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1.KochiDraftCSP VolumeI Main
1.KochiDraftCSP VolumeI Main
1.KochiDraftCSP VolumeI Main
Contents
SECTION I: OVERVIEW AND CONTEXT SETTING ................................................................................................ 1
1. INTRODUCTION ....................................................................................................................................... 2
City Sanitation Plan for Kochi - Draft Report Volume 1, Main Report ii
GIZ-ASEM Corporation of Cochin
12. CSP SUMMARY: VISION GOALS AND ACTION PLAN ......................................................................... 107
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Tables
TABLE 2.1: POPULATION DENSITIES IN KOCHI AND ADJOINING AREAS ................................................................................... 11
TABLE 2.2: WARDS WITH THE HIGHEST POPULATION DENSITIES ......................................................................................... 11
TABLE 2.3: POPULATION TRENDS: COCHIN CORPORATION AND KOCHI URBAN AGGLOMERATION .............................................. 11
TABLE 2.4: OFFICIAL POPULATION PROJECTIONS: COCHIN CORPORATION AND KOCHI URBAN AGGLOMERATION........................... 12
TABLE 2.5: POPULATION PROJECTIONS: IMACS ANALYSIS AND OTHER SOURCES .................................................................... 12
TABLE 2.6: DETAILS OF IMACS CALCULATIONS ............................................................................................................... 12
TABLE 2.7: BPL POPULATION IN KOCHI ......................................................................................................................... 12
TABLE 2.8: SLUMS AND SLUM POPULATION IN KOCHI ....................................................................................................... 13
TABLE 2.9: SANITATION INFRASTRUCTURE DEMAND ......................................................................................................... 13
TABLE 3.1: ACCESS TO TOILETS – SWOT ....................................................................................................................... 16
TABLE 3.2 ACCESS TO TOILETS SUPPLY: SHORT MEDIUM AND LONG TERM TARGETS............................................................... 19
TABLE 3.3 INFRASTRUCTURE DEMAND AND COST ESTIMATE .............................................................................................. 19
TABLE 3.4 ACCESS TO TOILETS SUPPLY: RECOMMENDED ACTIONS ....................................................................................... 20
TABLE 3.5 ILLUSTRATIVE CHECKLIST FOR TOILET INSPECTION AND RECTIFICATION .................................................................... 22
TABLE 4.1: BRIEF HISTORY OF SURFACE WATER SUPPLY TO KOCHI ....................................................................................... 25
TABLE 4.2 WATER SUPPLY CONNECTIONS IN KOCHI, MARCH 2009 ..................................................................................... 27
TABLE 4.3: WATER TARIFFS IN KOCHI ............................................................................................................................ 28
TABLE 4.4 PROPOSED NEW TARIFF REGIME UNDER THE KWA ............................................................................................ 29
TABLE 4.5: WATER QUALITY FINDINGS: INDUSTRIAL STRETCHES OF PERIYAR RIVER................................................................. 29
TABLE 4.6: PROJECTED WATER DEMAND, COC AREA ........................................................................................................ 31
TABLE 4.7: WATER SUPPLY – SWOT ............................................................................................................................ 32
TABLE 4.8 WATER SUPPLY: SHORT MEDIUM AND LONG TERM TARGETS .............................................................................. 35
TABLE 4.9 COST ESTIMATES – SHORT, MEDIUM AND LONG TERM ...................................................................................... 35
TABLE 4.10 WATER SUPPLY: ACTION PLAN .................................................................................................................... 36
TABLE 4.11 POSSIBLE LIST OF INFORMATION TO BE CAPTURED DURING THE MULTI-PURPOSE HOUSEHOLD SURVEY ....................... 36
TABLE 4.12TARIFF SETTING PHILOSOPHY - SHORT TERM AND LONG TERM ............................................................................. 38
TABLE 4.13 SURAT MUNICIPAL CORPORATION: WATER QUALITY MONITORING PROTOCOL AND SAMPLING PLAN ....................... 39
TABLE 5.1: SEWAGE GENERATION DEMAND .................................................................................................................... 44
TABLE 5.2: COMPONENTS PROPOSED UNDER THE KSUDP SEWERAGE DPR .......................................................................... 45
TABLE 5.3: WASTE-WATER MANAGEMENT - SWOT ........................................................................................................ 47
TABLE 5.4 WASTE WATER MANAGEMENT: EVALUATION OF OPTIONS ................................................................................... 49
TABLE 5.5: WASTE WATER MANAGEMENT: SHORT, MEDIUM AND LONG-TERM TARGETS ......................................................... 52
TABLE 5.6 COST ESTIMATES – SHORT, MEDIUM AND LONG TERM ...................................................................................... 52
TABLE 5.7 WASTE WATER MANAGEMENT: SUGGESTED ADDITIONAL ACTIONS........................................................................ 57
TABLE 6.1: DRAINAGE CANAL NETWORK DETAILS ............................................................................................................. 60
TABLE 6.2: DETAIL OF MAJOR INDUSTRIES IN KOCHI ......................................................................................................... 62
TABLE 6.3: WASTE-WATER MANAGEMENT – SWOT........................................................................................................ 63
TABLE 6.4: STORM WATER MANAGEMENT: SHORT MEDIUM AND LONG TERM TARGETS ......................................................... 64
TABLE 6.5 INFRASTRUCTURE COST ESTIMATE.................................................................................................................. 64
TABLE 7.1: BREAK-UP DETAIL OF SOLID WASTE GENERATION BY SOURCE IN KOCHI .................................................................. 66
TABLE 7.2: SWM PERFORMANCE SUMMARY .................................................................................................................. 68
TABLE 7.3: SWM SERVICE LEVELS VIS-A-VIS SLB SET BY MOUD ........................................................................................ 68
TABLE 7.4: SWM - SWOT ......................................................................................................................................... 69
TABLE 7.5: SWM: SHORT, MEDIUM AND LONG-TERM TARGETS ......................................................................................... 70
TABLE 7.6 SWM: RECOMMENDATIONS ........................................................................................................................ 70
TABLE 8.1: LEGISLATIVE AND ADMINISTRATIVE FRAMEWORK FOR URBAN INFRASTRUCTURE IN KOCHI ......................................... 74
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TABLE 8.2: STATE LEVEL PROGRESS ON URBAN REFORMS UNDER JNNURM ......................................................................... 74
TABLE 8.3: INSTITUTIONAL RESPONSIBILITY MATRIX FOR CIVIC SERVICES, KOCHI ..................................................................... 79
TABLE 8.4: INSTITUTIONAL RESPONSIBILITIES UNDER THE MOU .......................................................................................... 80
TABLE 8.5: OVERALL ACCOUNTABILITY FOR SANITATION SERVICES – PROJECTED SCENARIO ....................................................... 82
TABLE 8.6 ILLUSTRATIVE LIST OF AREAS FOR FORMULATING BYE-LAWS AND POLICY GUIDELINES................................................. 83
TABLE 9.1: ILLUSTRATIVE TRAINING NEEDS ACROSS SELECT SANITATION COMPONENTS ............................................................ 88
TABLE 9.2: POSSIBLE LIST OF INFORMATION TO BE CAPTURED DURING THE MULTI-PURPOSE HOUSEHOLD SURVEY ......................... 89
TABLE 10.1: ILLUSTRATIVE BEHAVIOUR CHANGE OBJECTIVES .............................................................................................. 92
TABLE 10.2: CHANNELS OF COMMUNICATION................................................................................................................. 94
TABLE 10.3: ILLUSTRATIVE PILOT CAMPAIGN FOR SANITATION AND HYGIENE AWARENESS ........................................................ 95
TABLE 10.4: ILLUSTRATIVE PILOT CAMPAIGN FOR SAFE WASTEWATER MANAGEMENT.............................................................. 96
TABLE 10.5: ILLUSTRATIVE PILOT CAMPAIGN FOR LITTER FREE WARD ................................................................................... 97
TABLE 11.1: COC: INCOME AND EXPENDITURE ............................................................................................................... 98
TABLE 11.2: FINANCIAL SUSTAINABILITY: SHORT MEDIUM AND LONG TERM TARGETS ............................................................ 99
TABLE 11.3 CAPITAL INVESTMENT ESTIMATE AND POSSIBLE PHASING (FIGURES IN RS. LAKH) ................................................. 100
TABLE 12.1: SANITATION COMPONENTS VISION AND TARGETS ........................................................................................ 107
TABLE 12.2 ACCESS TO TOILETS: ACTION PLAN ............................................................................................................. 109
TABLE 12.3 WATER SUPPLY: ACTION PLAN .................................................................................................................. 109
TABLE 12.4 WASTEWATER AND STORM WATER MANAGEMENT: ACTION PLAN .................................................................. 110
TABLE 12.5 SOLID WASTE MANAGEMENT: ACTION PLAN ............................................................................................... 110
TABLE 12.6 ILLUSTRATIVE LIST OF AREAS FOR FORMULATING BYE-LAWS AND POLICY GUIDELINES ............................................. 111
TABLE 12.7 LIST OF DPRS AND ADDITIONAL STUDIES...................................................................................................... 112
TABLE 12.8 CAPITAL INVESTMENT ESTIMATE AND POSSIBLE PHASING (FIGURES IN RS. LAKH) ................................................. 112
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Figures
FIGURE 1.1 FRAMEWORK FOR THE CSP: INTEGRATED APPROACH TO INCLUSIVE SANITATION..................................................... 4
FIGURE 1.2 STRATEGIC PILLARS SUPPORTING INCLUSIVE SANITATION .................................................................................... 4
FIGURE 1.3 A PARTICIPATORY, MULTI-STAKEHOLDER CONSULTATIVE PROCESS ADOPTED .......................................................... 6
FIGURE 2.1 LOCATION OF KOCHI .................................................................................................................................... 9
FIGURE 2.2: KOCHI AND ITS VARIOUS ISLANDS ................................................................................................................ 10
FIGURE 2.3: KOCHI URBAN AGGLOMERATION AND COC AREAS ........................................................................................... 10
FIGURE 3.1: PRIMARY SURVEY FINDINGS: TOILET FACILITIES USED BY SURVEYED HOUSEHOLD .................................................... 15
FIGURE 3.2: WARDS REPORTING OPEN DEFECATION ......................................................................................................... 16
FIGURE 4.1: SCHEMATIC OF THE EXISTING WATER SUPPLY SYSTEM....................................................................................... 26
FIGURE 4.2 PRIMARY SURVEY FINDINGS: SOURCES OF HOUSEHOLD WATER SUPPLY ................................................................. 27
FIGURE 4.3 PRIMARY SURVEY FINDINGS: SUPPLY DURATION AND SUFFICIENCY ...................................................................... 28
FIGURE 4.4 PRIMARY SURVEY FINDINGS: PERCEPTIONS ON WATER QUALITY .......................................................................... 30
FIGURE 5.1: EXISTING AND SEWERAGE COVERAGE AREAS .................................................................................................. 40
FIGURE 5.2: A VIEW OF THE KWA STP AT ELANKULAM .................................................................................................... 41
FIGURE 5.3: SCHEMATIC OF TYPICAL WASTEWATER FLOWS IN KOCHI ................................................................................... 43
FIGURE 5.4: SANITATION SCENARIO 2014 (SHORT-TERM) ................................................................................................. 53
FIGURE 5.5: SANITATION SCENARIO 2021 (MEDIUM TERM) .............................................................................................. 54
FIGURE 5.6: SANITATION SCENARIO 2031 (LONG TERM)................................................................................................... 55
FIGURE 5.7: SANITATION SCENARIO 2041 (LONGER TERM) ............................................................................................... 56
FIGURE 8.1 ORGANISATIONAL ALIGNMENT FOR SANITATION FUNCTIONS - KWA AND COC ...................................................... 84
FIGURE 10.1: STEPS TO ADDRESS AWARENESS ISSUES ....................................................................................................... 91
FIGURE 10.2: COMMUNICATION OBJECTIVES, ACTIONS AND CHANNELS................................................................................ 93
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Volume 2: Annexure
ANNEX 1: SCOPE OF WORK AS PER TOR
ANNEX 2: LIST OF OFFICIALS/PERSONS MET
ANNEX 3: LIST OF CTF MEMBERS
ANNEX 4: MINUTES OF CTF MEETINGS
ANNEX 5: QUESTIONNAIRES FOR PRIMARY GAP FILLING SURVEY
ANNEX 6: DETAILS OF LANDUSE IN KOCHI
ANNEX 7: WARD MAP AND WARD LEVEL POPULATION PROJECTIONS
ANNEX 8: CLIMATE, HYDROLOGY, HYDROGEOLOGY AND GROUNDWATER
ANNEX 9: KOCHI UFW COMPUTATIONS
ANNEX 10: QUALITY DATA
ANNEX 11: KSPCB NOTIFICATIONS
ANNEX 12: NOTES ON KOCHI BACKWATERS
ANNEX 13: VISUAL EVIDENCE OF DRAINAGE ISSUES
ANNEX 14: SWM BYE-LAWS, AS AMENDED
ANNEX 15: ADDITIONAL INFORMATION ON INSTITUTIONAL FRAMEWORK
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1. Introduction
1.1. Background
1.1.1. National Urban Sanitation Policy
The 2008 National Urban Sanitation Policy (NUSP) of the Ministry of Urban Development (MoUD), Government
of India (GOI) outlined an aspirational sanitation vision for Indian cities.
All Indian cities and towns should become totally sanitized, healthy and liveable and ensure and sustain good
public health and environmental outcomes for all their citizens with a special focus on hygienic and
affordable sanitation facilities for urban poor and women.
The NUSP defines Sanitation as safe management of human excreta (including its safe confinement,
treatment, disposal and associated hygiene-related practices). It further recognises that integral solutions are
needed to take account of other elements of environmental sanitation, i.e. Solid Waste Management (SWM);
generation of industrial and other specialized / hazardous wastes; drainage and management of drinking water
supply. The NUSP emphasises that a fully Sanitized City should achieve a wider set of positive sanitation
outcomes including:
Elimination of Open Defecation
Elimination of manual scavenging and ensuring safety of sanitation workers.
Safe management of Municipal wastewater and storm water
Recycling of treated wastewater for non-potable applications
Full and safe collection and disposal of Municipal Solid Waste
Inclusive, efficient and sustainable service delivery in all sanitation services
Improved Public Health Outcomes and Environmental Standards
1
The focus of the study is area under the jurisdiction of the Corporation of Cochin (CoC).
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Figure 1.1 Framework for the CSP: Integrated approach to inclusive sanitation
Water Supply / use Access to Toilets Solid Waste Management
• Piped supply • Individual connections • Generation
• Household sources • Community / Shared • Conveyance
• Tankers / Bottled supply • Public places • Processing / Disposal
Extent of Toilet access and Extent of drain clogging,
Extent of safe prevalence of open defecation stagnation and contamination
equitable water due to poor SWM practices
access
4. Strategic support pillars for inclusive sanitation: The approach also recognises that sustainable and
inclusive sanitation cannot be achieved simply by focusing on the necessary technical options along these
components, but requires critical interventions on four other dimensions namely (i) Governance /
Institutional framework, (ii) Capacity Development, (iii) Awareness Generation and (iv) Financial
Sustainability (Figure 1.2).
Figure 1.2 Strategic pillars supporting inclusive sanitation
Financial
Technical Governance Capacity Sustainability
Options /Institutional development • Tariff
Awareness Rationalisation
• DPRs/Further • Institutional • Information Generation • Institutional
studies • Regulation and Management improvements
• Actions Monitoring • Training
Inclusive Sanitation
1.3.2. Methodology
The CSP was an effort to generate much-needed momentum, both within government and civil society, in a
segment of urban infrastructure that requires demand-led planning and renewed attention. To this end, a
structured, participatory and multi-stakeholder engaging consultative process was adopted through creation
of a City Task Force (CTF) and engaging with different stakeholders including staff of the Municipal
Corporation, departments, parastatal agencies and other state and local institutions, policy makers and
citizens (Refer
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Figure 1.3). Also refer Annex 2 for details and for a list of officials met during the course of this exercise.
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Inception Interactions: A kick-off workshop was held on 17 March 2010 at GIZ office Delhi. The workshop
was coordinated by GIZ to provide a shared understanding of the baseline scenario in the 6 cities namely,
Kochi, Nashik, Tirupati, Raipur, and Shimla and to agree on the broad activities and timelines for the
exercise. Following interactions facilitated by GIZ in Kochi, direct one-on-one meetings were held with
officials of the Corporation of Kochi (CoC), coordinated by the GIZ Environmental Cell in Kochi. The CTF
was constituted in consultation with CoC officials and the GIZ Environmental Cell. The list of CTF members
is enclosed in Annex 3.
Meetings with City Task Force: Following the formation of the City Sanitation Task Force a formal kick-off
meeting was organised on 19 May 2010. The objective of this meeting was to apprise the CTF of the
objectives of the CSP exercise being undertaken and the role of the CTF during the course of preparation
of the CSP and during its implementation. Apart from the inception meeting, we had one-on-one meetings
during the course of the preparatory phase with several of the CTF members, in addition to the formal
inception meeting. This was followed by two more meetings (on 23 March 2011 and 20 Aug 2011); one to
discuss and obtain approval of the Status Report and another meeting to discuss the draft CSP findings
and recommendations. The minutes of the CTF meeting are enclosed in Annex 4.
Baseline research: Interactions were held with CoC officials to understand the existing situation in terms
of (a) existing information on demographics, infrastructure and municipal finances; (b) documents such as
CDPs, Master Plans, DPRs and thematic maps and (c) qualitative issues. All findings were discussed with
the GIZ Environment Cell and the CoC to arrive at a shared understanding of issues. Interactions were held
with CoC officials to understand the existing situation in terms of (a) existing information on
demographics, infrastructure and municipal finances; (b) documents such as CDPs, Master Plans, DPRs and
thematic maps and (c) qualitative issues. All findings were discussed with the GIZ Environment Cell and the
CoC to arrive at a shared understanding of issues.
Primary Gap-filling surveys: IMaCS inducted Socio-Economic Units Foundation (SEUF), a local consulting
firm from Kerala, to support local fact-finding and to conduct rapid gap-filling field surveys of on-the-
ground sanitation issues across households, commercial establishments, slum pockets and public areas.
The survey was done to provide a field-level check of the situation of water supply, sanitation, solid waste
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disposal and health services in order to supplement available secondary data. A total of 500 households
were surveyed along with 20 commercial and institutional establishments and reconnaissance, review of
10 public locations were covered. Detailed data collection and data entry formats were designed for each
of these categories by IMaCS and discussed with field staff that carried out the survey. The questionnaires
were administered in by surveyors in local language to facilitate better understanding, after incorporating
feedback from initial field testing in the questionnaire and survey methodology. The questionnaire format
is enclosed in Annex 5.
Reconnaissance visits and qualitative feedback: This questionnaire-based survey was complemented by
reconnaisance visits to various parts of the city, street corner meetings and interactions with opinion
leaders. The objective of this exercise was to capture insights into underlying issues and better field level
understanding of gaps and features of the sanitation infrastructure and service delivery in different parts
of the city and better validation of some of the findings emerging from the quanitative survey. The
reconnaisance visits covered all parts of the city with focus on low income pockets and public places.
Apart from a physical reconnaisance of facilities, street corner meetings and interactions with local
populace were also held to further capture local perceptions and feedback to complement findings from
the quantitaitive survey.
Review of slum survey findings: Survey findings from 70 selected slums conducted under the Kerala
Sustainable Urban Development Project (KSUDP) in Kochi were also reviewed.
Identification of pilot wards: Following discussions with CoC officials, a detailed survey was conducted in
Wards 26 and 62 to identify ward level issues to feed in to the main CSP and also to identify possible
proposals for ward level sanitation improvements in these two wards as pilot projects.
Preparation of Thematic maps: A series of thematic maps have been prepared and submitted along with
this report. These include maps on ward wise population density and projections, water supply, sewerage,
slums and visible open defecation spots.
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Access, Water supply, Waste-water management, Storm water management and SWM and outlines
targets and actions for each of them.
Section III Plan Support pillars is organised along four chapters (Chapters 8-11) and cover issues and
actions relating to Institutional Framework and Governance, Capacity Building, Awareness Generation and
Financial Sustainability respectively.
Section IV Action Plan summary organised as a single chapter (Chapter 12) summarises Sanitation Vision,
Goals and Actions of the CSP.
Annexures and Primary Survey Findings are presented as Volume II and III respectively. Slum Lists, Summaries
and Maps are presented as Volume IV and Thematic Maps are presented as Volume V. Ward Proposals for
project proposals in Election wards 26 and 62 are presented in Volume VI.
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As the economic and commercial capital of Kerala, Kochi is well connected by road (Refer Map 1 in Volume 5
for a location map of Kochi and Map 2 for connectivity), rail, water and air to the rest of the country. The
Cochin port is one of the major ports in the country and is well connected to countries in Southeast Asia as
well as the Persian Gulf. It is strategically located and is the closest among Indian ports to the International
East-West shipping routes. Kerala’s status as one of the top tourist destinations in the country makes Kochi,
dubbed as the “Gateway to Kerala”, one of the most visited cities in India.
The city consists of islands (Figure 2.2) and parts of the mainland are linked by water transport and bridges. It
is dissected by numerous canals and is a coastal settlement interspersed with backwater system. It is fringed
on the eastern side by laterite capped low hills from which a number of streams originate and drain into the
backwater system. Kochi is inseparably linked with the wetlands of Vembanad estuary. A number of major
rivers of central Kerala, namely Chalakkudypuzha, Periyar, Muvattupuzha, Meenachilar, Manimalayar, Pampa
and Achancoil and lesser rivers like Keecheri, Karuvannur and Puzhackal flow into the Vembanad Lake and the
surrounding geological formation. The Vembanad wetland system is the largest of its kind on the west coast.
