Consent for Operation (CFO)
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:
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Units with Upto 1 Cr Investment:
- Approving Authority: Environment Engineer
- Regional Office
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Units with Above 1 Cr Investment:
- Approving Authority: Joint Chief Environment Engineer
- Regional Office: Zonal Office
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Red Category:
- Approving Authority: Joint Chief Environment Engineer
- Regional Office: Zonal Office
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Units which do not require Environment Clearance:
- Approving Authority: Joint Chief Environment Engineer
- Regional Office: Zonal Office
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Units/Projects which require Environment Clearance but less than Rs 5 Cr investment:
- Approving Authority: Joint Chief Environment Engineer
- Regional Office: Zonal Office
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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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Frequently Asked Questions
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What are the primary concerns at the time of application for Consent NOC?
Key considerations for evaluating a Consent for Operation (CFO) application encompass assessing potential environmental impacts on water, air, and soil pollution, scrutinizing the pollution management plan and engineering drawings. Additionally, thorough examination involves ensuring the compatibility and compliance of the proposal with other rules, regulations, and standards as notified by the State or Central Governments.
What is the purpose of a feasibility report?
The feasibility report encompasses comprehensive details, including engineering designs and drawings of proposed Pollution Control Measures for wastewater, solid waste, and emissions. Supporting information includes anticipated wastewater and air emission quality, secure waste disposal methods, equipment efficiency, and the mode of final disposal for treated effluent and emissions. The report also addresses air quality post-treatment and before discharge.
What is the role of CGWA at the time of seeking a Consent for Operation (CFO)?
Industrial units prioritize water conservation measures to minimize consumption. Hence, units must obtain all required clearances from relevant agencies. Specifically, proposals reliant on groundwater for new units necessitate clearance from the Central Ground Water Authority (CGWA) before applying for Consent for Operation (CFO).
Which are the specific sectors thatrequire additional documents?
The mentioned industries, including Stone Crusher, Mining Projects, Building, Construction, and Township Projects, Oil and Gas, Chemicals and Dyes Units, Hot Mix Plant, Brick Kiln Units, and Hydro Electric Projects, necessitate category-specific approvals from the state government in addition to the specified documents.
What are the pollution Criteriafor discharge of effluents to look for while applying for CFO?
Several parameters must be regulated, including pH, TSS (Total Suspended Solids), TDS (Total Dissolved Solids), Oil & Grease, BOD (Biochemical Oxygen Demand), and COD (Chemical Oxygen Demand).
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