Lake - AG - Karnataka PA Report
Lake - AG - Karnataka PA Report
Lake - AG - Karnataka PA Report
Government of Karnataka
Report No.1 of the year 2015
Table of contents
TABLE OF CONTENTS
Page
Chapter Contents
Number
Preface iii
Executive summary v
I Introduction 1
II Audit approach 3
Section I Effectiveness of institutional mechanism and legal
framework for long-term environmental sustainability of lakes
III Effectiveness of institutional mechanism and
legal framework in conservation and restoration 7
of lakes
Section II Effectiveness of survey and demarcation of lakes
IV Effectiveness of survey and demarcation of
17
lakes
Section III Effectiveness of the initiatives to restore water quality and
maintain ecological health of the lakes
V Efforts and initiatives to restore water quality in
23
lakes
VI Biodiversity of water bodies 39
Section IV Lake specific findings of 12 test-checked lakes
VII Lake specific findings of 12 test-checked lakes 45
VIII Conclusion 54
Appendices 57
Glossary 68
LIST OF APPENDICES
Appendix Page
Details
Number Number
3 Sampling methodology 59
1. This Report of the Comptroller and Auditor General of India for the year
ended March 2014 has been prepared for submission to the Governor of
Karnataka under Article 151 (2) of the Constitution of India for being laid
before the State Legislature.
Executive summary
Lakes and reservoirs which are crucial for human survival are facing
degradation all over the world. Deterioration of water quality, loss of
biodiversity and fast depletion of water resources are the main challenges
which need urgent attention. Further, urbanisation has increased pressure on
water bodies with increasing demand on land for infrastructural needs.
Neither the Karnataka State Pollution Control Board nor the implementing
agencies had complete data on the pollution levels in the lakes. The
assessment of pollution was inadequate and the water quality of none of the
test-checked lakes conformed to the prescribed standard. Major source of
pollution in Bengaluru was sewage which could not be regulated by Bengaluru
Water Supply and Sewerage Board. The construction of underground
drainage lines to convey sewage was still under progress and the treatment of
sewage was inadequate. The diversion of sewage, due to it being untreated,
from the inlets to the waste weir of the lakes resulted in drying up of lake
beds, and loss of its ecological characteristics.
(Chapter VI)
Lake specific findings of the 12 test-checked lakes indicated that in most cases
restoration works were carried out without arresting sewage flowing into the
lakes and water quality was not being monitored. Works were also undertaken
without removal of encroachments.
(Chapter VII)
Chapter I
Introduction
1 Background
Due to rapid urbanisation and change in land use pattern, the lake areas
including catchment areas have been encroached in many cases. This led to
reduced inflow of water into lakes, thereby resulting in numerous lakes being
lost over the years. Many lakes have lost even their original characteristics.
Some of the prominent lakes that have lost their characteristics are given in
Appendix 1.
Owing to the above reasons, the State Government felt the necessity to
constitute (July 1985) an expert committee (headed by Shri. N. Lakshman
Rau, IAS (Retired)) to look into various aspects relating to preservation and
restoration of the existing lakes/tanks. The Committee, inter alia,
recommended that efforts should be made to ensure that these lakes are not
breached but retained as water bodies. Lakes should not be polluted by
discharge of sewage, effluent and industrial wastes; off-shore area of lakes
should be protected and suitable areas adjoining the lakes should be earmarked
for recreational and tourism activities. They also recommended the
construction of more tanks along the natural valleys which have a run-off.
The State Government accepted (1988) the recommendations made by the
Committee. Important recommendations of this Committee are mentioned in
Appendix 2. The State Government also constituted (July 2002) the Lake
Development Authority (LDA) registered under the Societies Act to regulate
and monitor the conservation, rejuvenation and restoration of lakes.
Despite the above measures, encroachments and pollution in lakes could not
be contained, leading to several public interest litigations. The Hon’ble High
Court of Karnataka, as part of its proceedings, appointed (November 2010) a
Committee headed by Justice N.K. Patil and officers from the State
Government as members, to examine the ground realities and prepare an
1
A publication by Shri. Pratap K. Mohanty, Department of Marine Sciences, Berhampur
University, Berhampur, Orissa
2
A study report submitted to Infrastructure Development Department, Government of
Karnataka by Infrastructure Development Corporation (Karnataka) Limited to assess the
feasibility of conserving lakes in Karnataka
action plan for restoration and preservation of lakes. The Committee prepared
a strategic plan for various entities to restore lakes in terms of the decision of
the Hon’ble High Court of Karnataka in Writ Petition No.817/2008. Based on
the decision of the Hon’ble High Court of Karnataka (April 2012), the State
Government constituted (May 2013) various committees including an Apex
Committee to monitor the conservation and restoration works of lakes.
Chapter II
Audit approach
2.1 Audit objectives
¾ whether the survey and demarcation of lakes were effectively carried out
and action to prevent encroachments and diversions were effective; and
The performance audit for the period 2009-14 covered the activities relating to
conservation and restoration of lakes in Revenue Department, Forest
Department, Urban Development Department (UDD), and Fisheries
Department. The role of various implementing agencies under these
departments namely, LDA, Bruhat Bengaluru Mahanagara Palike (BBMP),
Bengaluru Development Authority (BDA), two City Corporations (CCs)
(Belagavi and Hubballi-Dharwad), Karnataka State Pollution Control Board
(KSPCB) and Bengaluru Water Supply and Sewerage Board (BWSSB) has
also been covered in the performance audit.
3
A Centrally Sponsored Scheme exclusively aimed at restoring the water quality and ecology
of lakes in urban and semi-urban areas
4
Government of India Scheme for conservation of wetlands to benefit the local communities
and biodiversity
The Exit Conference was held on 2 February 2015 and the details of
discussion have been appropriately incorporated wherever applicable.
The audit criteria for the performance audit were derived from the following
sources:
¾ Shri Lakshman Rau Committee Report and Hon’ble Justice N.K. Patil
Committee Report
2.5 Acknowledgement
The audit findings have been organised into three sections which are aligned
to the three audit objectives set for the performance audit. An additional
section has been devoted to lake specific findings of 12 lakes. The sections
are as under:
Chapter III
Effectiveness of institutional mechanism and legal framework
in conservation and restoration of lakes
3.1 Entities involved in conservation and restoration of lakes
Government of Karnataka
¾ The office of LDA is situated at Bengaluru and it does not have any branch
offices though its jurisdiction is spread over other areas of CCs and CMCs
in the State.
¾ It operates with skeletal staff which has not been reviewed by the State
Government since its inception in 2002.
¾ LDA does not have any statutory powers. As a result, laxity in exercise of
powers conferred as per Bye-law was observed.
¾ Environmental Planning was one of the objectives for which LDA had
been constituted. LDA had not undertaken any integrated planning in
association with all the entities involved in restoration of lakes.
The KSPCB was required to assess the quality of water in the lakes
periodically and report to the concerned agencies for taking follow up action.
The agency was to levy penalties on the polluters of lakes.
¾ Audit observed that KSPCB monitored pollution levels in only 120 lakes
out of 36,568 in the entire State which included 48 lakes in Bengaluru
City.
¾ With regard to levy of penalties and action taken against polluters, KSPCB
replied (May 2014) that they had filed a criminal case against BWSSB.
However, no action was taken against the polluters of the lakes such as
residential apartments which were pumping sewage directly into lakes like
Horamavu-Agara Lake.
KSPCB stated (May 2014) that due to shortage of manpower and funds, the
quality of water was not assessed in all lakes. The reply is not acceptable as it
was the duty of KSPCB to perform its job properly and ensure adequate
manpower by taking up the matter with the State Government.
The department stated (January 2015) that action is being initiated to create a
separate cell with dedicated surveyors to complete the survey of lakes.
Most of the lakes in Bengaluru were under the custody of BBMP and BDA.
The lakes in ULBs (CCs and CMCs) outside Bengaluru were under the
custody of the respective Deputy Commissioners (DCs). The DCs were
responsible for development and restoration of lakes under their jurisdiction.
¾ There are six lake series in Bengaluru, each of which consists of a set of
lakes. The restoration works in the lake series should be such that works
in a downstream lake should be carried out after completion of restoration
works of its upstream lake. This will ensure that the outflow of the
upstream lake which flows into the downstream lake is free from pollution.
However, it was observed that the distribution of lakes in the lake series
was such that the upstream lake and the downstream lake was given to two
different entities (BBMP and BDA) and restoration works were carried out
independently without any coordination between the two agencies for
ensuring proper planning and execution.
¾ As per the 2010 order, BDA was to transfer the lakes under their
jurisdiction to BBMP for maintenance, as and when the developmental
works were completed by BDA. However, even after communicating the
completion of the development works, the transfer had not been effected
till date (February 2015) citing financial constraints by BBMP. Of the
test-checked lakes, it was observed that in three5 lakes, BDA had incurred
an expenditure of `30.31 crore for their restoration. However, since the
lakes had not been transferred from BDA to BBMP as per the above order,
the jurisdiction for maintaining the lakes was with neither of these
agencies, resulting in their maintenance being neglected.
¾ There were cases of damage caused to fencing around lakes as can be seen
from the photographs given below. BBMP had not engaged watch and
ward staff in all the restored lakes. BBMP replied (February 2015) that
miscreants were entering the lake area and stealing the fence materials.
This indicated that there were inadequate security measures for protecting
the assets related to the lakes.