(Refer Annex 6 for details of land-use)
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Within CoC, 7 wards had a population density of above 200 persons per hectare in 2001and are projected to
have the highest densities in the coming decades (refer Table 2.2 below. Also Map 4 in Volume 5 for a spatial
representation of ward-wise population and population projections).
Table 2.2: Wards with the highest population densities
Ward Area Population Density Population Density
Ward Number Ward Name
(in hectares) in 2001 Projected for 2041*
2 Kalavathy 38.23 215 253
3 Iraveli 17.39 522 612
4 Karipallam 39.62 271 318
5 Mattancherry 62.11 209 245
6 Kochangadi 31.71 253 297
26 Nazarath 32.88 217 255
28 Amaravathy 47.64 236 277
* Source: DPR, Sewerage, KSUDP & IMaCS Analysis assuming unchanged ward areas.
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Table 2.4: Official population projections: Cochin Corporation and Kochi urban agglomeration
Population in
2001 2005 2010* 2011 2021
Cochin Corporation 5,96,473 6,05,335 6,16,598 6,18,348 6,40,000
Kochi Urban Agglomeration 1,138,413 1,173,958 1,219,954 1,252,025 1,368,800
*Based on data from City Development Plan, Kochi
Despite the decreasing population growth in the Cochin Corporation area, in addition to the city’s natural
growth, migration into the city is expected to continue (An inward migration of 1.5 lakh families is expected
over the next 20 years) into the Urban Agglomeration. As per estimates of the Kochi’s City Development Plan
(Kochi CDP), Kochi is estimated to have a daily floating population of 2.5 lakh people. Population projections
for 2041 compiled from six different sources and computation by IMaCS are summarised in Table 2.5 below.
Table 2.5: Population projections: IMaCS analysis and other sources
Source 2001 2011 2021 2031 2041
ADB’s PPTA Study Report 5.96 6.30 6.60 6.83 -
RGI Study Report 5.96 6.47 6.82 7.07 7.24
JNU Study Report 5.96 6.50 6.86 7.04 7.00
Health Department Government of Kerala (GoK) I 5.96 6.33 6.45 6.35 6.02
Health Department GoK II 5.96 6.42 6.69 6.75 6.63
Health Department GoK III 5.96 6.42 6.74 6.88 6.90
IMaCS Analysis 5.96 6.40 6.69 7.11 7.58
Note: Sources as quoted in the KSUDP DPR: PPTA = Project Preparation Technical Assistance (ADB); RGI = Rajiv Gandhi
Institute; JNU = Jawaharlal Nehru University.
IMaCS analysis is based on an average of arithmetic, geometric and incremental growth rates based on the
estimates given in the KSUDP DPR for sewerage (see below).
Table 2.6: Details of IMaCS calculations
Year Arithmetic Geometrical Incremental Average
2001 5.96 5.96 5.96 5.96
2011 6.38 6.41 6.28 6.36
2021 6.79 6.89 6.70 6.80
2031 7.21 7.41 7.22 7.28
2041 7.62 7.97 7.86 7,82
Source: IMaCS analysis
The share of urban poor (Below Poverty Line or BPL) population in the CoC area and in the urban
agglomeration area is roughly the same, approximately 33-35% of the total population (Table 2.7). There are a
reported 283 slums within CoC area (See Map 5 in Volume 5, PDF Maps folder for a spatial distribution of the
number of slums in each ward). A complete list of all 283 slums in the CoC area and fact sheets of 70 select
slums are given in Volume 4 of the report. Slum Data; PDF and CAD Maps for these 70 slums are given in
Volume 5, Thematic Maps in separate folders.
Table 2.7: BPL population in Kochi
BPL as a %age of total
Area Population (2006) BPL population
population
Cochin Corporation 603,597 213,120 35
Kochi Urban Agglomeration 1,191,741 398,574 33
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1. Rapid population growth in both the CoC and urban agglomeration areas: Though urbanisation has
spread far beyond the CoC limits into neighbouring areas, long-term planning is constrained by the
presence of multiple municipal/panchayat bodies. While the CSP covers only the CoC areas, there is a
need to plan for sanitation infrastructure and services keeping in mind the growth in the urban
agglomeration as a whole.
2. High floating population: Since Kochi is a strong economic centre that receives a very high level of floating
population; sanitation planning should take into account this aspect.
3. Diversity in sanitation service levels and characteristics of slums: Even though there are 283 slums in
Kochi, there is significant diversity in the characteristics of sanitation services. While most are fully
equipped with individual toilets and sanitation facilities, there is inadequate service delivery in some slums
and open defecation is prevalent in some areas. Baseline information on sanitation at the level of
individual slums available with CoC is only for 70 slums (surveyed under the KSUDP programme)
inadequate and reflects the need for a detailed mapping at a slum level.
Net Water demand will be 88 MLD in 2016 and increase to 90 MLD in 2021 and 102 MLD in 2041. This
translate to a waste water generation (@ 80% of net water consumed) to be 70 MLD in 2016, increasing
to 82 MLD in 2041.
Solid Waste generation is likely to grow at a faster place due to a combination of population growth and
increase in per capita consumption to 325 TPD in 2016, 368 TPD in 2021 and 493 TPD in 2041.
The demand for Public Toilet blocks (@ 1 per 100 Households and 6 seats per toilet block) is expected to
be 217 in 2016 going up to 223 in 2041 while the demand for Community toilet blocks (@ 10% slum
population requiring shared access, 1 seat per 15 HH and 4 seats per toilet block) is expected to increase
from 87 in 2016 to 101 in 2041.
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3. Access to Toilets
3.1. Baseline status
Coverage: During the primary survey (refer Figure 3.1) nearly 95.5 % of respondents reported having individual
in-house toilet facilities (which is at almost the same level as reported during Census 2001). Thus, a significant
portion of households in Kochi has access to individual toilet facilities. About 1.4 % of the respondents
reported use of shared toilets, while 0.4% reported open defecation.
Figure 3.1: Primary survey findings: toilet facilities used by surveyed household
4.1% 0.4%
18%
82%
95.5%
Open defecation: Prevalence of open defecation is somewhat rare and was reported by 0.4 % of respondents
covered in the primary survey, and is practised in some areas including Vathuruthy, Ayyappankavu, parts of
Gandhinagar and Mattencherry (along the canals). In the case of Vathuruthy, open defecation takes place
along the railway track. Figure 3.2 provides a spatial overlay wards reporting open defecation spots (also
presented in Map 7). The prevalence of open defecation suggests the need for greater awareness generation
and creation of additional public/community toilet facilities.
2
Toilet access in slums: Nearly 51 % of the Most Vulnerable, 61 % of the Just Vulnerable and 74 % of the Upper
Crust of the Poor have their own toilets. 25 % of the poor depend on public toilets and 3 % of poor resort to
open defecation. A slum survey in 70 selected slums carried out by KSUDP indicates that 3.7 % of the slum
households have a flush type toilet, 57.4 % with toilet connected to septic tanks, 25.1 % households using a
common toilet facility, and 13% with pit toilets or other types (which presumably includes open defecation).
Other findings from the survey included the following:
o Current sanitation facilities are either poor or non-existent in below-poverty-line (BPL) and slum
areas. Even in areas where slum rehabilitation has taken place, such as Mundamveli, toilet
infrastructure has not been adequately provided.
o In some slum areas, community toilets have been built. Roughly ten households share one community
toilet, which is usually a pit latrine. However, since these slum areas are typically plagued by
inadequate water supply, it is difficult to manage the toilets and keep them clean
o Rag pickers and manually scavenging occurs, particularly in the low-income pockets of Matencherry
o Although the CoC has constructed 8 community toilets in the area, only 5 of these toilets are currently
operational. Of these, three have been recently damaged due to a disagreement between a few of
the households. The remaining two toilets are used by a few of residents in the area.
o In several cases, outlets of toilets have been directly connected to a waterway or canal.
2
Kerala Sustainable Urban Development Project (2005) City Report Kochi Volume 2, PPTA 4106 – IND, Kochi.
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Use and condition of public toilets: There are currently a reported 6 public toilet complexes set up by the
GCDA, and managed by Sulabh International under contract, and another 9 Public Toilets set up by the CoC,
under contract management by private entrepreneurs (although some toilets do not appear to be within the
CoC area). Refer Map 8 for the location of public toilet facilities. Lack of adequate water supply in public
restrooms has made it difficult to keep Public Toilets clean. Even Toilets in public institutions such as Kochi’s
General Hospital, are poorly maintained. Most slums have community toilets, but many are poorly maintained.
The primary survey revealed a similar picture: Of the 33 % that reported having used a public toilet, nearly 82
% considered facilities to be poorly maintained (Figure 3.1).
Willingness to pay: Around 80 % of those surveyed were willing to pay for public toilets: 47 % were prepared
to pay Re. 1 and 49 % were willing to pay between Rs. 1 – 3 per use, 3 % were willing to pay more than Rs. 3
per use. This possibly indicates the need for shared facilities in areas where access is constrained.
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The key issues with respect to access to toilets within CoC are summarised below:
1. Open defecation while rare is still prevalent in select pockets of the city. Open defecation still prevalent
in some pockets as shown spatially in Figure 3.2. Select locations include Wellington Island (along Railway
line), Mattenchery (along canals), Fort Kochi (Fishermen colony) and some parts of Gandhinagar.
2. An integrated approach to assess, plan, maintain and monitoring provision of shared toilet access is
missing. There is a lack of a city level plan for toilet construction and access provision. Public toilet access
is through one-off efforts without adequate assessment of city level demand considerations.
3. Accountability for public toilets and community toilets is diffused across multiple agencies. Sanitation is
under the Health Department of the CoC. However, the Engineering Department is responsible for repairs
and maintenance, leading to diffused accountability. Also, public facilities are established by CoC, GCDA
and other agencies. Often the facilities and service provision are outsourced without adequate contractual
safeguards and formal oversight mechanisms. Without clear standards, critical considerations such as
gender sensitivity, 24x7 access, water availability etc., often get ignored.
4. Financing for Toilets is based on funding availability; financing for maintenance is not earmarked. There
is a need to recognise the financing gap, particularly with respect to O&M. Provision of toilets is handled
under multiple schemes and expenditure reporting on toilet construction and O&M needs improvement.
Box 3.1 Shared Toilet Access; Lessons and insights from recent research
WSUP. Feb 2011. When are communal or public toilets an appropriate option.
This paper argues that while individual toilets are preferable, communal or public toilets may be appropriate medium-term solution notably
in high-density slums with a high proportion of tenants and/or frequent flooding.
• The Sulabh organisation runs Pay-per-use toilets throughout India. Reports suggest that these facilities are profitable
in public locations, but tend to be loss-making in residential areas and are often inadequately maintained.
• In some African countries (e.g. Senegal), public toilets are not widely used while in others (e.g. Kenya), public toilets,
often poorly maintained, are seen in poor settlements. In Ghana, pay-per-use model for residential use is widespread.
• Communal toilets are seen in low-income communities of African/Asian cities. The SPARC model, implemented in
Pune and Mumbai are managed by NGOs. A moderate per-household monthly fee is collected.
• They are dirty and unhygienic because of poor design, construction, maintenance and insufficient funds.
• They may be unsafe, particularly women/children at night, when located in dark places with poor lighting.
• The distance to a communal/public toilet could be dissuasive; very often they lack facilities for women and children.
• User charges may be dissuasive, because people can’t pay or are unwilling to pay.
• They lack privacy and may be embarrassing for some users: they sometimes lack even basic facilities like water.
• Public toilets may be taken over by street gangs or political factions and run for excessive profit with little regard to
affordability, services or reinvestment.
Key conclusions
• Communal or public toilets may be an appropriate solution in low-income high density districts, where a) there is high
proportion of tenants, b) in areas of water-logging and c) widespread open defecation and/or foul wastewater.
• Communal or public toilets should only be introduced after exploration of the social and economic context.
• People will generally prefer communal toilets closer to home over public toilets located far-off.
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• Communal or public toilets are only acceptable if they provide effective service for women and children.
• Communal toilets charging a monthly per household fee will be preferred by users than pay-per-use public toilets.
Water and Sanitation Program. Dec 2007. Public Toilets in Urban India; Doing Business differently.
This field note looks at both the achievements and challenges in the use of these contracts for public toilets in New Delhi and presented
some significant lessons for meeting the sanitation needs of the city as a whole.
The New Delhi Municipal Corporation (NDMC) proposed to engage private operators to construct new toilet blocks using
private financing and operate them for a fixed period. The right to use walls as advertising space was provided to enable
operator offset part of capital costs. The proposal allowed private financing and an incentive for maintenance.
Though the increased revenue was a bonus for NDMC in the initial years, there was a marked deterioration in performance
and services subsequently. In the absence of appropriate monitoring, profits were derived from advertising revenue, and
with insufficient revenue to cover operating costs there was little incentive to spend on cleaning and maintenance. The
consequences were disastrous; while some opted to minimize open hours, closing became a profitable option for others.
The Delhi experience illustrates both the benefits and risks of private sector participation and provides valuable lessons on:
Importance of financial incentives: Advertising provides a cost recovery avenue, but needs to be judiciously exploited.
The need for monitoring and accountability mechanisms. Whatever financial incentives are in place, monitoring and
enforcement of contract conditions is critical, including termination for non-performance.
The need to prioritize service delivery. Excluding technical criteria from bidding process can result in contracts being
awarded to agencies without either the capacity or motivation to fulfil service delivery.
Advertising rights potential does make toilet complexes profitable, so that maintenance is commercially viable. The
challenge is to develop contracts so that the public service is delivered to an acceptable standard. The following could help:
• Assess Local Demand before developing New Toilet Blocks. Where demand is high, toilets can be profitable without
advertising revenue. Demand is a prerequisite for contracts based on user charges.
• Revitalize Monitoring and Strengthen Accountability. Media interest, municipal accountability, consumer feedback
are possible solutions. Service parameters should be defined/monitored with enforcement of punitive measures.
• Increase the Lease Period. Longer lease periods could enable longer term cost recovery plans with proper attention to
maintenance when backed by contractually enforcing penalties for poor performance.
• Bundle Contracts. Bundling toilets into single contract would simplify administration and reduce monitoring burden.
WSP. April 2004. From Hazard to Convenience: Towards Better Management of Public Toilets in the City of Nairobi.
This field note looks at private sector participation in public toilet management in Nairobi and possible benefits include efficiency gains,
improved quality of service, and the ability to raise funds for refurbishment.
In 2001 the Nairobi City Council (NCC) approached WSP for technical support to develop guidelines to involve private
service providers in managing Public Toilets. The study identified the following deterrents to public toilet use:
• Insecurity. Mugging, molestation, theft, and demands for money constitute a major concern.
• Inadequate lighting. Most PTs are poorly lit, making it both difficult and unsafe to use them.
• Poor accessibility. The accessibility of some toilets is poor, with approach paths in substandard condition.
• Lack of privacy. Most PTs have broken doors and windows and so lack privacy.
• Dirty and unhygienic environment. Human waste and excreta around many toilets, renders them unhygienic to use.
The main issues to be addressed by any new management option were identified as:
• Changing the role of NCC in direct management to one of policy formulation and oversight.
• Retaining ownership by NCC (asset holding) while causing minimum disruption to the existing NCC structure.
• Meeting costs of the initial repairs /rehabilitation and subsequent O&M
• Ensuring competitive practices in allocating management responsibilities and avoiding cartel control.
Three management models were considered: a) Private management contracts of PTs refurbished by NCC, b) Private
company owned by NCC and c) Concession contracts. Eventually two options were selected: (1) a full concession for a
private sector company inside the CBD and (2) a community-based contract in markets and residential areas.
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3.4.2. Goals
Table 3.2 summarises service delivery targets to achieve the above Vision.
Table 3.2 Access to toilets Supply: Short Medium and Long Term targets
Timeframe To Achieve SLB Norms
Parameter Unit Norm Baseline
Short Medium Long
Open Defecation and Urination
% Of population practising OD * % 0% 0.4% √
No. Of open urination spots * Nos. 0 ~ 10 √
No. Of open defecation spots * Nos. 0 ~ 10 √
Toilet Coverage
Access to Public Conveniences (PC)* HH / PC 100 ~ 500 √
Access to Community Toilets (CT) * Slum HH / CT 15 N.A √
Source: IMaCS analysis. Discussions with CoC officials. *These parameters are not part of MoUD SLB indicators and have
been introduced to complement the SLB indicators.
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3.5. Recommendations
Specific actions in this regard are summarised in Table 3.4 and detailed below.
Table 3.4 Access to toilets Supply: Recommended actions
TIMEFRAME
ACTIONS BY
S M L
1. Prepare and Implement a city wide Toilet Development/Rehabilitation Plan CoC √
i. Prepare DPR for location selection, configuration and sizing of Public and Community Toilets CoC √
ii. Implement Community Toilets, starting with identified slums / wards with OD prevalence CoC √
iii. Implement Public Toilets starting with commercial areas having high floating population CoC √
iv. Progressively increase Public Toilet coverage to provide city wide access CoC √ √ √
v. Enable facilities for the treatment of wastewater or sludge from public toilets CoC √
2. Implement a comprehensive inspection/monitoring protocol for Toilet monitoring CoC √
i. Render existing toilets usable through designated accountability among sanitation officials CoC √
ii. Engage local stakeholders in maintenance, monitoring and oversight of shared toilets CoC √
iii. Undertake periodic Third Party Evaluation Audit of facilities and disseminate findings CoC/GoK √
3. Strengthen statutory basis and capacity through formulation of bye-laws and guidelines CoC / GoK √
i. Incorporate Toilet Sizing and specifications as part of Building regulations. CoC / GoK √
ii. Enforce fines for open defecation and urination as per amended Municipal bye-laws CoC / GoK √
iii. Prepare a Guidance Manual on development and maintenance of public toilets CoC / GoK √
4. Drive behaviour change through awareness campaigns and branding initiatives CoC √
i. Initiate a Slum sanitation campaign to eliminate open defecation CoC √
ii. Initiate a Trader-support campaign in commercial areas to eliminate open urination CoC √
iii. Leverage the MoUD –GIZ School Sanitation initiative to initiate a school level campaign. CoC √
iv. Standardize branding (logos, painting, signage) for Public Toilets and Community Toilets CoC √
5. Initiate actions to improving financial sustainability CoC √
i. Prepare a dedicated Toilet Budget annually CoC √
ii. Explore appropriate outsourcing models for Public Toilets; Adopt contractual safeguards
CoC √
while outsourcing toilet development and maintenance.
iii. Encourage adoption of toilets through Corporate Social Responsibility initiatives CoC √
1. Prepare and implement a comprehensive city wide Toilet Development and Rehabilitation Plan. CoC
should initiate implementation of a City-wide Toilet Development and Rehabilitation Plan with the
objective to eliminate open defecation and open urination within a time frame of three years.
a. CoC should prepare a comprehensive DPR to i) validate demand for Public and Community Toilet
access, ii) identify locations for setting up Public and Community Toilets, iii) develop standardized
designs and configurations for setting up toilets (including infrastructure and facilities required)
depending on space available and iv) Estimate Capital and O&M costs for implementing this plan. A
possible Terms of Reference for preparation of this DPR is provided below.
Box 3.2 Suggested Terms of Reference for Toilet Development and Rehabilitation Plan:
While preparing this DPR, it may be useful for CoC to make a distinction between Public Toilets and Community Toilets
during planning and execution. Community Toilets are typically required to tackle open defecation in slums / low-income
pockets. Community toilets complexes typically require facilities for bathing, particularly in dense slums and separate areas
for washing clothes. They are primarily required in view of the land limitations and nature of building layouts in low-income
areas, provision of individual toilets does not appear feasible in these areas. Public Toilets on the other hand are required
to address the needs of floating population. They are required to be provisioned on priority in commercial areas and
progressively in all parts of the city. These need to be typically designed to have a higher proportion of urinals and wash
basins, given that these tend to be used primarily for urination.
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• Conduct a slum mapping exercise to validate Visible Open Defecation spots within the city
• From the findings of the Multi-purpose household sanitation survey, comprehensively map vulnerable clusters with
low individual toilet access and along with existing community toilet locations
• In vulnerable pockets with existing community toilets, undertake and report an inventory of Community toilets
covering, asset condition, facilities, gaps, availability of designated care-taker, current and potential level of usage.
• In vulnerable pockets without existing community toilets, identify potential locations and confirm land availability.
• Develop modular toilet designs along three or four types; Single Male and Female Toilet; Small, Medium and Large
Toilet complex with bathing, urinal, wash basin and toilet facilities factoring gender sensitivity and needs of children.
Identify demand for facilities for bathing, particularly in dense slums and separate areas for washing clothes.
• Comprehensively map a list of locations for a) developing new toilets with appropriate size and design and b)
rehabilitation of existing toilets with added features and improvement in asset condition and facilities.
• Recommend appropriate measures to handle, treat and dispose waste-water safely at each of the locations
• Identify user group organisations such as resident associations , slum associations, community groups or NGOs that
could potentially handle local oversight and monitoring
b. This DPR should be followed with a phased investment program for implementation. Priority of
implementation could be as suggested below:
i. As an immediate step, CoC should enable facilities for treatment of wastewater or sludge in all existing
public toilets.
ii. Initial focus of new development should be to provide Community Toilets in slums, especially
those wards/locations with high OD prevalence. Since the focus of NUSP is to eliminate open
defecation, slum locations having high OD prevalence and low availability of individual toilets are
high priority. Importantly, Infrastructure upgradation and slum development /re-location
proposed as part of other slum development initiatives, if any should be factored in this regard.
iii. This should be complemented by provision of Public Toilets in commercial areas with high
floating population. CoC is already in the process of evaluating proposals for implementing Public
Toilets in about 10-15 high floating point locations in the city.
iv. In the medium to long term, CoC should progressively expand Public Toilet facilities in all parts
of the city to meet a pre-set standard, say 1 Public Toilet every 500 m of arterial roads and roads
in commercial areas.
v. CoC should explore provision of Mobile toilets in slums that could potentially be re-located or
proposed for comprehensive rehabilitation / upgradation as part of slum development programs.
