Introduction

This article identifies the gaps in governance of our water system management, and recommends corrective actions.

The document is divided in 3 sections:

1. An overview of our water system assets, stakeholders, their needs, and their conflicts.
2. An overview of the problems in our water system management:
   water pollution, water scarcity, and floods
3. Suggested solutions

The article contains four appendixes:

• Appendix-A shows all tasks in a typical lake rejuvenation project.
• Appendix-B shows the recommended single-window clearance process for lake-rejuvenation projects
• Appendix-C shows the long-term measures needed to institutionalize the new processes.
• Appendix-D describes the structural changes needed in KTCDA.

Part-1: Our water system

As shown in the diagram below, our water system comprises the following components:

• Underground Sewerage System (UGD)
• Sewage Treatment Plants (STPs): Both privately owned and BWSSB-owned
• Wetlands
• Lakes
• Channels: Interconnecting the lakes
• Aquifers

A simplified diagram of how these components work together is given below:

Lake Assets

A lake is not a monolithic entity. Rather, it consists of 34 types of assets. Each of these assets costs money to create, maintain and rejuvenate. Therefore, it is best to manage lakes in terms of these assets.

Ecological zone	Lake periphery	Social zone
1. Interceptor channel 2. Sluice gate at inlet 3. Silt trap 4. Debris trap 5. STP 6. Wetland 7. Stabilization pond 8. Lake body (water, fish stock, etc.) 9. Aerator (diffuser, paddler, fountain) 10. Fish cage 11. Fish barrier 12. Bund 13. Rock lining of the bank 14. Island 15. Weir 16. Water release gate and chute 17. Borewell 18. Jack well	1. Gate 2. Approach road 3. Fencing 4. Water supply system (for garden and toilets) 5. CCTV coverage	1. Garden 2. Trees and bushes 3. Butterfly park 4. Walking/biking track 5. Lighting 6. Toilets 7. Gazebo 8. Amphitheater 9. Children’s play area 10. Recreation facilities 11. Kalyani

The Stakeholders

A system would be incomplete without considering its stakeholders. The following table lists the different stakeholders and their desired “win conditions”. 

Stakeholder	Win conditions
Custodian of the lake	1. Maintain the lake in prime condition 2. Get the budget for rejuvenation and management 3. No pollution ingress (solid waste, sewage)
BWSSB (Bengaluru Water Supply and Sewerage Board)	Integrated water management
KSPCB (Karnataka State Pollution Control Board)	Compliance with Water Act, 1974
KTCDA (Karnataka Tank Conservation and Development Authority)	Protection, conservation and rejuvenation of water bodies
Lake activists	1. Maintain all lakes in prime condition 2. No pollution ingress (solid waste, sewage) 3. Biodiversity in flora and fauna
Corporate donor (CSR fund-provider)	1. Ease of selecting a target lake 2. Reasonable budget 3. Maximum brand promotion 4. Regular proof of success 5. Projects that yield instant and highly visible success (e.g. half-day clean-up drive)
CSR fund manager	1. Maximum number of lake-contracts 2. Maximum-possible profit margin 3. Minimum-possible procedural overheads
Community around the lake	1. Safe (pollutant-free) water 2. Improvement in groundwater yield and quality 3. Mosquito-free open space at lake 4. Migratory birds (boasting rights) 5. Recreation/sports facilities 6. Social events (e.g. Ganesha/Durga immersion) 7. Safety at the lake (drowning, anti-social elements)
Farmers	1. Safe water for irrigation 2. Easy access to the lake to harvest fodder 3. Safe (pollutant-free) fodder
Fishers	1. Maximum-possible yield of fish 2. Good premium on the fish

Conflicts among stakeholders

1. Conflicts between stakeholders

The expectations of all stakeholders can never be identical or harmonized. While designing, managing and rejuvenating a lake, the stakeholder conflicts must be considered and a judicious balanced must be found. The final decision would always be the best compromise.

The following table lists the conflicting needs of the stakeholders. 

