Environmental Compliance

What is it?

CTE is SPCB permission to set up a new industrial unit. CTO is permission to begin operations — both issued under the Water Act 1974 and Air Act 1981.

Why is it required?

Mandatory before construction (CTE) and before operations (CTO). Operating without these is a criminal offence. SPCBs issue closure orders and Environmental Compensation for non-compliance.

Who requires this?

• New manufacturing plants and industrial units
• Existing units expanding capacity or changing product mix
• Hotels, hospitals, and bulk water users
• All industries listed in SPCB schedules

How Greenovate helps

• Complete document preparation and application filing
• SPCB liaison and follow-up to reduce delays
• Condition compliance plan post-approval
• Timely renewal management (120 days ahead)
• Closure order resolution and revocation support

Typical Timeline

CTE: 30–90 days · CTO: 30–60 days · Renewal: 45–75 days. Timeline varies by SPCB state and industry category (Red / Orange / Green).

Key Documents Needed

• Site plan, layout, and process flow diagram
• Pollution control equipment details
• Water balance and ETP design
• Stack emission calculations

What is it?

Prior Environmental Clearance from MoEFCC or SEIAA for Category A and B projects under EIA Notification 2006. The EIA report is the technical document required for clearance.

Why is it required?

Mandatory before any construction begins. Projects starting without EC face demolition orders and criminal prosecution. Post-facto regularisation is increasingly disallowed by NGT.

Who requires this?

• Real estate projects above 20,000 sq.m. built-up area
• Mining, quarrying, and mineral extraction projects
• Industrial estates, SEZs, power plants
• Highways, pipelines, large industrial projects

How Greenovate helps

• Project categorisation (A / B1 / B2) determination
• Baseline data collection (air, water, soil, ecology)
• Full EIA/EMP report preparation
• Public hearing preparation and management
• PARIVESH portal filing and EC condition compliance

Typical Timeline

Category B2 (SEIAA): 4–8 months · Category B1: 8–14 months · Category A (MoEFCC): 12–24 months — including scoping, public hearing, and expert appraisal.

Post-EC Compliance

• Half-yearly compliance reports to MoEFCC/SEIAA
• Environmental monitoring as per EC conditions
• CER fund management and utilisation

What is it?

A No-Objection Certificate from the Central Ground Water Authority (CGWA) permitting extraction of groundwater beyond prescribed thresholds, applied for via the online CGWA portal.

Why is it required?

Mandatory for industries and institutions extracting groundwater above defined limits — particularly in notified, over-exploited, or critical groundwater zones. CGWA conducts regular inspections.

Who requires this?

• Manufacturing industries using borewells
• Hotels, resorts, hospitals with groundwater extraction
• Real estate projects and townships
• All industries in notified groundwater areas

How Greenovate helps

• Extraction quantity assessment and zone classification
• Hydrogeology report preparation
• CGWA online portal application filing
• Rainwater harvesting and recharge plan
• Renewal and condition compliance

What is it?

Permission for development in Coastal Regulation Zone under CRZ Notification 2019. CRZ areas are classified CRZ-I (ecologically sensitive) to CRZ-IV (islands and lagoons).

Why is it required?

Mandatory for construction within 500m of the High Tide Line. Unauthorised construction faces demolition orders and criminal prosecution under the EP Act 1986.

Who requires this?

• Coastal real estate and resort developers
• Port operators and jetty constructors
• Tourism and hospitality projects on coastlines
• Fishing harbours and aquaculture projects

How Greenovate helps

• CRZ mapping and HTL/LTL demarcation
• Beach profile and hazard line study
• CZMA application preparation and filing
• EIA for CRZ-I and CRZ-II projects
• SCZMA and NCZMA coordination

What is it?

A systematic, periodic evaluation of your facility's compliance status against all applicable environmental laws — consents, EC conditions, waste rules, and CPCB/SPCB guidelines.

Why is it required?

EC conditions mandate half-yearly compliance reporting. Banks require compliance certificates for project loans. Pre-inspection audits prevent surprise closures and show-cause notices.

Who requires this?