They could also be considered in high floating population locations during peak tourist seasons to
complement Public Toilets.
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2. COC should establish a comprehensive inspection/monitoring protocol covering the following actions.
a. Render existing Toilets usable by designating sanitation officials to be responsible for specific
Public/Community toilets. COC could consider initiating a periodic inspection protocol for existing
Public toilets. An Illustrative checklist for carrying inspection is provided in the format in Table 3.5
Table 3.5 Illustrative checklist for toilet inspection and rectification
Location
Date and time of inspection
Checks Compliance vis-à-vis standard
Smell
Floor
Wall
Dustbin
Mirror
Basin
Soap
Water Availability
Taps
Urinals
Toilet seats
Qualitative Remarks and Complaints
Actions to be taken by COC / Service Provider along with Time frame for rectification
b. Designated sanitation inspectors should be given the responsibility for inspection at a fixed frequency
say, once every week to start with. The frequency of inspection could be reduced progressively as the
maintenance process is streamlined. The maintenance should cover provision of the following:
i. Designated caretaker and ensuring round-the-clock access
ii. Water availability: Where piped water supply is not available, COC should providing connection
from existing power bore to a storage tank to ensure continuous water availability.
iii. Lighting, signage and doors for privacy and safety: Rectify and provide lighting and proper doors
/ ventilation along with padlocks. Provide signage at and around the toilet.
iv. Consumables for users and for cleaning the toilets.
v. Waste-water disposal: All toilets should be connected to sewerage network or onsite facilities.
c. Engage local stakeholders in maintenance, monitoring and oversight of shared toilets. COC should
involve local stakeholders in monitoring and oversight. Operationalization of ward committees and
formalized local oversight for sanitation to these Ward Committees can help in this regard.
d. Undertake periodic Third Party Evaluation Audit of facilities and disseminate findings. An annual
Third Party Evaluation Audit can provide independent inputs on status of toilets and could review
service levels, asset condition and citizen satisfaction. The findings when disseminated can help
improve public confidence. Refer Box 3.5 for Terms of Reference for such an audit.
Box 3.5 Suggested coverage of the Terms of Reference for Third Party Evaluation Audit:
Review and report findings with respect to functioning of Shared Toilet facilities with respect to the following
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3. COC should in consultation with GoK, create and enforce statutory provisions / guidance to support
toilet management including the following:
a. Incorporate Toilet Sizing and specifications as part of Building regulations. Several countries have
specific regulation for toilets in their building code. Refer box 3.4.
b. Enforce fines for open defecation and urination in public places. CoC should explicitly communicate
citizens’ duties to maintain cleanliness (including prohibition of littering, open defecation and open
urination) and should enforce levy of fines for open defecation.
c. Incorporate toilet specifications as part of slum re-development and re-location programs. Planning
of toilets should be done in synchrony with any slum re-development/relocation programs. If a slum
is to be re-located, explore use of mobile toilets in existing slum in the interim. If an in-situ re-
development is planned, plans for toilet access should be incorporated in the design.
d. Prepare a Guidance Manual on design, development and maintenance of shared public toilet
facilities. COC in consultation with GoK and MOUD should consider bring out a Guidance Manual,
which could spell out standards and guidance that could cover:
i. Norms and Modular Designs for development of Public / Community Toilets with particular focus
on gender and children sensitivity, 24x7 safe and secure access.
ii. Minimum Technical standards and infrastructure to be made available at the toilets.
iii. Governance and monitoring process including local participation in oversight.
iv. Revenue and outsourcing models along with bid documents and term sheets for contracting
Box 3.4 Building regulation for toilet provision in commercial areas: select examples from other countries
• Accessibility: Under the California Health and Safety Code, any local or state-run building that's open to the public
has to maintain at least one restroom for each gender, and the toilet must be open for use free of charge. Publicly and
private facilities open to public must be equipped with temporary or permanent restrooms to meet peak demand.
• Cleanliness: All public restrooms are required to be regularly maintained and reasonably sanitary. Members of the
public can't be exposed to any unreasonable danger due to unsanitary conditions in public restrooms, and local
building codes govern what is considered an unreasonable danger.
• Commercial Buildings: The number of toilets required in a commercial building depends upon how many employees
work in the building. In non-industrial office buildings, public buildings, and similar establishments, only one toilet is
required if the building has between one and 15 workers. Two toilets are mandatory for buildings with 16 to 35
workers, and buildings with 36 to 90 employees are required to house a minimum of three toilets. In buildings used
for industrial purposes, such as factories and warehouses, one toilet is required for every 10 employees, up to 100.
For industrial buildings that house over 100 employees, one additional toilet is required for every 15 employees.
The relevant legislation is the Workplace (Health, Safety and Welfare) Regulations 1992. Regulation 20, Sanitary
conveniences, states: Suitable and sufficient sanitary conveniences shall be provided at readily accessible places. Without
prejudice to the generality of paragraph (1), sanitary conveniences shall not be suitable unless the rooms containing them
are adequately ventilated and lit; they and the rooms containing them are kept in a clean and orderly condition; and
separate rooms containing conveniences are provided for men and women except where and so far as each convenience is
in a separate room the door of which is capable of being secured from inside.
1-5 1/1
6-25 2/2
26-50 3/3
51-75 4/4
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76-100 5/5
4. COC should initiate awareness campaigns to facilitate awareness, usage and ownership of shared
community toilet facilities at the levels of slums, trader communities and schools.
a. The Community Toilet Development and Rehabilitation program should be backed by an intensive
Slum level sanitation campaign to facilitate awareness, usage and ownership. The focus of the
awareness campaign in vulnerable pockets should be on a) Health Hazards of Open Defecation and
social mobilisation/peer communication b) Use of toilet facilities and c) Good sanitation practices
including washing hands, keeping toilets clean and d) Community role in monitoring and oversight.
b. An awareness campaign with support of traders could help limit open urination in commercial areas.
c. A campaign targeted at primary schools students backed by provision of good sanitation facilities at
schools should be initiated in coordination with the school sanitation initiative of MoUD/GIZ.
d. COC (in collaboration with other agencies) should develop a standardised visual themes (logos,
painting, signage) for Public Toilets and Community Toilets in the city as a means of effective
branding and ease of spotting of toilets for users.
5. Initiate the following actions relating to improving financial sustainability of toilet access provision
a. Prepare a dedicated Toilet Budget annually. CoC should prepare and earmark dedicated budget for
development and maintenance of toilets annually and report expenditure on toilets separately.
b. Adopt appropriate outsourcing models and endeavour to achieve O&M Cost recovery. CoC should
actively adopt outsourcing approaches. In general, Public Toilets are amenable to pay per use
approaches and advertising streams could potentially enable full cost recovery for Public Toilets in
high density traffic locations. If managed well, CoC should be able to recover the O&M cost of
provision of all shared toilets (public + community toilets) and recovery part of its capital costs.
i. Pay and use public toilets in high density commercial areas have potential to recover full cost if
advertising potential is leveraged. CoC could consider unbundling advertising rights and toilet
maintenance as separate contracts. This could enable CoC to maximize its revenue potential.
ii. Community toilets will require subsidization but could recover O&M cost. Since a pay-per-use
model could deter usage, a monthly flat fee through issue of toilet use cards may be a better
alternative for Community Toilets. COC could consider using Self Help Groups or delegate
maintenance to local community while providing oversight to ensure asset upkeep and repairs.
c. Adopt contractual safeguards while outsourcing toilet development and maintenance. As stressed
under the section on insights and lessons from experiences elsewhere in Box 4.1, it is critical to
ensure contractual safeguards in developing and maintaining toilets particularly in PPP and
maintenance contracts. Possible procurement and contractual safeguards are suggested below:
i. Appropriate shortlisting criteria to ensure well contested bids among reputed operators
ii. Well defined service levels to ensure communication of expectations on service delivery
iii. Meeting obligations of COC including land, water supply and waste-water infrastructure
iv. Clearly defined monitoring mechanisms involving three-way monitoring covering COC,
community and independent audit as explained earlier
v. Punitive measures including right to terminate in case of non-compliance.
d. Encourage adoption of public and community toilets on CSR to reduce financial burden. To further
reduce burden on the Municipal finances, COC could encourage adoption of toilet complexes by
reputed entrepreneurs and business houses as a Corporate Social Responsibility (CSR) initiative. COC
could coordinate with agencies like CREDAI Kochi, which have supported such initiatives. Reputed
Institutions with a strong CSR focus may not allow their reputation to be tarnished by poor
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maintenance and would generally tend to ensure a strict oversight and may therefore pave the way
for more sustained toilet upkeep and maintenance.
4. Water supply
4.1. Baseline status
4.1.1. Climate, rainfall and groundwater
Climate and rainfall: Ernakulam district has wet monsoon type of climate. The district experiences heavy
rainfall during southwest monsoon season followed by northeast monsoon, while during other months rainfall
is considerably lower. Nearly 100 years of data (1901 – 1999) show that the annual rainfall averages 3359 mm
and ranges from 3233 to 3456 mm at different places of the district. The district is drained by the Periyar River
and its tributaries on the north and Muvattupuzha River on the south.
Groundwater: The depth to water level in the district shows wide variation on account of the physiographical
units in which the wells are located and undulating terrain in the mid land. Water level is shallower in western
coastal part (less than 2 mbgl in general) while in the eastern part of the district it follows the riverine alluvial
belt of Periyar River. In the midland region, the water table is between 5 and 10 mbgl and at isolated pockets
it is found at deeper levels (more than 10 m). In the coastal belt, the water level is very shallow and less than 2
mbgl throughout. Analysis of hydrographs show that some areas show a rising trend of water level (shallow
wells of 2 mbgl in the coastal belt) while some others show declining trends.
Climate, rainfall, and hydrology are described in detail in Annex 8.
4.1.2. Infrastructure
Sources and availability
The primary source of drinking water is the Periyar River, which is located approximately 20 km northeast of
CoC. A brief history of water supply to the Kochi area is provided in Table 4.1 below.
Table 4.1: Brief history of surface water supply to Kochi
Year Capacity Treatment Plant Source
1914 Chowara Water Works
1965 + 48 MLD
1969 + 72 MLD Periyar River
Aluva Head Works
1993 + 70 MLD
2002 + 35 MLD
Source: City Development Plan, Kochi
Treatment facilities
Currently, the water treatment plant, called the Aluva Head Works, which was set up in 2002 and services the
following areas: CoC, four adjoining municipalities (Paravur, Aluva, Kalamassery and Thrippunithura) and 27
Panchayats. The installed capacity of the Aluva plant is 225 MLD, and it is the sole source of drinking water
supply point to most parts of GCDA area and adjoining Panchayats. KWA estimates indicate that the supply to
the CoC area is currently approximately 170 MLD; other unofficial estimates suggest it may be around 140
MLD.
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GIZ-ASEM Corporation of Cochin
distribution mains from the Aluva Water Treatment Plant and a total water supply distribution network of
approximately 1,500 km long (Figure 4.1).
The first main 900 mm CI pipe supplies approximately 48 MLD of water to Perumannur sump at Ernakulam
and boosted into the town distribution system, covering areas such as Cochin Port, Naval Base, Cochin
Shipyard and Western part of Kochi.
The second main is a 1050 mm diameter pipeline that conveys water to Ernakulam town and several
tappings are provided to convey water to various local bodies and bulk consumers.
Figure 4.1: Schematic of the existing water supply system
Source: KWA; based on Kerala Sustainable Urban Development Project (PPTA 4106 – IND), Technical Analysis, Final Report
Volume 6, May 2005
The third main, a 1200 mm pipeline, also conveys water to the CoC, and is the other main supply water to
Municipality/Panchayat populations located in close proximity to the head works. Although a pipe was laid by
HUDCO (with World Bank assistance) to augment water supply of 105 MLD in West Kochi, existing railroads
caused an obstruction, and the pipes could not be extended past Thammanam. Thus the current service levels
of water supply in West Kochi, especially in areas like Fort Kochi and Mattancherry is poor. The water supply
network in the CoC is between 10 and 25 years old as per the Service Level Benchmarking (SLB) exercise of the
3
MoUD.
3
At a national workshop on 6 February 2009, the Ministry of Urban Development (MoUD) launched a Service Level Benchmarking (SLB)
pilot project covering 27 cities spread across 14 states and one Union Territory, including 16 JNNURM cities (NIUA, 2010). Service levels for
various parameters are calculated based on the methodology given in MoUD (2009).
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GIZ-ASEM Corporation of Cochin
20%
45%
35%
Per capita supply: After taking into account losses in processing and distribution of water (including water lost
due to leakages in pipes, storage reservoirs), present per capita water availability to the Ernakulam region is
estimated to be approximately 90 LPCD. Parts of West Kochi, such as the Mattancherry area suffers from low
water supply, estimated to be approximately 25-30 LPCD. As a result, many households in the West Kochi area
rely on private tankers for additional supply of water. The sources for these tankers are from the Periyar River
at Aluva area and near around. The CoC normally makes 1200 trips/month with each tanker making 3-4
trips/day and depends upon the service area.
Supply hours and Sufficiency: The duration of water supply across the Corporation area is intermittent and
ranges from half an hour per day to eight hours per day. These observations are validated by the primary
survey, with a majority (49%) reporting 2-4 hours per day, 34% reporting more than 8 hours per day, 12%
reporting 4-8 hours per day and 5%, less than 2 hours per day (Figure 4.3). More than a third of the
respondents indicated that the water supply quantity is insufficient.
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6%
8%
32%
39%
34% 68%
13%
< 2 hours >8 hours 2-4 hours 4-8 hours all day Insufficient Sufficient
In connections with faulty meters, water tariff is calculated based on average water consumption in previous
three months. For non-domestic consumers having more than 10KL, meter readings are taken once a month,
while non-domestic consumers having a consumption of less than 10KL, no fixed meter reading cycle exists. In
cases, where meters are not working, an alternative of estimating the actual consumption by adopting certain
per capita consumption norms are carried out. There are about 650 consumer personal ledgers (CPL) for about
65,000 consumers. In addition, a large proportion of the meters (50 to 70%) are not working, largely due to the
poor water pressure and intermittent supply. A systematic approach and mechanisms to maintain and replace
faulty meters is missing. KWA proposes to increase existing tariffs as given below to cover O&M costs and
increase financial viability.
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Domestic
Minimum tariff 38
0-10 KL 3.50 per KL
11-30 KL 6.00 per KL
31-50 KL 10.00 per KL
Above 50 KL 15.00 per KL
Non-Domestic
Minimum tariff 203.00
0-50 KL 15.00 per KL
Above 50 KL 20.00 per KL
Industrial Consumers
Minimum tariff 503.00
All consumers 20.00 per KL
Public Fountains, etc. 3100.00 per year
Source: KWA, Summary of the JNNURM Water Supply Scheme to Kochi City, Part 1
4
Non-revenue water: KSUDP reports suggest that the estimated loss of water in the distribution system on
account of leakage is to the tune of 30 % but when taking into account other losses like process, transmission,
unauthorized connections, the estimated unaccounted for water (UFW) within CoC could be greater than 60
%. A detailed UFW analysis carried out by KSUDP is presented in Annex 9.
Water quality: Findings on surface and ground water quality, as well as consumer perceptions are presented
separately below.
5
Surface Water: A recent report suggests physiochemical water quality parameters in River Periyar exceed
the desirable limits of the downstream stations during all the seasons.
Table 4.5: Water quality findings: Industrial stretches of Periyar River
Parameters Minimum Maximum
1 Temperature 28.5 31.7
2 pH 3.59 7.4
3 EC (micro siemens/cm) 86.1 28900
4 DO(mg/l) 4 6.06
5 BOD(mg/l) 0.5 2.33
6 Colour (Hazen) 8.4 15.8
7 Turbidity (NTU) 2.3 22
8 TDS, (mg/l) 55.36 18582.7
9 Total Alkalinity(mg/l) 400 800
10 Total Hardness(mg/l) 400 4000
11 Calcium Hardness (mg/l) 200 800
12 Calcium (mg/l) 80 320
13 Magnesium (mg/l) 0 780.8
14 Sodium (mg/l) 4.4 15306
15 Potassium (mg/l) 0.7 335
16 Iron (mg/l) 0.02 0.18
17 Chloride( mg/I) 237.05 10777.5
18 Sulphate(mg/l) 3.68 282.4
19 Nitrate-N,(mg/l) 0.02 2.48
20 Salinity(ppt) ND 17.6
21 Phosphate-P,(mg/l) ND 0.05
4
Kerala Sustainable Urban Development Project (PPTA 4106 – IND) Final Report Volume 2 - City Report Kochi, May 2005
5
Source: KSCST, Environmental Monitoring Programme on Water Quality, Chapter 2, Periyar River Basin, 2009
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Bacteriological analysis carried in the same study clearly indicates the microbial contamination of the river.
6
Ground Water: Surveys of groundwater carried out by the CPCB in 2008 show the following.
o The pH values for most samples are well within the limits prescribed by BIS (1991) and WHO (1996)
for various uses of water including drinking and other domestic supplies.
o About 20% of samples had total dissolved solids (TDS) above the desirable limit but within the
maximum permissible limit of 2000 mg/L during both pre- and post-monsoon seasons.
o About 12% of the samples had calcium and magnesium (along with their carbonates, sulphates and
chlorides) above the desirable limit of 300 mg/L, but within the permissible limit of 600 mg/L during
both the pre- and post-monsoon seasons
o More than 90% of the samples fall within the desirable limit of chloride, i.e., 250 mg/L, during both
pre- and post-monsoon season, while all samples were within the desirable limits for sulphate.
o About 92% of the samples fall within the desirable limit of 45 mg/L while only 4% of samples exceed
the maximum permissible limit of 100 mg/L. Phosphate levels were generally low at all the locations.
o No sample exceeds the maximum permissible limit of 1.5 for fluoride.
o The bacteriological analysis indicates contamination at few sites.
o Heavy Metals concentrations are largely within permissible limits.
o Out of 25 samples analysed for pesticides and two pesticides (Aldrin, and DDE) have been detected at
few locations, due to their use in agricultural activities and for vector control programmes. Although
the concentrations of these pesticides were lower in the post-monsoon season as compared to pre-
monsoon season, the concentration of Aldrin exceeded the permissible limit prescribed for drinking
water at one location in the pre-monsoon season.
At Treatment Plant Level: At the Aluva WTP level, only turbidity and pH is analysed and recorded at the
raw water intake and treated water. Annex 10 provides a sample of quality data on Turbidity and pH.
At Pumping Station Level: Examples of water quality monitoring data at a distribution pumping station
level is given in Annex 10.
Perceptions of Water Quality: About 36% of respondents of the household-level primary survey felt that
the water quality was good and about 22% felt that quality was average (refer Figure 4.4). About 42% of
respondents felt that water quality was occasionally or always poor. Since a majority (64%) consider water
quality average or poor, this perception needs to be rectified by visible and tangible actions on priority.
Figure 4.4 Primary survey findings: perceptions on water quality
36%
41%
22% 1%
Service levels in slums: The primary survey revealed that all the slums in CoC are equipped with a water supply
network and thus seem to have a reasonable good access to water supply relative to the rest of the city.
However, while many of the slum dwellings are pucca structures, most residents often do not have direct
access to drinking water supply at the household level. Often, several households, usually ten or more, share
6
Status of Groundwater Quality in India -Part-Ii, Groundwater Quality Series: GWQS/ 10/2007-2008, CPCB, April, 2008
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one water pipe and a community toilet. In areas like West Kochi, where the average water supply per capita
7
per day is as low as 25 lpcd , piped water is only available twice a day, for an hour each. The water pressure is
often very low, and access requires the use of a hand pump. Moreover, the water quality is poor. Primary field
surveys revealed that in areas such as Mattancherry, residents of the slums reported the presence of worms
and maggots in the water, rendering it unsafe to drink without boiling. The slum survey carried out by KSUDP
for 70 select slums suggests that public water taps are available in 93 % of the slum settlements, and that five
out of the 70 slums do not have any public water taps at all. KSUDP’s findings also suggest that in only 89% of
cases is treated water supplied. The frequency ranges from daily supply in 80% of slums, alternate days’ supply
in 12%, and occasional supply in 8% of slums.
At present, there appears to be no integrated master plan for water supply covering the entire value chain
from source to customer tap for the CoC and the extended urban agglomeration including the neighbouring
municipalities and panchayat areas. This is critical to ensure that new initiatives or augmenting sources and
water availability take into account demand in extended areas and equitable service across the urban
agglomeration in medium to long term.
7
Kerala Sustainable Urban Development Project (PPTA 4106 – IND) Final Report Volume 2 - City Report Kochi, May 2005
City Sanitation Plan for Kochi - Draft Report Volume 1, Main Report 31
GIZ-ASEM Corporation of Cochin
The key issues with respect to water supply within CoC/KWA are summarised below:
1. Service delivery in Water Supply within CoC falls significantly short of SLB norms. There is wide variation
in supply duration and frequency with very low pressure and duration of supply in parts of the CoC area, in
the Fort Kochi area in particular. Reconnaissance indicates use of local hand pumps to suck out water from
the piped networks due to low pressure. There is inadequate information baseline on NRW levels and
water supply is based on an intermittent supply system and not continuous supply. Even though KWA has
implemented universal metering, lack of periodic recording and faulty meters (estimated at 40%)
constrains effective volumetric tariffs.
2. Information discrepancies and inadequacies severely constrain baseline analysis and decision-making.
Very poor information base/availability on most aspects of water supply, service provision. It is also critical
to capture and analyse ring-fenced financial and operating information relating to water supply to
evaluate costs of supply and to rationalise user charges to meet the target of 100% O&M cost recovery.