Stakeholders	Conflict
Community vs. Lake-owner	The Ganesh/Durga immersion and other religious rituals dump idols and puja material in the lake, which is difficult to clean up. It also increases the cost of maintenance.
Community vs. community	Different people within community want different deliverables, which cannot be achieved together. Example-1: To attract more birds, the lake must be shallow. For sports, the lake must be deep. Example-2: If lake is used for fishing, nets are used, which obstruct sports.
Community vs. Lake-owner	When public is not provided with an effective SWM logistics, they try to dump garbage in lakes.
Corporate vs. Lake-owner	The mundane maintenance activities are far more expensive than the decoration outside the lake. But the corporate cannot capitalize on such activities. Thus their focus remains on a tiny fraction of the whole lake. Most of the lake remains cash-starved.
Corporate vs. Lake-owner	The sponsor gets a small amount of publicity through lakes, for which he is not ready to spend big. There is no competition, so the sponsors do not try to outbid each other.
Corporate vs. Lake-owner	A corporate cannot show a visible major improvement if the lake is already well-maintained. So they try to keep shifting to new lakes, thus withdrawing their support to the previous lakes.
Lake owner vs parastatal bodies	The parastatal bodies have a chokehold on the lake-owner’s rights. Small things like failing to inform them in advance triggers a lash-back, and the project suffers.
Corporate vs. Community	A corporate may want to convert a part of the lake to suit its own operations (e.g. thoroughfare road for its employees).
Corporate vs. CSR fund manager	If the fund manager’s margins are high, the net CSR fund available for the project reduces.
Corporate vs. Community	Excessive brand promotion at the lake becomes obtrusive for the lake visitors.
Fishermen vs. Community	Fishing nets cause problems for the birds, and obstruct boating.

Part 2: Why our water system is in distress

This section is split in three subparts:

1. Why our lakes are in poor shape
2. Why floods occur across the city
3. Why our groundwater has depleted alarmingly

2A. Why our lakes are in poor shape

Lakes suffer from garbage, industrial effluents, and encroachments due to poor governance and enforcement by local bodies like ULBs and KSPCB.

Root cause	Agency	End result
Solid Waste Management (SWM) is missing / poor	Urban Local Body (ULB)	Garbage in the drains+lake
Lack of Effluent Treatment Plant (ETP) for all industries	KSPCB	Chemicals and heavy metals in lake water
Lack of tertiary treatment – Biological Nutrients Removal (BNR)	ULB, KSPCB	Algal bloom, macrophytes ►Fish kill
Lack of Sewate Treatment Plant (STP), malfunctioning STP	ULB, KSPCB	Silting of the lake Algal bloom, macrophytes ►Fish kill
No protection against soil erosion	ULB	Cloudy water, low Dissolved Oxygen (DO) ►fish kill
Lake maps not in public domain	ULB	Rampant encroachment
No evictions from lake area	ULB	Rampant encroachment

2B. Why we have frequent floods in the city

Root cause	Agency	End result
Storm Water Drain (SWD) issues: a. Inadequate size b. Encroached c. Eliminated d. Displaced e. Disconnected f. Choked with silt/waste g. Blocked	ULB	Area gets flooded
Lake management issues a. No sluice gate b. Heavily silted c. Bypassed d. No flood management system e. Encroached f. Converted	ULB	Area gets flooded
Roads block water flow a. Lack of culverts b. Leveling issues	ULB	Area gets flooded
Lack on floodplain planning	ULB	Floodplains get flooded after heavy showers.

2C. Why our groundwater has depleted

1. 