5
Jakkur-Sampigehalli, Rachenahalli and Venkateshpura
Adequacyofinformationonpublicdomain
Adequacy of information in public domain
(Custodian/expenditureonrestoration
about the lakes 29 27
works/statusofpollution/encroachments,
(Partially available/Not available)
etc.)(Available/Partiallyavailable/Not…
Formation of Lake Management
FormationofLakeManagement
Committees
56
Committee(Constituted/Notconstituted)
(Constituted/Not constituted)
Involvement of NGOs/Voluntary
InvolvementofNGOs/Voluntary
organisations in restoration/maintenance of 2 54
organisations/Adoptionoflake(Yes/No)
lakes
(Yes/No)
0 10 20 30 40 50 60
Number of lakes
¾ Under the Public Disclosure Law, the ULBs were required to disclose the
names of the existing water bodies like lakes, tanks, ponds, custodians of
¾ There was no single window agency to address the issues and grievances
of public on lakes. The necessity of a single window agency was
expressed by two Non-Governmental Organisations (NGOs) which were
involved in maintenance of two test-checked lakes (Kaigondanahalli and
Chinnappanahalli). BDA stated (February 2015) that the matter would be
taken up at State Government level to constitute a single window agency
for grievance redressal mechanism.
6
Bairasandra Kelaginakere, Challakere, Kenchanahalli (Bachikere), Kundalahalli,
Mahadevapura and Sheelavanthana
7
such as dumping of construction debris, burial of dead bodies in lake area, trespassers, etc.
The State Government had constituted (May 2013) an Apex Committee, sub-
committees, and district level committees to oversee and supervise the
restoration and maintenance of lakes in Bengaluru Metropolitan Areas, CCs
and CMCs.
¾ The Apex Committee had not called for periodical progress reports on
restoration works from the implementing agencies. None of the
implementing agencies had any methodical system of inspections and
reporting.
¾ LDA had not inspected (2009-14) any lake except 747 lakes in Bengaluru
(Urban) district.
The various entities responsible for the lakes conservation had their own
budgets and contributed financially towards lake conservation-related
activities. However, with no overall plan or budget made out for a lake
involving all entities concerned, the funds expended by these entities tended to
be uncoordinated thereby resulting in non-achievement of the desired
objectives. Also, no assessment had been made for financial resources
required and the available financial resources were also not managed properly.
As of March 2014, BBMP, BDA, LDA and two CCs (Belagavi and Hubballi-
Dharwad) had 55, 123, 28 and 32 lakes under their custody and an expenditure
of `165.83 crore, `53.19 crore, `14.71 crore and `1.14 crore was incurred by
BBMP, BDA, LDA and CCs, respectively. Details of expenditure incurred on
restoration works in the test-checked lakes are given in Appendix 5.
¾ BDA had not collected cess amounting to `33.09 crore during the period
2009-10 to 2013-14. The State Government (UDD) replied (March 2015)
that cess was now being collected for rejuvenation of lakes.
¾ LDA collected `12.18 crore towards annual lease rent from lessees in four8
lakes as of August 2014, however this amount was kept idle. The LDA
agreed (April 2015) to utilise the available funds.
¾ LDA had not collected (February/March 2014) the annual lease rents
including interest thereon, from two lessees (M/s. Lumbini Gardens
Limited and M/s. PAR.C), amounting to `48.64 lakh. On this being
pointed out (April 2014) by Audit, LDA replied (August 2014) that
`26 lakh had been remitted by the lessees during May/June 2014. The
LDA further replied (April 2015) that notices had been issued to lessees
for remitting balance amounts.
¾ GoI approved and released (February 2002) `44.04 lakh for conservation
and management of Kamakshipalya Lake, Bengaluru under NLCP. The
restoration work could not be taken up due to encroachments in the lake
bed. Consequently, another proposal to develop an alternate lake was sent
to GoI, which was rejected. Due to failure of State Government to ensure
prevention of encroachments, the funds released by GoI had to be returned
(April 2014), thereby losing the grant received for restoration work.
8
Agara, Hebbal, Nagavara and Vengaiahanakere
Chapter IV
Effectiveness of survey and demarcation of lakes
4 Survey and demarcation of lakes
The primary task for conservation and restoration of lakes was survey and
demarcation of the area of a lake. This was necessary to ensure that no
encroachments take place in lake area. This chapter deals with the status of
the survey and demarcation of lakes. It also contains audit findings on
irregular grant of lake land, encroachments upon lakes, reduction of lake area,
etc.
SurveyofLakecompletedpost2006
Survey of lake completed (Yes/No) 25 31
(Yes/No)
lakeareawithoutEncroachmentasper
Lake area without encroachment 20 36
records(Yes/Datanotavailable/No)
(Yes/No)
0 10 20 30 40 50 60
Number of lakes
Department. Of these, survey maps in respect of two9 lakes, were not certified
by the concerned jurisdictional Tahsildar10 of the Revenue Department.
The State Government (UDD) replied (March 2015) that action has been
initiated to get the survey done for all the lakes.
Area of a lake is mainly determined by the water spread area which has a
direct correlation with the height of the waste weir (full tank level) of the lake.
Reduction in height or breach of waste weir would result in shrinkage of water
spread area of the lake.
Audit observed in JPV that during restoration works of Rachenahalli Lake, the
height of the waste weirs was reduced to 883.20 metre (approximately) from
the existing full tank level of 884.40 metre above Mean Sea Level (as per
DPR). This effectively reduced the area of the lake from 168 acres (as per
survey map) to 128 acres (as per DPR). In another lake (Doddanekundi) the
waste weirs which existed on both sides of the bund were breached and
allowed out flow of water, resulting in reduction in area of the lake by
24 acres13.
Audit also observed that the implementing agencies and LDA were not using
satellite data for ascertaining the actual lake area. A comparative study of the
lake area for 33 test-checked lakes in Bengaluru from the recent records of
Revenue Department, Survey maps, Shri. N. Lakshman Rau Committee
Report, DPRs, UDD and KSRSAC showed that there were inconsistencies in
lake area as per these different records and the more recent records in many
cases indicated reduction in the area of the lake. This was mainly due to
construction of roads, infrastructure and residential layouts, and change in land
use. Details are indicated in Appendix 6.
9
Chinnappanahalli and Kasavanahalli
10
Authorised signatory on the survey maps
11
Dasarahalli, Kasavanahalli and Vibhuthipura
12
Amruthahalli, B.Channasandra, Chinnappanahalli, Gangashetty, Garebhavipalya,
Kaigondanahalli and Kasavanahalli
13
135 acres as per 2006 Survey map of Revenue Department and 111 acres as per DPR
The State Government (UDD) accepted (March 2015) that there was
difference in area of the lake with reference to the records and survey
conducted. It also stated that the difference in area of the lake with reference
to land records and certified sketch would be brought to the knowledge of
jurisdictional revenue authorities for necessary action. The LDA stated
(April 2015) that it was taking help from Indian Space Research Organisation
(ISRO) to assess the actual area of lake. However, no documentary evidence
was furnished to substantiate the reply.
The National Water Policy, 2002 also states that encroachments and diversion
of water bodies (like rivers, lakes, tanks, ponds, etc.) and drainage channels
(irrigated area as well as urban area drainage) must not be allowed and
wherever it has taken place, it should be restored to the extent feasible and
maintained properly.
i) Rachenahalli Lake: The lake land of 43.1714 acres had been granted out
of 76.05 acres in Survey No.82 to Government bodies and private parties in
violation of Rule 108-I of the Karnataka Land Revenue Rules.
14
20 acres to Mahatma Gandhi Institute of Rural Energy Development, 16.54 acres to
Jawaharlal Nehru Centre for Advance Scientific Research, three acres to Ms. M.K. Indira
and others, three acres to Wakf Board, 0.63 acre to BBMP for formation of road and gas
line
15
94(C) - grant of Government land to unauthorised occupants prior to 1998
Urban Areas Act, 1991 which stipulated that unauthorised construction in tank
bed should not be regularised.
iv) In five16 lakes, the lake area had been granted during the period from
1991 to 2010 to various entities such as National Highways Authority of India,
BDA and Karnataka Industrial Area Development Board (KIADB) for
formation of residential layouts, road works, etc.
The State Government (UDD) replied (March 2015) that the above issues of
grant of lake land were under consideration with the Revenue Department.
Audit observed that the Revenue Department had not maintained a database
on lakes including the area under encroachments.
The State Government (UDD) stated (March 2015) that the jurisdictional
revenue officers had been instructed to evict encroachments and action would
be taken to fence all the lakes soon after the completion of survey. It was also
stated that the issue of recording of GPS reading is under consideration of
Government.
According to the provisions of the Karnataka Town and Country Planning Act,
1961, the Comprehensive Development Plan (CDP)/Revised Master Plan
(RMP) shall include the areas reserved for parks, play grounds and other
recreational uses, public open spaces, public buildings and institutions and
areas reserved for such other purposes, etc. The Act does not explicitly
describe the area preserved as tanks or lakes in the CDP/RMP.
16
B.Narayanapura Lake granted to BDA, Dasarahalli Lake to KIADB for road, Mestripalya
Lake to BDA (1991); Shivanahalli Lake to National Highways for road; Vengaiahanakere
to National Highways for road
land use/status of lake area in RMP of 2015 for formation of roads, residential
layouts, etc., led to reduction in lake area.
Instances of the change in land use pattern as per the CDP 2005 and RMP
2015 and as observed by Audit during JPV of test-checked lakes are described
in Table 1 below:
Table 1: Details of change in land use pattern as per CDP 2005, RMP
2015 and as noticed during JPV
Status as
Sl. Name of the Status of lake noticed
per Status as per RMP 2015
No. Lake during JPV
CDP 2005
Lake bed encroached by
1 Allalasandra Tank, park Lake, partly residential slum and Forest
Department.