3. Lack of an updated Master Plan for water supply constrains planning and coordination across multiple
project development initiatives. Since KWA, a state agency is managing the water supply function, there
is need for a greater clarity on the road map for transfer of the water supply function to the ULB as
required under JNNURM reform commitment. While the MoU between CoC and KWA is a good starting
point, the level of coordination in planning, operational management and information sharing among
KWA and CoC needs significant improvement. Though there have been recent initiatives to synchronise
project development initiatives under KWA and KSUDP, seamless coordination is constrained by the
absence of a holistic Water Supply Master Plan for CoC and the urban agglomeration. Further, in the
absence of ring-fenced information on water supply system costs within the CoC area, analysis of
baselines cost recovery and collection efficiency levels is constrained.
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Box 4.1 Water conservation: RWH legislation, Performance Contracts for NRW reduction
Several states and cities have passed legislation for implementing Rainwater harvesting as a water conservation measure.
Andhra Pradesh: The Government of Andhra Pradesh vide a Government Order of the Municipal Administration and
Urban Development Department in 2000 had made it mandatory for all including residential buildings to provide
required facilities for conservation and harvesting of rain water.
Himachal Pradesh: All commercial and institutional buildings, tourist and industrial complexes, hotels etc., existing or
coming up and having a plinth area of more than 1000 square metres will have rain water storage facilities
commensurate with the size of roof area. No objection certificates, required under different statutes, will not be
issued to the owners of the buildings unless they produce satisfactory proof of compliance of the new law. Toilet flush
systems will have to be connected with the rainwater storage tank. Buildings will have rain water storage facility
commensurate with the size of open roof and set back area of the plot at the rate of 0.24 cft. per sq m of roof area.
Ahmedabad: In 2002, the Ahmedabad Urban Development Authority (AUDA) had made rainwater harvesting
mandatory for all buildings covering an area of over 1,500 square metres. According to the rule, for a cover area of
over 1,500 square metres, one percolation well is mandatory to ensure ground water recharge. For every additional
4,000 square metres cover area, another well needs to be built.
Bangalore: In order to conserve water and ensure ground water recharge, the Karnataka government in February
2009 announced that buildings in the city will have to compulsorily adopt rain water harvesting facility. Residential
sites, which exceed an area of 2400 sq. ft. (40 x 60 ft.), shall create rain harvesting facility according to the new law.
Chennai: Rainwater harvesting has been made mandatory in three storied buildings (irrespective of the size of the
rooftop area). All new water and sewer connections are provided only after installation of RWH systems.
Kerala: The Kerala Municipality Building Rules, 1999 was amended by a notification dated January 12, 2004 issued by
the GoK to include rainwater harvesting structures in new construction.
High levels of NRW reflect huge volumes of water being lost through leaks, not being invoiced or both and affect the
viability of water utilities through lost revenues and increased costs. An estimated 45 million cubic meters are lost
daily through water leakage in distribution networks in developing countries. All this affects capacity of water utilities
fund expansion of service, especially for poor. Reducing NRW is not just a technical issue but one that goes to the
heart of failings of water utilities. They often lack incentives and specialist expertise to implement an effective NRW
program. This is where private sector could be of assistance. Short of management contract or concessions, a new
alternative for private involvement, performance-based service contracting (PBC) holds good potential. Here, a
private operator is contracted to carry out a NRW reduction program with sufficient incentives and flexibility to
ensure accountability for performance and payment linked to actual results in NRW reduction. Such an approach
could be especially attractive when the government decides to keep the water utility under public management, but is
looking for ways to capitalize on technical expertise and efficiency of the private sector. The driving factor when
designing a PBC for NRW reduction is to establish incentives to encourage private sector to deliver results cost-
effectively and allocate risk appropriately between the parties. Such contracts have been used in Selangor (Malaysia),
Bangkok (Thailand), Dublin (Ireland) and Hubli-Dharwad (India).
Selengor (Malaysia)
In 1997, an estimated 40 % of water produced in Selangor was not being invoiced and leakage was estimated at 25 %.
The State Waterworks Department accepted an unsolicited proposal from a consortium led by a local firm, in joint
venture with an international operator that committed to reduce NRW by specified amount agreed in advance in a
given time. The contractor had full responsibilities for designing and implementing NRW reduction activities with own
staff, in exchange for a lump sum payment, with penalties of 5 % of total fees and a performance guarantee of 10 % of
contract value. The project was done in two phases: an 18 month Phase I on a limited part of network to reduce NRW
by 18,540 cubic meters per day (cu.m / day) for a lump sum payment of US$4.5 million or US$243 per cu.m / day of
NRW saved. Phase 2 followed a similar framework over 9 years to reduce NRW by 198,900 cubic meters per day, with
a lump-sum price of US$105 million or US$528 cu.m / day.
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The contract began in April 2000 and showed impressive results. 222 NRW reduction zones were established, about
11,000 leaks were repaired and over 119,000 meters were replaced. Physical water loss reduction of 117,000 cubic
meters per day (20 % more than 2009 target of 97,500 cu.m / day) and commercial loss reduction of 50,000 cubic
meters per day was achieved. Positive featured included impressive NRW reduction, simple performance metrics and
clear monitoring. Negatives included negotiated contracting in Phase 2, scattered zoning and high fees.
Hubli-Dharwad had been suffering from irregular water supply; once in 5-6 days and covering only 50 % of its
population. Since all households did not have individual meters, a fixed rate of Rs 90 per month was charged to all
users. Richer households met their additional water needs by buying water from tankers. Illegal water supply
connections were prevalent in many households. Contamination of water with sewage due to leaking pipes led to
health and hygienic issues. The Karnataka Urban Water Supply Improvement Programme (KUWASIP), a structured
initiative to reduce NRW involved a PBC in select demo zones in three cities namely Hubli-Dharwad, Belgaum and
Gulbarga. The management fee structured into fixed and performance fee – 60:40 with the performance fee only
after achieving milestones for Performance Targets set in the Contract. The Capital expenditure limited to a maximum
ceiling (agreed after three pre-bid meetings) and beyond this, the Contractor to bear the additional expenditure. A
bonus of saving of more than 25% of maximum ceiling was allowed. Penalties were to be imposed if minimum
stipulated performance targets were not achieved. A private operator was selected through an International
Competitive Bidding process to develop an investment program to refurbish and transform the existing system and to
implement the program. Today more than 2 lakh residents enjoy the benefits of 24X7 water supply with a world class
water distribution system as a result of a pilot project. Billed volumes went up to nearly 91% of water supplied while
losses were reduced to 5.3 litres per connection per day versus a target of 20 litres per connection per day
In the context of Kochi, it is important to explore models to progressive increase the role of CoC in discharge of
the water supply function. Box 4.1 provides a recent initiative in Orissa to create corporatized entities as a
gradual approach starting with ring progressively increasing role of ULB in water supply service delivery.
Box 4.1 Ring fencing and creation of Corporate Operating Entity – Orissa approach
In Orissa, Water supply and sewerage assets are created and maintained by PHEO. Clarity on the roadmap for transfer of
water supply function to ULBs will facilitate effective development and appraisal of projects and become essential for
innovative funding options including PPPs and loan financing of projects. Devolving of responsibility of Water Supply and
Sewerage to ULBS in tune with 74th constitutional amendment was programmed to be implemented by 2009-10 as per
decision of Government of Orissa. As per Government Resolution circulated in November 2006, the operation and
maintenance of water supply systems and collection of water tariff was to be transferred to ULBs along with personnel on
deputation basis in 2009-10 in fulfilment of the provisions of 74th Constitutional Amendment Act. After a detailed study, a
ring-fenced regional or city-level Corporate Operating Entity (COE) approach as shown below was recommended.
Under this approach, COEs carved out by ring-fencing assets of PHEO and corporatization will provide services through a
performance based contractual relationship with the ULB, thus ensuring accountability of ULBs in service provision in
accordance with JNNURM reform agenda. While Corporatization would provide administrative and financial autonomy, the
th
proposed contractual relationship with the ULB will ensure consonance with the letter and spirit of the 74 Constitutional
Amendment Act. Additionally, areas such as introduction of accrual based double entry accounting system, ring fencing of
operations, benchmarking of performance of utilities, financial sustainability, MIS, capacity building and training etc. will be
addressed in a holistic manner. As a first step, a pilot implementation to ring-fence water supply assets of PHEO
Bhubaneswar division and to prepare a budgeting and costing manual has been carried out.
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4.4.2. Goals
Table 4.8 translate the above vision into tangible service delivery targets. CoC and KWA could potentially
achieve the SLB norms for water supply within a 10-year timeframe.
Table 4.8 Water Supply: Short Medium and Long Term targets
Timeframe
Parameter Unit Norm Baseline Short Medium Term Long Term
3 years 5 years 10 years
Coverage % 100% 83% √
Per Capita Supply LPCD 135 90 √
Non-Revenue Water % 20% 60% √
Metered connections % 100% 100% Achieved
Continuity Hours 24.00 2-4 √
Complaints Redress % 80% NA √
Quality of Supply % 100% 58% √ √
Cost Recovery % 100% NA √
Collection Efficiency % 90% 22% √
Source: CoC. IMaCS analysis. *Though the reporting under BSL indicates that these SLB norms have been achieved in the
context of poor information reliability on these indicators, these figures need to be validated.
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4.5. Recommendations
Table 4.10 summarises a set of suggested actions on water supply, each of which is detailed subsequently.
Table 4.10 Water Supply: Action Plan
TIMEFRAME
ACTIONS BY
S M L
1. Strengthen Baseline information on water supply (and sanitation indices) CoC/KWA √
i. Conduct a Household Sanitation Survey to capture baseline sanitation information* CoC/KWA √ √
ii. Install Bulk Meters at Intake points, Treatment Plants, Storage and Pumping points KWA √ √
iii. Put in place organizational accountability for maintaining and reading of water meters KWA √ √
2. Set up a coordination committee to implement the institutional framework envisaged
CoC/KWA/GoK √ √ √
under KWA-CoC MoU; Shift to a Service Agreement framework in the medium-long term*
3. Develop a Water Supply Master Plan for CoC and Urban agglomeration; prepare DPRs to
CoC/KWA/GoK √ √ √
implement a phased investment program to achieve SLB norms
4. Track costs of service provisioning in CoC area; Formulate a Water Tariff Policy and set
CoC/KWA √ √
mechanisms for tariff fixation /revision*
5. Formulate/Enforce Bye-laws and policy instruments for a) Ground water conservation/
CoC/KWA √
Rainwater Harvesting, b) Tariff Policy, c) Connection Policy and d) Citizen charter*
6. Implement a water quality monitoring protocol for piped supply and ground water CoC/KWA √
7. Implement measures to improve coverage and collection efficiency. CoC/KWA √
Source: IMaCS analysis. *These recommendations are relevant across other sanitation sub-components.
1. CoC and KWA should initiate the following actions to strengthen baseline information:
a. Conduct a comprehensive household sanitation survey on priority and tag this to its property tax
database. A possible approach to capture/household baseline information is suggested below:
i. A list of information to be captured at household level is presented in Table 4.11. This
information when compiled should be recorded in the property tax database.
ii. Updation should then be done through a periodic self-declaration process (this can be
coordinated with payment of property taxes by citizens)
iii. Accuracy of information can be ensured through sample inspection of say 1-2% households along
with hefty fines in case of providing erroneous information will help ensure information validity.
Table 4.11 Possible list of information to be captured during the Multi-purpose household survey
Property Tax Identification Code
Toilet Access Yes/No
Type Toilet within Property / Shared facility
No. of people using the toilet
Primary Water Source
Other Water source 1
Other Water source 2
Toilet connected to Septic Tank/Sewer/local treatment system/open drain/others
If Septic Tank, last cleaned on Date
If Sewered, is grey water outlets also connected Yes / No
Covered under SWM Door-to-door collection Yes/No
Practising source segregation Yes/No
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b. CoC /KWA should undertake installation and maintenance of Bulk Meters at Intake points,
Treatment Plants, Storage and Pumping points. To overcome information constraints on water flows
along with implementing mechanisms to keep a log of water flows and discharge at these locations
daily. As a medium-long term measure and along with service improvement initiatives, CoC should
also shift to comprehensive consumer level metering.
c. Given that KWA has already adopted universal metering, it should undertake immediate steps to put
in place processes for regular meter reading and periodic repair/maintenance of meters to
effectively implement volumetric tariffs with a view to improve cost recovery.
2. CoC should steer creation of a coordination committee to implement the institutional framework
envisaged under KWA-CoC MoU; Shift to a Service Agreement framework in the medium-long term
a. CoC in consultation with GoK should steer creation of a Coordination Committee (comprising officials
from CoC, GoK and other ULBs in Kochi agglomeration) charged with implementing the following:
i. Completion of ring-fencing of ULB level water supply accounts of KWA to enable identification
and tracking of assets that service each of the ULBs, identify ULB specific direct O&M Costs and
appropriate mechanisms for allocation of shared costs (for instance, costs of Water Treatment
Plant can be allocated to various ULBs based on the actual demand within a ULB)
ii. Oversee and finalise preparation of Water Supply and Wastewater Management Master Plans
and DPRs in line with the priorities outlined in point 3 below.
iii. Share information on properties and connections among CoC and KWA to improve penetration
of piped connections and deal effectively with unauthorised connections.
iv. Put in place processes for effective O&M and financial sustainability of water and waste-water
service delivery within CoC and other ULBs in the agglomeration.
b. In order to shift to a service agreement framework as envisioned under the MoU between KWA and
CoC, the Government of Kerala (GoK) should prepare a roadmap for KWA level institutional reform
th
to bring in more effective accountability and decentralisation (in line with the requirements of 74
CAA). While specific recommendations on institutional reform of KWA is beyond the scope of this
exercise, future actions could possibly involve evaluating the following options:
i. Restructuring KWA as a bulk service provider with the city level network planning and distribution
investment and O&M responsibility vested and transferred to the local bodies
ii. Corporatize regional / city-level assets of KWA as a service provider in all the ULBs through a
formal service agreement with independent regulation of tariffs.
3. KWA should develop a Water Supply Master Plan for Kochi urban agglomeration, followed by DPRs to
implement a phased investment program to achieve SLB norms within CoC.
a. In order to ensure effective service delivery and prioritisation of implementation actions, KWA in
coordination with CoC and other ULBs in Kochi agglomeration should prepare a Water Supply Master
Plan. This Master Plan should review aggregate demand for services in the context of urbanisation
and population growth in the agglomeration and given the prevailing service levels and outline a
prioritised time-bound set of actions to achieve SLB norms in Kochi urban agglomeration.
b. Along with preparation of the Master Plan, KWA along with CoC and GoK should initiate preparation
of DPRs for implementing a time-bound investment program to achieve SLB norms in CoC. The
prioritisation of the investment program for water supply could be along the following lines.
i. Speedy completion of projects currently underway under KSUDP and KWA initiatives
ii. Water supply system (including storage capacity upgradation) improvements in Fort Kochi area
iii. Water supply system (including storage capacity upgradation) improvements in rest of CoC
iv. Water supply system (including storage capacity upgradation) improvements in rest of Kochi
agglomeration.
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4. KWA should track costs for service provisioning in CoC area and implement a Water Tariff Policy to
clarify cost recovery objectives and set mechanisms for tariff fixation /revision involving the following:
a. Map the various components of the water value chain and develop processes / mechanisms to
ascertain overall cost of service provision (Capital and O&M costs)
b. Implement a tariff policy that clarifies cost recovery objectives to trade-off affordability and financial
sustainability considerations. A possible approach to tariff fixation and cost recovery is shown below:
Table 4.12Tariff setting philosophy - short term and long term
TYPE OF CUSTOMER /
Service Commitment Tariff Type Cost recovery principle
CONNECTION
5. KWA and CoC, in consultation with GoK, should implement the following actions relating to formulation
and enforcement of guidelines and bye-laws:
a. Formalise adoption of tariff setting principles and cost recovery targets for not just water supply, but
all sanitation services, through development of a Tariff Policy.
b. Formulate and enforce municipal bye-laws on Groundwater management and Rainwater harvesting.
c. Develop and disseminate a periodically updated Citizen Charter outlining commitments and
assurances on service levels including the following:
i. Duration, quantity, quality and cost of supply,
ii. Periodicity of reading and calibration of water meters
iii. Process and Time taken for providing a water connection
iv. Time taken for resolving major and minor complaints
v. Periodicity and policy for tariff revision
vi. Penalties in case of detection of unauthorized connection
6. KWA and CoC Implement a Water Quality Monitoring Protocol covering both piped supply and ground
water in consultation with KPCB to ensure compliance to IS: 10500 standards. As an illustration, the
water quality sampling plan of Surat Municipal Corporation (SMC) is presented in Table 4.13. CoC should
also consider implementing a protocol for monitoring of groundwater quality. Given low penetration of
sewage connections and weak regulation of septic tanks, this is critical to monitor groundwater for
possible contamination and confirmation of suitability of ground water for potable use.
City Sanitation Plan for Kochi - Draft Report Volume 1, Main Report 38
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Table 4.13 Surat Municipal Corporation: Water Quality Monitoring Protocol and Sampling Plan
Stage Type of Test Frequency
Turbidity, FRC, DO, pH Online
Source (River)
Turbidity, FRC, pH Hourly
at stilling
Physical-Chemical tests Every shift of 8 hours
chamber
Bacteriological tests Weekly
Turbidity, TDS, FRC, DO, pH Online
Turbidity, FRC, pH Hourly
WTP Outlet
Physical-Chemical tests Every shift of 8 hours
Bacteriological tests Weekly
Intermediate FRC, Turbidity at inlet of WTP Once in every supply from WTP
(At WDS) FRC, Turbidity before supply Twice in every supply to consumers.
Consumer end FRC (At site) Daily 460-480 samples
(During supply) Chemical test (Lab testing) Daily average 220 samples collected from all zones
SMC reports summary of consumer quality test results on a monthly basis on its website.
Source: http://www.suratmunicipal.org/content/hydraulic/water_quality.shtml
7. CoC and KWA should initiate a connection drive to increase penetration of individual piped connections
and implement measures to improve and sustain collection efficiency covering the following actions:
a. Consider an instalment based option spread over 1-2 years for recovery of connection deposits of
water supply and sewerage connections. A number of ULBs have introduced this in the recent past
with a reasonable degree of success in improving penetration of connections. In addition, the
following actions could help improve connection penetration and in handling customer complaints:
i. Commit and articulate service levels and timelines with respect to provision of water
connection/handling complaints and disseminate the procedure widely.
ii. Initiate steps to make the process of applying for water connections and filing complaints user-
friendly including allowing filing of applications/complaints online and on telephone.
iii. Incentivise adherence to timelines for providing a water service connection through a partial / full
waiver of connection deposit in case of delays beyond the committed timelines.
iv. Track status of connection applications; set targets to improve timeliness in giving connections.
v. Track and report information on time taken for providing connections, with the names of
operating personnel responsible to fix effective accountability and reduce delays.
b. KWA should initiate specific measures to improve collection efficiency including the following:
i. Integrated billing and multiple payment options to customers including through a) payment
through banks b) additional facilitation / e-governance counters, c) mobile vans and door-to-door
collection drives and d) online payment option
ii. Combination of rebates (for early payment) and penalties (for late payment) and create
awareness regarding these options to incentivise payment on time
iii. Dissemination of user charge defaulters online and across media. The Top 20 default cases in
each ward should be brought to notice of individual Council members and support of the Council
Members and Residents’ Welfare Associations should be sought to resolve these cases.
iv. Insist clearance of user charge dues when citizens require access to other urban services (issue of
birth certificate etc.)
v. Focused one-time drives and settlement schemes to clear arrears in a focused manner.
vi. Implementation of clear Accounting policy to provide for and write-off of bad debts.
City Sanitation Plan for Kochi - Draft Report Volume 1, Main Report 39
GIZ-ASEM Corporation of Cochin
5. Wastewater management
5.1. Baseline status
5.1.1. Off-site sanitation
Network, coverage, and connections
The Master Plan of Kochi divides the CoC areas into seven major sewerage zones depending on geography,
existing sewerage and sanitation for planning purpose. However, currently, only a small scale sewerage system
(managed by the KWA) in the municipal area, which partially serves (Ernakulam South) the central area. (See
Figure 5.1 below and Map 9, Volume 5 for a representation of current /proposed sewerage coverage areas.)
Figure 5.1: Existing and sewerage coverage areas
o or
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Rajive Stadium Elamkula Selected Sewerage Projects
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m jn. Population - 60,000
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or
n Population - 180,000
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Sewrage System/network Map - Kochi
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Scale: Consultant:
0 0.4 0.8
Two and half sq.km of sewerage network runs through some part of the Central Business District, such as M.G.
Road and the General Hospital area, and the 1.50 square kilometre stretch of sewerage network runs through
Gandhi Nagar area. Although parts of Gandhi Nagar have a sewerage line running through it, very few
households are connected to the main sewerage line and most have opted for on-site sanitation instead.
Discussions with KWA suggest that details of service connections were recorded only from 1998-99 onwards –
and records indicate 1052 connections, including about 300-400 in the Gandhinagar area.
Additionally, the GCDA maintains a small sewerage network in the Marine drive area designed and
implemented to collect the wastewater generated in the GCDA complexes/other apartments constructed in
the immediate vicinity, and covers only about 0.01 square kilometres.
City Sanitation Plan for Kochi - Draft Report Volume 1, Main Report 40
GIZ-ASEM Corporation of Cochin
Treatment facilities
Elankulam STP: Currently, the KWA maintains one sewerage treatment plant (STP) located on Fatima Road in
Elankulam, which has a capacity of only 4.45 MLD, although this can be expanded up to 10 MLD (Figure 5.2).
The STP follows the Activated Treatment Process (ATP) of sewerage treatment
Figure 5.2: A view of the KWA STP at Elankulam
Treated effluent is discharged into the Elankulam Thodu. Sample time series influent (after grit chamber) and
effluent discharge quality data available with the KWA show that BoD levels of influent are abnormally low.
