1. Preparing a monitoring…

1. Preparing a monitoring plan should not be solely left to the LEP. It should be reviewed and approved before being accepted for registration.

2. MNRF and municipal consultation for the monitoring plan is not sufficient. The LEP should obtain a sign-off from both agencies.

3. More robust compliance protocols should be included in the program. Making inspection and records available upon request is not sufficient. Such reports and subsequent corrective actions, if required, should be periodically submitted to ensure compliance.

4. How would the EASR program modify the transfer of review responsibility entrusted to the municipalities?

5. Spill reporting needs stricter enforcement. Since spill management, including mitigation and cleanup, involves tremendous efforts, there is a likelihood that such occurrences would be concealed to escape repercussions. The spill management and reporting requirements under the EASR should be made more fool-proof.

6. The effluent limits are too general and need to be expanded to mention the maximum limits of common contaminants.