The lake area
Dasarahalli Tank, park Lake, partly park, partly
2 encroached, reduced due
(Chokkasandra) residential
to formation of roads.
The lake area covered
Park and Lake and residential area,
3 Garebhavipalya with industrial and
Tank 67 metre road
residential layouts.
Lake bed area granted for
Lake, mainly residential,
Educational Institutions
4 Kowdenhalli Tank industrial and 18 metre
and market place. BBMP
road, High tension line
road in the lake area.
Residential, roads New road formation/Park
5 Rachenahalli Tank
measuring 18 metre road on lake bed.
Lake, railway line, 45 Formation of National
Lake, road,
metre road, mainly Highway and railway
6 Shivanahalli railway
residential with 12 metre, line.
line
15 metre road
Green belt, Residential mainly, and Graveyard noticed in lake
7 Yelahanka
Tank partly lake area.
Source: Information furnished by BDA
The State Government (UDD) accepted (March 2015) that lake areas of
Bellanduru, B.Channasandra, B.Narayanapura, Chinnappanahalli,
Mestripalya, Mahadevapura and Shivanahalli lakes had been shown as
residential, road, railway line in the RMP 2015 and the error would be
rectified in the RMP 2035 which was under preparation. The reply is not
acceptable as the lapse on the part of BDA in changing the land use would
facilitate use of lake land for other purposes.
Chapter V
Efforts and initiatives to restore water quality in lakes
5 Background
The Water (Prevention and Control of Pollution) Act17, 1974 defines pollution
to mean such contamination of water or such alteration of the physical,
chemical or biological properties of water or such discharge of any sewage or
trade effluents or of any other liquid, gaseous or solid substance into water
(whether directly or indirectly). Pollution in lakes leads to eutrophication18 and
ground water contamination causing loss of habitat and healthy environment.
The levels of quality of water as per NLCP and KSPCB are given in Table 2
below:
The quality of water in lakes was required to be of ‘B’ Class i.e. suitable for
outdoor bathing. Out of 56 test-checked lakes, KSPCB conducted the water
quality testing in only six19 lakes (Bengaluru) and in nine20 lakes (other
ULBs). The water quality in all these lakes was categorised as either ‘D’ or
‘E’. The implementing agencies had also not undertaken any exercise to
assess the pollution levels in those lakes which were rejuvenated by them.
Thus, the objective of ensuring the standard of ‘B’ class outdoor bathing was
not achieved.
The State Government (UDD) stated (March 2015) that in addition to KSPCB,
private agencies would be identified and entrusted the job of testing water
17
Section 2 (e) of the Act
18
A process where water bodies receive excess nutrients that stimulate excessive plant
growth.
19
D Category - Jakkur-Sampigehalli, Yelahanka; E Category-Chinnappanahalli,
Doddanekundi, Kaigondanahalli and Kasavanahalli
20
Dalvoy, Kelageri, Kolikeri, Kotekere, Navalur, Nuggikeri, Sadankeri, Someshwara and
Unkal (Main) lakes
quality and monitoring of pollution levels in lakes. The reply, however, did
not specify the penal provisions to be imposed on polluters.
It was observed during JPV that out of 56 test-checked lakes, 47 lakes were
severely polluted. Sewage was the major cause of pollution in 30 lakes. Apart
from the inflow of sewage, it was observed during Audit that the lakes were
being polluted by dumping of municipal solid waste and construction debris,
open defecation, industrial effluents, etc. Details of pollution in test-checked
lakes are given in Appendix 8.
The kinds of pollution noticed in test-checked lakes are given in the Chart 4
below:
36
32
30
28
Number of lakes
24
20
16
12
10
8
4 3
2 2
0
Sewage Multiple Open Construction Others
defecation debris (Industrial
waste and
pesticides)
The lakes were not free from sewage primarily because the Storm Water
Drains (SWDs) which were to bring in rain water run-off were carrying
sewage. This was attributed to the fact that UGD lines were laid by BWSSB
inside the SWDs at many stretches in Bengaluru. The UGD pipes laid almost
40 years back in core areas of Bengaluru were also corroded, encroached
upon, choked and blocked.
The State Government directed (April 2010) that the DPRs for the works be
approved by LDA. In respect of NLCP works, the DPR required the approval
of GoI. Deficiencies in approval of DPRs, monitoring of lake restoration
works, pollution and creation of biodiversity are dealt in subsequent chapters.
In the test-checked lakes, out of 34 lakes where works were taken up, LDA
had given approval for 21 works and in the remaining 1323 cases, works were
taken up without approval of LDA.
¾ LDA had approved DPRs in 1124 cases where the cost provided for non-
core works (such as boat jetty, guard rooms, play stations, etc.) was much
more than the stipulated 25 per cent of the total project cost proposed in
the DPRs (detailed in the succeeding paragraph).
¾ The works proposed in the DPRs varied with the works actually taken up
in eight25 test-checked lakes.
The LDA accepted the audit observations and attributed (April 2015) the
delays to improper preparation of DPRs by BBMP and BDA. It was stated
that care would be taken to provide less than 25 per cent of the project cost for
non-core items and DPRs would be approved in future only on submission of
pollution classification level. It was further stated that variations in works
were mainly due to local site condition.
As per the NLCP guidelines, the development works in lakes were categorised
as core and non-core works. The core works associated with ecological
restoration included the works such as strengthening of bund, desilting,
foreshore planting, inlet and waste weir restoration works, etc. These works
were significant for maintaining a healthy ecology of lakes. The non-core
activities included construction of walkways, boat jetties, idol immersion
23
Alarwad, Allalasandra, Attur, Chinnappanahalli, Dasarahalli, Jakkur-Sampigehalli,
Kaigondanahalli, Kowdenhalli, Kuduchi, Kuduchi (small), Rachenahalli, Venkateshpura
and Yelahanka
24
Amblipura Melinakere, B.Narayanapura, Bellanduru, Chokkanahalli, Doddanekundi,
Gangashetty, Kogilu, Mestripalya, Thirumenahalli, Varthuru and Vibhuthipura
25
B.Narayanapura, Chokkanahalli, Doddanekundi, Gangashetty, Kogilu, Mestripalya,
Thirumenahalli and Vibhuthipura
tanks, children play area, gazebo, toilets, food courts, etc. Over emphasis on
these works would adversely impact the bio-diversity of the lakes.
90
80 Percentage of
70 cost of core
works
60
Percentage
50 Percentage of
40 cost of non-core
works
30
20
25 per cent of
10 project cost
0
Names of Lakes
Audit observed that the implementing agencies had not segregated the
expenditure based on core and non-core works. In the absence of a stringent
system of monitoring by LDA of the expenditure on lake related activities,
there would be difficulty in maintaining the ratio of expenditure between core
and non-core activities. This would impact the expenditure on essential core
works necessary for the ecological health of the lakes.
The State Government (UDD) stated (March 2015) that in urban lakes,
requirement of executing non-core components were very essential and works
were carried out based on site specific requirements. The DPRs for these
lakes were also technically approved. The reply cannot be accepted as
execution of non-core works in excess of norms is detrimental to the
ecological health of the lake.
BWSSB stated (October 2014) that as at the end of August 2014, the re-laying
of UGD lines in the core area was complete. This was, however, not the
position as seen during JPV of test-checked lakes in core areas.
Thus, it is evident that the problem of sewage entering lakes will continue to
persist until the UGD works are completed and therefore works taken up in
such lakes will be rendered largely unfruitful.
During JPV of seven27 of these lakes, it was observed that BWSSB had also
laid UGD pipelines in parallel. Thus, the expenditure incurred for the sewage
26
B.Narayanapura, Chinnappanahalli, Chokkanahalli, Dasarahalli, Doddanekundi,
Gangashetty, Jakkur-Sampigehalli, Kaigondanahalli, Kasavanahalli, Kowdenhalli,
Rachenahalli, Vibhuthipura and Yelahanka
27
Doddanekundi (`1.26 crore), Jakkur-Sampigehalli (`0.24 crore), Kaigondanahalli
(`1.15 crore), Kowdenhalli (`0.21 crore), Rachenahalli (`0.95 crore), Vibhuthipura
(`0.04 crore) and Yelahanka (`2.26 crore)
diversion channel for which the estimated cost was `6.11 crore was
unwarranted as these works were taken up without coordinating with BWSSB.
BDA replied (February 2015) that diversion drains were laid in a few lakes as
the BWSSB work of UGD was not complete as anticipated and that diversion
drains were still required to prevent entry of sewage mixed rain water into the
lake during the first few showers of the monsoon. The State Government
(UDD) also stated (March 2015) that BWSSB is laying UGD lines in common
places such as roads, common utility areas and lakes which are situated quite
below the levels of the trunk lines.
The replies are not acceptable as diversion drains led to drying up of lake
beds, loss of characteristics and eventual death of the water bodies and
expenditure was rendered unfruitful where UGD lines had been laid by
BWSSB in parallel.
In the State of Karnataka, out of 219 local bodies, only 55 local bodies had
been provided with STPs. KSPCB stated (May 2014) that directions had been
issued to the local bodies to ensure that STPs are provided to prevent entry of
sewage into water bodies. The DPRs had suggested establishment of STPs to
treat sewage based on the inflow through all the inlets of the lake. This would
ensure that the entire sewage flowing into the lake be treated and thereafter the
treated water alone would enter into the lake, thereby improving the ecological
health of the lake.