The reasons for this will require further research, but could be due to dilution from fresh water entering the
system or probably diluted by infiltration into the sewerage, probably groundwater or water from the drains
infiltrates into the sewer system. Various reports available from the KSPCB unit in Kochi for the water quality
parameters for Elankulam Thodu, where the treated effluent from the KWA STP is discharged, show that the
discharged water is high in chloride and total dissolved solids (see Annex 10, in Volume 2 to this report).
GCDA STP: To service the sewer network in the Marine Drive area, the GCDA maintains a small STP, also
located in Marine Drive. The overall capacity of the STP is 900 m3 and has a collection tank, aeration chamber
(diffused type), clarifloculator, and a filter bed. Treated effluent is discharged into the sea nearby. A report
from the KSPCB analysing the effluent from the GCDA STP (see Annex 10) shows that the effluent discharged
from the STP are within desirable limits for pH, suspended solids (SS), biochemical oxygen demand (BOD) and
oil and grease.
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GIZ-ASEM Corporation of Cochin
Source: Report of Hamburg Wasser and University of Applied Sciences, Ostwestfalen-Lippe, Germany
City Sanitation Plan for Kochi - Draft Report Volume 1, Main Report 43
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Gross Water Supply Demand (at 170 LPCD) in MLD 110 115 122
Net Water Supply Demand (at 135 LPCD) in MLD 88 91 97
Waste water generation (at 80% of Net Supply) in MLD 70 73 77
Source: IMaCS analysis
8
Extract from Action plan for Greater Kochi Area. Kerala State Pollution Control Board. July 2010
City Sanitation Plan for Kochi - Draft Report Volume 1, Main Report 44
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Zone – III is an island mostly occupied by Indian Navy, separated from main land by large water bodies,
ultimate projected population of this zone is 6794. Therefore, a treatment plant of 1.2 MLD based on
Sequential Batch Reactor technology is suggested.
Zone – IV is Central Kochi, some portion of this zone has been covered under sewerage scheme, ultimate
population of this zone is 87, 894, and sewage generation from this zone will be in the order of 14.50 MLD, out
of which 4.5 MLD is already treated in the existing STP at Ernakulam, it is proposed to expand the present STP
for accommodation of additional units of 10 MLD STP based on FAB technology.
Zone – V is the West Kochi covering Kaloor, Edappally and part of Vennala, this area is of relatively low
population density. Ultimate population of this zone is 151,329 and sewage generation from this zone will be
around 28 MLD. A private land has been identified at the north end of Amritha Institute of Medical Science for
treating sewage generated from this zone.
Zone - VI is East Kochi with ultimate population of 86, 543 and sewage generation from this zone will be in the
order of 15 MLD. it will be economical to construct a STP in the ward no. 45 nearer to Edapally Thodu.
Zone – VII is the South Kochi area comprising of Thevara. Ultimate population of this zone is 52, 676 and
sewage generation will be in the order of 9 MLD. As this zone covers a wide area, it will be economical to
construct a STP in the ward no. 55 nearer to Chilavannoor area.
Proposed initiatives
KSUDP and KWA have proposed new initiatives to address parts of the Sewerage Master Plan
Proposed sewerage component under KSUDP: This is aimed at extension of the sewerage networks in
South Ernakulam and North Kochi, extending the existing STP at South Ernakulam for additional 10 MLD
capacity, construction of a 20 MLD STP, procurement of sewer cleaning equipment, in order to collect and
treat approximately 30 MLD of sewage from 160,000 users in the urban areas of Kochi Corporation. Total
component beneficiaries at EOP (2011) are expected to be 573,300 of which 40,800 are poor.
Table 5.2: Components proposed under the KSUDP sewerage DPR
Sub-
Proposed initiative
Component
Sub- Extension of sewerage in South Ernakulam -- 92 km. Sewers (150-750mm dia) and 12,000 house
Component 2a connections serving 60,000 population; and Sewage Pumping Stations
Extension of existing STP at South Ernakulam -- Construction of additional 10 MLD STP using FAB
Sub-
technology at existing STP. The STP will also have provision to treat the septic tank sludge of non-
Component 2b
sewered areas of Ernakulam
Sub- Extension of sewerage in North Kochi -- 110 km. Sewers and 20,000 house connections serving 100,000
Component 2c population; and 4 No. Sewage Pumping Stations
Construction of new STP for West Kochi -- Construction of new 23 MLD STP using FAB technology at
Sub-
Mundamveli at MC land. This STP will have provision to treat the septic tank sludge of non-sewered
Component 2d
areas of Kochi
Facilities for Non-Sewered Areas -- One jetting cum suction sewer machine each for South Ernakulam
and North Kochi plus seven vacuum (4 in Ernakulam and 3 in Kochi) sludge cleaning machines will be
Sub-
procured for emptying sludge from septic tanks benefiting a total population of 382,500; and Provision
Component 2e
of 4,500 household twin pit pour-flush latrines and 30 community sanitation blocks (included under
poverty alleviation component).
Proposed scheme by KWA: Based on the demand studies conducted by KWA and considering land
availability, the KWA has proposed a sewerage scheme covering six Divisions (Kadavanthara and Thevara)
out of the 20 divisions under the Central Zone, under the JNNURM. Administrative sanction has been
obtained from the GoK and the proposals have been forwarded to GoI. The total proposed budget for the
project is 7555.84 lakhs.
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Design and construction: The depth of the sewer system is planned to be up to more than 5 m bgl (below
ground level). The width of the roads is generally very limited and the soil is reported as unconsolidated
sand. Hence a proper shoring is necessary to keep the trench open and to avoid damage to the adjacent
buildings. Proper shoring requires excellent expertise of the construction companies on this terrain and
will consequently raise the cost of construction.
Level of groundwater: The ground water table at Fort Kochi is high. As a result most of the sewers will be
constructed below the ground water table. This necessitates heavy pumping to dewater the area during
construction to keep the ground water below the invert level of the pipes. Nevertheless the risk of
groundwater entrance from aside or from the bottom of in the excavation area is still very high. An
additional risk is that the water saturated sandy soil starts caving into the trench. This would weaken the
bearing capacity of adjacent areas and again forms a risk to the buildings. Drawdown of groundwater will
still have an impact on the soil conditions. This impact could cause severe damages on the buildings due to
settings and claim of compensations of the property owners may follow.
Sewer pipe bedding: Proper foundation work is required to avoid settling of the RCC pipes in the different
soil conditions. Otherwise cracks will occur and will cause infiltration of groundwater into sewer system.
Excavation works: Bottom of sewerage pumping stations in the sewer system is reported to be approx. 8.0
m bgl. This construction requires large excavation works with proper shoring and dewatering. Under the
boundary conditions mentioned above this work can be undertaken only by excellent experienced
construction companies.
House connections: Connections provided for the houses have to be designed in advance and done during
the construction. Otherwise later connections will cause higher cost due to dewatering and in proper
connections may lead to entry of ground water into the sewer.
Tendering: The project has already been tendered and with work initiated.
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The key issues on waste-water management within CoC areas are summarised below:
1. Baseline information on waste-water flows and facilities is weak. There is no reliable baseline database
on septic tanks in the city. Given that less only 5% of the city area is sewered, the lack of information on
household sanitation makes planning for city-wide interventions challenging.
2. Existing STP capacity utilisation is sub-optimal: Treated effluent is discharged into the Elankulam Thodu.
Effluent discharge quality data show abnormally low BoD levels of influent which will require examination.
3. Apart from the recent KSPCB guidelines for high rise apartments and commercial establishments,
regulation of on-site sanitation and septage management is very weak. There is no accountability for
onsite sanitation. Septage management is handled by informal private service providers, without
adequate safety practices and discharge of sludge in open places is the default mode of black water
disposal. Grey water is predominantly discharged in the open. A recent study on groundwater in Kochi
revealed high bacteriological contamination in groundwater.
4. Implementing sewerage systems in Kochi is technically challenging, could involve higher costs and will
require very rigorous preparatory work in the form of design, baseline information compilation and
sophisticated construction capabilities. The analysis by Hamburg wasser presents challenges involved in
implementing sewerage systems which do not appear to be adequately factored in project development.
Septic tank with soak pits: All discharge of waste water resulting from bathing, washing, cooking, cleaning and usage
of toilets is treated in the septic tank. The septic tank effluent is disposed in dispersion trenches or soak pits. Septage
is periodically cleared and taken to a treatment facility. In the case of Kochi, soak pits are not recommended owing to
the high water table and infiltration of blackwater or water with excreta into groundwater is undesirable; therefore, in
the Kochi context, soakage trenches are more appropriate.
Twin soak pits (leach pits): Wastewater from latrine is discharged into soak pits. Domestic waste water from bathing,
washing, cooking, cleaning, etc. is disposed into another soak pit. For an uninterrupted functioning, two pits are used.
Improvements in existing household disposal facilities: Existing household sanitation arrangements, which do not
have proper disposal, can be improved by a) Construction of soak pits for existing toilets having only septic tanks, and
b) Providing a septic tank / soak pits.
Public toilets: Community/public toilets could also be provided with a septic tank based on-site system with a soak pit
or soakage trenches (for effluent disposal).
Septage management: An efficient septage collection system, operated by the ULB or private agencies is required
along with regulation and monitoring of septic tanks and septage disposal.
Small-bore sewerage: Here, all waste water is diverted to an on-plot septic tank. Households constructing new individual
sanitation facilities should be encouraged to construct septic tanks/interception chambers. Some households could use pit
latrines. Only grey water may be connected to sewers. Septage is removed for further treatment and final disposal. Small
diameter sewer pipe (< 200 mm) is laid at a flatter gradient to carry the effluent from septic tanks. Here the following
arrangements will be possible:
Household sanitation: a) Septic tank is connected to small-bore sewerage network: all domestic waste water is
partially treated in septic tank and the effluent is disposed into small-bore sewerage network. Septage is periodically
cleared. b) Twin pit latrine waste water is disposed into soak pits.
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Public toilets: A septic tank-based on-site system is constructed. The septic tank effluent is disposed into a small-bore
sewerage network for further treatment and final disposal.
Disposal of septage: An efficient septage collection system, operated by the ULB or private agencies is required along
with regulation and monitoring of septic tanks and septage disposal.
Conveyance of septic tank effluent: The septic tank effluent is disposed into a network of small-bore sewer pipes for
centralized or decentralized treatment and final disposal.
Treatment of waste water: Effluent from septic tanks is partially treated, but still is not safe for discharge into water
bodies. Prior to disposal, the collected waste water should be treated to meet effluent discharge standards.
Centralized or decentralized sewerage system: This alternative includes the regular sewerage network to collect the waste
water from the households. The network is normally laid through most of the town. A detailed topographical and land
availability survey will be necessary to determine the feasibility and required number of decentralized waste water
treatment plants. In the area covered with a sewerage network, efforts should be made to connect all households to the
sewerage network. Even in this alternative, there is a possibility that a few households will still be served by on-site
sanitation systems – mainly pit latrines. The following household arrangements will be possible:
Household sanitation arrangement: The entire domestic waste water discharge of a household is disposed into the
sewerage network, or the entire domestic waste water (including bathing, washing, kitchen and latrine) of those
households, who chose not to connect to the sewer network, is disposed directly into soak pits.
Public toilets: Public sanitary conveniences will be directly connected to the nearest sewer line of the network.
Mixed system: Here, a combination of all options is promoted. The combination includes both on-site sanitation
arrangements and off-site sanitation systems. Here, the following arrangements are envisaged for household/public
sanitation and waste water treatment and disposal arrangements.
Household sanitation: a) Septic tank with soak pits receives the entire household waste water. Septage is periodically
cleared and taken away to a common treatment facility. b) Sewerage network receives all the household waste water
and conveys it to the centralized or decentralized treatment plant(s).
Public conveniences: Waste water discharge is disposed into sewerage network for further treatment and disposal. In
areas where some sewer network is provided and in others, discharged is done into a septic tank with soak pits.
Disposal of septage: For households served by on-site sanitation systems, an efficient septage collection system,
operated by the ULB or private agencies is required along with regulation / monitoring of septage disposal.
Waste water conveyance and treatment: Domestic waste water, disposed into the sewerage network, is transported
to the waste water treatment site(s) for treatment and final disposal. Treatment will meet the disposal standards.
Combined systems with infrastructure systems in parallel (e.g. on-site and areas with sewer coverage) should be
avoided. This will led to additional costs and cannot be communicated to other stakeholders; rather, the
infrastructure system should be adopted to the local conditions with area-wide infrastructure systems: areas with on-
site sanitation and areas with central infrastructure systems
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• Madhya Pradesh (MP): The Government of MP has developed draft guidelines for Septage Management Program.
These guidelines articulate septage management and its imperative, the role of septic tanks, basic regulatory
provisions for constructing these, as well as regimes for permits, etc. The roles of ULBs and the Town and Country
Planning Department have also been articulated. Institutional arrangements have been articulated, included
formation of a City Septage Management Cell (CSMC), comprising officials and representatives from ULBs, District
Administration, City Health Office, General Services, and Pollution Control Board, apart NGO representation. Basic
mention of monitoring evaluation, and desludging protocols have been included, apart from user fees (to cover O&M
costs, and fixed in consultation with public), and penal provisions.
• Maharashtra: Maharashtra has developed a draft State Urban Sanitation Policy that envisions fully sanitized cities by
2015 with a focus on urban poor and women. The Policy recognizes that “The underground systems are expensive,
need higher amounts of water supply and are expensive in operations and maintenance. The ULBs that cannot afford
to build and manage such centralized underground systems should adopt the onsite and decentralized options...” The
Policy puts the onus of providing on-site systems on households: “.... ULBs should encourage and incentivize all
households to build/ repair their own toilets, urinals and septic tanks…. Where space is a problem for households to
build their own toilets, ULB should encourage the households to adopt community latrines and / or go for decentralized
options like: small bore sewer, DEWATS etc.
• Orissa: Bhubaneswar city has specific clauses under Sub-Section (3) of Section 16 of the Orissa Development
Authorities Act, 1982 to make installing of sanitation systems a pre-condition for obtaining building permissions. The
Rules lay down that:1) The applicant shall first develop all infrastructure work, including septic tank, soak pit, water
supply, and drainage system up to the satisfaction of the Bhubaneswar Municipal Corporation (BMC) and the
Department of Public Health and 2) A joint inspection of the above facilities would be carried out by the BMC and the
Bhubaneswar Development Authority (BDA), and the permissions to go ahead with the main building shall be given
only after the site inspection report is approved.
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Lippe, Germany have proposed a decentralised approach using shallow bore networks to address waste-water
management in Kochi. Box 5.3 presents a summary of the approach suggested and through provide a
schematic of the approach suggested for short, medium and long term actions.
Box 5.3 Conceptual outline for a shallow bore decentralised waste-water management system for Kochi
Source: Report of Hamburg Wasser and University of Applied Sciences, Ostwestfalen-Lippe, Germany
The proposed sanitation system is based on a decentralized structure of collection, transport, and disposal of
wastewater, sludge and septage. Treatment has to take place in specific areas, the so-called Service Centres, which are
distributed throughout the city. Decentralized operation areas on the lower level are the Local Service Centre (LSC). These
local service centres will serve approx. 10,000 – 40,000 inhabitants. Therefore, these service centres have to be installed in
the city area. For each 10,000 inhabitants an area of approx. 1,000 m2 is necessary. These areas have to be reserved as
soon as possible by the Corporation of Cochin. The Local Service Centres (LSC) are required for similar purpose as the
existing secondary collection points used for waste segregation and further transfer. It is suggested that a feasibility study
is carried out whether the secondary collection points for waste, which are located throughout the city of Kochi, can be
upgraded to serve as local service centres for sewage management as well or if additional plots are required to fulfil the
function of local service centres. The next level of more centralized operation is located at sites called Urban Service
Centres (USC), where final treatment facilities are in place. The USC can also be located outside of the city in the Greater
Kochi region. They will serve approx. 250,000 inhabitants. Depending on the project status LSC have different functions: -
treatment of sludge from septic tanks (2021); - collection of blackwater (2031); - treatment of greywater (2041)
In the short term, the focus should be to strengthen septage management and create Urban Service Centres (Treatment
Plants) to receive, treat and safely dispose wastewater and sludge. Such facilities should be equipped with drying beds
possibly in the STP site or the waste-processing site. This will also entail putting in place guidelines for septage
management and onsite sanitation and strengthening baseline information on waste-water flows.
In the medium term, existing septic tanks could be rehabilitated to make them impervious and be used as interceptor
tanks linked to Localised service centres (LSCs) through small bore systems. Focus medium activity on black water
management; initiate planning for secondary activities including deployment of grey water management systems.
In the long term, include grey water management systems in addition to the (by now deployed) black water systems. Grey
water pipes can be deployed along existing areas drains and transported to grey water treatment plants, which are located
in the LSCs. Treatment, can be by rotating biological contactors or even simple filter ditches. Upgrade black water handling
systems to vacuum sewers. The vacuum pipes suck off the septic tank contents from time to time (controlled by the
centralized operation of the vacuum system) and transport the black water to the LSC. This can be done by the former
transport pipes. From the LCS black water will be transported via pressure pipes to the USC, where the treatment and use
of the black water is located.The proposed concept plan developed by Hamburg wasser, based on source separation of
wastewater and the installation of local and urban service centres has advantages of incremental implementation while
potentially enabling achievement of a larger and prioritised coverage (Bigger problem first approach where black water is
the initial focus).
The implementation of a settled sewerage (i.e. with smaller pipes at shallower depth for the settled effluent of septic tanks
only) could potentially reduce construction costs compared to a conventional sewerage scheme (i.e. UGSS). Treatment
facilities are also designed for smaller wastewater volumes, which reduces investment costs. The approach helps prioritise
the bigger problem first i.e., tackling Black water. As analysis of the current sanitation situation in Kochi shows (see, for
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example, City Development Plan, 2006), KWA is highly underfunded for extending the sanitation infrastructure. Therefore,
external funds can play an important role for supporting any investments (i.e. construction activities). The step-wise
implementation and upgrading of the proposed concept also facilitates flexibility in financial investments that can be
carried out depending on availability of funds.
5.4.2. Goals
Table 5.5 indicates targets in short, medium and long-term.
Table 5.5: Waste water management: short, medium and long-term targets
Timeframe to achieve norm
Parameter Unit Norm Baseline
Short Medium Long
% of area with piped network % 100% 5% NA – alternatives recommended
% of households with individual connections % 100% ~5% NA – alternatives recommended
Coverage of appropriate sanitation options % 100% NA √
WW Collection Efficiency % 100% NA √
WW Treatment Adequacy % 100% NA √
Quality of WW Treatment % 100% NA √
Septage sludge treatment % 100 NA √
Reuse and Recycling % 20% NA √
Cost Recovery % 100% NA √
Complaints Redress % 80% NA √
Collection Efficiency % 90% NA √
Source: IMaCS analysis. SLB ISIP report
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Figure 5.4: Sanitation scenario 2014 (short-term)
Source: Report of Hamburg Wasser and University of Applied Sciences, Ostwestfalen-Lippe, Germany
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Figure 5.5: Sanitation scenario 2021 (medium term)
Source: Report of Hamburg Wasser and University of Applied Sciences, Ostwestfalen-Lippe, Germany
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Figure 5.6: Sanitation scenario 2031 (long term)
Source: Report of Hamburg Wasser and University of Applied Sciences, Ostwestfalen-Lippe, Germany
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Figure 5.7: Sanitation scenario 2041 (longer term)
Source: Report of Hamburg Wasser and University of Applied Sciences, Ostwestfalen-Lippe, Germany
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5.5. Recommendations
Table 5.7 summarises suggested actions on waste water management, each of which is detailed subsequently.
Table 5.7 Waste water management: Suggested additional actions
TIMEFRAME
ACTIONS WHOM
S M L
1. Review on-going sewerage projects, given challenges identified for possible changes in √
CoC/KWA
design/construction ; Strengthen project monitoring and oversight on these projects
2. Implement mechanisms and processes for Onsite sanitation CoC/KWA √
i. Create a dedicated onsite sanitation department within CoC CoC √
ii. Implement guidelines and bye-laws on onsite sanitation and septage management. CoC/KWA √
iii. Empanel service providers and regulate tariffs for cleaning septic tanks CoC/KWA √
iv. Conduct a feasibility study to create facilities to receive and treat septage. CoC/KWA √
3. Conduct a feasibility study for a shallow bore system in a pilot area; Scale-up project if √
CoC/KWA √ √
pilot yields favourable results
4. Review Sewerage Master Plan and prepare DPRs for implementing a phased √
CoC/KWA √
investment program for waste-water management in Kochi Urban Agglomeration
5. Establish a waste-water quality monitoring protocol in coordination with KSPCB; CoC/KWA √
6. Conduct a feasibility study to evaluate/ address reasons for low incoming BOD at STP CoC/KWA √.
7. Earmark budgets and clarify tariff policy and cost recovery objectives CoC/KWA √
8. Initiate the following actions to encourage waste-water recycling and re-use √
i. Mandate recycling in commercial establishments and large townships CoC / KSPCB √
ii. Evaluate feasibility for catering to industrial water demand from recycled sewage CoC / KWA √ √
Source: IMaCS analysis
1. Review on-going sewerage projects, given challenges identified for possible changes in
design/construction; Strengthen project monitoring and oversight on these projects.
a. KWA along with CoC should undertake a technical and financial review of the proposed projects to
factor challenges highlighted and to incorporate safeguards as necessary to mitigate adverse impacts,
including gravity, which is a challenge also due to the high risk of failure (failures during construction
(bedding, joints etc.).
b. The steering committee proposed among KWA and CoC (as recommended under section 4.5 point 2)
could be charged with the responsibility of monitoring of implementation of these projects.