Root cause	Agency	End result
Focus on exporting water	GoK	Focus on local water balancing is lost
Lack of proactive urban planning a. Urban form planning b. Densification c. Preventing leapfrog development d. Green zone planning+management	BDA+ BMRDA+ ULB	Demand for water grows haphazardly across the city and even outside the city limits. Since BWSSB supply is not available, people use groundwater. If people do not have sewerage connections, they dump raw/treated sewage in drains.
Lack of proactive planning of water supply and sewerage	BWSSB
Lack of control on OC	ULB	People occupy buildings without official water supply and sewage handling.
Lax RWH implementation	ULB	No groundwater recharging ►Depletion
Lack of focus on water balance	ULB	Assets are not used to recharge groundwater a. SWDs b. Wetlands c. Lakes d. Old mines e. Recharge wells
Focus on getting rid of rainwater ASAP	ULB	Rainwater is not used for groundwater recharging.
Lack of control on STPs	KSPCB	SWDs carry poorly treated sewage
No focus on water recycling	KSPCB+ BDA+ BMRDA+BWSSB+ULB	Treated sewage cannot used to recharge groundwater, and therefore it is discarded.

Notes:
BDA is Bangalore Development Authority, BMRDA: Bengaluru Metropolitan Region Development Authority.
A recharge well is not the same as a recharge pit: It is wider and deeper, and designed to recharge at a much higher rate.

Part 3: Suggested solutions

In the following tables, only the main responsible agency is listed. However, that agency would need support from multiple other agencies. Also, note that the water system is highly interdependent – a single flaw can trigger a long chain of problems.

3A. Structural reforms

In this section, we will see problems that occur because our government agencies are not structured properly.

Problem	Suggested solution
Wetlands are treated as wastelands, and therefore ULBs do not try to preserve, protect or develop them.	Section 26(2)(b) of Karnataka Town and Country Planning Act must be amended to respect lakes and wetlands as “entities with incomparable values”(1). Accordingly, BBMP must release a bye-law about how wetlands are protected, preserved and developed.(2)
Lakes are treated as individual tanks, and not as part of a water system that fulfills functions such as flood-mitigation, surface water storage or groundwater recharging.(3)	The jurisdiction of KTCDA is limited to lakes only, but not over the other elements of the water system.(4) KTCDA is also not responsible for IWRM aspects such as flood-mitigation, surface water storage or groundwater recharging. We need a senior regulatory authority that looks after the water system as a whole, and controls all related functions under one umbrella. This includes all valleys, lake chains and interconnected watersheds and microsheds.
Although KTCDA is given the task to protect, conserve and rejuvenate all water bodies, it has never defined how to achieve that goal.	KTCDA is just a high-level group of secretaries chaired by the Chief Minister, where the Secretary of the MI department is the ex-officio CEO. However, the design of the rest of the organization is left undefined. There are no rules that define how KTCDA would be able to execute its tasks effectively and efficiently. Appendix-D describes the problems in detail.
KTCDA does not have the staffing to fulfill its duties	Given the enormous scope of KTCDA’s duties, it should have a large staff with specialists in multiple domains (limnology, hydrogeology, hydraulics, etc.). KTCDA must publish Rules that identifies all the required skill sets and their required number. (5)

Notes:

1. Ref: Section 4(vi) of the National Environmental Policy, 2006
2. According to Section 2(1)(g) of Wetlands (Conservation and Management) Rules, 2017, lakes up to 6 m depth are considered “wetlands”, which applies to all lakes in Bengaluru.
3. Lakes have multiple functions, such as flood-mitigation, water reservoirs or recharging groundwater. There is no planning for such functions. For example, none of our lakes have sluice gates to control the amount of water released. There is no provision to synchronize water release from all lakes in a chain.
4. The KTCDA Act defines that the term “surface water” includes water occurring on the land of tanks. This is a flawed definition: The term “surface water” actually means all water that flows anywhere in the catchment, including SWDs.
5. For example, KLCDA (the predecessor of KTCDA) had KLCDA Rules, 2015; in which 96 specialists were identified, including senior officers to be posted on deputation from Police department, Forest department, etc. KTCDA has no equivalent rules that define such staffing needs

3B. Functional reforms

In this section, we will see problems that occur because the existing process is ineffective in delivering results, or no agency accepts certain tasks as their responsibility, or an activity was somehow never performed.

