6/27/23, 8:49 PM
Gmail - Observations/feedback/comments furnished on the draft manual
Pradip Kalbar <pradipkalbar@gmail.com>
Observations/feedback/comments furnished on the draft manual
Pradip Kalbar <kalbar@iitb.ac.in>
Tue, Jun 27, 2023 at 8:47 PM
To: chaitra devoor <chaitradevoorphe@gmail.com>
Cc: Ms D Thara <tharad@ias.nic.in>, "Dr. M.Dhinadhayalan" <adviser-phee-mhua@gov.in>, "Dr. Ramakant"
<dr.ramakant@nic.in>, Vipin Kumar <Vk.patel@gov.in>, ashokn@steadytaps.in, "Dr. Ravindra P.N"
<drpnravindra@gmail.com>, drsvd14 <drsvd14@gmail.com>, himans24@gmail.com, ms mohankumar
<ms.mohankumar@gmail.com>, pawankl@hotmail.com, Pawan Labhasetwar <pk_labhasetwar@neeri.res.in>,
rajeshguptavnit@gmail.com, rajeshguptavnit@hotmail.com, schary@asci.org.in, manual watersupply
<manual.watersupply@gmail.com>, shreerangdeshpande <shreerangdeshpande@gmail.com>, monika bahl
<monika.bahl@giz.de>, supriya <supriya@washinstitute.org>, director@iitb.ac.in, punita <punita@washinstitute.org>
Dear CPHEEO Team,
Thanks for responding to my email wherein I communicated my feedback on the Draft Water Supply and
Treatment Manual 2023. I was expecting a point-wise reply to the technical points raised in my email
(attached herewith again). The generic reply received in the trailing email does not indicate any
engagement towards addressing the concerns raised regarding the recently issued Draft Manual.
My response in this email has three sections: First of all, I will again reiterate my main points
regarding the unsuitability of adopting 24x7 water supply as the immediate solution for safe drinking
water nationally; secondly, I will respond to the unsuitability of using the ‘Drink from Tap’ Scheme
implemented as a success story in Puri, and thirdly, I will provide some alternate solutions to
address the water supply issues in the Indian context.
A. WHY CPHEEO SHOULD NOT ADOPT 24x7 WSS AS A PANACEA FOR OUR WATER
WOES:
1. First of all, we need to understand and agree that water management is a ‘wicked’ problem
and there cannot be one solution fitting to all situations as the implementation of one
solution at a large scale, especially in a diverse country such as India, will have unimaginable
cascading effects (see these articles supporting this argument LINK1 and LINK2).
2. 24x7 water supply is not the right solution for us, even developed countries are
moving away from it: It is not at all well-established that a 24x7 piped water supply system is
the only way to ensure safe drinking water (refer to the paper on this LINK). It is just one of
several possible approaches. However, this model of water provisioning has its own limitations
and is unsuitable in the context of a developing country like ours. Today, even the developed
countries are unable to cope with their own O&M costs of 24x7 system of water provisioning,
which requires huge recurring costs (see the paper on this LINK)
3. There are many studies pointing out the need for alternate ways of water provisioning in
cities as 24x7 piped water supply does not necessarily guarantee safe drinking water to
residents, who end up depending on household water filters or suffer health
effects. https://www.nature.com/articles/s41545-021-00128-z
There are emerging ideas on non-grid/non-network or hybrid solutions for water provisioning
instead of centralized piped water supply systems due to their enormously large CAPEX and
OPEX costs rendering them unsuitable for many situations. The adoption of centralized piped
water supply systems will lead to a very long technological and social lock-in period which can
be very detrimental given our context.
https://pubs.acs.org/doi/10.1021/acs.est.9b05222?ref=pdf Full article available on this LINK
Further, there are growing risks due to emerging contaminants such as pesticides, residual
pharmaceuticals and microplastics which will result in residents having to use household water
filters even if 24x7 water supply system provides water with quality matching the current
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standards. Hence, we must consider these future challenges before deciding on large-scale
infrastructure changes. We can leapfrog and avoid the mistakes made by developed countries
rather than follow the same models of infrastructure development and incur failure in the long
run. Circular economy adoption can be such an example and our recent work on this topic is
given LINK
4. In today’s scenario of the growing water demand and climate change-induced extreme
events, we need distributed and local systems of water provisioning with a diversity of
sources, such as recycled water for toilet flushing and modular treatment systems for drinking
purposes. Out of 135 LPCD, only 3 to 5 L of water is needed for human consumption. For this
small quantity, treating the entire water quantity to the highest purity and transporting it to the
consumer with pressurized pipes does not assure both cost-effectiveness and health safety. In
most of the cities, every household has a water filter, and even if a piped water supply is
provided, residents will not do away with the water filters. Hence, we have to think of different
alternatives of water provisioning for marginalized and low-income communities. For example,
there are already community water filter plants in some cases, which can be formalized and
governed as part of the new guidelines. The funds saved by the non-provisioning of massive
infrastructure aimed to deliver 24x7 water supply (which cannot assure safety) can instead be
used to set up local service providers for delivering free drinking water to low-income
communities, who are now forced to do this at their own costs.
