RTI for HSPCB — Haryana Pollution Control Board: Factory Consents, Air Quality and Complaint Records

The Haryana State Pollution Control Board (HSPCB) is the statutory environmental regulator for all of Haryana, constituted under the Water (Prevention and Control of Pollution) Act, 1974, and empowered further under the Air (Prevention and Control of Pollution) Act, 1981, and the Environment (Protection) Act, 1986. HSPCB issues Consent to Establish and Consent to Operate orders to every polluting industry in Haryana, monitors compliance with consent conditions, responds to public pollution complaints, operates ambient air quality monitoring stations (including CAAQMS under the national network in the NCR belt), monitors river water quality, and takes enforcement action — from show-cause notices to closure orders and penalty proceedings. HSPCB is headquartered at Bays 5–6, Sector 5, Panchkula, and maintains regional offices across the state.

As a state public authority under Section 2(h) of the Right to Information Act, 2005, HSPCB is legally obligated to respond to RTI applications within 30 days of receipt. For matters directly affecting life or liberty — such as ongoing discharge of toxic effluent into a drinking water source — the response is due within 48 hours under the proviso to Section 7(1). Citizens, environmental journalists, community advocates, researchers, and businesses can use RTI to bring HSPCB's records into the public domain: factory consent orders, pollution complaint outcomes, air quality monitoring data, Yamuna water quality reports, and the enforcement history of specific industries operating in Haryana.

Why RTI Matters for Haryana's Industrial and Environmental Context

The NCR Belt: Gurugram, Faridabad, Sonipat, and Manesar

Haryana's eastern and northern fringe forms a critical segment of the National Capital Region (NCR). Gurugram, Faridabad, Sonipat, Panipat, Manesar, Palwal, and Jhajjar are consistently among India's most severely polluted urban areas by PM2.5 and PM10 concentrations during winter months.

Gurugram hosts the largest concentration of auto ancillary units, auto component manufacturers, and logistics warehouses in India, clustered in IMT Manesar, the Udyog Vihar industrial estates, and various sector-based industrial plots. These units operate paint booths, welding shops, forging and casting facilities, electroplating lines, and chemical storage depots — all regulated under HSPCB consent. Alongside the manufacturing cluster, Gurugram's rapid IT and commercial growth has brought in diesel generator sets and construction activity. CAAQMS stations at multiple Gurugram locations provide real-time air quality data; RTI can reveal whether HSPCB's enforcement actions against non-compliant industries track with periods when CAAQMS readings exceeded NAAQS (National Ambient Air Quality Standards).

Faridabad's manufacturing cluster — engineering goods, rubber products, chemicals, fabricated metals, paper and packaging — is one of Haryana's oldest and most dense industrial zones. Industrial areas along the Mathura Road (NH 19), Ballabhgarh, and the Old Faridabad sector industrial belt have been the subject of repeated complaints from residents and NGOs regarding effluent discharge into drains and ambient dust from factories without proper emission control. RTI with HSPCB's Faridabad regional office can yield inspection records, consent status of specific units, and action taken on registered complaints.

Sonipat's IMT (Integrated Manufacturing Township) and its industrial zones near Kundli and along the GT Road host pharmaceutical, food processing, light engineering, and auto component industries. Manesar, administratively in Gurugram district, is a dense auto manufacturing cluster anchored by Maruti Suzuki and its supply chain — hundreds of Tier-1 and Tier-2 vendors operate in its industrial estates.

Yamuna Contamination: Panipat, Yamuna Nagar, and Upstream Industrial Load

The Yamuna enters Haryana at Yamunanagar district and traverses the state before entering Delhi. By the time it exits Haryana, it carries industrial and agricultural effluent from some of India's most concentrated polluting clusters.

Yamuna Nagar paper mills: Yamuna Nagar district hosts a cluster of large paper mills — Jagadhri and Yamuna Nagar — that have historically been among the Yamuna's most significant industrial polluters. Pulp and paper manufacturing generates large volumes of black liquor, bleaching effluent, and biological oxygen demand-laden wastewater. HSPCB issues CTO orders to these mills and monitors their compliance. RTI can reveal the consent conditions attached to the paper mills, the treated effluent quality they are permitted to discharge, HSPCB's inspection findings, and whether closure directions have been issued and complied with.

