation (CFO)

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Overview of Consent for Operation (CFO) from SPCB

Granting Consent for Operation (CFO – Air and Water), also referred to as Consent to Operate (CTO), is a prerequisite for industrial units intending to commence operations. In accordance with Section 25/26 of the Water Act (1974) and Section 21 of the Air Act (1981), industries with potential air and water pollution must apply for the Pollution No Objection Certificate from their respective State Pollution Control Board (SPCB) or Pollution Control Committee (PCC). The issuance of pre-operation NOC is mandatory for initiating planned activities, and it applies to green, orange, and red category industries. Some State Pollution Control Boards maintain a list of exempted categories (white category) that can operate without consent, subject to local authority site clearance. Upon establishing the industrial unit and installing necessary pollution control equipment, obtaining consent to operate (CTO/CFO) becomes essential. Since this consent has a specified duration and requires periodic renewal, industrial units must ensure timely renewal and compliance with terms and post-compliances stipulated by the Board for the specific unit.

Consent for Operation (CFO)Approval Procedure

Upon establishment of the unit with requisite pollution control systems, the entrepreneur must obtain consent to operate from the State Board before commencing operational activities. The consent management process involves: Submission of Online Application and Consent Fee through OCMMS: States utilize the Online Consent Management and Monitoring System (OCCMS) for receiving applications, simplifying the process for obtaining fresh Consent to Establish (CTE) and Consent for Operation (CFO) as well as their renewals. Specific units handling various wastes require authorizations, including Pollution NOC, issued by the concerned SPCB/PCC. Some states have adopted Consolidated Consent and Authorization (CC&A) for a streamlined application and clearance process. Application Scrutiny: The section officer reviews the application and forwards it to a supervising officer (Senior Scientific Officer/Scientific Officer/Environmental Engineer) for examination and recommendations if necessary. Site Inspection: An inspecting officer, appointed by the Board, conducts a site visit, examines the facility, and provides recommendations based on findings and sample analysis of the trade effluent. Issuance/Rejection of Consent for Operation (CFO): The Chairman/Member Secretary, in line with delegated powers, grants or rejects Consent for Operation based on the inspecting officer's recommendations and resolution of concerns raised during the inspection.

Inspection during Consent for Operation (CFO)

After completing site construction and installing requisite waste management and pollution abatement equipment in accordance with standards, the entrepreneur applies for CFO, a process typically taking 30 days. The unit must consider this timeframe when applying. Additionally, strict adherence to discharge standards is vital, ensuring compliance with limits for air emissions (PM10, NOx), wastewater parameters (pH, TSS, TDS, Oil & Grease, BOD, COD), and noise levels during daytime and nighttime, as specified by the Board.

Approving Authority for Consent for Operation (CFO)

Location-wise hierarchy for environmental clearance is as follows:

Units with Upto 1 Cr Investment:
- Approving Authority: Environment Engineer
- Regional Office
Units with Above 1 Cr Investment:
- Approving Authority: Joint Chief Environment Engineer
- Regional Office: Zonal Office
Red Category:
- Approving Authority: Joint Chief Environment Engineer
- Regional Office: Zonal Office
Units which do not require Environment Clearance:
- Approving Authority: Joint Chief Environment Engineer
- Regional Office: Zonal Office
Units/Projects which require Environment Clearance but less than Rs 5 Cr investment:
- Approving Authority: Joint Chief Environment Engineer
- Regional Office: Zonal Office
All units/projects which require Environment Clearance and above Rs 5 Cr investment:
- Approving Authority: Member Secretary
- Regional Office: Head Office

Validity of Consent for Operation (CFO) from SPCB

Consent to operate durations vary across industry categories:

Red Category (Large, Medium, Small & Micro-scale units): 5 years
Orange Category (Large, Medium, & Small scale): 10 years
Orange Category (Micro-scale): 10 years
Green Category (Large scale): 15 years
Green Category (Medium scale): 15 years
Green Category (Micro & Small scale): 15 years

While green category industries enjoy a longer initial validity period, all units, regardless of category, must proactively renew their consent well before the expiration to ensure continuous compliance.

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Required Document List

Document Required for CFO under Air Act
Index/Site Plan
Topo Map
Detailed layout plan of different processes and point sources of Emissions and position of Stacks and Chimneys.
Process Flow Sheet Latest analysis report
Details of Air Pollution Control devices provided or proposed
Ambient Air Quality Report (If available)
CFE Copy along with implementation for Specified Conditions
List of raw materials with the quantity per month (MT/M) MSDS in the case of chemical industries

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