5. Large-scale changes are needed in thinking and planning the futuristic urban water
infrastructure to achieve sustainability and resilience. Adopting appropriately scaled
decentralized systems according to the scale of the city is one such approach, which is
documented in our recent work available on this LINK.
6. CPHEEO has accepted a 24x7 water supply with high pressure as a model for water
provisioning; however, as discussed above, it’s not futuristic; instead, it has limitations such as
high capital costs, high O&M, resource-intensive and needs better governance at the city level
which is currently missing in Indian cities.
7. Though CPHEEO accepts that there is an intermittent water supply in India and
approximately 30 to 50 % NRW (as against the permissible 15%), there is no section in the
manual on how to address such a situation first and bring reliability, efficiency, and equity in the
distribution of water, rather the focus is on planning for direct 24x7 continuous water supply. It is
hardly practical and an absurd thought that all cities will get brand new water infrastructure and
will do away with all existing infrastructure.
8. If the guidelines provided in the draft manual are adopted, there is a high chance it will
reinforce the current intermittent water supply as other requirements such as operational
economics, governance, and monitoring will not be addressed; refer to our work on this aspect
on this LINK and some other studies showing no change of consumer behavior even after 24x7
water supply implementation in India (refer on this LINK)
Hence, it is of utmost importance to try different models of water provisioning and then make
recommendations for the entire nation.
B. WHY PURI ‘DRINK FROM TAP’ IS AN UNSUITABLE MODEL FOR THE REST OF INDIA
The case of Puri in Odisha, which is taken as the basis for the preparation of the guidelines, is
not suitable due to the following reasons:
a. It is a very recent case that started in 2019/20 and needs to be sufficiently studied by
multiple organizations to establish its success over the long run.
b. Most of the pipe network is brand new in Puri (refer to MoHUA’s own document on
Puri case), which is not the case in several other cities, as many cities already have large
existing networks.
c. I have contacted a few residents in Puri and learned that they still receive intermittent
water supply and have to use household-level sumps and water filters. (I will be happy to
visit Puri with CPHEEO representative and see evidence to the contrary.)
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d. There are total of 19 operation zones and the same number of DMAs in Puri. This
contravenes the basic logic of DMAs. How can this non-standard DMA-based design be
proposed for the entire country?
e. In the case of Puri, the residual pressure used is 14m. The reason for increasing it to
21 m in the Draft guidelines is not clear (refer to MoHUA’s own document). In my
previous comments, the disadvantages of such pressure criteria increase are given.
f. Puri has very good river water source; however, many cities in India source their
water from highly polluted rivers having regular and emerging contaminants. In such a
scenario, how can we recommend “Drink from Tap” in such cities when conventional
WTPs will not be able to remove emerging contaminants?
Clearly, Puri cannot be considered a complete success and model in terms of Drink from Tap
(which is really a distant dream) and further, 24x7 water supply is also only a reality in some
zones in Puri. Hence, it is unclear how a single case showcased as a success story can be used
for emulation. Therefore, using the Puri case to issue guidelines for upcoming projects across a
large country like ours should be avoided. As there are no other proven models of water
provisioning, it does not make a case that the approach presented in Chapter 2 is the only way
to proceed. Considering our country's diversity, using Puri as a case in the guidelines issued in
the Draft manual is incorrect.
C. SOME ALTERNATIVE WAYS FORWARD:
1. Keep 7 m residual pressure criteria with peak factors ranging from 1.5 to 3 for the distribution
system. This is more suitable considering the diversity of our cities. Let cities decide what kind of
water provisioning model they wish to choose based on the local conditions.
2. A detailed techno-economic comparison of alternative water provisioning measures based on
a life cycle perspective must be carried out (CPHEEO can fund such research projects) to check
whether uniform guidelines can be issued nationwide.
3. Manual should list all possible options/routes of possible options with pros and cons and
should not over-emphasize on only one option.
4. Innovative and futuristic water provisioning models, such as non-grid decentralized options,
should also be piloted in different cities.
5. Manual can also fix per connection cost for different regions/topography, and cities can
decide what kind of water provisioning they wish. This will allow greater flexibility to the city
engineers.
Lastly, I thank CPHEEO for including JalTantra, a free software developed at IIT Bombay, in the draft
Manual. We also have some other innovations to improve water supply systems, which we are currently
testing on the ground in different settings.
Thanks for providing me with the opportunity to give feedback. With the short time provided (I was in a
conference, and we have MTech exams going on this week), I could gather this short note, I hope this
will help CPHEEO to reflect on the proposed guidelines.
Best regards,
Dr. Pradip Kalbar
Associate Professor
Centre for Urban Science and Engineering (CUSE)
Editor - Water Reuse IWA Journal
Indian Institute of Technology Bombay
Powai, Mumbai 400 076
Maharashtra, India
Office Tel.: +91 22 2576 9330
Email: kalbar@iitb.ac.in
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Kalbar__Email__19June2023.pdf
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