Panipat dyeing and textile cluster: Panipat is one of India's largest textile recycling and dyeing centres. Hundreds of dyeing and processing units generate heavily coloured, chemically contaminated effluent. While a Common Effluent Treatment Plant (CETP) exists, its performance record — influent vs. effluent quality, BOD and COD reduction, colour removal — is a matter of ongoing regulatory scrutiny. RTI to HSPCB can yield CETP compliance audit reports, treated effluent quality data submitted to HSPCB, and the consent status of individual dyeing units.

Panipat Refinery: The Indian Oil Corporation Panipat Refinery and Petrochemical Complex is one of India's largest refineries. As a Red category industry, it operates under strict HSPCB consent conditions for air emissions, effluent discharge, and hazardous waste management. RTI can provide HSPCB's inspection records, consent conditions for the refinery, and any enforcement notices issued.

NCR Stubble Burning and HSPCB's Winter Action Plan

Haryana is the second-largest contributor to NCR stubble burning after Punjab. While stubble burning is primarily enforced through the Agriculture Department and district administrations, HSPCB plays a role in coordinating the winter air quality action plan, implementing Graded Response Action Plan (GRAP) directions issued by the Commission for Air Quality Management in NCR and Adjoining Areas (CAQM), and directing industrial units in the NCR to reduce emissions during high-pollution episodes (Stages III and IV under GRAP). RTI can reveal HSPCB's communication with CAQM, the list of industries directed to shut down or curtail operations during GRAP Stage III/IV periods, and compliance records for those directions.

HSPCB Structure and Regional Offices

HSPCB is headquartered in Panchkula and is administered by a Board of Members drawn from state government departments. The day-to-day administration is led by the Chairman and Member Secretary. For RTI purposes, the CPIO is at the Panchkula head office for state-level and aggregate data.

For factory-specific and complaint-specific records, HSPCB's regional offices are the appropriate filing addresses:

• Faridabad Regional Office — covers Faridabad and Palwal districts (NCR manufacturing cluster, Ballabhgarh industrial area)
• Gurugram Regional Office — covers Gurugram, Nuh, Rewari, and Jhajjar districts (Manesar auto cluster, Udyog Vihar, IMT Manesar)
• Ambala Regional Office — covers Ambala and Kurukshetra districts
• Karnal Regional Office — covers Karnal and Panipat districts (Panipat refinery, dyeing cluster, Yamuna Nagar paper mills)
• Rohtak Regional Office — covers Rohtak, Jhajjar, and Bhiwani districts
• Sonipat Regional Office — covers Sonipat, Jind, and surrounding areas (IMT Sonipat, Kundli industrial zone)
• Hisar Regional Office — covers Hisar, Fatehabad, Sirsa, and Hissar division industries

If you are unsure which regional office covers your district, file your RTI with the CPIO at the Panchkula head office. Under Section 6(3) of the RTI Act, the head office CPIO is obligated to transfer the application to the regional office that holds the relevant records within five days, notifying you of the transfer.

What RTI Can Obtain from HSPCB

Consent to Establish (CTE) and Consent to Operate (CTO)

Every industry in Haryana that potentially pollutes air or water is required to obtain CTE before construction and CTO before commencing operations. CTOs are renewed periodically — typically every one to five years depending on the industry category.

Through RTI, you can obtain:

• Certified copy of the CTE and CTO issued to a named factory, with all conditions — effluent discharge limits, stack emission standards, ETP specifications, green belt requirements, and monitoring obligations
• Confirmation of whether the CTO of a specific factory is currently valid or has lapsed without renewal
• Details of any expansion consent granted or refused to a unit seeking to increase capacity
• Consent categorisation of the unit (Red, Orange, or Green) and the rationale for the classification

Industries operating with lapsed CTO are in violation of both the Water Act and the Air Act. RTI that documents a lapsed consent is the starting point for a formal complaint to HSPCB, a complaint to the National Green Tribunal (NGT), or a writ petition to the Punjab and Haryana High Court.

Pollution Complaint Action-Taken Reports (ATRs)

When a citizen files a pollution complaint with HSPCB — whether through the head office, the regional office, the HSPCB website's online complaint portal, or the Central Pollution Control Board's complaint management system — HSPCB is expected to inspect the facility and record its findings in an Action-Taken Report.

RTI can compel disclosure of:

• The ATR for a specific complaint, including whether an inspection was carried out, what the inspector observed, what samples were collected and what laboratory results showed, and what regulatory action was initiated
• Show-cause notices issued to the factory following the complaint
• The factory's reply to the show-cause notice and HSPCB's final order on the matter
• Whether a complaint was closed without action, and the basis for such closure

ATRs are among the most directly useful documents for communities affected by factory pollution — they document whether the regulator responded, what it found, and whether it acted.