Problem	Suggested solution
Large lake areas are encroached, and the authorities are not acting to recover that land.	KTCDA must initiate surveys to identify the encroached lake land (including buffer zone) and launch a drive to recover such land.BBMP must initiate surveys to identify the encroached and/or diverted SWDs (including buffer zone) and launch a drive to recover such land.
Lake areas do not appear in public online maps, which makes them easy target for encroachers	Release all lake area definitions to public domain: All online maps (Google Maps, OpenStreetMap, Wikimapia, etc.) must show the revenue boundary and buffer zones of all lakes and major SWDs accurately.
No attention paid to water balance of the watersheds.	KTCDA must change its strategy to maintain the water balance of all watersheds, by utilizing the lakes, SWDs, wetlands and STPs to replenish our fast-depleting groundwater. Note that the definition of a water body includes peripheral catchment area, Inlet channels and outlet channels in Section 2(1)(g) of KTCDA Act.
There is no coordination between ULBs in the region.	Our water system is spread beyond the BDA-controlled area. Therefore, KTCDA must coordinate between all ULBs that have jurisdiction over the interconnected lakes.
Lake projects deal with civil engineering issues only, not with environmental engineering	KTCDA must reconstitute a Technical Approval Committee that has designated slots for limnologists, ecologists, hydrogeologists, and environmental engineers, with a clear mandate to look into all the aspects of a lake and not just the civil engineering aspects.
Lakes are designed for commercial fishing, not to support the food web.	KTCDA must change the DPR for lake rejuvenation projects to design a self-sustaining lake that supports all kinds of aquatic life; not a fish-breeding tank.
Lake projects suffer because of lack of single-window clearance	KTCDA must appoint a nodal officer who tracks all projects, who must provide information to the public about the status of any lake, including the time-bound action plan, copy of DPR, status of the project, etc. He must also manage the coordination among all the 13 agencies that deal with lakes.
DPRs are ad-hoc, and often violate the basic principles of environment engineering.	KTCDA must amend the standard format of lake rejuvenation DPRs, to include flood-mitigation, rainwater harvesting and groundwater recharge. The DPR must call for transportation of the silt removed from the lake bed, instead of allowing it to be dumped on the bund under any pretext.
KTCDA’s flawed interpretation of lake capacity allows any amount of lake encroachment	KTCDA allows building of roads/bridges if the original capacity of the lake is not reduced. First of all, there is no such thing as “rated or original capacity” of a lake: Due to natural siltation, its capacity keeps decreasing over time (till it is desilted). Conversely, it can be deepened beyond its natural holding capacity. So, anyone can grab any part of lake, by simply desilting in the remaining part of the lake, which “restores” the capacity of the lake!
Lake rejuvenation projects focus on social zone, but not ecological zone of the lake.	KTCDA must change the template of DPR to focus on the ecological function of the lake, rather than focusing on gardens, parks, gazebos, amphitheater, walking tracks, etc.
Lake rejuvenation is totally ignored, or is ad-hoc	KTCDA must issue lake rejuvenation guidelines and standard operating procedures (SOP) as mandated in the KTCDA act. For example, rejuvenating a lake is a waste of money if all upstream lakes are not rejuvenated before it.
Routine lake management is totally absent, or is ad-hoc	KTCDA must issue guidelines and standard operating procedures (SOP) for management of lakes, including controlling the eutrophication levels of the lakes.
Residential and industrial pollution is allowed unchecked.	KSPCB and KTCDA must not allow any pollution –either domestic sewage or industrial effluent– in any lake.
Bypass channels are created at lakes to divert Incoming pollution, which pollutes the entire SWD system.	KSPCB and KTCDA must ban creation of bypass channels at any lake. The incoming pollution at any lake must be diverted to the UGD system only.
Officers of ULBs (BBMP, Grama/Taluk/Zilla Panchayat) violate the law with impunity.	KTCDA must take up actions against the defaulting officials, and also file legal suits against the project proponents and sponsors of illegitimate projects.