2. Implement mechanisms for effective Onsite Sanitation management covering the following actions
a. Create a dedicated Onsite sanitation department within CoC vested with responsibility of
implementing recommendations on onsite sanitation.
b. Formulate bye-laws for monitoring and regulating guidelines on septage management and on-site
sanitation backed by implementation of Onsite Sanitation Monitoring framework. A set of well-
defined bye-laws and guidelines, accompanied by a draft set of rules for on-site sanitation and
septage management should be adopted by CoC and backed by implementation of a Septage
Management Program. The following principles should be factored while drafting bye-laws.
Model Byelaws and Guidelines for Onsite sanitation: Possible coverage
• Creation of database of on-site sanitation installations in use and their share in waste water management
• Accountability for development, maintenance and monitoring of onsite installations
• Criteria for choosing between onsite and offsite options on area level
• Potentially appropriate onsite technologies and septage treatment options
• Regulation of services (including septage collection, desludging and O&M of decentralized treatment facilities)
• Empanelment and licensing of service providers (septage management and decentralized treatment)
• Guidelines for Safety, Health and Environment Practices and reduction in extent of manual intervention.
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• Design and Construction. Regulatory oversight for the design, installation and use of onsite options
• Procedures for Septage pumping, Transportation and Treatment. Best practices for pumping and transporting the
septage once it is removed from the tank.
• Recordkeeping and Reporting. Mechanisms such as manifests, receipts, and other records.
• Septage Treatment and Disposal. Infrastructure to accomplish septage treatment, disposal and reuse.
• Full Cost recovery. Mechanisms for full cost recovery
• Social Marketing and Awareness generation. Selling the concept of improving sanitation to the people.
c. Empanel service providers and regulate tariffs for provision of onsite sanitation services to facilitate
compliance to safety, health and environment practices. CoC should initiate empanelment of service
providers and periodic renewal of this empanelment to ensure adequate availability of equipment,
effectively regulate tariffs and monitor compliance to safety, health and environment practices.
d. Conduct a feasibility study to create facilities for receiving and treating septage collected from
septic tanks and soak pits to avoid indiscriminate dumping of waste-water. Such facilities can be
created alongside existing/proposed STPs or solid waste processing facility.
3. Conduct a feasibility study to implement a small bore system pilot as suggested by Hamburg Wasser
team; Scale-up the project if pilot yields favourable results. CoC along with KWA should initiate a
feasibility study to explore implementation of options other than conventional sewerage including the
Hamburg Wasser concept plan for a small bore system.
4. Review and update the Waste-water Management Master Plan and follow it up with preparation of
DPRs for implementing a phased investment program for waste-water management.
a. KWA along with CoC should initiate preparation of a waste-water Management Master Plan. A
possible scope for the Master Plan is recommended below.
Suggested coverage of Terms of Reference for review of Sewerage Master Plan in Kochi
Validate Waste-Water Demand in Kochi agglomeration at intermediate state (2026) and ultimate stage (2041)
Evaluate alternative options for waste-water management including gravity sewers, shallow bore approaches based
on empirical evidence of past initiatives and suitability to unserved areas.
Review overall approach including zoning and strategy for different zones in terms of technology options including
centralised / decentralised approaches for collection, conveyance and treatment
Evaluate Technical options to achieve MOUD’s SLB norms including coverage and connection of grey and black water.
Prioritisation of DPR preparation and investment program in terms of geography and investment components.
Estimates of investment and DPRs required to implement the Master Plan for ULBs / group of ULBs within Kochi
Phasing of implementation starting with implementation of sewerage network within CoC and in rest of Kochi
Scope for waste-water re-use and waste-to-energy solutions for environmental / financial sustainability
b. Based on the prioritisation of components and locations to be provided under the updated Master
plan, CoC and KWA should initiate preparation of DPRs and launch of a phased investment program
(in consultation with GoK) to implement waste-water management infrastructure within Kochi
agglomeration and to achieve SLB norms within a ten-year timeframe.
5. Establish a waste-water quality monitoring protocol in coordination with KSPCB. As in the case of water
supply, CoC should in consultation with KSPCB and KWA implement a waste-water quality sampling,
monitoring and information dissemination protocol to ensure compliance of water quality to CPCB and
KSPCB norms.
6. Conduct a feasibility study to evaluate reasons for low incoming BOD levels at the STP. In view of low
incoming BOD levels at STP, CoC/KWA should conduct a feasibility study to evaluate/ address the same.
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7. Earmark budgets for capital and O&M costs; clarify tariff policy and cost recovery objectives. KWA and
CoC should put in place processes to ascertain costs of service both O&M and Capital Costs. In line with
commitment under JNNURM, O&M costs should be recovered in full through user charges along with
identified allocation of tax revenues in a transparent manner to aid financial sustainability.
8. KWA and CoC in consultation with KSPCB should initiate the following actions to encourage recycling
and re-use of waste-water in the medium to long term.
a. KWA and CoC should work with KSPCB to mandate waste-water recycling and re-use provisions in its
guidelines for according consent to establish and operate decentralised treatment facilities for
commercial establishments and large residential projects.
b. KWA and CoC should conduct a feasibility study to assess scope for use of tertiary treated sewage to
meet industrial water demand in the adjoining industrial areas of Kochi. Along with a progressive
water tariff policy (that recovers full cost of industrial water supply), this initiative could potentially
help improve financial and environmental sustainability of industrial water supply.
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As part of the Kochi CDP the following primary and secondary canals were identified as priority canals for
rehabilitation and upgradation:
Primary Canals: Thevara-Perandoor canal and its major branches, Edappally thodu and its major branches,
Rameswaram – Kalvathy canal, Chilavanoor puzha, Champakara canal, Changadam poku thodu,
Karanakodam thodu, Ponnethuchal thodu, Koyithara canal, Railnagar thodu, Punchathodu, Valavikadavu
tho du, Pallichal thodu,Pandarachal, Pushnithodu, Chitrapuzha and Konothu puzha
Natural Secondary Canals: Kari thodu, Adimuri thodu, Karuveli thodu, Athirthi thodu, Thodu along Major
road, Kathmbayil thodu, Mullassery canal, Market canal and, Seena thodu.
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9
Adapted from Department of Ocean Development (2002), Critical Habitat Information System for Kochi Backwaters – Kerala, Integrated
Coastland Marine Area Management Project Directorate, Department of Ocean Development, Government of India Chennai, and K. K.
Balachandran, (undated) Ecosystem modelling of the Vembanad Lake (Cochin backwaters), Regional Centre, National Institute of
Oceanography, Dr. Salim Ali Road, Kochi, which, in turn, are summarized in Annex 12.
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Major threats to Kochi Backwaters and related concerns include massive reclamation for development,
creation of hydraulic barrier bunds that impact natural flushing in the canal systems, siltation, sewage dumping
and disposal, pollution due to coconut husk retting, industrial pollution from the Eloor Kalamassery belt and
over-exploitation of fish and other resources.
An analysis by KSPCB indicates that river quality data show that Periyar and Chitrapuzha rivers are meeting
designated water quality parameters except for DO at Brahmapuram and Manackakadavu. The high coliform
count at Kalady and the lowering of DO at Brahmapuram, Manackakadavu and Irumpanam are influenced by
non-industrial sources. Even though 95 % of household in Kerala have toilet facilities, there is negligible
sewerage coverage. The rest of the householders and institutions are depending on on-site sanitation, the
inadequacies of which also contribute to the pollution.
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The lowering of DO is attributable to agglomeration of residential buildings and high rise apartment buildings
in and around Kakkanad, which houses the District administration headquarters and many IT industries and
also due to the stagnation caused due to silt deposition due to run off from agricultural farms. The area has no
sewerage coverage. Provision of sewerage and sewage treatment for the fast developing residential area is an
urgent necessity.
Though all large industries in GKA are having in situ effluent treatment plants, there is risk of major chemical
pollutant contamination through acids, alkaline, suspended solids, fluorides, free ammonia, ammoniacal
nitrogen, insecticides, dyes, chromium, Hg, Zn, other metals and unknown quantity of radioactive materials
(Thorium and Uranium). Ambalamugal, 16 km east of Kochi has also been developed into an industrial complex
with establishment of a giant fertilizer plant and an oil refinery. Many hazardous substances including heavy
metals discharged into the aquatic environment are known to accumulate in the estuarine sediments. It affects
the productivity and larval resources of this environment. While this may beyond the purview of CoC, a
coordinated effort to mitigate risks of industrial pollution is critical for environmental sustainability.
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3. Inadequate provision of area level drains in several pockets of the city coupled with poor canal and
primary drain efficiency leads to water logging and other health/sanitation problems. Relative to total
road length of 1665 km, the drainage network coverage is estimated at 41 %. Area drains are absent in
many of the areas especially in areas with urban proliferation. These drains need immediate attention.
These are the primary cause for water logging in the various neighbourhoods in the city.
6.3.2. Goals
CoC should aspire to provide a city wide drain network to cover both sides of 100 % of all roads in the city that
takes into account the city’s topography and flooding areas within a 5 – 10 year time frame. Table 6.4 provides
the timeframe for achieving SLB norms relating to storm water management
Table 6.4: Storm water management: Short Medium and Long Term targets
Info Baseline Time to meet SLB norms
Parameter Unit Norm
reliability SLB S M L
Coverage (Drain length/road length) % 100% NA 41% √
Incidence of waterlogging Nos. Zero B N.A √
Source: IMaCS analysis. SLB ISIP report. Kerala Sustainable Urban Development Project (PPTA 4106 – IND) Final Report
Volume 2 - City Report Kochi, May 2005
6.4. Recommendations
The storm drain and canal network in Kochi is emerging as vulnerable pollution hotspot as solid waste
dumping, sullage flows and poor maintenance threatens to create adverse health and environmental impacts.
Storm water drain networks cannot be addressed in isolation, but need to be managed along with initiatives
on SWM and waste water flows covering the following actions.
Firstly, it is critical to stop garbage dumping and sullage flows into storm drain networks on priority. This
will require putting actions to improve SWM and waste-water management (as detailed in chapter 5 and
chapter 7). These are crucial to keep the drain network effective to deal with storm water flows in the city.
Secondly, as cleanliness in existing drain networks improve, a city wide Drainage Master Plan should be
formulated and implemented. The design of storm water drains should be done by using appropriate
meteorological and hydraulic parameters. Specific actions to be implemented with respect to Storm water
management (in addition to actions listed under SWM and Waste-water management) are listed below:
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1. CoC in consultation with GoK should prepare a Master Plan for Drainage for Kochi urban agglomeration.
To facilitate an integrated approach to dealing with storm water flows, the CoC in consultation with the
GoK should prepare a detailed Master Plan which among other things should cover
a. Review of the status and efficacy of primary and secondary drainage in Kochi urban agglomeration to
identify interventions to rehabilitate / develop them given city topography and water flows
b. Run-off management strategy at a regional / zonal level including identification of low-lying areas
where gravity based flow is limited and pumping maybe required to address water logging
c. Network Zoning and phasing for implementation of a comprehensive area level drains across the city
to achieve SLB norms for storm drains within CoC
2. Following the preparation of the Drainage Master Plan, the CoC and other agencies should in
consultation with GoK prepare Detailed Engineering studies and Project Reports and implement a
phased investment program to rehabilitate and improve the entire drain network.
3. CoC in consultation with GoK should clarify accountability for operations and maintenance of drain
systems. Each of these agencies should earmark adequate budgets for maintenance and upkeep of the
drainage and canal systems, based on the requirements identified in the Master Plan. Given that the
drain network is being executed and maintained by multiple agencies including Concerned local bodies
including CoC, Irrigation Department and Public Works Department, GoK should clarify the responsibility
for development and O&M of these networks (including earmarking adequate budgets for the same)
among the various agencies.
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Awareness generation programme: An awareness campaign with the aid of audio-visual presentations
was initiated in the apartment complexes intending to enlighten the residents. Initial reluctance gradually
subsided; and the success of the system provided wider acceptance for this unique social initiative. Today,
70 % of apartments in the city of Kochi are covered by this scheme.
Bio-Bin System: The Clean City Movement uses Bio-Bins to process the Bio-Degradable Organic Waste.
The Bio-Degradable Waste is deposited in 6 feet long, 3 feet wide and 2.5 feet high bio-bins and a solution
of Micro Organism is sprinkled onto it. Corporation of Kochi approved the system and made it mandatory
in all apartment complexes during 2009. Encouraged by this, CREDAI Kochi decided to enlarge the scope of
its Corporate Social Responsibility activities. Now the Bio-Bin system has been set up in more than 200
apartment complexes covering 15,000 flats in the City of Kochi.
SWM System for individual houses: CREDAI Clean City decided to spread the concept of SWM into the
residences with an aim to adopt the system to the entire city. A suitable model has been identified and
successfully tested in some gated colonies.
The Don Bosco Initiative: Don Bosco, a Christian charitable service, is running a shelter for orphans and rag
pickers. They work in various areas throughout the city, such as Panampalli Nagar, with the help of pushcarts.
Through Don Bosco, there are currently six rag pickers for the area of Panampalli Nagar, who are involved in
primary waste collection for approximately 1,200 households. The rag pickers charge households a user fee of
Rs. 25 each. Rs. 20 of this is paid to the refuse collection crew and Rs. 5 is allocated to vehicle repairs and
maintenance. Rag pickers transport the collected waste to secondary collection points, after which it is
transported by the Corporation to landfill sites. Rag pickers earn a minimum income of Rs. 4,000, but many
supplement this income with other work, usually odd jobs.
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India Environment Portal at http://www.indiaenvironmentportal.org.in/
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The key issues with respect to SWM within Kochi are summarised below:
1. Information base and limited scientific/systematic approach to manage solid waste need to be address t
to improve SWM service delivery from current levels: Even though the Kutumbashree program and other
initiatives of CoC has improved the waste collection significantly, there is littering and waste dumping
observed in canals, indicating scope for improvement. Further, there are environmental concerns at the
waste processing facility which need to be addressed comprehensively.
2. Accountability for SWM is diffused which overlaps between Health and Engineering departments: While
the manpower and conservancy staff report into the Health department, the Engineering department is
responsible for procurement of vehicles and tendering creating overlaps in responsibility. Sanitary staff
are not exposed to modern waste management practices including door-to-door collection, bin-free roads
in residential areas, aesthetic waste collection points in commercial areas, optimal routing to rationalise
transportation cost and waste recovery and processing options, PPP structuring and bidding.
3. While user charges collected, there is inadequate information on extent of cost recovery achieved by
CoC: Given the current context of cost recovery norms, etc., the lack of mechanisms to track user charge
collection, utilisation and cost recovery constrains analysis and progressively achieving O&M cost recovery
objectives. Further, user charges collected under the Kutumbashree initiative for door-to-door collection
are retained with the service providers. Since CoC incurs costs of downstream transportation/ processing
user charges clearly do not meet the full cost of service provision of CoC.
4. Rampant littering reflects public apathy and lack of awareness on their responsibilities towards SWM.
General evidence from reconnaissance around the city points to rampant littering, dumping of waste at
street corners, overflowing bins and chocked storm drains apart from poor waste management practices,
also point to citizen apathy and lack of awareness of their responsibilities with respect to SWM. Therefore
a concerted effort to involve public participation and awareness generation should back infrastructure and
service delivery improvement efforts.
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7.3.2. Goals
Table 7.5 translate the vision into tangible service goals.
Table 7.5: SWM: Short, medium and long-term targets
Timeframe to achieve norm
SLB Info.
Parameter Unit Norm Baseline Short Term Medium Term Long Term
Reliability
(3 years) (5 years) (10 years)
HH coverage % 100% B 100% √
Waste Collection Efficiency % 100% D 97% √
Source Segregation % 100% D 86% √
MSW recovery % 80% N.A 80% √
Scientific disposal % 100% N.A - √
Cost recovery % 100% N.A N.A √
Cost Collection efficiency % 100% N.A N.A √
Complaints redress % 100% A N.A √
Source: SLB ISIP report; IMaCS Analysis.
7.4. Recommendations
Table 7.6 summarises a set of suggested actions on water supply, each of which is detailed subsequently.
Table 7.6 SWM: Recommendations
TIMEFRAME
ACTIONS BY
S M L
1. Strengthen on-going efforts on door-to-door collection to effectively implement source
CoC √
segregation and eliminate road side littering and dumping of waste in drains
i. Widen Kutumbashree initiative to effectively cover the entire city CoC √
ii. Encourage wider adoption of local processing efforts CoC √
iii. Designate waste transfer locations and improve linkages with secondary transportation CoC √
2. Conduct a feasibility study to evaluate options for processing and landfill; build on findings
CoC √ √
to prepare/implement a DPR on the solution(s) identified in the feasibility study.
3. Initiate following actions to clarify and achieve cost recovery objectives. CoC √
i. CoC should implement a system to comprehensively track costs of SWM service provision CoC √
ii. Rationalise user charges under kutumbashree to achieve cost recovery objectives CoC √ √
iii. Explore the use of PPPs in waste recovery and landfill CoC √ √
4. Initiate actions to improve accountability, oversight and public participation CoC √ √
i. Improve coordination among health and engineering departments and carve out a
CoC √ √
separate SWM department to facilitate better accountability in the medium term
ii. Initiate a training initiative on modern waste management practices CoC √
iii. Engage local stakeholders in monitoring and oversight of SWM activities CoC √
iv. Introduce by-laws to conform to MSW rules and to introduce user charges, articulate
CoC √
citizen duties, ban on plastic below 40 microns and fines for littering
v. Complement door-to-door collection and source segregation with awareness campaigns CoC √
Source: IMaCS analysis.
1. CoC should strengthen on-going efforts on door-to-door collection to effectively implement source
segregation and eliminate road side littering and dumping of waste in drains
a. The Kutumbashree initiative should be progressively expanded to cover the entire CoC area and
efforts to introduce source segregation should be scaled up and implemented city wide on priority.
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b. CoC should undertake efforts to adopt bin-free approaches to the extent possible and earmark
designated locations for transfer stations / points for seamless litter-free secondary transportation.
This should be complemented with efficient street sweeping and cleaning programs along with citizen
awareness programs to avoid littering in public places / streets and waste dumping in canals/drains.
c. In recent years, Kochi has seen a significant increase in local level waste collection and processing
initiatives such as those launched by CREDAI clean city program. CoC should actively engage with
these stakeholders to widen adoption of such initiatives to pave the way for waste minimisation and
instil the principle of reduce-reuse-recycle in its SWM system.
2. CoC should conduct a feasibility study to evaluate options for processing and landfill and
prepare/implement a DPR on the solution(s) identified in this study. CoC should initiate a feasibility
study to evaluate measures for mitigating pollution and environmental concerns at existing facility and/or
evaluate alternate sites /options for waste processing (including composting, waste-to-energy etc.) in view
of recent concerns over the waste processing/ landfill facility at Brahmapuram. This should be followed up
with preparation and implementation of a DPR on proposals identified in the feasibility study for
effective waste-recovery and landfilling in a time-bound manner.
3. CoC should initiate actions to clarify and achieve cost recovery objectives in light of CoC’s reform and
cost recovery commitments under JNNURM.
a. CoC should set cost recovery objectives and should implement measures to track costs of SWM
service provision comprehensively.
b. CoC allows the service providers under Kutumbashree initiative to collect/retain user charges for
door-to-door collection, but it incurs costs of downstream transportation/ processing which are not
recovered. Therefore CoC should possibly consider mechanisms for setting / rationalising user charges
in a manner that they reflect cost of service provision and also to ensure that part of the user charges
go into the account of CoC. CoC could consider two alternative to rationalise and collect user charges
i) the local kutumbashree NGO collects a higher user fee, retains a part and passes on the reminder to
CoC or ii) CoC charges and collects a user fee and in turn pays the local kutumbashree NGOs.
4. CoC should initiate the following actions to improve accountability, oversight and public participation
a. Improve coordination among health and engineering departments. In the medium term, carve out a
dedicated SWM department within CoC to facilitate single-point accountability.
b. Initiate a training initiative on modern waste management practices Areas for training in the SWM are
highlighted in chapter 9. CoC should initiate steps to implement these on priority.
c. Engage local stakeholders and community participation in monitoring and oversight of SWM activities
on the lines of the three level monitoring and evaluation framework described in chapter 8.
d. CoC should incorporate bye-laws for formalising and articulating policy with respect to the following:
i. CoC should impose and enforce a ban on use of plastic below 40 microns and fines for littering
ii. CoC should explicitly articulate citizens’ duties with respect maintaining clean environment
(including keeping the public places litter-free and not indulging in activities like open
defecation/urination) and to fulfil their obligations in implementing modern practices such as
door-to-door collection and source segregation.
iii. CoC should enforce fines and punitive measures in case of non-compliance of citizens with
respect to their duties regarding sanitation.
e. CoC should complement door-to-door collection and source segregation with awareness campaigns.
Initiatives like door-to-door collection and source segregation involve significant mind-set change and
therefore engaging public involvement in initial stages through awareness campaigns is critical to get
public support.