Ambient Air Quality Monitoring Data — NCR CAAQMS Stations

HSPCB operates or coordinates Continuous Ambient Air Quality Monitoring Stations (CAAQMS) at several locations across Haryana, with the greatest density in the NCR districts. These stations record PM2.5, PM10, SO2, NO2, CO, and ozone concentrations in near-real time. RTI can provide:

• Station-wise ambient air quality data for named CAAQMS or manual monitoring locations in Gurugram, Faridabad, Sonipat, Manesar, Panipat, and other districts
• Monthly, quarterly, or annual averages and peak readings for each pollutant parameter
• Exceedance data — the number of days per year on which PM2.5 or PM10 levels exceeded NAAQS standards
• Comparison data for industrial areas versus residential monitoring points, useful for establishing the contribution of industrial clusters to ambient concentrations

This data, when cross-referenced with CAQM and CPCB's published data, provides a factual basis for advocacy about industrial pollution in specific Haryana districts.

Yamuna River Water Quality Monitoring Data

HSPCB monitors water quality at designated stations on the Yamuna and its tributaries. RTI can provide:

• Water quality monitoring data at named stations — covering parameters such as BOD (Biochemical Oxygen Demand), COD (Chemical Oxygen Demand), dissolved oxygen, total dissolved solids, pH, coliform bacteria, and heavy metals including chromium, lead, mercury, and cadmium
• Trend data over multiple years — whether Yamuna water quality upstream, within, and downstream of industrial clusters is improving or deteriorating
• Data from effluent sampling of specific drains discharging into the Yamuna, documenting the source of industrial load
• Monitoring reports for the Ghaggar river system (relevant for Ambala, Panchkula, and Hisar districts where HSPCB also has monitoring responsibilities)

CETP Compliance and Industrial Cluster Effluent Treatment

For industrial clusters that operate Common Effluent Treatment Plants — Panipat dyeing, various industrial estates — HSPCB holds compliance records including:

• Influent and treated effluent quality data from CETP laboratories, and whether effluent meets prescribed discharge standards before it reaches drains and water bodies
• CETP compliance audit reports conducted by HSPCB
• Records of CETP units that have been issued directions or show-cause notices for non-compliance
• The list of member industries connected to a CETP and their individual contribution to the shared effluent load

Penalty Orders, Closure Directions, and Enforcement Records

• Copies of closure directions issued under Section 33A of the Water Act or Section 31A of the Air Act against named industries in a given district or industrial area
• Penalty orders issued under the Environment (Protection) Act, 1986 and the amounts collected
• List of industries sealed or directed to cease operations during GRAP Stage III/IV NCR pollution emergency measures
• Records of industries that were previously closed and subsequently allowed to reopen, with the compliance conditions attached to the reopening

Self-Monitoring Reports and Online Continuous Effluent Monitoring Data

Red category industries in Haryana are required to install online continuous effluent monitoring systems (OCEMS) linked to HSPCB's central server. RTI can reveal:

• Whether a named Red category factory has installed and operationalised its OCEMS
• Data downloaded from OCEMS showing real-time treated effluent quality — and whether it consistently meets consent conditions or shows periodic exceedances
• Stack emission monitoring data submitted by industries to HSPCB under their consent conditions

How to File RTI with HSPCB

Step 1: Identify the Factory, Records, and Time Period

Before filing, be specific about:

• The registered name of the factory — not just a colloquial name or the name the neighbourhood uses. HSPCB's records are indexed by the factory's registered name and address. If you only know the factory colloquially, note its GPS coordinates or the Survey/Plot Number to help identify it.
• The type of records — consent order, inspection report, ATR on a complaint, water quality data, penalty order. Each category is stored separately.
• The time period — specify the financial year or a calendar date range. Requests without a time boundary are difficult to process and easier for the PIO to deflect.
• The complaint number, if you are following up on a previously filed pollution complaint.

Step 2: Draft Your Application

Use the sample RTI at the top of this guide as a template. Number each point separately — mixing multiple requests into a single sentence creates ambiguity that reduces the quality of the response.

For ambient air quality data requests, name the specific CAAQMS station by its location. For Yamuna water quality, name the monitoring station (e.g., "upstream of Yamuna Nagar industrial area at village name"). Specificity makes it harder for HSPCB to claim it does not hold the records you have requested.