The Govt has failed to implement orders of our courts (HC, SC, NGT) to rejuvenate and maintain our lakes.	The concerned authorities must produce a time-bound action-plan to implement the orders issued by the courts.
All lakes receive a lot of waste and silt via SWDs.	For every lake, there must be a debris trap and silt trap. These must be constructed in such a way that it is easy to transport the waste and silt collected by these traps.
A lot of waste is dumped in lake areas.	BBMP must set up a separate cell that monitors dumping of waste in lake areas, and adjusts the local SWM logistics to prevent future occurrences. In addition, BBMP must set up a system to empanel vendors who carry the C&D waste, and introduce geofencing for all vehicles, so that the C&D waste is not dumped in deserted areas, including lake areas.
Money spent on lakes is mostly unaccountable	KTCDA must introduce the lake asset management system, and conduct annual audits to monitor these assets. All lake project DPRs must be justified in terms of these assets.(Which assets are being added, repaired or rejuvenated, and at what cost.)
No attention is paid to the water system outside the lake.	Any project undertaken by KTCDA must address the entire catchment of any lake: Its feeder water system (incoming drains), the quality and quantity of incoming water, floodplains, etc.
CSR sponsors are not facilitated at all	KTCDA must revamp its MoU and DPR templates to encourage the CSR sponsors to participate. The sponsors must be indemnified against any problems that occur in the project (provided that they have taken up a duly approved project).
No attention is given to the role played by a given lake	KTCDA must identify special purposes served by each lake based on its geographic location and surrounding terrain: flood mitigation, groundwater recharge, rainwater storage, etc. For any given lake, the routine management and rejuvenation projects must be designed to address these specific purposes.
The govt does not involve the public in lake-management or rejuvenation	There are more than 13 types of stakeholders for any given lake. KTCDA must develop a SOP to involve all stakeholders in the rejuvenation projects. There must be a separate SOP to keep these stakeholders engaged in the routine lake management also.
STPs and wetlands are unscientifically added just as show-piece. Such lakes become hypertrophic rapidly and become dead.	KTCDA must ban all wetland designs that cannot remove nutrients (Nitrates and Phosphorus) from the incoming water and bring it to eutrophic levels.
There is no control imposed on the quality of the incoming water	KTCDA must make it mandatory for every lake rejuvenation project to ensure that the incoming water quality meets CPCB standards. This can be done by- (a) fitting the upstream STPs with BNR, and  (b) diverting raw sewage coming from upstream to UGD.
Govt keeps announcing that “dead” lakes would be converted to parks or sold off to builders	The idea of “dead lakes” is a fallacy. A lake is only killed when water coming to it via SWDs is cut off or diverted. KTCDA must ban all such activities, and reverse any such action to revive all lakes. KTCDA also must investigate why certain lakes have gone dry, and recover its feeder drains from encroachments. KTCDA must launch a terrain-wide hydraulic analysis to assess how much water arrives at each lake, and ensure that water flow is not interrupted or diverted.
KSPCB routinely reports that most of our lakes are severely polluted (in E/F category), but fails to make a systematic plan to upgrade them.	KSPCB must declare time-bound targets to upgrade specific lakes to a better category. Based on these targets, KSPCB must launch a campaign to identify pollution sources and eliminate them. This can be done by monitoring the water quality at strategic points in the catchment area of that lake.
Local water balancing is not considered at all.	BBMP must plan water balancing of all watersheds in Bengaluru. Water must be sent out of the city (Kolar, Doddaballapur, etc.) only after the city’s water balance is restored using the local resources. Currently, a large area of the city depends on groundwater, and the water table has dropped alarmingly fast. This is not sustainable.
KSPCB has not issued STP design guidelines for builders	KSPCB has issued a STP design guideline, but it was withdrawn after expert feedback. KSPCB must issue a fresh STP design guideline, so that builders do not end up building non-standard STPs with questionable or unviable designs.