In Bengaluru, approximately 900 Million Litre per Day (MLD) of water was
being consumed. Out of this, 80 per cent was generated as waste water.
KSPCB norms require BWSSB to treat the entire waste water to secondary
level before letting it into water bodies. Although BWSSB had the capacity to
treat 721 MLD in the existing STPs, only 521 MLD of waste water was being
treated and the remaining untreated sewage (200 MLD) was let into the lakes.
BWSSB (November 2014) stated that construction of STPs of additional
capacity of 339 MLD was under progress. Regarding apartment complexes
which had their own STPs, BWSSB during Exit Conference (February 2015)
stated that treated water from such apartments which had their own STPs28
should be let into the lakes rather than into the sewer lines. However, KSPCB
and BWSSB need to ensure that only treated water is let into the lakes from all
such apartments.
There were two cases where STPs had not been established which are as
under:
i. In Nagavara Lake in Bengaluru, the lease holder of the lake did not
provide for a five MLD STP (on the north-western side of the inlet) even
though it was a pre-requisite for leasing of the lake as per the contractual
obligation.
28
apartments which have 50 dwelling units or generating 50 cum of sewage daily were
required to operate an STP within their premises
ii. In Kotekere tank of Belagavi, the rejuvenation works, which included the
component of establishment of an STP, were completed (May 2009)
incurring an expenditure of `5.73 crore. However, the item of STP was
deleted and during JPV (March 2014) it was seen that the sewage
continued to pollute the lake.
The State Government (UDD) stated (March 2015) that establishing STPs for
other lakes will be extended on priority basis, while keeping in view budgetary
allocations.
All these instances indicate that the functioning of STPs was not effective and
due to under-utilisation and lesser capacity of these STPs, sewage entering the
lakes could not be contained. The Additional Chief Secretary, Forest, Ecology
and Environment also stressed during the Exit Conference (February 2015) the
need for direct supervision of STPs to ensure that the sewage is being treated
to the desired level before being let into lakes.
Photograph below taken during JPV also illustrates the level of pollution in a
test-checked lake.
Dasarahalli Lake main drain (inlet 1 of the lake) receives all the effluents from Peenya Industrial area as
evident from the thick viscous black water flowing in the drain
As per the NLCP guidelines, increase in the lake depth through de-siltation
has an adverse impact on its flora and fauna. Execution of de-siltation
component should be carried out scientifically under expert guidance. The
DPRs pointed out that excessive desilting would affect the lake ecology due to
hydrological retention time29. The Principal Chief Conservator of Forests
(PCCF) highlighted (2008) the need for preserving natural foreshore region
without substantial desilting and without formation of steep embankment. The
Technical Advisory Committee of LDA suggested that desilting of the lake
should be restricted to the quantity required for formation of embankment.
The State Government also instructed (April 2010) LDA to supervise and
monitor the works executed by BBMP and BDA.
Scrutiny of records revealed that desilting was undertaken for increasing the
impounding capacity of water, replenishment of ground water, etc. It was
noticed that the quantity of desilting carried out was much higher when
compared to the estimate and the DPR. There was no justification on record
for the excess excavation and the expenditure incurred on the excess desilting
was `4.02 crore in 1330 test-checked lakes. Further, it was observed that
29
Hydrological retention time is the mean time that water is retained in a lake. If the
retention time is longer, pollutants stay longer in the lake and the lake is less often
flushed, thereby increasing the pollution of the lake.
30
Allalasandra, Attur, B.Narayanapura, Chinnappanahalli, Dasarahalli, Doddanekundi,
Gangashetty, Jakkur-Sampigehalli, Kaigondanahalli, Kowdenhalli, Mestripalya,
Rachenahalli and Yelahanka
though desilting activities were not proposed in the DPRs of three 31 lakes,
desilting work was carried out incurring an expenditure of `99.78 lakh.
Excessive desilting had, therefore, increased the hydrological retention time
and consequently increased pollution level in the lakes.
LDA also failed to supervise and monitor the excessive desilting works
executed by BBMP and BDA. The LDA accepted the audit observation and
stated (April 2015) that it did not have sufficient technical staff to carry out
regular inspection and monitoring of lakes.
The BDA stated (January 2015) that the deepening of the lake bed was carried
out to bring saucer shape to the lake bed. The reply is not acceptable as this
was contrary to the expert guidance given (July 2008) by the PCCF. The State
Government (UDD) admitted (March 2015) that there was excessive desilting
due to accumulation of debris and other wastes in the lakes which was due to
delay in the process of preparation of DPRs and execution of the work. Also,
slushy soil cannot be used for formation of embankment. The reply is not
acceptable as accumulation of debris and other wastes should be avoided once
the lake has been handed over to the implementing agencies. For categorising
the soil as ‘slushy soil’, there should be proper soil test reports which were not
there. Also, bills showed that that even dry soil was transported out of the
lake area. As such, the issue calls for investigation and fixing of responsibility
for doing excess excavation as compared with DPRs.
Saucer shaped desilting and formation of elevated ring bunds seen in B.Narayanapura
and Chokkanahalli Lakes
Lead charges are payable to the contractor for carrying material from the
quarry to the work site and also for disposing of unused/unwanted material to
the identified dumping place.
Audit noticed that the excess desilting also increased the expenditure incurred
on the lead charges paid to contractors for the work of dumping the excavated
soil. The payments were made to contractors even though there were no lead
charts/maps enclosed with the approved technical estimates as required under
31
Kogilu, Thirumenahalli and Venkateshpura
The State Government (UDD) admitted (March 2015) that there was variation
in lead calculation due to non-availability of dumping area near the lakes. The
reply is not tenable, as it does not address the issue of non-availability of the
lead charts/maps for calculation of the lead charges which are to be enclosed
with the approved technical estimates, for which responsibility may be fixed.
LDA admitted (December 2014) that it had not carried out any supervision
and monitoring of rejuvenation works in BBMP and BDA lakes. Failure on
the part of LDA to monitor and supervise lake rejuvenation activities in
BBMP/BDA lakes resulted in works adversely affecting the ecology of the
lakes.
32
Amblipura Melinakere, Attur, Chinnappanahalli, Dasarahalli, Gangashetty, Jakkur-
Sampigehalli, Kaigondanahalli, Kogilu, Mestripalya, Rachenahalli, Thirumenahalli,
Vibhuthipura and Yelahanka
33
Allalasandra, Amblipura Melinakere, Attur, B.Narayanapura, Chinnappanahalli,
Dasarahalli, Doddanekundi, Jakkur-Sampigehalli, Kaigondanahalli, Kasavanahalli,
Kogilu, Kowdenhalli, Mestripalya, Rachenahalli, Venkateshpura, Vibhuthipura and
Yelahanka
The State Government (UDD) replied (March 2015) that the ring bunds were
provided after ensuring inlets for flow of water into the lake and the
expenditure incurred on ring bunds was actually necessitated. The reply is not
acceptable, as the ring bunds obstruct the inflow of run-off water from the
surrounding catchment area.
Fencing of the lake area was one of the works to be taken up on priority. Out
of 56 test-checked lakes, 22 lakes were fully fenced, 25 lakes were partially
fenced and there was no fence for nine lakes. During 2009-14, fencing works
were taken up in 1734 lakes and `11.13 crore expenditure was incurred on
these works.
The expenditure on fencing and its effectiveness needs to be seen in the light
of the fact that survey had not been completed and lake area was not
decisively demarcated.
The State Government (UDD) admitted (March 2015) that some miscreants in
order to dump debris had damaged fencing for easy access and this would be
rectified. The reply is not acceptable, as the primary duty of implementing
agencies was to safeguard the lake area by deploying sufficient security soon
after the lake was taken over.
Audit observed that constructed wetlands were provided in 1435 lakes and the
area of wetlands in all of these lakes was much less than the desired minimum
25 per cent of the lake area. It was also seen that the wetlands were provided
inside the ringed elevated bunds whereas the diversion drains in these lakes
(except Allalasandra and Attur) were provided outside the ringed elevated
bunds. This resulted in the wetland region (and water spread area of the lake)
remaining dry through most part of the year. During JPV of the lakes, it was
34
Allalasandra, Attur, B.Narayanapura, Bellanduru, Dasarahalli, Doddanekundi,
Gangashetty, Jakkur-Sampigehalli, Kaigondanahalli, Kowdenhalli, Mestripalya,
Rachenahalli, Thirumenahalli, Varthuru, Venkateshpura, Vibhuthipura and Yelahanka
35
Allalasandra, Attur, B.Narayanapura, Chinnappanahalli, Chokkanahalli, Dasarahalli,
Doddanekundi, Gangashetty, Jakkur-Sampigehalli, Kaigondanahalli, Mestripalya,
Rachenahalli, Vibhuthipura and Yelahanka
observed that the wetland region remained dry even during monsoon season
and was devoid of even aquatic weeds.
Allalasandra Lake wetland was breached to let sewage water directly into the lake without
filtration
The State Government (UDD) accepted (March 2015) the observation and
stated that action would be taken to rectify the breached bunds as well as inlet
levels would be ensured in the lakes.
Of the test-checked lakes, the Nagavara Lake in Bengaluru was the only lake
in which a natural wetland formation was noticed. However, even this
wetland was full of water hyacinth and floating debris due to lack of
maintenance.
¾ The State Government instructed (April 2010) that disused tanks should
also be restored to their original status. However, contrary to the
instructions, the planting of trees was carried out on the lake bed itself in
seven36 test-checked cases.