Step 3: File Online at rtionline.haryana.gov.in

Haryana operates its own state RTI online portal at rtionline.haryana.gov.in. This is the recommended route for filing RTI with HSPCB:

1. Register or log in at rtionline.haryana.gov.in
2. Select Haryana State Pollution Control Board (HSPCB) from the public authority list — if filing with a specific regional office, select the appropriate regional designation
3. Type or paste your numbered application text
4. Pay the ₹10 fee online by debit card, credit card, or net banking
5. BPL cardholders can claim fee exemption by uploading a self-attested copy of their BPL ration card
6. Note the registration number for tracking purposes

Online filing creates an immediate digital receipt, a tracking number, and a documented timeline — all of which are valuable for First Appeal purposes if HSPCB delays or refuses to respond.

Step 4: File by Post (Alternative)

If online filing is not available or preferred, send your written, signed application by speed post or registered post to:

The CPIOHaryana State Pollution Control Board (HSPCB)Bays 5–6, Sector 5, Panchkula – 134109, Haryana

Or, for factory-specific and complaint-specific records, to the relevant regional office CPIO (Faridabad, Gurugram, Karnal, Rohtak, Sonipat, Hisar, or Ambala).

Enclose a ₹10 Indian Postal Order (IPO) drawn in favour of the Accounts Officer, HSPCB, or as directed on the HSPCB website. Retain your speed post receipt — it is your proof of filing date and the starting point for calculating the 30-day response period.

Key RTI Act Provisions for HSPCB Applications

• Section 2(h): HSPCB is a public authority — a statutory body constituted under the Water Act, 1974, substantially funded from the Consolidated Fund of Haryana and by consent fees levied on industries.
• Section 2(f): Consent orders, inspection reports, ATRs, monitoring data, CETP records, penalty orders, and OCEMS data are all "information" as defined — material held by or under the control of HSPCB.
• Section 6: The procedure for filing your RTI application with the prescribed fee of ₹10.
• Section 7(1): HSPCB must respond within 30 days of receipt; within 48 hours where the information relates to the life or liberty of a person — applicable, for example, when ongoing discharge of toxic effluent threatens a community's drinking water supply.
• Section 19(1): First Appeal to the First Appellate Authority within 30 days.
• Section 19(3): Second Appeal to the Haryana State Information Commission (HSIC) within 90 days.
• Section 20: Penalty of ₹250 per day (up to ₹25,000 maximum) on the PIO personally for unjustified refusal, unexplained delay, or furnishing of false or misleading information.

First Appeal — Section 19(1)

If HSPCB does not respond within 30 days of receipt, or if the response is incomplete, evasive, or unsatisfactory, file a First Appeal under Section 19(1) within 30 days of the date of decision or expiry of the 30-day response period, whichever is applicable. Address it to the First Appellate Authority (FAA) within HSPCB — typically the Member Secretary or Chairman at the Panchkula headquarters, or the Regional Officer for a regional office RTI. No fee is required for the First Appeal.

In your First Appeal, include:

• Your original RTI registration number and the date of filing
• A copy of your original application
• A clear statement of what information was not provided, what was provided incompletely, or what was incorrectly withheld
• The specific exemption (if any) claimed by HSPCB in its refusal, and why that exemption does not apply

The FAA must decide within 30 days, extendable to 45 days with recorded reasons.

Second Appeal — Section 19(3) — Haryana State Information Commission (HSIC)

If the First Appeal is unsatisfactory, unanswered, or the FAA's order is inadequate, the Second Appeal under Section 19(3) lies with the Haryana State Information Commission (HSIC) — not the Central Information Commission (CIC). HSPCB is a Haryana state authority. The HSIC is the correct second-appeal body for all Haryana state public authorities. Filing a Second Appeal with the CIC against HSPCB would be dismissed for lack of jurisdiction.

File the Second Appeal with HSIC within 90 days of the FAA's order or the expiry of the FAA's response deadline. The HSIC can:

• Direct HSPCB to provide the information
• Impose a personal penalty under Section 20 on the CPIO for unjustified delay or refusal
• Award compensation to the applicant for loss suffered due to wrongful non-disclosure
• Recommend disciplinary proceedings in cases of persistent or malafide non-compliance

Section 20 Penalty — Holding the PIO Accountable

If HSPCB's CPIO unjustifiably refuses information, gives incomplete or misleading responses, or fails to respond within 30 days without reasonable cause, the HSIC can impose a penalty of ₹250 per day (up to ₹25,000 maximum) on the CPIO personally under Section 20(1) of the RTI Act. In your Second Appeal, explicitly request that HSIC consider imposing a Section 20 penalty if the delay or refusal was unjustified. This request prompts the HSIC to actively consider the penalty question rather than merely ordering disclosure.