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There is a fairly complex legislative and administrative framework governing urban infrastructure development
and urban management, based on Acts, Rules and Regulations formulated by the Central and State
Government (Table 8.1):
Table 8.1: Legislative and administrative framework for urban infrastructure in Kochi
A. Central Acts and Rules
a. Constitutional Provisions (Article 48 and 51) Infrastructure and Environment
b. Constitutional Provisions (Project Affected Persons) Infrastructure and Social
c. Land Acquisition Act, 1894 and as amended 1984 Infrastructure and Social
d. Wildlife Protection Act, 1972 Infrastructure and Environment
e. Water (Prevention and Control of Pollution) Act, 1974, amended in 1978 & 1988 Infrastructure and Environment
f. Water (Prevention and Control of Pollution) Cess Act, 1974 Infrastructure and Environment
g. Environment Protection Act and Rules, 1986 Infrastructure and Environment
h. Forest (Conservation) Act, 1980 and as amended In 1988 Infrastructure and Environment
i. Environmental Guidelines for Rail/Road/Highway Projects, MoEF, 1989 Infrastructure, Environment and Social
j. Hazardous Waste (Management & Handling) Rules, 1989 Infrastructure and Environment
k. Biomedical Waste (Management and Handling) Rules, 1998 Infrastructure and Environment
l. Coastal Regulation Zone (CRZ) Notification, 1990 Infrastructure and Environment
th
m. 74 Constitutional Amendment Act (CAA), 1992 Infrastructure and Management
n. Environmental Impact Assessment Notification, 1994 Infrastructure, Environment and Social
o. Municipal Solid Waste (Management & Handling) Rules, 2000 Infrastructure, Environment and Social
p. Municipal Solid Waste (Management and Handling) Rules, Notification, 2000 Infrastructure and Environment
q. National Policy on Resettlement and Rehabilitation for Project affected Persons, 2003 Infrastructure and Social
r. Labour Welfare Laws Infrastructure and Social
B. State Acts, Rules and Policies
a. Local Authorities Loans Act, 1963 Management
b. Kerala Water and Sewerage Act, 1986 Infrastructure and Environment
c. Kerala Municipalities Act, 1994 Infrastructure and Management
d. First State Finance Commission, 1996 and Second State Finance Commission, 2001 Management
e. Kerala Decentralization of Powers Act, 2000 Management
f. Kerala State Transport Project (KSTP), R&R Policy, 2000 Infrastructure and Social
g. Kerala Ground Water Control and Regulation Act, 2002 Infrastructure and Environment
h. Urban Policy and Action Plan, 2002 Infrastructure and Management
i. Kerala Infrastructure Development Bill, 2001 Infrastructure and Management
k. Kerala Fiscal Responsibility Act, 2003 Management
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As can be seen from the above table, the GoK has been fairly progressive with respect to institutional and legal
reform commitments under JNNURM. However, transfer of functions and responsibilities such as city planning
and water supply is partial and has not yet been accompanied by a comprehensive assessment of staff and
appropriate transfer of staff and resources.
State Departments
The Local Self Government Department (LSGD) is in charge of urban development in the State. Through
the Secretary, Urban, the LSGD oversees the functioning of the State’s ULBs. The Secretary Urban, LSG is
assisted by a Deputy Secretary and Under Secretary in overseeing functions of the Department.
The Water Resources (WR) Department ensures urban basic service delivery through three organizations
under its control: a) Kerala State Ground Water Department, which controls ground water regulation for
domestic/industrial consumption; b) Kerala Water Authority (KWA), which is responsible for water and
sewerage provision in urban and rural areas (with the enactment of the Kerala Municipalities Act, 1994,
service provision related to water and sewerage has passed on to the ULBs); and c) Irrigation Department,
which is responsible for maintaining the waterways in the State (stretches of waterways carrying
wastewater pass through urban areas).
The State Public Works Department (PWD) is responsible for maintenance of roads (Highways and District
Roads) and roadside drains in urban areas. Through the Kerala Road Development Fund (KRDF), the PWD
has initiated improvement and maintenance of roads in Thiruvananthapuram under the Capital Region
Road Improvement Project on an Annuity system.
The Revenue and Housing (R&H) Department, through the Kerala State Housing Board (KSHB), which was
established in 1971, provides organized direction and planning in the preparation and execution of
housing and improvement schemes in the State. The primary objective of KSHB is to formulate and
implement various housing construction schemes as well as housing loan schemes catering to the housing
needs of various income groups in the State. In addition to this, KSHB also executes general improvement
schemes (like commercial cum office complex), government directed schemes (rental housing schemes,
slum improvement schemes, housing complexes for EWS, rehabilitation housing scheme, revenue towers,
etc.) and deposit works (undertaking construction of work of other agencies). The R&H Dept. is also
associated with land acquisition issues and plays an important role in providing clearances for land
availability in infrastructure creation.
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The General Administration Department (GAD) facilitates urban management through the Modernizing
Government Program (MGP).
The Power Department supports urban management through the Kerala State Electricity Board (KSEB).
The KSEB is responsible for supply of electricity and maintenance of street lighting for ULBs, and is
responsible for power supply to the KWA towards pumping of water and sewage.
The Health Department controls environmental pollution in urban areas and regulates solid waste
collection and disposal through the Kerala State Pollution Control Board (KSPCB). The KSPCB’s mandate is
to ensure that ULBs comply with the Supreme Court Guidelines on municipal, bio-medical and hazardous
waste handling and disposal. The Health Department is responsible for a) preventive measures against
infectious and communicable diseases; b) overall supervision of the administration of the Prevention of
Food Adulteration Act; and c) matters pertaining to the Public Health Act within the local area.
The State Planning Board administers GoK’s FYPs, regularly assesses the State’s economy, formulates
Annual Plans for budget integration, organizes and guides planning units at the district/local levels; and
advises on all economic development and policy matters.
The Town and Country Planning Department (TCPD) is the prime agency for providing technical inputs for
the planned development of urban settlements. The TCPD a) prepares Master Plans for the State’s cities
and towns; b) prepares detailed development plans; c) provides guidance to local bodies and
Development Authorities on plan implementation; d) prepares area development plans for controlled
areas; and e) advises various State-level agencies on planning, site selection, and preparation of
development schemes
The Finance Department largely perform the function of advising the Government on all financial matters.
The formulation of the budget is one of its most important functions. The Finance Department is also
entrusted with the responsibility of framing rules regulating pay, emoluments and other service conditions
of all Government employees. It has administrative control over the departments of Local Fund Audit,
Directorates of National Savings, State Lotteries, State Insurance and Treasuries. The Department is
headed by the Principal Secretary and has two Secretaries in charge of Expenditure and Finance
Resources.
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both KSUDP as well as the KWA are entrusted with the responsibility of augmenting as well as newly
constructing water supply and sanitation infrastructure in the Corporation area. This will be further
explained in the subsequent sections of this report.
Kerala State Pradesh Pollution Control Board (KSPCB): The KSPCB is responsible for controlling of water
and air pollution caused by various sources across the state including Kochi. It is responsible of monitoring
and oversight to ensure compliance with various state and central legislation on pollution. In particular,
the KSPCB has been active in the area of waste water management and has laid guidelines for waste water
management in apartments and commercial establishments and is responsible for providing consent to
establish and operate and in the area of Septage management where it has recently initiated discussions
with CoC and private service providers to streamline safe septage management and disposal.
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Kudumbashree Project of the Urban Poverty Alleviation Department (UPAD) channels funds of centrally
sponsored schemes to the MC and monitors fund utilization through its District Mission Coordinator
(DMC). Infrastructure requirement is identified through the neighbourhood groups/area development
societies/community development societies and indicated to both the MC and Kudumbashree. Based on
the funds available through Centrally Sponsored Schemes and projects/schemes approved by the MC,
Kudumbashree transfers the requisite amount to the MC for utilization in BPL settlements – 2 % of the
Municipal Corporation’s own revenue is earmarked for poverty alleviation schemes.
Town Planning: The Development Authority (DA) is a coordinating agency responsible for Master Plan
implementation, which is prepared by the Town and Country Planning Department (TCPD). The DA is expected
to coordinate with State Line Agencies and the MC regarding plan implementation. The MC currently oversees
land use zoning originally the responsibility of the DA. Under Section 30 of the KM Act, 1994, the MC is
required to carry out spatial planning; this function is currently carried out by the TCPD at the MC’s request.
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Service delivery by the KWA and the relationship between the KWA and the CoC is governed by a tripartite
MoU signed in November 2007, between the CoC, KWA and the Departments of Local Self Government &
Water Resources, GoK. This Memorandum of Understanding (MoU) seeks to develop a governance framework
including mechanisms for accountability between the parties through performance agreements for water
supply and sewerage service delivery projects under the JNNURM, UIDSSMT supported by the MoUD, GoI and
the Kerala Sustainable Urban Development Project supported by the ADB. The MoU is valid for the
JNNURM/UIDSSMT/KSUDP project period and is subject to annual review and periodic revisions as required by
all parties (See Table 8.4).
Table 8.4: Institutional responsibilities under the MoU
Municipality/ Municipal
LSGD (GoK) Kerala Water Authority GoK
Corporation
Policy Principal/Contracting Service Provider Dispute
Authority resolution/arbitration (GoK
through Special
Coordination Committee)
Facilitation of MoU Regulation Operation and
Maintenance
Financing Approvals and Supervision Technical support to
Municipality/Municipal
Corporation
Capacity building of Monitoring and evaluation
Municipality/Municipal
Corporation and KWA
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Kudumbashree programs are designed on a participatory approach. The women members at the grass root
level are encouraged to take up leadership through functional activities like Community Health Volunteers,
Income Generation Activities Volunteers, Infrastructure Volunteers, Secretary and President. These groups
prepare periodical micro plans, which become the base for the Community Development Society (CDS) plan or
antipoverty sub-plan of the local body. Based on the local body’s approval, the CDS societies take up the
sanctioned work. The Kudumbashree project has built a network of the poor women groups from slum areas
through a three-tier system, i.e. Neighbourhood groups, Area Development Society and Community
Development Societies. CoC has 1,763 Neighbourhood Groups and 79 Area Development Societies.
1. Institutional multiplicity and inadequate ULB level involvement in long-term planning: Though
urbanisation has spread beyond CoC limits into neighbouring areas, long-term planning is constrained by
the presence of multiple bodies. Since the organisations such as KWA and GCDA continue to be
responsible for implementation of large capital projects, city level master planning, etc., CoC and other
ULBs play a limited role in planning for and implementation of key functions such as water supply and
sanitation systems. While the MoU for inter-agency coordination is a welcome step and is expected to
increase coordination, there is need to back this initiative with greater implementation focus and
formalisation of interactions across agencies. Also there appears to be a need for greater coordination
among KWA, CoC, GCDA and KSPCB in light of pollution concerns to put in place accountability for setting
and implementing appropriate monitoring protocol.
2. Overlapping accountability for sanitation within CoC limits: As in case of many ULBs, responsibility for
sanitation is diffused across multiple agencies. Water supply and sewerage infrastructure is being handled
by the KWA, while some parts of the water and sewerage projects are being developed under KSUDP.
SWM services and Public Toilets are being handled by CoC. There is no regulation and accountability in
place for on-site sanitation. The CSP will provide inputs for better institutional accountability and
addressing service/ organisational gaps pointed here.
3. Lack of institutional accountability for onsite sanitation: Though more than 95% of the city is dependent
on onsite sanitation, there is no formal accountability within CoC for regulation and oversight of onsite
sanitation. Collection and Disposal of septage is completely managed by private service providers and is
unregulated.
4. Unclear Land ownership and titles often tends to constrain decision making at the local levels. There are
issues at two levels: A) Accountability for Land ownership is diffused. While the Revenue Department of
the State Government has the overall oversight and accountability for land, the Local body (which by its
authority to plan land use and levy Property Taxes) also has a role. Very often there could be discrepancies
between the two. B) Secondly, when encroachments happen and this is largely applicable to most low-
income settlements, Municipal bodies are wary to provide infrastructure services in such areas as there is
a concern that provision of services gets construed as a deemed acceptance of ownership and legalise the
encroachment. Often services are not provided till the settlement is regularized and this creates potential
for sanitation becoming a casualty.
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8.3. Recommendations
8.3.1. Overall accountability
Table 8.5 provides an overall perspective on the possible institutional structure in the short to medium term.
Table 8.5: Overall accountability for sanitation services – projected scenario
Community Public
Role SWM Onsite sanitation Sewerage Water Supply
Toilets Toilets
Guidance MOUD and CPHEEO
Planning CoC KWA + CoC
Asset Creation/capital
CoC Households + CoC KWA + CoC
investment
O&M CoC Households + CoC COC W&S Department
Monitoring (a) CoC; (b) Ward Committees; and (c) independent evaluation
Regulation and tariff
CoC
setting
Clarity on land titles CoC with Revenue Department, GoK
The framework attempts to fix accountability for sanitation components with respect to various roles namely,
planning, asset creation, O&M, monitoring and evaluation, regulation and tariff setting and recognises that
CoC has single point accountability for toilet access, SWM, and planning/monitoring of onsite sanitation.
A three-pronged monitoring approach is recommended for oversight of water and sanitation services.
KWA will continue to play a large role in water supply and sewerage service delivery. However, in keeping
with the MoU signed between CoC and KWA, an increased role for CoC is envisaged in these areas.
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Corporatization and ring-fencing provides a useful transitioning approach in this regard. Box 1 provides a
recent initiative in Orissa to create corporatized entities as a first step towards greater local responsibility.
Box 1 Ring fencing and creation of Corporate Operating Entity – Orissa approach
In Orissa, Water supply and sewerage assets are created and maintained by the Public Health and Engineering Organisation
(PHEO). Devolving of responsibility of Water Supply and Sewerage to ULBS in tune with 74th constitutional amendment
was programmed to be implemented by 2009-10 as per decision of Government of Orissa. As per Government Resolution
circulated in November 2006, the operation and maintenance of water supply systems and collection of water tariff was to
be transferred to ULBs along with personnel on deputation basis in 2009-10 in fulfilment of the provisions of 74th
Constitutional Amendment Act.
After a detailed study, a ring-fenced regional or city-level Corporate Operating Entity (COE) approach as shown below was
recommended. Under this approach, COEs carved out by ring-fencing assets of PHEO and corporatization will provide
services through a performance based contractual relationship with the ULB, thus ensuring accountability of ULBs in
service provision in accordance with JNNURM reform agenda. While Corporatization would provide administrative and
financial autonomy, the proposed contractual relationship with the ULB will ensure consonance with the letter and spirit of
th
the 74 Constitutional Amendment Act. Additionally, areas such as introduction of accrual based double entry accounting
system, ring fencing of operations, benchmarking of performance of utilities, financial sustainability, MIS, capacity building
and training etc. will be addressed in a holistic manner. As a first step, a pilot implementation to ring-fence water supply
assets of PHEO Bhubaneswar division and to prepare a budgeting and costing manual has been carried out.
3. GoK should actively support ULBs in implementing local level policy framework through model bye-laws
and guidelines. A range of regulatory interventions are required in the form of guidelines and bye-laws to
have a shared understanding of obligations and responsibilities and to provide statutory basis for
enforcing compliance. A list of byelaws and regulations recommended under the various sanitation
components are summarised below. GoK should facilitate the same through appropriate instruments
including Government Orders, Guidelines and model bye-laws.
Table 8.6 Illustrative list of areas for formulating bye-laws and policy guidelines
Sl. No. Nature of Action Subject
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4. GoK should undertake an independent organisation assessment of CoC and KWA to identify the
hierarchy, number and scale of officers required, identification of gaps vis-à-vis existing sanctioned
positions, detailing of job descriptions and drafting / amendments to service rules in the context of
changes in requirements owing to changes in services (Onsite sanitation, door-to-door collection etc.),
potential for technology led productivity improvements (E-governance, GIS/ GPS) and growth in service
demands (as a result of increase in population in area under jurisdiction). Refer Figure 8.1 for a possible
approach to structuring the water and sanitation organisation.
Figure 8.1 Organisational alignment for sanitation functions - KWA and CoC
Functional
Overall Head Department in charge
responsibilities
Drain Cleaning
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Source: http://www.waterawards.in/2009-winner-profile-jusc.php
JUSCO Sahyog Kendra was an initiative to increase customer satisfaction and improve customer service by introducing a
single point of contact, creating zones, setting standards for service delivery, managing the complaint-registration process
effectively, and capturing customer perception and benchmarking service levels.
Context: Jamshedpur is spread over an area 64 sq. km, and has a population of 0.7 million. The erstwhile Town and Power
Business divisions of Tata Steel had been responsible for its development, and for providing civic and allied services, for
over around for nine decades. In 2003, Tata Steel took the path-breaking initiative of corporatizing municipal services and
creating a unique organization called Jamshedpur Utilities and Services Company Limited (JUSCO). JUSCO was incorporated
as a wholly-owned subsidiary of Tata Steel on August 25, 2003. The major challenge it faced in terms of customer relations
was that the complaint-management redressal system was ineffective because it was manual, decentralize and had no
specific service delivery standards, and it was not possible to collate data for managerial decision making.
Initiative: JUSCO Sahyog Kendra was an initiative towards customer satisfaction to improve customer service. The
objectives behind this initiative were to provide real-time data for decision making, provide analytical support for solving
issues, identify areas of improvement, and create a transparent and effective interface with customers.
Key Features: The Sahyog Kendra laid out explicit service-delivery standards which are time-bound, relevant, accurate,
measurable and specific. A survey was conducted to find the service level expectation against each of the services. Based
on the findings and capability of the service-delivery mechanism, service level guarantees are agreed. Customers now have
a single-point contact. JUSCO also went through an exercise of job prioritization, third party assessment of customer
perception, and benchmarking of service levels.
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6. CoC strengthen its baseline information on land / property information and de-link ownership of
property from sanitation service provision.
a. In this regard, CoC could leverage its property tax database to capture and update the land ownership
information. Clearly there is a case for greater coordination between CoC and the Revenue
Department of the state. This can be facilitated through facilitating greater information exchange, so
that there is synchrony of information and an active engagement to resolve discrepancies if any. The
following actions are recommended in this regard
b. CoC and KWA should de-link service provision from recognition of ownership through a clarification
and amendment to the municipal act. This is critical to ensure that properties with dubious
ownership records do not end up becoming sanitation hotspots (or) get provided unauthorised
services (water/sewerage connections). While regularization is difficult choice to make and is subject
to other legal and enforcement issues, service provision and user charges for the same should be
payable irrespective of authentic title on the part of the owner/ occupier. A number of states have
passed legislation to this effect in an effort to de-incentivise illegal construction and to improve the
revenue potential of Local Bodies. The Karnataka Municipal Corporations Ordinance, 2008 (excerpt
below) is clear in this respect and allows collection of Property Taxes from unauthorised properties.
‘The Bruhat Bangalore Mahanagara Palike may levy and collect the property tax from all building,
vacant land or both including a building constructed in violation of the provisions of building byelaw or
in an unauthorized layout or in a revenue land or from a building occupied without issuance of
occupancy or completion certificate except the building constructed illegally in Government land, land
belonging to any local body, any statutory body or an organization owned or controlled by the
Government. The property tax collected from such building shall be maintained in a separate register:
Provided that levy and collection of property tax under this sub-section from such building does not
confer any right to regularize violation made, or title, ownership or legal status to such building. Such
buildings shall always be liable for any action for violation of law in accordance with the provisions of
this Act or any other law.’
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a. Holding consultative interactions with public stakeholders and elicit feedback on citizen satisfaction
with sanitation services.
b. Monitoring and evaluating service level and financial performance, oversee reporting and information
dissemination by CoC and KWA on performance, costs and rationale for tariffs.
c. Implementing tariff fixation and revision measures after a review of information provided by CoC and
KWA in line with cost recovery and tariff policy formulated by CoC.
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9. Capacity building
9.1. Training
The training related recommendations should be read in conjunction with the recommendations under
institutional framework particularly the recommendations on organisation under section 8.3.2. While a
detailed Training Needs Assessment (TNA) is required to ascertain and validate the training requirements, we
outline below key principles relating to undertaking training in general:
1. CoC should set aside a training budget annually as part of its budgetary exercise.
2. CoC should conduct a TNA exercise in conjunction with the manpower needs assessment recommended
as part of the institutional recommendations in order to ascertain in detail the areas of training required.
3. The TNA should be followed by a phased time-bound program to impart training as per the areas and level
of instruction required in collaboration with local academic institutions and GoK. Given that Kochi has a
number of leading educational institutions, GoK and CoC should leverage the same to undertake such
training initiatives. In addition, since Kerala is home to some leading training institutions in governance
and urban services including the Kerala Institute of Local Administration (KILA), the same could be
leveraged for this purpose.
4. The TNA should cover all classes of employees with the recognition that the nature and type of training
requirements could be very different. For instance, an engineer in charge of Distribution Networks may
require training and exposure to conducting a leakage audit study while a plumber in the department may
need to be trained in good practices while providing a ferrule level connection.
Table 9.1 provides an illustrative set of training needs across select sanitation components. The
recommendations of GIZ’s Capacity Enhancement Needs Assessment report (which focuses on training needs
focused on Environment and cover a range of sanitation issues) have been factored, apart from interactions
with CoC officials in drawing up the list of these illustrative training needs.
Table 9.1: Illustrative training needs across select sanitation components
Sanitation Component Senior officials Technicians/Operating Staff/Workers
All Departments Municipal Legislation; powers and duties Rights and responsibilities
Citizen Charter and commitments Good Safety, Health and Environment
Urban Reforms and JNNURM Practices
Service Level Benchmarking Citizen Charter and commitments
Procurement and PPPs
Information Systems Improvement
Use of Computers and Office applications
Water Supply CPHEEO Manual and norms Water Quality Testing methods
Developing a Water Supply DPR Guidelines for providing a ferrule
Benefits and approach to shift to 24x7 connection
Approach to conduct a Water Loss Audit Installation of Meters/Reading.
Approach to sizing Discreet Metering areas Repairing water leakages
MIS generation and SLB reporting Handling pipe breaks
Field Inspections and reporting
Use of equipment and safe work
practices
Sewerage CPHEEO Manual and norms Septage management
Developing a Sewerage DPR Water Quality Testing
Treatment systems including decentralised Guidelines for providing connections
options and septage management Repairing pipe breaks and choking
Recycling/Reuse and Methane Generation Field inspections and reporting
Onsite sanitation options and mechanisms Use of equipment and safe work
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discharged at these locations on a daily basis. This will aid accurate assessment of distribution of water and
waste-water flows at a bulk level.