36
Amblipura Melinakere, Attur, B.Channasandra, Chikka Bellanduru, Chokkanahalli, Kogilu
and Thirumenahalli
The State Government (UDD) agreed (March 2015) that the works of
afforestation were carried out while fencing works were in progress. This was
necessary to bring the evicted area of encroachment under plantation. The
reply is not acceptable as these plantation works were destroyed due to
desilting and formation of elevated ring bunds in the lake. This resulted in the
expenditure incurred on these afforestation works as wasteful.
Audit observed that impact assessments were not done by any of the
implementing agencies on lakes after restoration works were carried out.
There was also no assessment on the impact of ground water levels; water
quality; damage caused to the wetlands, keystone species, flora, fauna and
aquatic birds due to pollution; and the health of human beings in the vicinity
of lakes before and after restoration works.
The State Government (UDD) stated (March 2015) that the KSPCB was
responsible for assessing the impact of pollution of lakes on human health.
Reply is not tenable as there was no effort on the part of the implementing
agencies to assess the impact of pollution on lakes before or after restoration
works were carried out. Also, BBMP, being the civic agency, was responsible
to assess any outbreak of diseases due to deterioration of environmental
conditions.
However, instead of preserving the natural slopes in the foreshore area, Audit
found that even the estimates and DPRs provided for deep cutting and
formation of elevated ring bunds with stone pitching in the 2038 test-checked
lakes. This was also seen during JPV. Deep cutting of lake area was carried
out to utilise the soil excavated for formation of elevated ring bunds within the
periphery of the lake. The execution of these works in the test-checked lakes
thus disturbed the gentle foreshore slopes and shallowness at the mouth of the
lake which would, therefore, not support flora and fauna.
Deep cutting and ring bund formed in Chokkanahalli Lake and B.Narayanapura Lake
The State Government (UDD) replied (March 2015) that due to urbanisation,
vast area was not available for maintaining the foreshore area. The reply is
not acceptable as the available foreshore area has been destroyed to create
elevated ring bund contrary to the directions issued and could therefore not
support the flora and fauna and aquatic life.
SWD (Raja Kaluves) are the inlets and outlets for the lakes. They are the
lifelines for the survival of lakes and harbour immense potential for
biodiversity conservation. During JPV of lakes, it was noticed that five39 lakes
did not have inlets, the inlets of two40 lakes were encroached upon and there
38
Allalasandra, Amblipura Melinakere, Attur, B.Narayanapura, Chinnappanahalli,
Chokkanahalli, Dasarahalli, Doddanekundi, Gangashetty, Jakkur-Sampigehalli,
Kaigondanahalli, Kasavanahalli, Kogilu, Kowdenhalli, Mestripalya, Rachenahalli,
Thirumenahalli, Venkateshpura, Vibhuthipura and Yelahanka
39
B.Channasandra, Chikka Bellanduru, Heggeri, Mahadevapura and Venkateshpura
40
Amblipura Melinakere and Thirumenahalli
were no outlets in eight41 lakes. Audit also observed from the records that the
SWDs leading to the lakes were encroached upon/diverted in 1442 test-checked
lakes of Bengaluru. As such, there was no free inflow from Raja Kaluves and
there was no outflow through the SWD.
Of the 56 test checked lakes, 1643 lakes had shrunk considerably or dried up as
the inlets were either encroached upon or diverted.
The State Government (UDD) stated (March 2015) that inlets and outlets were
technically designed and constructed and that there were no incidents of
inundation surrounding the lakes developed by BBMP. The reply was
contrary to the fact that after Revenue Department survey, it was found that
the Raja Kaluves for 14 test-checked lakes were either encroached upon or
diverted.
None of the agencies which were entrusted with the development of lakes was
in possession of the details of flora and fauna including keystone species44
available in the lake after restoration works.
The State Government (UDD) admitted (March 2015) that there was no
database of lakes and species therein. The Government, however, agreed to
take action to maintain a database.
Audit examined the impact of one of the most common invasive plants i.e.
Eichhornia crassipes, commonly known as water hyacinth. This kind of plant
doubles itself within two weeks time. When not controlled, it blocks the
sunlight reaching native aquatic plants and starves the water of oxygen, killing
the fish/turtles. The rapid growth of water hyacinth was due to entry of
41
Amblipura Melinakere, B.Narayanapura, Chokkanahalli, Horamavu-Agara,
Mahadevapura, Mestripalya, Rachenahalli and Vibhuthipura
42
Attur, B.Narayanapura, Bellanduru, Chokkanahalli, Gangashetty, Horamavu-Agara,
Jakkur-Sampigehalli, Kaigondanahalli, Kalkere-Rampura, Kasavanahalli, Kogilu,
Kowdenhalli, Varthuru and Yelahanka
43
Amblipura Melinakere, B.Narayanapura, B.Channasandra, Chikka Bellanduru,
Chokkanahalli, Doddanekundi, Gangashetty, Heggeri, Horamavu-Agara, Kogilu,
Mahadevapura, Mestripalya, Shivanahalli, Thirumenahalli, Venkateshpura and
Vibhuthipura
44
species whose presence and role within an ecosystem has a disproportionate effect on
other organisms within the system
sewage into the lakes. Unless this menace of pollution is tackled, the growth
of water hyacinth cannot be controlled.
In the test-checked lakes, Audit observed in three45 lakes that the entire water
spread area was covered with water hyacinth. In nine46 lakes, this invasive
species was found near the inlets/outlets. In 1047 lakes under BBMP,
`9.83 lakh had been spent on works to de-weed the invasive species.
The State Government (UDD) stated (March 2015) that due to diversion of
sewage entering the water body, growth of water hyacinth was noticed and the
agency maintaining the lakes would remove such invasive species. The reply
was contrary to the concept that growth of water hyacinth was mainly due to
entry of sewage in to the lakes leading to eutrophication. The solution lies not
just in removal of the species but in ensuring entry of only treated water into
the lakes.
45
Amruthahalli, Garudacharpalya and Kalkere-Rampura
46
Amruthahalli, Bellanduru, Garudacharpalya, Kalkere-Rampura, Kempkere, Kolikeri,
Unkal, Varthuru and Yelahanka
47
Amblipura Melinakere, Attur, Chinnappanahalli, Dasarahalli, Kaigondanahalli,
Kasavanahalli, Kogilu, Kowdenhalli, Thirumenahalli and Yelahanka
48
Mahadevapura Parisara Samrakshane Matthu Abhivruddhi Samithi (MPSMAS)
Buffer zones had not been created by acquiring land or regulating construction
activities on the periphery in any of the test-checked lakes. Instead, the lake
periphery was breached upon by slums, formation of roads and residential
layouts, construction of buildings/apartments, functioning of schools,
construction of quarters by Forest Department, etc. Possible breach of buffer
zone was noticed in all the 34 test-checked lakes in Bengaluru. Illustrative
cases are indicated in Appendix 9.
The State Government (UDD) replied (March 2015) that the buffer area of
lakes are owned by private people and development activities are going on at a
rapid pace due to escalation of land prices. They also stated that the
enforcement of buffer zone vests with the planning authorities. The reply is
not acceptable as it indicates that the State Government has not taken any
effective measures over the years for ensuring protection of the buffer zones.
49
during March 2008 and corrigendum during October 2008
50
B.Channasandra, Horamavu-Agara, Jakkur-Sampigehalli and Kalkere-Rampura
Chapter VII
Lake specific findings of 12 test-checked lakes
Unplanned rapid urbanisation in Bengaluru and other CCs in Karnataka
witnessed large scale conversion of catchment areas of the lakes to residential
and commercial layouts that altered the hydrological regime and enhanced silt
movement in the catchment area. In this section, an overview of twelve lakes
test-checked by Audit in Bengaluru and other ULBs are highlighted indicating
the present status of these lakes.
1. Bellanduru Lake
The area of the lake was only 597 acres as per the satellite map of
KSRSAC (2011). Thus, there was a reduction in lake area as per the
revenue records.
The lake area was fenced partially, incurring an expenditure of `3.31 crore
due to non-removal of encroachments.
2. Horamavu-Agara Lake
The lake is located on the eastern part of Bengaluru and is under the custody
of BDA.
The survey map of 2006 indicated that an area of 5 acres 0.25 gunta51 was
under encroachments. The lake was not demarcated and did not have a
waste weir.
During JPV, it was observed that the lake area was filled with construction
debris and fencing was damaged.
Lake area was encroached upon for construction of bus-stand near north-
west inlet. Several apartments and other residential houses had breached
the buffer zone. This indicated implementing agencies were not taking
measures to safeguard the buffer zone.
The pollution level was not being monitored by any of the agencies and no
works were taken up during 2009-14.
The lake is located in Bengaluru (East) Taluk and at present is under the
custody of BDA.
51
Gunta is a unit of measurement of area. 40 guntas is one acre.
The village map and other records revealed that the adjoining
Survey.No.63 of Mullur village which was part of the lake is now shown
as private land in the latest certified revenue survey map (2010).
BBMP had planted trees in the lake bed area and no restoration works
were taken up either by BBMP or BDA to revive the lake as a fresh water
body.
There were no inlets to the lake and thus, the entire lake bed had dried up.
Lake was polluted with solid waste and construction debris and the
pollution level was also not being monitored by any of the agencies.
Construction debris dumped inside the lake bed and solid waste dumped
Dried up lake bed
near huts in the lake area
4. Vengaiahanakere
The lessee was operating motor boats, violating the agreemental clause
and polluting the lake. The LDA stated (April 2015) that lessee had been
directed not to use motor boats in the lake.