KSPCB does not have a formal process to approve an STP. No data, calculations or engineering drawings are collected to prove the process capability of the STP.	KSPCB must publish a dedicated data-collection format for each type of STP, where all calculations are required to be submitted step-by-step. The form must ask for specific engineering drawings that demonstrate that the design has incorporated all the design features that are essential for a given type of STP. These drawings and calculations must be kept in records for any future comparison and investigations (in case of a failure or accident).
KSPCB allows construction of STPs of unsuitable types, which do not work reliably.	KSPCB must introduce type-approval process.  a. Issue CFE only if the STP is of a pre-approved type. b. If STP has a new/hybrid design, subject it to a rigorous type-approval process first. c. If the new design passes, add that to the list of pre-approved types.
KSPCB frequently changes its specifications for treated sewage, which forces the RWAs to make costly upgrade to their STPs.	KSPCB must freeze its specification, and align them with national standards. Apartment buyers must not be made to pay to modify their STPs to meet the ever-changing effluent quality standards.
Private STPs are passed haphazardly without any process	KSPCB must release SOP about regulation of STPs: a. Issue CFE only after scrutiny of design drawings and calculations b. Issue CFO only after verifying compliance with CFE data, and fabrication DOs and Don’ts. c. Enforce official handing-over by builder to RWA only after a third party audit.
KSPCB approves STPs without any functional test, even when the STP may have many defects.	Split the first CFO stage into two parts: a. Issue provisional CFO if physical inspection passes. b. Issue final CFO only after functional tests.
Private STPs have poor quality, because of lack of control by KSPCB.	KSPCB must have dedicated checklists for each type of STP, so that its health and status can be checked thoroughly. Without such checks, annual inspection of STP is useless.
A lot of dysfunctional STPs exist in the city, for which KSPCB holds the RWA responsible, although the STP was never formally handed over to the RWA.	KSPCB must accept its liability in such cases. If the builder abandons a project without handing over the STP formally to the RWA, KSPCB is responsible, because the buyers relied on the CFE-CFO approval issued by a government authority (KSPCB). KSPCB can claim indemnity only if the builder submits the STP to a 3rd party formal audit, rectifies all problems and then formally hands over the STP to the RWA in KSPCB records.
A lot of buildings (both residential and commercial) release untreated sewage	BBMP and BWSSB must survey the entire city. Each building must have sewage-treatment: a. Its own STP, and connection with SWD b. Connection with an underground sewerage (BWSSB’s STP)
Sewage treated in an STP still has nutrients, which kills SWDs and lakes.	Even after sewage is treated in a private/public STP, it still has nutrients (Nitrates, Phosphorus and Potassium), which makes the water bodies (SWDs and lakes) hypertrophic, which kills all aquatic life. Therefore, BWSSB must set up BNR (Biological Nutrient Removal) plants to remove the nutrients from treated sewage.
BWSSB STPs are not strategically located to protect all lakes of the city	Bengaluru city straddles on four valleys: Hebbal, K&C, Vrishabhavathi, Arkavathi) In all valleys, it is expanding toward downstream areas. Therefore BWSSB is able to find space only in the downstream areas. As a result, many upstream lakes cannot receive fully treated sewage. KSPCB must arrange for mini STPs to feed the upstream lakes. Alternatively, KSPCB, BWSSB and KTCDA can plan to feed these lakes with BNR-treated sewage from local STPs.
Wetlands are added only for cosmetic purposes, not for their ecological function	KSPCB and KTCDA must issue design guideline for wetlands: a. Area needed for treating specific quantity of sewage b. Alternative designs of wetland c. Minimum HRT (Hydraulic Retention Time) d. Harvesting frequency to maintain the efficiency of the wetland. e. Periodic maintenance procedure (e.g. desilting)
BWSSB pipelines are too small to serve large areas. Such pipes are time-shared by shutting off supply to different areas manually. This is unreliable and promotes bribery.	BWSSB must follow hub-and-spoke supply model: Large pipelines must be extended to central hubs in different parts of the city, from where spokes must be extended in all directions. Also, the supply to the branches must be automated and remote-controlled, so that people cannot bribe the local linesman to get their water supply hours extended.