Practical Tips for Effective HSPCB RTI Applications

1. Name the factory precisely. HSPCB registers consent orders and inspection records by the factory's legal registered name. Writing "the factory behind Sector 58, Gurugram" is far less effective than "M/s XYZ Auto Components Pvt. Ltd., Plot No. 12, IMT Manesar, Gurugram." If you have the HSPCB consent number from the nameplate visible at the factory gate, include it — this eliminates all ambiguity.

2. Quote your complaint number. If you previously filed a pollution complaint with HSPCB (through its website, by post, or through CPCB's Prakriti app or similar complaint channel), always reference the complaint number in your RTI. "Action-taken report on Complaint No. HSPCB/2024/XXXXX" is precise and leaves no room for HSPCB to claim it cannot trace the complaint.

3. Separate your requests by category. Consent records, inspection reports, water quality data, and penalty orders are stored differently. A single request combining all four types may result in a partial response that conflates different categories. Number each item separately and ask for one specific document or dataset per numbered point.

4. Specify financial years for monitoring data. Ambient air quality and river water quality monitoring data are typically compiled and reported on a financial year basis. Asking for data "for the financial year 2024–25" is clear and follows the format in which HSPCB compiles its records.

5. NCR industries are subject to CAQM directions. For Gurugram, Faridabad, Sonipat, and other NCR districts, HSPCB is required to implement directions from the Commission for Air Quality Management in NCR and Adjoining Areas (CAQM). RTI to HSPCB can reveal: the list of Red category industries directed to install dust control systems under CAQM orders, the list of industries directed to shut down during GRAP Stage III or Stage IV, compliance records for those directions, and HSPCB's monitoring reports submitted to CAQM. This data is not on any public dashboard and is only accessible through RTI.

6. CETP performance is the key variable for Panipat dyeing. The Panipat dyeing cluster's CETP performance determines whether Yamuna tributaries receive treated or untreated effluent. Ask HSPCB specifically for the CETP's influent and effluent quality data by month, not just annual averages — monthly data often reveals seasonal non-compliance that annual averages obscure.

7. Yamuna Nagar paper mills and consent compliance history. The paper mills at Yamuna Nagar have been the subject of NGT and High Court proceedings over several years. Asking for the consent compliance history — including all show-cause notices, directions, and closure orders from the past five years — provides the full regulatory timeline and reveals whether HSPCB has enforced the orders it issued or allowed repeated violations.

8. HSPC second appeal goes to HSIC, not CIC. This is the single most common error made by applicants who are familiar with Central Government RTI processes. HSPCB is a Haryana state authority. Second appeals go to the Haryana State Information Commission (HSIC) at Panchkula — not to the Central Information Commission in New Delhi.

9. Cross-reference with CPCB's Grossly Polluting Industry (GPI) list. For the most important industrial polluters on the Yamuna — particularly in the Panipat and Yamuna Nagar clusters — CPCB maintains a list of Grossly Polluting Industries. Industries on this list are subject to additional CPCB monitoring. A parallel RTI to CPCB (via rtionline.gov.in, second appeal to CIC) for CPCB's own inspection and monitoring data for these Haryana units, combined with RTI to HSPCB for state-level consent records, gives the most complete picture of regulatory compliance and failure.

10. Lapsed CTO is a common and actionable violation. Many industrial units — particularly in older industrial areas in Faridabad and the unplanned industrial clusters around Gurugram — operate with CTO orders that have lapsed and not been renewed. RTI confirming a lapsed consent is direct evidence of an ongoing statutory violation. This can form the basis of a complaint to HSPCB's Chairman, a complaint to CAQM for NCR industries, or a petition to the Punjab and Haryana High Court's Green Bench.

The Right to Information Act is among the most effective legal tools available to communities, journalists, environmental lawyers, and civic organisations to hold HSPCB accountable for its regulatory mandate in one of India's most industrially dense and environmentally stressed states. Haryana's air — particularly in the NCR belt — and its share of the Yamuna's health are matters of urgent public interest. Where regulatory records are withheld or enforcement is absent, RTI provides the documented foundation for accountability.