BWSSB’s UGD line inside the lake bed was seen overflowing into the
lake area. The treated water from STP and untreated sewage was mixed
and was entering the lake. The water quality of the lake was not being
monitored by any of the agencies. The LDA stated (April 2015) that
BWSSB had been directed to make provision for diversion of sewage and
lay down separate pipeline for entry of treated water into the lake.
5. Allalasandra Lake
Allalasandra Lake forms part of the Yellamallappa Chetty Lake Series and is
at present under the custody of BBMP.
6. Rachenahalli Lake
BDA had formed a residential layout in the lake area. It also irregularly
diverted 11 acres of lake for formation of park as part of rejuvenation
works in violation of rules.
Fencing was breached and left open in many stretches to provide access
roads to the nearby residential areas.
The level of pollution was not assessed by any agency. BWSSB laid
UGD network very close to the water spread area with the approval of
LDA and BDA.
The treated water flowing from Jakkur Lake was not entering the lake as
the inlet was connected to sewage diversion channel and wetland
remained dry.
7. Nagavara Lake
Nagavara Lake is situated in Bengaluru (East) taluk and the outer ring road
had been constructed on one side of the lake. The lake was developed by
LDA during 2002-03 with NLCP grants. The lake was given on lease to
M/s. Lumbini Gardens in 2004.
There was no demarcation of lake area and a portion of lake area on the
south east corner was diverted for providing connectivity to the upcoming
Special Economic Zone. LDA stated (April 2015) that letters had been
addressed to BBMP and BDA to stop the road formation in the lake area.
It was further stated that a police complaint had been lodged as BBMP was
in the process of laying sewage pipeline and connecting it to SWD of
Nagavara Lake.
The lessee had provided restaurants, party halls, amusement and water
theme parks, motor boats etc., thereby polluting the lake area. Due to
sewage ingression, the entire wetland region was covered with water
hyacinth and floating debris. The level of pollution was not assessed by
any agencies. LDA replied (April 2015) that action would be taken to
improve the ecological health of the lake.
Sewage with floating debris from Formation of Special Economic Wetland fully covered with water
SWD entering the lake Zone in the Buffer zone hyacinth and weeds
8. Chokkanahalli Lake
The atchcut area across the main bund had been demarcated for residential
site formation.
The lake bund was used as a road to provide connectivity to the nearby
areas.
During JPV, a graveyard was noticed inside the lake area. Local people
were fishing in the lake.
The constructed inlet was defective as the opening of inlet was below the
existing waste weir. The inlet provided with silt trap, screen barrier etc.,
was clogged and the excess water was not flowing into the lake.
The pollution level was not being monitored by any of the agencies.
9. Kaigondanahalli Lake
Kaigondanahalli Lake is part of Varthuru Lake series and the lake is at present
under the custody of BBMP.
The Sarjapura main road is passing through the lake bund, thereby
reducing the lake area.
Natural flow of rain water/storm water had been restricted to flow through
pipeline due to the formation of ring bund.
Sewage diversion line was laid inside the water spread area by cutting
trees.
The foreshore area on the southern part of the lake was being developed
into residential complex, breaching the buffer zone.
An open amphitheatre was constructed in the lake bed, reducing the lake
area.
KSPCB (November 2013) classified the quality of water of lake as “E”
category, which was below the prescribed standard “B” for outdoor
bathing in developed lakes.
An NGO (MPSMAS) had taken up the responsibility to maintain the lake.
The natural wetland was encroached by the ITI factory and a road was
formed in the centre as a connecting route to K.R. Puram.
The lake is spread over 55 acres 5 guntas and half of the lake area had
been encroached upon by a college, slum, residential layouts, road,
market, etc. The conservation and restoration works were, therefore,
carried out only in the remaining area of 20 acres and 35 guntas.
The lake was full of weeds which was removed and dumped alongside the
pathway.
The pollution level was not being monitored by any of the agencies.
Bhishma Lake with an area of 103 acres (41.70 hectare) is the only water body
in Gadag-Betageri City and the lake is under the custody of Forest
Department.
The lake has been de-watered for restoration work and for erection of the
statue of Lord Bashweshwara. The lake area where the statue was erected
had dried up as indicated in the photograph below.
The inflow of sewage from one inlet had stagnated on one side of the lake
as indicated in the photograph below.
The pollution level was not being monitored by any of the agencies.
Due to non-maintenance, the lake periphery and the bund were full of
bushes/weeds as shown in the photograph below.
Open defecation was prevalent and clothes were being washed in the lake
polluting the lake. This was shown in the photograph below.
KSPCB categorised the water quality as “D” which did not conform to the
required standard of “B” class.
Chapter VIII
Conclusion
The Performance Audit on ‘Conservation and Ecological restoration of Lakes
under the jurisdiction of Lake Development Authority and Urban Local
Bodies’ indicated weak institutional mechanisms and legal framework, with
assigned functions and responsibilities not being effectively carried out by the
entities involved in the conservation and restoration of lakes.
It was also observed that restoration works were carried out without adequate
planning with no integrated approach amongst the different implementing
agencies responsible for lake rejuvenation work. The disconnect in the efforts
of the various implementing agencies resulted in irreparable damage in
achieving the goal of conservation and ecological restoration of the lakes. The
emphasis of the implementing agencies was seen to focus more on engineering
measures rather than ecological preservation and restoration of the lakes.
Most lakes continued to remain polluted with the efforts to reduce sewage
entry into lakes being inadequate. Sewage Treatment Plants did not have
adequate capacity for treating fully the contaminated water and many of the
existing plants also did not function effectively. Works were also carried out
without proper planning and prioritisation as evidenced from numerous
executions of non-core works. Even core activities were undertaken in a
haphazard manner as observed from excessive desilting, formation of elevated
ringed bunds, ineffective wetland constructions, etc.
The lake specific findings of the 12 test-checked lakes indicated that sewage
was the major source of pollution. Also, many encroachments persisted and
proper fencing of lake boundaries was inadequate. Restoration works carried
out in these lakes were seen to have been more for providing recreation
facilities rather than for preservation of the ecosystem.
Thus, the various agencies involved were not effective in taking sustainable
initiatives for restoring water quality and maintaining ecological health of the
lakes. If adequate and effective measures are not taken, we will continue to
lose lake areas and will not be able to conserve, preserve and restore our lakes
for the benefit of future generations.
Countersigned
Appendix 1
Lakes that have lost their characteristics
(Reference: Paragraph 1/Page 1)
Sl.
Name of the Lake Converted as
No.
1 Marenahalli Lake Marenahalli
2 Sarakki Agrahara Lake/Doresanipalya JP Nagar 4th Phase
3 Chinnagara Lake Ejipura
4 Challaghatta Lake Karnataka Golf Club
5 Domlur Lake Domlur Second Stage
6 Siddapura Lake Siddapura/Jayanagar 1st Block
7 Geddalahalli Lake RMV II Stage, I Block
8 Nagashettihalli Lake RMV 2nd Stage, 2nd Block
9 Kadirenahalli Lake Banashankari 2nd Stage
10 Tyagarajanagar Lake Tyagarajanagar
11 Tumkur Lake Mysore Lamps
12 Ramshettypalya kere Milk Colony (Playground)
13 Agasana Lake Gayathri Devi Park
14 Ketamaranahalli Lake Rajajinagar (Mahalakshmipuram)
15 Gangashetty Lake Minerva Mills & Open Ground
16 Jakraya Lake Krishna Flour Mills
17 Dharmambudhi Lake Kempegowda Bus Terminal
18 Agarahar hosakere Cheluvadipalya
19 Kalasipalya Lake Kalasipalya
20 Sampangi Lake Kanteerava Stadium
21 Shoolay Tank Ashoknagar, Football Stadium
22 Akkitimmanahalli Tank Sai Hockey Stadium
23 Sunkal Tank KSRTC Regional workshop
24 Koramangala Lake National Dairy Research Institute
New Thippasandra/Government
25 Kodihalli Lake
Buildings
26 Hoskere Residential/Railway Stockyard
27 Sonnenehalli Lake Austin Town (RES Colony)
28 Gokula Tank Mathikere
29 Vidyaranyapura lake Vidyaranayapura (Jalahalli East)
30 Kadugondanahalli Lake Kadugondanahalli
31 Hennur Lake Nagavara (HBR Layout)
32 Banaswadi Lake Subbayanapalya Extention
33 Chennasandra Lake Pulla Reddy Layout
34 Vijinapura Lake (Kotturu) Rajarajeshwari Layout
35 Murugeshpalya Lake Murugeshpalya
36 Parangipalya Lake HSR Layout
37 Mestripalaya Lake Mestripalaya (Open Ground)
38 Timberyard Lake Timberyard Layout
39 Gangodanhalli Lake Gangodanhalli
40 Vijayanagar Chord Road Lake Vijayanagar
41 Oddarapalya Lake Rajajinagar (Industrial Area)
42 Saneguruvanahalli Lake Shivanahalli (Play Ground)
43 Kurubarahalli Lake Basaveshwaranagar
Source: Annexure XII of Report of Committee constituted by the Hon’ble High Court of Karnataka to
examine the ground realities and prepare action plan for preservation of lakes.