BWSSB has not implemented the JICA project to install aggregate meters to detect pilferage.	All meters must be installed immediately,
BWSSB’s water distribution data is not made public. This promotes social injustice and large-scale bribery.	The water distribution data must be placed in public domain, so that NGOs and activists can analyze the data to find issues with the distribution pattern; and find pilferage and illegitimate beneficiaries.
BWSSB’s water distribution plans are not in sync with the city’s target growth pattern.	BWSSB must declare a water distribution plan in sync with the city’s growth plan. For example, if the city needs densification along its Metro corridor, then BWSSB must lay its supply and sewerage networks to match that target population density. Similarly, BWSSB’s policy can discourage urban sprawl.
KSPCB’s draconian ZLD (Zero Liquid Discharge) policy causes wanton misery to the public	The ZLD must be officially repealed, as even CPCB has clarified that it was declared only for molasses units in the Namami Gange project area; and was never meant for domestic STPs. For any private/public STP, it is impossible to recycle the entire treated sewage. In residential buildings, about 50% of the treated sewage has to be discharged in SWDs.
Most STPs are run by unqualified operators, who fail to treat the sewage, and also damage the STP.	We had devised a detailed course for STP operators, but KSPCB must rigorously implement it, and make it mandatory for the STP operator to employ only certified operators.
KSPCB violates Water Act section 22 while drawing samples of treated sewage	KSPCB must split the sample, and seal both samples. KSPCB must allow the occupier to send one sealed sample to any NABL-approved lab. If the two samples yield different readings, the test is deemed invalid, and a fresh sample has to be drawn.
KSPCB insists that when the RWAs get their treated sewage tested on monthly basis from an NABL-approved lab, those test-results are wrong, while its own test-results are always accurate.	KSPCB’s own lab is an NABL-approved lab, just like any other NABL-approved lab in the city. Therefore, KSPCB cannot insist that its own test-results are correct, and the RWA’s test-results are invalid. It is illogical that all NABL-approved labs in the city yield wrong test-results, while only KSPCB’s lab yields correct test-results!
Every STP needs 1-2 weeks of down-time annually, but during this period, there is no provision to divert the raw sewage to UGD network.	BWSSB must make a provision so that every STP operator can divert the raw sewage to the UGD system during the 1-2 week downtime. A nominal charge can be fixed for this. Without this facility, the STP operator ends up dumping raw sewage in the SWDs.
A lot of honey-sucker tankers ply in the city, which are supposed to carry the raw sewage to BWSSB delivery points. But BWSSB has not made such points available within convenient distance. As a result, the tankers just dump sewage into nearby SWDs.	BWSSB must make connection-points available throughout the city so that the maximum distance from any point is within a threshold distance. BWSSB must geo-fence all tankers that provide such service, so that they cannot dump sewage in SWDs.
SWDs are not designed to carry clean water. They are not protected against ingress of waste and sewage.	BWSSB and BBMP must take multiple steps to protect the SWDs against ingress of waste and sewage. a. BBMP must monitor where waste is dumped into SWDs, and improve its waste-collection logistics in the surrounding areas till the black spots vanish. b. BBMP must geo-fence all vehicles that carry C&D waste, so that no one is able to dump C&D waste in SWDs and lakes. c. All SWDs must be revamped to include debris traps and silt traps at regular intervals, and there must be provision to transport the debris and silt collected. d. The pollution in the drainage system must be monitored at strategic points across the whole city. If pollution is detected at any strategic point, additional measurement points must be set up upstream of that point till the pollution sources are identified. e. If any ingress of sewage is observed, it must be diverted to the nearest UGD.If ingress of industrial effluent is observed, KSPCB must force them to set up an ETP, or relocate. f. Even treated sewage still has NPK nutrients (Nitrogen, Phosphorus, Potassium), which leads to explosive growth of vegetation (hyacinth and/or algae) in the water bodies (SWDs and lakes). Therefore, even presence of NPK must not be tolerated in SWDs. The nutrients must be removed by installing BNR (Biological Nutrient Removal) plants.

