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Groundwater Regulatory Intelligence for Industries in India

Ground Water abstraction cycle in India
Ground water borewell with metering and telemetering

Groundwater availability can materially affect the feasibility, expansion and long-term operation of an industrial project.

For an industry planning a new facility, installing or operating borewells, increasing production, renewing groundwater permission or acquiring industrial land, the key question is not simply whether groundwater exists below the site.

The more important questions are:

  • How is the location classified from a groundwater-resource perspective?

  • Which authority regulates groundwater abstraction at the site?

  • Is the project a new or an existing groundwater user?

  • How much groundwater is proposed to be abstracted?

  • What is the plant's actual water requirement and water balance?

  • Are alternative sources available?

  • What recharge, rainwater-harvesting, monitoring or reuse measures may be relevant?

  • Does the project require additional hydrogeological or impact-assessment work?

SARK Engineers & Consultants provides engineering-led groundwater regulatory and technical support to industries, helping project owners connect groundwater regulation with actual plant water demand, process requirements, wastewater reuse, rainwater harvesting and project feasibility.

Groundwater Assessment Categories in India

Groundwater resources in India are periodically assessed by the Central Ground Water Board together with State Governments.Assessment units are categorised according to groundwater-resource conditions and the stage of groundwater extraction.

 

The principal categories commonly encountered are:

01

Safe

A Safe assessment unit generally has comparatively lower groundwater-development stress relative to available extractable groundwater resources.

A Safe classification should not, however, be interpreted as automatic permission to construct or operate an industrial borewell. Applicable groundwater regulations, project characteristics, abstraction quantity, competent authority and other requirements still need to be checked.

03

Critical

A Critical assessment unit represents a substantially stressed groundwater-resource situation.

For industries, this can make groundwater availability and regulatory feasibility an important part of project planning, expansion assessment and water-source strategy.

02

Semi-Critical

A Semi-Critical assessment unit indicates increasing pressure on groundwater resources.

Industrial projects proposed in such locations should evaluate their future water requirement carefully rather than treating groundwater as an unlimited utility source.

04

Over-Exploited

An Over-Exploited assessment unit is one in which groundwater extraction has exceeded the assessed annual extractable groundwater resource.

For a proposed industrial project, the presence of an Over-Exploited classification should trigger a detailed regulatory and technical review before assumptions are made regarding borewells or fresh-groundwater availability.

Why Groundwater Classification Matters for an Industrial Project

Groundwater classification can affect much more than a groundwater-NOC application.

​

It can influence:

  • project-site feasibility;

  • availability of dependable process water;

  • borewell planning;

  • industrial expansion;

  • water-source diversification;

  • rainwater-harvesting strategy;

  • recharge planning;

  • treated-wastewater reuse;

  • plant water balance;

  • environmental approvals;

  • capital expenditure on water infrastructure; and

  • long-term operating risk.

​

For a groundwater-dependent project, these issues should ideally be studied before major capital expenditure is committed.

​

An industrial plot that appears suitable from the perspective of land price, connectivity and utilities can become considerably less attractive if its planned water demand cannot be supported by a technically and legally sustainable water-source strategy.

Industrial Water Balance

Can a Factory Extract Groundwater in an Over-Exploited Area?

There is no useful universal answer based only on the words “Over-Exploited”.

Groundwater eligibility should be determined from the currently applicable groundwater regulations and project-specific facts.

Important factors can include:

  • location of the project;

  • applicable Central or State groundwater authority;

  • latest classification of the relevant assessment unit;

  • whether the unit is new or existing;

  • nature of the activity;

  • quantity and purpose of groundwater abstraction;

  • existing groundwater permissions;

  • alternative sources of water;

  • project expansion or modification;

  • water-conservation measures;

  • wastewater recycling and reuse;

  • rainwater harvesting or recharge provisions; and

  • additional studies or documentation applicable to the project.

​

Industries should therefore avoid making investment decisions from a generic online statement such as “groundwater is prohibited” or “borewells are permitted”.

​

The correct question is:

What groundwater abstraction is legally and technically feasible for this particular project at this particular location under the rules currently applicable to it?

New Industry vs Existing Groundwater User

The regulatory position of a greenfield project may differ materially from that of an operating industrial unit.

A new industrial project

New Industrial Projects

Before finalising groundwater as a primary water source, a new project should establish:

  1. the applicable groundwater authority;

  2. the current groundwater classification;

  3. expected process, domestic and utility water demand;

  4. alternative water availability;

  5. wastewater generation;

  6. potential recycling and reuse;

  7. rainwater-harvesting potential;

  8. groundwater-monitoring requirements; and

  9. whether the proposed abstraction strategy is compatible with applicable requirements.

This analysis should preferably form part of the project feasibility process.

Existing Industry

Existing Industries

An operating factory may have different issues, such as:

  • groundwater-NOC renewal;

  • increased abstraction following production expansion;

  • additional borewells;

  • non-operational or replacement borewells;

  • ​

  • piezometer or monitoring arrangements;

  • altered water balance;

  • increased workforce or domestic demand;

  • changes in the groundwater classification of the area since the original permission.

An old permission should not automatically be assumed to represent the current regulatory or operating position.

CGWA or State Groundwater Authority: Which One Applies?

Groundwater regulation in India requires an important jurisdictional check.

Depending on the State or Union Territory and the applicable legal and administrative framework, groundwater abstraction may fall under the Central Ground Water Authority or an applicable State groundwater authority.

An industrial applicant should therefore establish the competent authority before preparing the application or technical documentation.

Using the wrong regulatory pathway can result in unnecessary delay, incorrect documentation or a fundamentally incorrect assessment of project feasibility.

SARK's approach is to identify the applicable jurisdiction first and then develop the technical and documentation strategy around the actual project.

What Should an Industry Check Before Buying Land?

For groundwater-dependent projects, groundwater due diligence should ideally be carried out before land purchase or major project commitment.

A preliminary review should consider:

Groundwater Classification

Identify the latest classification applicable to the assessment unit containing the proposed site.

Project Water Requirement

Estimate realistic demand for:

  • manufacturing processes;

  • washing;

  • cooling;

  • boilers;

  • utilities;

  • domestic consumption;

  • horticulture;

  • fire-water make-up where relevant; and

  • other site requirements.

Alternative Water Sources

Evaluate potential availability of:

  • municipal or industrial water supply;

  • surface water;

  • treated sewage;

  • purchased water;

  • recycled process water;

  • recovered condensate; and

  • rainwater.

Wastewater Reuse Potential

A plant requiring 300 m³/day of total water does not necessarily require 300 m³/day of fresh groundwater.

Proper segregation, treatment and reuse can materially change fresh-water demand.

Rainwater-Harvesting Potential

Roof area, paved area, local rainfall, storage potential, recharge feasibility and stormwater management should be considered as part of the overall water strategy.

Future Expansion

A water strategy that works for the first production line may become inadequate when a second line is installed.

Future water demand should therefore be incorporated into the feasibility review.

​

Groundwater Permission Before Industrial Expansion

Industrial expansion is often evaluated from the perspective of machinery, power and production capacity while the water requirement receives attention relatively late.

That can be a costly mistake.

Before increasing production, industries should compare:

Existing permitted abstraction

against

Current actual abstraction

against

Projected abstraction after expansion.

The assessment should also review the revised process water balance, additional domestic demand, cooling requirements, boiler demand, wastewater generation and potential increase in recycled-water availability.

Where the expansion materially changes water demand, groundwater regulatory implications should be evaluated before commissioning the additional capacity.

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