• All industries with Environmental Clearance
• Companies undergoing M&A due diligence
• Industries facing SPCB show-cause notices
• Facilities seeking ISO 14001 certification

How Greenovate helps

• Compliance gap assessment across all applicable rules
• Compliance calendar with deadline tracking
• Half-yearly EC compliance reports to regulators
• Environmental monitoring programme management
• Regulatory change alerts and advisory

What is it?

Ongoing compliance with the Water Act 1974 and Air Act 1981 — covering effluent treatment (ETP/STP), stack emissions, ambient monitoring, and periodic returns to the SPCB/CPCB.

Why is it required?

All industries holding CTO must maintain ETP/STP performance, conduct stack testing, and submit monitoring data. SPCB inspections lead to closure orders for non-compliant units.

Who requires this?

• Manufacturing units with process effluent or wastewater
• Industries with stack emissions (furnaces, boilers, DG sets)
• Hotels, hospitals & townships with STP
• All Red and Orange category industries under SPCB schedule

How Greenovate helps

• ETP/STP design review and performance optimisation
• Stack emission testing coordination (NABL labs)
• Ambient air and water quality monitoring programme
• Monthly/quarterly SPCB returns and CEMS data submissions
• CTO condition compliance calendar and tracking

What is it?

End-to-end compliance with the Hazardous and Other Wastes (Management & Transboundary Movement) Rules 2016 — classification, labelling, storage, transport, and authorised TSDF disposal.

Why is it required?

Hazardous waste generators must hold SPCB authorisation, maintain waste inventories, file Form 3/4 annual returns, and dispose only through authorised TSDFs. Violations are cognisable offences.

Who requires this?

• Chemical, pharmaceutical, and paint manufacturers
• Electroplating, tannery, and textile dyeing units
• Automobile and engineering industries
• Hospitals generating chemical or cytotoxic waste

How Greenovate helps

• HW classification audit per Schedule I/II/III of HW Rules
• SPCB Form 1 authorisation application and renewal
• TSDF identification, evaluation, and empanelment
• Form 3/4 annual return preparation and portal filing
• Transboundary movement documentation (Form 6/7)

What is it?

Form V filing under Rule 14 of the Environment (Protection) Rules 1986 — an annual declaration of resource consumption, effluent and emission data, and environmental performance submitted to the SPCB.

Why is it required?

Mandatory for all industries holding CTO or Hazardous Waste authorisation. Non-filing attracts prosecution under the EP Act 1986 and can be cited as grounds for consent rejection at renewal.

Who requires this?

• All industries holding SPCB Consent to Operate
• Industries holding Hazardous Waste authorisation
• Units operating under Environmental Clearance conditions

How Greenovate helps

• Data compilation from production and monitoring records
• Form V preparation with all statutory annexures
• SPCB portal upload and submission confirmation
• Multi-year record maintenance for audit readiness

What is it?

SPCB/CPCB/NGT show-cause notices alleging regulatory violations require a formal written response within 15–30 days. A poor or absent response leads directly to closure orders and Environmental Compensation liability.

Why is it critical?

An SCN is a legal document. Ignoring it or submitting an inadequate reply can result in plant closure, criminal prosecution of directors, and compounded EC penalties that accrue daily.

Who needs this?

• Any industry receiving an SPCB or CPCB notice
• Units facing NGT orders or suo-motu actions
• Industries with pending closure directions
• Companies under Environmental Compensation proceedings

How Greenovate helps

• Rapid compliance gap assessment within 24–48 hours
• Legally sound SCN response drafting with evidence
• SPCB personal hearing representation
• Closure order revocation and EC quantification support
• Long-term compliance programme to prevent recurrence

What is it?

A pre-transaction environmental compliance review — assessing all consents, clearances, waste authorisations, pending liabilities, and contamination risks associated with a target facility or company.

Why is it required?

Undisclosed environmental liabilities — EC violations, missing NOCs, contaminated land — can invalidate transaction warranties and expose buyers to inherited prosecution and remediation costs.

Who requires this?

• Private equity and venture capital investors
• M&A buyers acquiring industrial facilities
• Project finance lenders (bank/DFI requirement)
• Real estate developers on brownfield sites

How Greenovate helps

• Phase 1 EDD — document review and compliance gap identification
• Phase 2 EDD — site visit, sampling, and liability quantification
• Red-flag report with risk ratings and remediation cost estimates
• Transaction support — warranty clauses and indemnity structuring