Appendix 2
Important recommendations of Shri. N. Lakshman Rau Committee
(Reference: Paragraph 1/Page 1)
¾ The existing tanks should not be breached but retained as water bodies;
¾ Efforts should be made to ensure that these tanks are not polluted by
discharge of effluent and industrial wastes;
¾ These tanks which have already been breached should not be utilised
for formation of sites but taken up to create tree parks;
Appendix 3
Sampling methodology
(Reference: Paragraph 2.2/Page 3)
LDA: LDA had provided funds for 16 lakes under NLCP, six lakes under
NWCP and six lakes under State Fund to implementing agencies for
development of lakes.
Eleven of these lakes (NLCP: 6 lakes, NWCP: 2 lakes and State Fund: 3 lakes)
were selected for detailed audit. Further, 33 per cent of CCs having lakes (two
out of six CCs excluding Bengaluru) were taken for review.
Bengaluru: BBMP lakes were selected by selecting three out of eight zones.
Out of the three zones, 33 per cent of the lakes (13 lakes) under the
jurisdiction of those zones were selected by adopting the simple random
sampling method. Similarly, lakes of BDA were selected by selecting two out
of four zones. Out of the two zones, 33 per cent of the lakes (19 lakes) under
the jurisdiction of those zones were selected by adopting the random sampling
method.
Lakes selected for the Performance audit
Names of the Lakes
Akkamahadevi Lake, Haveri; Amanikere, Tumakuru; Bhishma Lake,
NLCP Lakes
Gadag; Kotekere, Belagavi; Nagavara Lake and Vengaiahanakere,
(6 lakes)
Bengaluru.
NWCP Lakes
Gudavi Wetland, Shivamogga and Magadi Wetland, Gadag.
(2 lakes)
State Fund Dalvoy Lake, Mysuru; Kunnirkatte Lake, Channapatna and
(3 lakes) Rangarayanadoddi Lake, Ramanagara.
Allalasandra Lake; Amblipura Melinakere; Attur Lake;
Chinnappanahalli Lake; Chokkanahalli Lake; Dasarahalli
BBMP
(Chokkasandra) Lake; Kaigondanahalli Lake; Kasavanahalli Lake;
(13 lakes)
Kogilu Lake; Kowdenhalli Lake; Kundalahalli Lake; Thirumenahalli
Lake and Yelahanka Lake.
Amruthahalli Lake; B.Channasandra Lake; B.Narayanapura Lake,
Bellanduru Lake, Chikka Bellanduru Kere, Doddanekundi Lake,
Gangasetty Lake, Garebhavipalya Lake, Garudacharpalya
BDA
(Achanakere) Lake, Horamavu-Agara Lake, Jakkur-Sampigehalli
(19 lakes)
Lake, Kalkere-Rampura Lake, Mahadevapura Lake, Mestripalya
Lake, Rachenahalli Lake, Shivanahalli Lake, Varthuru Lake,
Venkateshpura Lake and Vibhuthipura Lake.
Heggeri Lake, Kelageri Lake, Kempkere, Kolikeri, Navalur Lake,
Hubballi-Dharwad
Nuggikeri, Sadankeri, Someshwara Lake, Unkal Main Lake and
(10 lakes)
Unkal Small Lake.
Belagavi Alarwad tank, Kuduchi big tank and Kuduchi small tank.
(3 lakes)
Total (56 lakes)
Appendix 4
Salient features of the Karnataka Lake Conservation and Development
Authority Act, 2014
1. The Authority shall exercise regulatory control over all the lakes within
the limits of Municipal Corporations and Bengaluru Development
Authority including prevention and removal of encroachment of lake.
4. The Authority shall have powers to cause entry upon or authorise any
officer to enter upon any land to survey, demarcate and make maps of
lakes, to receive grants, donations, etc.
5. The Act prohibits use of lake for any purpose other than storage or
impounding water.
6. The Act gives the Authority powers to direct any officer of Government or
any local or other authority who is the custodian, or in control of any lake
to permanently demarcate its boundaries, to remove encroachments or
unauthorised occupation of such lake.
8. The Authority shall create a fund and spend money for performing its
duties and functions; maintain accounts and other records, prepare budget
and annual financial statements, Annual Reports, etc.
Appendix 5
Details of expenditure incurred on restoration52 works in test-checked
lakes
(Reference: Paragraph 3.7/Page 14)
Estimated
Sl. Period of Expenditure
Name of the lake cost
No. Execution (` in crore)
(` in crore)
Bengaluru
1. Allalasandra Lake, BBMP 2009-13 9.04 7.58
2. Amblipura Melinakere, BBMP 2012-13 2.70 1.47
3. Attur Lake, BBMP 2009-11 3.75 3.68
4. B.Narayanapura Lake, BDA 2014-15 1.91 0.99
5. Bellanduru Lake, BDA 2009-12 3.78 3.31
Chinnappanahalli Lake,
6. 2009-10 0.78 1.59
BBMP
7. Chokkanahalli Lake, BBMP 2013-14 1.40 1.51
8. Dasarahalli Lake, BBMP 2008-14 10.31 5.97
9. Doddanekundi Lake, BDA 2013-14 9.07 6.13
10. Gangashetty Lake, BDA 2013-14 2.40 0.99
Jakkur-Sampigehalli Lake,
11. 2009-12 21.98 14.93
BDA
12. Kaigondanahalli Lake, BBMP 2009-14 8.41 6.06
13. Kasavanahalli Lake, BBMP 2013-14 3.00 3.24
14. Kogilu Lake, BBMP 2012-13 4.90 2.62
15. Kowdenhalli Lake, BBMP 2008-11 3.96 4.22
16. Mestripalya Lake, BDA 2012-14 2.29 0.87
17. Nagavara Lake, Bengaluru 6.00 3.35
18. Rachenahalli Lake, BDA 2009-12 19.00 14.65
19. Thirumenahalli Lake, BBMP 2012-14 2.20 2.33
20. Varthuru Lake, BDA 2013-14 2.33 0.87
21. Vengaiahanakere, Bengaluru 2.12 2.01
22. Venkateshpura Lake, BDA 2009-10 0.47 0.74
23. Vibhuthipura Lake, BDA 2013-14 3.37 0.68
24. Yelahanka Lake, BBMP 2011-13 16.15 14.34
Other cities
25. Akkamahadevi Lake, Haveri 2005-12 2.64 2.52
26. Alarwad Tank, Belagavi 2012-13 1.00 0.63
27. Amanikere Lake, Tumakuru 2008-14 13.37 9.09
28. Bhishma Lake, Gadag 2004-12 2.50 2.33
29. Dalvoy Lake, Mysuru 2013-14 1.17 0.82
30. Gudavi Wetland, Shivamogga 2005-13 0.98 0.61
31. Kotekere Lake, Belagavi 2004-09 5.64 5.73
32. Kuduchi Tank (Big), Belagavi 2011-12 0.23 ---
Kuduchi Tank (Small),
33. 2012-13 0.36 ---
Belagavi
Kunnirkatte Lake,
34. 2007-11 0.46 0.41
Channapatna
35. Magadi Wetland, Gadag 2005-14 0.66 0.39
Rangarayanadoddi Lake,
36. 2007-11 0.24 0.22
Ramanagara
Source: As furnished by the implementing agencies
52
de-watering, dredging, earthwork excavation, fixing foundation, construction of
granite/trap size stone masonry in basement, etc.
Appendix 6
Comparative study of lake area of test-checked lakes
(Reference: Paragraph 4.3/Page 18)
Area of the lake as Area as Area as Area as per Area as per
Area as per
per Shri per per KSRSAC Record of Rights,
Sl. 2006 revenue
Name of the lake Survey No. Lakshman Rau Government DPR (Cadastral Tenancy and
No. survey
Committee Report Order (2011) (Acres- maps) Crops (RTC)
(Acres-guntas)
(Acres-guntas) (Acres-guntas) guntas) (Acres-guntas) (Acres-guntas)
1 2 3 4 5 6 7 8 9
1. Allalasandra Lake 15 43-1.09 41-23 41-23 NA 49-31.77 41-23
12-
2. Amblipura Melinakere 36 47-29.80 61-11 12-16 13-7.8 12-16
15.97
3. Amruthahalli Lake 115 23-3.78 24-36 24-36 NA 25-20.752 24-36
81 74-0.52 56-29 56-23 90-6.2 84-9.06 56-29
4. Attur Lake
92, 39, 12 33-15 33-15 33-15
5. B.Channasandra Lake 64 18-19.02 19-17 19-17 NA 44-6.22 19-17
12-
6. B.Narayanapura Lake 109 19-36.32 15-06 14-20 0-18 15-06
18.94
1 284-02 284-02 597-1.1
6 13-15 13-15
12 399-14 399-14 399-14
7. Bellanduru Lake
62 4-3 3-04
43 166-15 166-15 166-15
2 915-0
8. Chikka Bellanduru Lake 9 Not listed 67-14 67-14 NA 68-1.824 67-14
11-33
(Sy. No.15)
9. Chinnappanahalli Lake 01-15 27-19.64 11-39 11-39 14-1.18 12-37.16
11-10
(Sy. No.17)
10. Chokkanahalli Lake 2 8-35.68 8-02 8-02 08-02 8-24.49 8-02
Dasarahalli 24 3-29 3-29 20-01 28-13.02 3-29
11.