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•Use pilot campaigns to achieve specific behaviour change goals; Leverage ‘peer
effect’ of positive outcomes to replicate results widely
Step 4
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Periodic field interactions with community organisations and RWAs: While the CoC has elected
representatives from each ward, in order to enhance interaction; CoC should compile a database of
community organisations and RWAs. Once the list of such organisations ward-wise is compiled, CoC
should organised structured consultations among municipal officials along with elected representatives
with such associations and welfare groups to improve citizen interface. Having municipal officials visit
respective wards and interact with such agencies periodically through a structured open house sessions
would improve the credibility of CoC as a responsive service provider
Operationalize/revitalise Ward Committees and involve them in oversight: CoC should explore if it
revitalise the roles of ward level committees by assigning them a lead role on organising periodic thematic
interactions as suggested above and to assign monitoring roles for initiatives if any undertaken at ward
level. A formal consultative structure in this manner will help in improve effectiveness of awareness and
communication campaigns launched by CoC.
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Communication actions
Communication actions should effect behavioural change by helping create awareness, reinforce positives and
benefits, and dispel misperceptions among stakeholders. There are three generic communication actions:
1. Information dissemination: At a basic level, communication should help disseminate and share
information on impacts of good sanitation practices. Often, even conveying factual information in a timely
and structured manner itself can create and/or stimulate positive behaviours.
2. Key messages: Achieving a higher degree of behavioural change (for instance, converting someone
practicing open defecation to use a public toilet) and retaining a higher level of support would call for
more persuasive communication. That would include developing and delivering “take-away” messages
that convey the salient benefits of the project to various stakeholders in a sensitive and impactful manner.
3. Facilitate interaction and feedback: Finally, communication actions should facilitate interaction and
feedback. Platforms for such interactions and consultation include meetings, brainstorming sessions,
workshops, public hearings, and web-based feedback.
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Communication channels
Channels enable delivery of messages and exchange of ideas and views amongst stakeholders. Table 10.2
provides a summary of possible channels options, their features and limitations.
Table 10.2: Channels of communication
Channel Typical Audience Features Limitations
1. Interpersonal Channels
Personal Elected Council, Interactive, enables formal and informal Cannot be done too often;
consultations Opinion leaders communication. Face-to-face hence needs a lot of planning
(including politicians) discussions allow frank communication and preparation
that brings out issues that may not be
voiced openly.
2. Community Channels
Community Advocacy groups, Participatory, relatively more credible Localised. May not be able to
channels (street Households, Slums, and lower-cost than mass media; reach a large audience.
corner meetings, Women institutionalises community effort and
open hearings, sustainability.
focus groups)
3. Mass Media Channels
Television General public, all Used for visual experience and Expensive and more “urban”;
stakeholders. demonstration. Makes issues come alive poses the reach vs. cost
and delivers a strong image. dilemma.
Radio Individuals, Can be more personal, with higher Costly to build reach,
Households reach than television, less expensive, fragmented
and more localised.
Print Educated Citizens, Creating awareness and topicality, Confined to literates only,
Opinion leaders disseminating information, creating a difficult to reproduce, with a
positive image. short shelf life, and not always
cost-efficient.
Outdoor/Transit Public at large and Glance and reminder value and location Limited exposure time and
Floating Population specific reach. durability of message.
4. Internet
Internet and Educated audience Dynamic, interactive, and allows real time Reach limited.
Websites with access. update.
1. Interpersonal consultation channels include one-to-one communication, such as between line ministry-
implementation agency, implementation agency-political leaders etc. They cover consultations, one-on-
one interactions and group interactions, structured deliberations through committees and task forces.
2. Community based channels reach a community or a group of people within a geographic area, or based
on common characteristics, such as occupation and includes Community media (local newspapers, radio
stations, bulletin boards), Community activities (health fairs, folk dramas, concerts, rallies, and parades)
and mobilisation (street meetings and consultations). They offer scope for ‘interactivity’
3. Mass media channels are used more to “broadcast” or “disseminate” information and offer limited scope
for interactive communication. Mass media channels help in reaching large audiences within a short time,
and include television, radio, print media and newspapers, outdoor/transit advertising, and direct mail.
Mass media campaigns could be relevant and useful for larger Sanitation campaigns.
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4. Internet and web-based communication has emerged as an important channel for communication. Web-
based dissemination of information on sanitation projects signals transparency and provides for a cost-
effective mechanism to reach wider audience. Interactive functionality can support consultative processes
and help elicit feedback and participation. Social networking sites could emerge as an important opinion
mobilising channel for public service delivery in the future. For instance, Delhi traffic police has recently
launched a page on the popular social networking website, Facebook, to engage with citizens and provides
traffic alerts through mobile text messages.
2. A 100 % safe wastewater disposal campaign in one of the predominantly residential wards with significant
disposal of wastewater in open drains. Run in collaboration with local resident welfare associations and
street corner meetings along with active reconnaissance by KWA engineers and backed by support from
the CoC Engineering Department, the objective of the campaign should be to get the ward declare itself
100 % safe waste-water disposal ward in six months. This campaign can be taken up in one of the two
selected Wards along with the phased sanitation improvement programme outlined in the section on
wastewater management.
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3. A 100 % source segregation and door-to-door collection campaign, to be run in coordination with one of
the sanitary supervisors and conservancy staff, this campaign should necessarily be launched with
significant planning at a ward level in terms of infrastructure and manpower for door-to-door collection. A
door-to-door campaign should precede the launch of actual service where municipal officials and
conservancy workers meet households and provide them pamphlets and instructions for source
segregation and use of two-bin system for collection of waste. The campaign should be backed by efficient
service delivery covering timely collection (with guarantee to pick up waste every day at a fixed time) and
provision for registering complaint in case of waste not being collected at doorstep. The objective should
be to get the ward declare itself 100 % litter free in six months.
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CoC has maintained a surplus over the last three years. However, total income (CAGR of -1%) has
exhibited a decreasing trend.
Own income as a percentage of Income is up from 59% to 91%, boosted by a steep growth in Tax income,
the share of which has gone up from 44% of revenue to 75% of revenue during this period.
Overall surplus after dipping in FY 2009 has increased to Rs. 31 crore in FY 2010.
Share of O&M expenditure in total has reduced from 22% in 2008 to 17% in 2010 also accompanied by an
absolute decline during this period.
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11.3. Goals
Table 11.2 provides tangible service delivery goals to meet SLB norms on cost recovery and collection
efficiency in water supply, sewerage and SWM. Given the poor service levels on these parameters, SLB norms
of 100 % O&M cost recovery can be achieved in the medium term (5 years). Further CoC and KWA should
initiate steps to move towards full cost recovery in the Long term.
Table 11.2: Financial sustainability: Short Medium and Long Term targets
Targets
Parameter Unit NORM
3 years 5 years 10 years
Water Supply
Cost Recovery % 100% 70% 100% 100%
Collection Efficiency % 90% 70% 100% 100%
Sewerage
Cost Recovery % 100% 60% 80% 100%
Collection Efficiency % 90% 60% 90% 90%
Solid Waste
Cost recovery % 100% 100% 100%
Collection efficiency % 90% 90% 90%
Source: IMaCS analysis. SLB ISIP report.
11
Cost Recovery in Water Services: Select Experiences in Indian cities. WSP. March 2011
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Access to Toilets
In general, pay per use approaches and advertising streams could potentially enable full cost recovery for
Public Toilets in high density traffic locations. If managed well, CoC should be able to recovery the O&M cost of
provision of all shared toilets (public + community toilets) and recovery part of its capital costs through
leveraging this potential. In this regard, it is often noticed that
a. Pay and use public toilets in high density commercial areas have potential to recover full cost if
advertising potential is leveraged and hence PPPs are a potentially viable option for public toilets.
CoC could consider unbundling advertising rights and toilet maintenance as separate contracts. This
could enable CoC to maximize its revenue potential from such toilet locations and have greater
oversight on monitoring maintenance.
b. Community toilets are likely to require subsidization and could possibly recover O&M cost. Since a
pay-per-use model could deter usage, a monthly flat fee through issue of toilet use cards may be a
better alternative for Community Toilets. CoC could consider using Self Help Groups or delegate
maintenance to local community while providing oversight to ensure asset upkeep and repairs.
Water Supply
Tariff setting philosophy is a critical element in determining the range of PPP interventions possible in the
water sector. For instance, if the tariff philosophy is to recover only the O&M costs in full, implementation of
projects using PPP models involving investment commitment (such as BOT) from the private operator would
require investment servicing financing to be met from resources of ULBs other than user charges (municipal
revenue surplus from other revenue streams such as property taxes and Grants and devolution income from
GoMP). PPP models including management contracts / service contracts (without an investment commitment
from private operators) are feasible, even within the realms of a 100% O&M cost recovery focus. KWA could
consider leveraging private sector capacities for improving system efficiency including focus on NRW reduction
and Performance based contracts (which were discussed earlier under Box 4.1).
Waste-water management
From an economic standpoint, water and wastewater tend to be viewed differently. Though water is a private
good, it tends to have both private/public good characteristics. On one hand, it is always possible to
disconnect/ not connect the consumer (private good), although economic/ social cost and difficulties of the
same can be high, making exclusion difficult (public good). On the other, wastewater collection, treatment and
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sludge disposal are purely public goods as no one can be excluded from pollution. PPPs in Sewerage and waste
water management have been relatively fewer in India. Firstly, sewerage coverage is limited. Secondly, user
charges and connection charges for sewerage are still in its infancy (though KWA has a framework for
connection deposits and user charges, cost recovery levels have been poor)
In this regard, it is instructive to look at the experience of Alandur city where the STP was implemented
through a PPP arrangement. (Refer case study below) and the project successfully leveraged a combination of
private participation, public deposits and user charges. The project presents a potentially replicable model for
extending sewerage services in large urban centres in an efficient manner. Recently, a PPP model structured
with fixed plus variable payments was developed for its sewerage project by Kolhapur Municipal Corporation.
The Alandur sewerage project initiated in 1996, is the first such project in India using a PPP framework (BOT format) and
presents a unique case in the area of public-private partnership in the urban sanitation sector. Alandur municipality falls
under the Kanchipuram district and has a population of approximately 1.25 Lakh, with one-fourth of them living in slums.
Alandur has developed mainly as a residential suburb of Chennai.
The proposed sewerage system was to be developed for the targeted population of about 3 Lakh persons and has the
following components: A sewerage network consisting of the main sewer line, branch sewer line and manholes;
Construction of a sewage pumping station; A sewage treatment plant; and Low cost sanitation
The work of the project was carried out in two phases. The first phase (initial two and half year period) involved
development of 50 per cent of the branch sewers, main sewers, pump house including installation of machinery, pumping
main and one 12 mld capacity sewage treatment plant with the remaining part of the sewer system developed in Phase II.
The construction of underground sewerage system was done through an EPC Contract and the sewerage treatment plant
was constructed on a BOT basis. The operation and maintenance of the sewerage system including sewer lines, pump
houses, pumping plants, will be carried out by the municipality. However, the BOT contractor will operate and maintain the
sewage treatment plant during the lease period of 14 years and hand over the STP to the municipality at the end of the
lease period. The project was awarded to the IVRCL Infrastructure & Projects Ltd. In joint venture with Balcke- Durr and
Wabag technologies Ltd. based at Hyderabad in February 2000 and the agreement was signed in March 2000. Phase I of
the project has been completed. Phase II is under progress and is expected to be completed this year.
The project was estimated to cost Rs 35 crore. The collection and pumping system were financed by debt of Rs20 crore and
grant of Rs3 crore. Tamil Nadu Urban Infrastructure Development Corporation (TUFIDCO) financed 50% of project cost
through loans and grants. GoTN provided bridge financing in the sewer account during the life of the project, after
providing for O&M expenses, debt servicing and contribution to sinking fund. GoTN would pay an amount of Rs 30 per
month/ sewer connection to balance the revenue account budget of sewerage. The project mobilised one-time deposits
through connection charges from citizens. Public awareness and support was sought through an extensive communication
campaign. More than 15,000 households have contributed Rs 5,000 per household representing one third of the project
cost.
A notable feature is the tariff structure, developed on full cost recovery with cross subsidies for the poor. The
municipality collects maintenance charges fixed at Rs 150 per month per connection from domestic users, Rs 450 per
month per connection from commercial users and Rs 750 per month from industrial users. While the project faced
challenges, including delays in operator selection for O&M, miscommunication on separate upfront payment and
connection fee etc. The municipality also had to reduce maintenance charges. However, it demonstrates scope for
implementing sanitation solutions through PPP and offers useful lessons in this regard.
Decentralised systems
In most cases, the costs of decentralised systems including capital and O&M costs are generally borne by the
users. This is also because decentralised and onsite systems have often been used as a ‘coping mechanism’ in
the absence of active ULB level provision of waste-water management services and ULBs have not looked
beyond centralised sewerage system for waste water management.
It may further be useful for CoC and Government of Kerala to provide support to decentralised solutions and
some of the options could include the following:
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CoC may need to consider providing capital support for creation of decentralised solutions in areas that
are currently unserved.
At present the levels of user charges and property taxes are very low. However, when CoC graduates to
100% O&M cost recovery and to at least partial capital cost recovery, then decentralised options could be
incentivised by providing discounts to residential /commercial properties on say property tax if the
property has installed and is maintaining a well-functioning decentralised treatment system.
Similarly, the Government of Kerala could consider providing tax breaks on waste-water treatment
equipment and thereby helping reduce the overall cost-to-user.
11.5. Recommendations
These recommendations should be read along with recommendations on improving financial sustainability at a
component level that have been detailed under chapters 3-7.
1. CoC and KWA should track costs of service provision and implement processes to disseminate
information on costs of provision of all sanitation services. To start with CoC and KWA should map the
costs of service provision for all sanitation services (CoC in case of Toilet access, Storm drains and SWM
and KWA in case of water supply and sewerage) and implement accounting/costing systems to capture
the information to enable compilation and analysis of costs along the above framework. In this regard, we
recommend the following actions:
a. Map the value chain for each of the sanitation components namely water supply, sewerage and SWM
for the city and the prevailing cost centres within the water value chain.
b. Incorporate the framework in the budgeting process for the various sanitation components
c. Track and compile information on costs along the framework described and use the information in
tariff setting based on the principles and the recommendations on tariff setting given below.
d. Implement reforms relating to accrual accounting and asset accounting (including depreciation
accounting) in the water supply within the next five years to enable having a true and fair picture of
the overall financial health of the water supply system.
e. Progressively move towards organisational accountability for budgeting, managing and rationalising
costs on a continuous basis.
2. CoC and KWA in consultation with GoK should formulate and implement a progressive Tariff / User
charges policy for all sanitation services. Under JNNURM, CoC and KWA are expected to achieve 100%
O&M cost recovery and 90% collection efficiency for all sanitation services. Component specific
recommendations pertaining to user charges are also discussed in chapters 3-7 earlier. The tariff policy
should be formulated taking into account the following considerations:
a. Linkage to service levels: Even though O&M costs tend to increase year after year, it is often difficult
to convince households to absorb these tariff increases unless a base level of service levels
commitments are defined, articulated and met. User charges must therefore be progressively linked
to service level improvements.
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b. Extent of Cost recovery: At present, Reform under JNNURM currently mandates recovery of O&M
costs as a minimum. It is critical to recognise the need to move towards full cost recovery in the
medium-to-long term to enable sustainable financing of creation and maintenance of water
infrastructure.
c. Addressing affordability considerations: Provision of universal access of water supply and addressing
the needs of urban poor is a key consideration for tariff reform. This needs to be addressed through a
combination of a minimum access commitment and by exploiting possibilities for differential pricing
including ‘ability to bear’ principle for high volume users and cross subsidisation. Keeping tariffs
universally low is a regressive policy and tends to disproportionately benefit the relatively rich.
3. KWA should undertake the following measures to improve cost recovery levels.
a. Enforce meter reading and volumetric tariffs effectively;
b. Implement a user charge framework for sewerage connections. The sewerage tariffs could be charged
as a function of water tariffs.
c. Align user charges in sanitation services with cost recovery targets enunciated in CoC/KWA Tariff
Policy.
4. KWA should implement measures to improve coverage and penetration of house level water supply and
sewerage connections. Factors underlying low penetration of water and sewerage include: a) Connection
deposits being considered a deterrent, b) Procedural difficulties in getting a connection, c) Illegal
properties and inability to seek / obtain a legal connection and d) Lack of access and unhappiness with
service levels. Improving coverage would require tackling each of these issues. Our recommendations for
improving coverage flow from these issues identified and are detailed below:
a. Consider an instalment based option spread over 1-2 years for recovery of connection deposits of
water supply and sewerage connections. A number of ULBs have introduced this in the recent past
with a reasonable degree of success in improving penetration of connections.
b. Initiate/enforce the following actions to streamline the process of providing water and sewerage
connections and handling complaints to make it consumer friendly:
i. Commit and articulate service levels and timelines with respect to provision of
connection/handling complaints and disseminate the procedure widely.
iv. Initiate steps to make the process of applying for connections and filing complaints user-friendly
including allowing filing of applications/complaints online and reporting of application status /
redressal online and on telephone.
v. Incentivise adherence to committed timelines for provision of a connection by a partial / full
waiver of connection deposit in case of delays beyond the committed timelines.
vi. Track and report status of connections sought / complaints addressed on a monthly basis and set
targets to improve performance with respect to these.
vii. Further tracking and reporting this information along with the names of operating personnel
entrusted with the task, incentivises effective performance monitoring and accountability and
will minimise chances of harassment of consumers if any.
viii. De-link provision of connections from the legality of the property / construction and develop a
connection policy for provision of access to water supply and sewerage.
5. KWA and CoC should initiate specific measures to improve collection efficiency including the following:
a. Provide integrated billing and multiple payment options to customers including through a) payment
through banks b) additional facilitation / e-governance counters, c) mobile vans and door-to-door
collection drives and d) online payment options.
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b. Use a combination of rebates (for early payment) and penalties (for late payment) and create
awareness regarding these options to incentivise payment on time
c. Prepare and disseminate list of user charge defaulters online and across media. When the Municipal
Council is elected, the Top 20 default cases in each ward should be brought to notice of individual
Council members and support of the Council Members and Residents’ Welfare Associations should be
sought to resolve these cases.
d. Apart from the existing penal and enforcement provisions, CoC/WA should also as part of their
statute require clearance of user charge dues when citizens require access to other urban services
(issue of birth certificate etc.)
e. Initiate a focused one-time drive and settlement scheme to clear arrears in a focused manner.
CoC/KWA should also report details of litigation cases and the actions taken on them annually for
public dissemination.
f. A clear Accounting policy regarding provisions and writing off of bad debts should be implemented to
clean up the Arrears account.
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All Indian cities and towns become totally sanitized, healthy and liveable and ensure and sustain good public
health and environmental outcomes for all their citizens with a special focus on hygienic and affordable
sanitation facilities for the urban poor and women.
The NUSP defines sanitation as safe management of human excreta (including its safe confinement treatment,
disposal and associated hygiene-related practices). It however, recognises the need to that integral solutions
need to take account of other elements of environmental sanitation, i.e. SWM; generation of industrial and
other specialized/hazardous wastes; drainage; as also the management of drinking water supply. A totally
Sanitized City will be one that has achieved the outputs or milestones specified in the National Urban
Sanitation policy, the salient features of which are as follows:
Cities must be open defecation free
Must eliminate the practice of manual scavenging and provide adequate personnel protection equipment
that addresses the safety of sanitation workers.
Municipal wastewater and storm water drainage must be safely managed
Recycle and reuse of treated wastewater for non-potable applications wherever possible.
Solid Waste collected and disposed off fully and safely
Services to the Poor and Systems for Sustaining Results
Improved Public Health Outcomes and Environmental Standards
ACCESS TO TOILETS
Eliminate Open Defecation through provision of equitable and efficient access to public and community toilet access and
by making all citizens sanitation-conscious through sustained awareness effort
Timeframe to achieve Norms*
Parameter Unit NORM BASELINE
S M L
Open Defecation
% of population practising OD % 0% 0.4% √
No. of open urination spots Nos. 0 ~ 10 √
No. of open defecation spots Nos. 0 ~ 10 √
Toilet Coverage
Access to Public Conveniences (PC) Households/PC 100 ~ 500 √
Access to Community Toilets (CT) Slum Households/CT 15 N.A √
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WATER SUPPLY
Achieve Water Security through provision of equitable and efficient access to continuous piped potable quality water
supply in a financially environmentally sustainable manner
Parameter Unit NORM BASELINE Timeframe to achieve SLB norms
Short Medium Long
Coverage % 100% 83% √
Per Capita Supply LPCD 135 90 √
Non-Revenue Water* % 20% 60% √
Metered connections % 100% 100% √
Continuity Hours 24.00 2-4 √
Complaints Redress % 80% NA √
Quality of Supply* % 100% 58% √
Cost Recovery % 100% NA √
Collection Efficiency % 90% 22% √
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4. GoK should undertake an independent organisation assessment of CoC and KWA to identify the hierarchy,
number and scale of officers required, identification of gaps vis-à-vis existing sanctioned positions,
detailing of job descriptions and drafting / amendments to service rules in the context of changes in
requirements owing to changes in services (Onsite sanitation, door-to-door collection etc.), potential for
technology led productivity improvements (E-governance, GIS/ GPS) and growth in service demands
(growth in services as a result of increase in population in area under jurisdiction). This exercise should
also facilitate greater alignment of organisation in line with sanitation service delivery requirements.
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Access to Toilets receives highest priority in view of poor baseline and higher impact potential. Investments in
sewerage, water supply and storm drains are phased largely in the latter half of the investment program.
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Disclaimer: The report is based on information collected by IMaCS from sources believed to be reliable.
While all reasonable care has been taken to ensure that the information contained herein is not untrue or
misleading, IMaCS is not responsible for any losses that the client may incur from the use of this report or
its contents. The assessment is based on information that is currently available and is liable to change. The
analysis that follows should not be construed to be a credit rating assigned by ICRA’s Rating Division for
any of the company’s debt instruments. IMaCS is not a legal firm and our advice/recommendations should
not be construed as legal advice on any issue.
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