18.02.

2019
Note on matter related to STP
State Level Environment Impact Assessment Authority ,Karnataka vide their letter
dated 28.12.2010 & dated 13 Aug 2013 gave Environmental Clearance for
construction and operation of Sewerage Treatment Plant in Sobha city ; with the
following conditions
Conditions -During construction phase :
Point 34.The project authority shall maintain and operate the common
infrastructure facilities created including STP and solid waste management
facility for a period of at least 5 years after commissioning the project.
Point 35.The project authority shall incorporate a suitable condition in the Sale
Agreement/Deed to be made with the buyers that the occupier/buyer holds the
responsibilities jointly with other users to maintain common infrastructure facilities
created including STP and solid waste management facility.
Conditions-During Operation Phase :
The installation of the Sewage Treatment Plant (STP) of total capacity 2,000 KLD (4
X 500 KLD) should be carried out before the construction of the second floor of
the main structure is commenced and the plant shall be got certified by an
independent expert and a report in this regard should be submitted to the SEIAA
immediately. Discharge of treated sewage shall conform to the norms & standards of
the Karnataka State Pollution Control Board.
Our observation on above conditions: Even though point 34 stipulates that project authority
shall maintain the STP for 5 years , the next sentence on point 35 states that the buyer is
equally responsible
Sobha has mentioned that they needed to commission the STP in 2014 itself to follow
environmental clearances
The STP was commissioned prior to Mykonos block was ready for occupation After
inspection by KPSCB officials , the consent order for discharge of sewerage was issued by
KSPCB vide consent order # PCB/60/CN/10/4332 dated 27 Nov 2015, valid upto
30.9.2017
On 12 th of July 2017 , Sobha has written a letter to SCAOA about closure of defect liability
period for SL on club house and STP ( 2 nd July 2016 to -1 July 2017 ) .In 2019, Sobha
confirmed to have completed 5 years of operation as stipulated after commissioning .
The combined consent order for 1958 Apartments was issued by KSPCB (vide order #
AW 311772 dated 28.03.2019 ) for discharge of treated sewerage water. The order gives
consent “to the occupier to operate “ and discharge the effluents /treated water. And is
valid upto 30.06.2022.
Action by SCAOA on STP was necessitated on following grounds :
The STP operations and maintenance had several complaints during the years 2017-2019
and several mails were received by Apex that there were worms and flush water was turbid,
discoloured etc .
When the Club house Facility Manager(of Sobha limited) was asked to reply against the
complaints , he/ Sobha limited started seeking approval for expenditure from the Apex
members towards breakdown maintenance of equipment such as blowers and pumps .
Apex debated the matter . A couple of members wanted Sobha to address the issue of
handling the STP and started suspecting even the capacity of STP .
In the larger interest of the people residing at Sobha city , Apex formed a sub
committee to look into the matter .
As communicated to residents in Apex news letter in June 2019 ,the committee engaged
an external consultant to evaluate the design ,construction and performance of STP and
submit a report . It was also communicated in the news letter that after evaluation and
rectification if any , Apex is planning to engage an expert agency to operate the STP.

I would like to add that : whether it is Sobha or any external agency operating the STP, the
cost of operation and maintenance of the STP equipment (preventive / refurbishment) has to
be paid by SCOA as per our agreements with the builder . Hence , moving from Sobha to
external agency is cost neutral
In the news letter dated Aug 2019 , findings of the expert committee was published to the
residents . Apex wrote to SL to take up rectification suggested for which SL refuted the
need for any need for upgradation
Sobha limited wrote to Apex that they are withdrawing the Facility manager posted at
Sobha city . As communicated to residents , Apex ,after evaluating 3 parties , engaged
ION Exchange India Limited , a veteran in the field of water management to operate the
STP in Nov /Dec 2019
On Dec-10 2019 it was observed STP water was building up rapidly and leading to flooding
of the pump room. STP being a very important asset for Sobha City and processes all its
sewage/effluents, it was decided to take immediate actions to engage an external agency for
dewatering and putting the equipment and processes back in order. Normal operations were
restored within a week with minimal or no impact to residents day to day activities.

On investigating the root cause, It was noted that couple of garden water pumps (including
the redundant one )had failed and operations team had failed to put it in order or make
alternate arrangements in a timely manner.

Approximately 3.5L INR in consequential damages are being recovered from ION Exchange,
and in a recent meeting it was agreed to recover this as part of their operational invoice.

STP consists of several pumps, motors and controls that need to be operated 24x7 for
continuous and effective operation of the plant. Apex has initiated preventive maintenance
and refurbishment (as needed) for all STP pumps and equipment. We have re-assessed the
manpower requirements based on our review of the operations and have taken corrective
measures to ensure better upkeep of the STP
The periodic maintenance schedule of Sobha is not clear despite follow up, So it's important
now to proceed with this activity without dependence on SL. This activity is done in a phased
manner and simultaneously sufficient stock of spares are being built up at the STP to
facilitate rapid repairs as necessary. This activity should be completed by Feb-March 2020
timeframe.

If budget permits we will reconsider a comprehensive AMC contract for STP maintenance .
Currently this is under discussion and consideration.. We shall continue to bring in possible
improvements and also follow up on open points with Sobha limited .

We request residents to use water judiciously, it impacts both the cost of water consumed
and pressure on the STP in treating the effluents.

Note on other matters concerning the builder

Apex had approached Sobha limited on certain other pending matters and had a round of
meeting on 5 th dec 2019 , but the discussions were not conclusive
SCAOA has approached Karnataka Real Estate Regulation Authority , vide complaint #
3946/2019 for adjudication on matters related to Sobha city , seeking relief . Case has been
admitted and will come up for hearing by the full tribunal bench of 3 judges
Secretary -SCAOA
PVB