(Chokkasandra) Lake 5 26-12.22 24-04 26-30 24-04
56-39
56-39 (Sy. No.200)
(Sy. No.200) 111- 3-15
12. Doddanekundi Lake 200, 13, 25 116-11.504 118-32 122-20.528
3-15 34.65 (Sy. No.13)
(Sy. No.13) 75-16
(Sy. No.25)
58 18-32 18-32 18-2.109 18-32
13. Gangashetty Lake
46 2-35 2-35 2-35
14. Garebhavipalya Lake 41 22-12.16 18-04 NA 17-39.017
Garudacharpalya Lake
15. 31 Not listed 5-36 5-36 NA 5-39.115 5-36
(Achanakere)
16. Horamavu-Agara Lake 77 134-16-89 51-34 51-34 NA 52-7.831
Appendix 7
Encroachment of lake area
(Reference: Paragraph 4.5/Page 20)
Sl. Name of the
As per DPR As per Joint Verification
No. lake/Custodian
Bengaluru
1. Allalasandra/BBMP DPR not produced to Audit Road, slum
The tank is land locked with
Amblipura Inlet encroached by Defence
2. compound walls of properties
Melinakere/BBMP authorities
abutting tank
A family settled inside, road passes
Amruthahalli/BDA through the main bund. Lake bed
3. DPR not produced to Audit
being filled up and cutting trenches
for BWSSB’s UGD work
Building and solid wastes are
unloaded in the lake bed and on
100 ft. asphalted road, raising of
4. Attur/BBMP bund and road; Farmers have
nursery inside lake
encroached the lake area,
formation of road in lake bed
The inlets to the lake missing and
considerable area of the lake was
5. B.Channasandra/BDA DPR not produced to Audit taken by BDA while forming
OMBR layout to allot compensatory
sites
Outer Ring Road, service road and
Outer Ring Road, service road and
approach road to nearby localities.
approach road to nearby localities.
6. B.Narayanapura/BDA In addition, lake land is encroached
In addition lake land is encroached
upon by temple, slum and other
by settlements
settlements
Encroachment in 16 acres Change of water course by diverting
7. Bellanduru/BDA
identified inlet at Kempapura village noticed
The lake inlet was missing. Earth
8. Chikka Bellanduru/BDA DPR not produced to Audit
filling, solid waste dumping
9. Chinnappanahalli/BBMP No encroachments indicated Temple and a house
10. Chokkanahalli/BBMP No encroachments indicated Lake bund was used as road
11. Dasarahalli/BBMP Road, slum Road, slum, temple
Road inside fenced area of lake,
As per topographical survey in
temple, children’s’ park, etc. During
DPR the lake spread over only 111
12. Doddanekundi/BDA JPV, only three inlets were
acres. There were four inlets to the
available. South-west inlet channel
lake
was missing
Encroachment, allotment for
Inlets missing and road formed on
13. Gangashetty/BDA government school building slum
the lake bed
and road
The lake area encroached and
Garebhavipalya/BDA formation of roads on the lake area.
14. DPR not produced to Audit
Also a temple exists inside the lake.
Earth filling inside the lake area
Garudacharpalya Road connecting Garudacharpalya
15. (Achanakere)/BDA DPR not produced to Audit to Outer Ring Road. Sheet houses
on the northern region of the lake
Roads formation on all four sides
and encroachments. Outlet
Horamavu-Agara/BDA encroached upon. Earth filling,
16. DPR not produced to Audit
breaching fencing and new
encroachments for formation of bus
stand noticed
Appendix 8
Sl.
Name of the lake Main source of pollution
No.
Bengaluru
1. Allalasandra Lake, BBMP Sewage
2. Amblipura Melinakere, BBMP Construction debris
3. Amruthahalli Lake, BDA Sewage
4. Attur Lake, BBMP Sewage
5. B.Channasandra Lake, BDA Defecation
6. B.Narayanapura Lake, BDA Sewage
7. Bellanduru Lake, BDA Sewage
8. Chikka Bellanduru Lake, BDA Multiple (construction debris and solid waste)
9. Chinnappanahalli Lake, BBMP Sewage
10. Chokkanahalli Lake, BBMP Sewage
11. Dasarahalli Lake, BBMP Multiple (industrial effluents, sewage and human defecation)
12. Doddanekundi Lake, BDA Sewage
13. Gangashetty Lake, BDA Sewage
14. Garebhavipalya Lake, BDA Multiple (sewage, solid waste and industrial waste )
15. Garudacharpalya Lake, BDA Sewage
16. Horamavu-Agara Lake, BDA Sewage
17. Jakkur-Sampigehalli Lake, BDA Sewage
18. Kaigondanahalli Lake, BBMP Sewage
19. Kalkere-Rampura Lake, BDA Multiple (sewage and construction debris)
20. Kasavanahalli Lake, BBMP Sewage
21. Kogilu Lake, BBMP Others (pesticides and fertilizers)
22. Kowdenhalli Lake, BBMP Sewage
23. Kundalahalli Lake, BBMP Multiple (solid wastes, debris and sewage )
24. Mahadevapura Lake, BDA Sewage
25. Mestripalya Lake, BDA Sewage
Multiple (human defecation, construction debris, sewage and
26. Nagavara Lake, Bengaluru
industrial effluents)
27. Rachenahalli Lake, BDA Sewage
28. Shivanahalli Lake, BDA Sewage
29. Thirumenahalli Lake, BBMP Industrial waste
30. Varthuru Lake, BDA Sewage
31. Vengaiahanakere Lake, Bengaluru Sewage
32. Venkateshpura Lake, BDA Construction debris
33. Vibhuthipura Lake, BDA Sewage
34. Yelahanka Lake, BBMP Multiple (solid wastes, sewage and industrial effluents)
Other cities
35. Akkamahadevi Lake, Haveri Human defecation
36. Amanikere Lake, Tumakuru Sewage
37. Bhishma Lake, Gadag Multiple (sewage and open defecation)
38. Dalvoy Lake, Mysuru Sewage
39. Kempkere, Hubballi-Dharwad Multiple (open defecation and sewage)
40. Kolikeri, Hubballi-Dharwad Sewage
41. Kotekere Lake, Belagavi Sewage
42. Magadi Wetland, Gadag Human defecation
43. Navalur Lake, Hubballi-Dharwad Sewage
44. Nuggikeri, Hubballi-Dharwad Sewage
45. Sadankeri, Hubballi-Dharwad Sewage
46. Unkal Main Lake, Hubballi-Dharwad Sewage
47. Unkal Small Lake, Hubballi-Dharwad Multiple (human defecation and cattle washing)
Appendix 9
Details of possible breach of buffer zone
(Reference: Paragraph 6.4/Page 43)
Survey Numbers and Nature of possible breach of
Sl. No. Name of the lake
Village/Hobli buffer zone
Survey numbers 33, 34, 35 and Private Apartments - Sai Shree
36 of Amblipura Melinakere Apartments
Manoj lake view residency,
Survey numbers 33, 34 and 36
No.21, Ward No.150
of Amblipura Melinakere
1 Amblipura Melinakere
Survey numbers 29 and 33 of Jana Jeeva Silver Palm
Amblipura Melinakere Apartments
Survey numbers 27 and 30 in SJR Park Vista Apartments
Amblipura Melinakere
Survey number 14 of Janapriya Apartments abbutting
2 Allalasandra
Allalasandra village lake and storm water drain
Survey numbers 16 and 44 of Private Apartments,
Chinnappanahalli village Chinnappanahalli village
Survey numbers 14 and 44 of Shri Lorven Nest Apartments,
3 Chinnappanahalli
Chinnappanahalli village Chinnappanahalli village
Survey numbers 14, 16 and 44 Saroj Aquila Apartments,
of Chinnappanahalli village Chinnappanahalli village
Survey number 15 of Dasarahalli
4 Dasarahalli Slum
village
Survey numbers 47, 48 and 49
Private Apartments construction
of Kasavanahalli village.
5 Kasavanahalli
Survey numbers 8, 27, 31 and 32
Private Apartments construction
of Kasavanahalli/Haralur village
Survey numbers 69/1, 69/2 and Construction of villas
63(P) Kasavanahalli, Haralur Road
Private Apartments
Survey number 63 of
Kasavanahalli, Haralur Road
Kasavanahalli village
6 Kaigondanahalli Apartments in Survey number 9 Mitra Spring Valley Apartments,
of Kaigondanahalli village Kaigondanahalli village
Survey number 11 of
Water Mark Homes Apartments,
Kaigondanahalli village and
Kaigondanahalli and
Survey number 68 of
Kasavanahalli villages
Kasavanahalli village
Source: Survey numbers and location as per KSRSAC maps
GLOSSARY
BBMP Bruhat Bengaluru Mahanagara Palike
BDA Bengaluru Development Authority
BWSSB Bengaluru Water Supply and Sewerage Board
CC City Corporation
CDP Comprehensive Development Plan
CMC City Municipal Council
DC Deputy Commissioner
DPR Detailed Project Report
GoI Government of India
GPS Global Positioning System
ITI Indian Telephone Industries
JPV Joint Physical Verification
KIADB Karnataka Industrial Area Development Board
KSPCB Karnataka State Pollution Control Board
KSRSAC Karnataka State Remote Sensing Applications Centre
LDA Lake Development Authority
MLD Million Litre per Day
Mahadevapura Parisara Samrakshane Matthu Abhivruddhi
MPSMAS
Samithi
NGO Non-Governmental Organisation
NLCP National Lake Conservation Plan
NWCP National Wetland Conservation Programme
PCCF Principal Chief Conservator of Forests
RCC Reinforced Cement Concrete
RMP Revised Master Plan
RTC Record of Rights, Tenancy and Crops
STP Sewage Treatment Plant
SWD Storm Water Drain
UDD Urban Development Department
UGD Underground Drainage
ULB Urban Local Body