Appendix-A: Lake rejuvenation tasks

Appendix-B Single-window lake-rejuvenation process

Appendix-C: Institutionalization of agencies

All agencies involved in managing our water system are expected to perform with consistent effectiveness and efficiency.

However, most Bengalureans complain that our water system is in extremely poor condition, and the agencies have failed to arrest the degradation. Worse, there is no transparency in the system, and the citizens cannot even know what actions are being taken, and when they would expect the outcome.

The root cause is that none of the agencies are effectively organized or institutionalized, as illustrated by the following diagram.

1. Appendix-D: Structural issues in KTCDA

The KTCDA Act has more than 100 issues. The more significant issues are listed here.

1. The objects and reasons of the KTCDA Act mention that improvement of groundwater. However, apart from lakes, there are no other measures for recharging the groundwater or restoring the water balance, such as MAR (Managed Aquifer Recharge)
2. The lakes would be administered by designated officers from MI, RDPR, FD or UDD, which means that no residual power is left with the lake custodians such as BBMP, BDA or BMRCL.
3. KTCDA focuses on “conservation and rejuvenation of water bodies”. That means maintaining status quo.
   However, maintaining the status quo is not enough: The rapidly changing social landscape needs more water across the state. But GoK is not ready with an integrated water resource management (IWRM) policy and plan.
   Karnataka —Bengaluru in particular— are already facing unprecedented water shortage crisis. Only an integrated water management can avert a crisis in the rural and urban areas.
   We will have a full-blown water crisis unless we adopt water recycling and reuse; and the wetlands and lakes play critical roles in it. Therefore, we need a revamped KTCDA act that deals with integrated water management.

4. KTCDA is empowered to alter, extend or abridge the purpose for which is established; merge or take over any other organization wholly or partially in furtherance of the objective of the Authority. This is dangerous. That’s the job of the legislature!
5. There is an inherent conflict of interest in KTCDA: It acts as a regulator, but at the same time, it is also supposed to seek funds and launch lake-related projects. Execution and regulation must remain with separate entities.
6. KTCDA seeks funds for the rejuvenation or development or maintenance of tanks, although it is a regulator who is NOT supposed to be executor or owner of any lakes. Such fund allocation will obfuscate the total spending after each lake; and encourage opaque practices and siphoning of money.
7. Originally, KTCDA provisioned for district-level teams to execute the decisions taken by the apex committee. But the district-level teams were abolished through the amendment in 2014, which means KTCDA will not be able to do its job in the rural areas.
8. The urban and rural water bodies need distinct strategies, as outlined in the old versions of KLCDA and KTCDA acts. A common approach and staffing will not work.
9. The original version of KTCDA required that all lakes-related projects be approved by the authority. But the amendment changed the word “approval” to “clearance”. The distinction is not clear. It is best to amend the act to include a clarification that this refers to environmental clearance only, and does not include scrutiny and approval of the project for its technical, financial or legal aspects; which is still the responsibility of the lake custodian.
10. KLCDA relied on getting officers on deputation. This ensures that they are not permanently entrenched in the power positions. It also ensures cooperation of all departments. KTCDA aims to appoint its own staff, which defeats both objectives.
11. The lakes belong to the ULB, and they are supposed to play a vital role in the water management in the cities. But if MI takes over the ownership of all lakes, effectively these assets are taken over by GoK from the ULB. This is in violation of the 74^th Amendment.
12.  The KLCDA Rules defined the required skills precisely. On the other hand, Section 3 of KTCDA allows staffing arbitrarily. In fact, KTCDA does not provide enough clarity about what functions are to be served.
13. While KLCDA was supposed to manage the lakes only within Bengaluru city, KTCDA is supposed to manage lakes across the entire state. Therefore, it would need a much larger staff.
    But given that KLCDA CEOs could not get 96 people on deputation despite the clear stipulation by the KLCDA Rules, how will the KTCDA CEO get a much larger permanent staff?
14. KTCDA brings 17 parastatal agencies together, but its quarterly meetings have a quorum of just 3 agencies! In other words, as many as 14 out of the 17 agencies may be absent in a quarterly meeting. Worse, the Act provides that any of these members may chair the meeting, if the Chair (the Chief Minister) or the Vice Chair (the PS of MI department) are unable to attend. Clearly, such meetings have no meaning.