Speaker: Srinithi Sudhakar
The Government of Tamil Nadu’s (GoTN) strategy to deliver and scale up Fecal Sludge Management (FSM) services across the State follows an approach of clustering Urban Local Bodies (ULBs) around existing or upcoming treatment facilities. To maximise utilisation of treatment facilities within these clusters of ULBs and fund their operation and maintenance, the GoTN has adopted two unique governance mechanisms: a Memorandum of Understanding and a Standard License Agreement (SLA). This paper highlights the attributes of these new mechanisms including welfare requirements built into the SLA and the MoU as a first-of-its-kind in the State with respect to sanitation.
Tamil Nadu was one of the first states in the country to recognise the importance of FSM in ensuring sanitation access to all, and the GoTN issued Operative Guidelines (OG) for Septage Management in 2014 and adopted a State Investment Plan for FSM in 2018. The five-phase plan is underpinned by two core principles: i) saturation of existing treatment facilities through co-treatment of sewage and septage, and ii) adoption of a cluster-approach. This approach involves clustering ULBs that fall within a 10 km radius of existing Sewage Treatment Plants (STPs) or potential new Fecal Sludge Treatment Plants (FSTPs). As these treatment facilities come into operation, they will be shared by clusters of ULBs.
To maximise utilisation of these treatment facilities and ensure sustained delivery of FSM services within these ULB clusters, the GoTN has institutionalised two new governance mechanisms through a Government Order issued in May 2020. The first includes an MoU between ULB clusters that governs the co-treatment process and the use of upcoming shared FSTPs.
The MoU is the first of its kind in the area of sanitation, establishing a formal process by which ULBs would utilise shared treatment facilities. While there exist few examples of formal agreements between local authorities that either share or provide services in areas of water supply and solid waste management, none appear to be implemented at scale.
The MoU details a set of obligations for the ‘Host ULB’ i.e. the ULB where the treatment facility is located, and ‘Participating ULBs’ i.e. ULBs that cluster around the said treatment facility. The key attributes of the MoU are:
The MoU assigns Host and Participating ULBs the responsibility of ensuring that all de-sludging operators operating within their jurisdiction are licensed. This reinforces the second mechanism developed to govern the process of FSM delivery across the State – the SLA for de-sludging operators.
Currently de-sludging operations are regulated in an ad-hoc manner across ULBs. Without adequate treatment facilities within reasonable distance from customer locations, de-sludging operators often resort to open dumping in storm water drainage systems or nearby surface water bodies. Alternatively, operators are forced to travel long distances to dispose septage, resulting in customers bearing high costs for de-sludging.
To streamline this collection and conveyance process, the GoTN has aligned de-sludging operations with the cluster-approach to treatment facilities. The SLA stipulates Host ULBs to license de-sludging operators to operate within their cluster. It mandates de-sludging operators to adopt proper de-sludging and disposal practices, and promotes use of treatment facilities through nominal Tipping and License Fees. Improving the health and safety of de-sludging workers is also the focus of the SLA, which aims to increase awareness and training on Occupational Health Safety as well as improve access to Personal Protective Equipment.
The governance mechanisms bring together multiple stakeholders (ULBs) to oversee the use and maintenance of shared treatment facilities. The MoU is a significant step towards ensuring sustainability of treatment facilities because:
The SLA helps further promote use of treatment facilities and safe disposal of fecal sludge and septage by keeping the monetary burden on operators to a minimal.
The two mechanisms together dis-incentivise open-dumping, and encourage sustained usage of treatment facilities. However, given the dearth of proven interventions in FSM, strengthening the enabling environment for FSM service delivery in Tamil Nadu is a time-intensive and iterative process.
As with most governance mechanisms, enforcement is key and would involve unique implementation models and monitoring support. Adequacy of ULB capacity is an added challenge to sustain interventions. With the MoU and SLA being unique governance mechanisms, the need for capacity building to operationalise the mechanisms is imperative.
Therefore, as a first step towards ensuring sustained use of these governance mechanisms, the MoU and SLA are currently being operationalised across Tamil Nadu through regional workshops and digital learning modules.
Commissionerate of Municipal Administration (2014). Operative Guidelines for Septage Management for Local Bodies in Tamil Nadu. Municipal Administration and Water Supply Department
Government of Tamil Nadu.
Municipal Administration and Water Supply Department (2014). Septage Management – Operative Guidelines for Septage Management for Urban and Rural Local Bodies in Tamil Nadu – Approved – Orders Issued (G.O. (Ms) No. 106.). Government of Tamil Nadu.
Municipal Administration and Water Supply Department (2018). In principle approval for creation of 49 numbers of Faecal Sludge and Septage Management (FSSM) treatment facility to cover 51 Municipalities and 59 Town Panchayats – Orders – Issued (G.O. (Ms) No. 88.). Government of Tamil Nadu.
Municipal Administration and Water Supply Department (2020). Faecal Sludge and Septage Treatment Plants – Approval of Faecal Sludge and Septage Management Licensing Agreement and Memorandum of Understanding of the Faecal Sludge and Septage Treatment Plants prepared by TSU of TNUSSP
IIHS for the use of the constructed Faecal Sludge and Septage Treatment Plants – Orders – Issued (G.O. (2D) No. 35.). Government of Tamil Nadu.