PARIVESH SPCB Comment Procedure: MoEFCC Clarification 2025

Introduction

The latest Office Memorandum from MoEFCC has created urgent attention across industries, and many project proponents now seek clarity on the PARIVESH SPCB Comment Procedure. Because the Ministry has now clarified the Standard Operating Procedure for obtaining SPCB/PCC comments, organizations can finally reduce confusion. Moreover, this clarification simplifies workflows. Additionally, it ensures faster processing of Environmental Clearance (EC) proposals. Furthermore, the update also distinguishes between projects that needed Consent to Establish (CTE) before 12.11.2024 and those that did not. As a result, industries gain a more predictable and efficient clearance process.

Background of the Clarification

The Ministry of Environment, Forest and Climate Change (MoEFCC) issued Notifications G.S.R. 702(E) and 703(E) dated 12.11.2024. These exempted projects with prior Environmental Clearance from the need to obtain CTE. To operationalize this, the Ministry issued detailed SOPs on 14.01.2025 and 08.10.2025. Consequently, the PARIVESH portal began routing EC proposals to SPCBs/PCCs for comments.

However, SPCBs raised concerns. For example, mining of minor minerals never required CTE under Water and Air Acts. Yet, PARIVESH still sent these proposals to SPCBs, although comments were unnecessary. Therefore, MoEFCC issued the present clarification on 25 November 2025.

Key Clarifications Issued by MoEFCC

1. SOP Applies Only Where EC + CTE Were Earlier Mandatory

MoEFCC confirmed that the SOPs of 14.01.2025 and 08.10.2025 apply only to projects that required both EC and CTE before 12.11.2024. Hence, projects that never needed CTE should not be routed for comments.

This significantly reduces unnecessary delays. Additionally, it ensures that the workflow remains aligned with pre-existing regulatory requirements.

2. SEIAA May Proceed Without Waiting for SPCB Comments

For projects requiring EC but not CTE earlier, SEIAA may continue processing. It may grant EC without waiting for SPCB comments or fee requests. Since these comments do not add new environmental safeguards, therefore the process becomes faster and smoother.

This increases efficiency and, moreover, avoids bottlenecks in the appraisal cycle.

3. Implementation Deferred to 31 January 2026

MoEFCC also received requests to defer the SOP implementation. Consequently, the Ministry extended the “designated date” to 31.01.2026. This allows smoother transition, better capacity building, and timely disposal of pending applications.

Additionally, this helps states adjust their systems and teams accordingly.

4. Projects Approved Between 12.11.2024 and 31.01.2026 Must Seek Safeguards

If EC was granted during this period for projects that earlier required CTE, then they must obtain environmental safeguards from SPCB within 30 days from 31.01.2026 or the EC grant date, whichever comes first.

This ensures continuity of environmental protections.

5. Projects Accepted on PARIVESH Before 31.01.2026 Must Also Seek Safeguards

If a project was accepted on PARIVESH before 31.01.2026 and earlier required CTE, it must seek safeguards within 30 days from EC approval.

This maintains compliance uniformity, and ultimately ensures environmental accountability.

Impact on Industries and Project Proponents

This clarification significantly affects how industries approach environmental compliance. Therefore, organizations must:

Update their EC submission strategies
Review project categories carefully
Understand whether CTE was mandatory before 12.11.2024
Align PARIVESH submissions with revised workflows
Track safeguard obligations within new timelines

Moreover, these changes improve clarity and reduce duplication. Additionally, they help both SEIAA and SPCBs streamline decision-making.

Why This Clarification Matters

Because many proposals were unnecessarily routed to SPCBs, the process slowed down. Thus, this clarification ensures:

Faster EC processing
Correct workflow alignment
Removal of unnecessary steps
Reduced workload for SPCBs
Improved ease of doing business

Furthermore, the clarification restores consistency with long-standing regulatory practices.

Conclusion

The PARIVESH SPCB Comment Procedure clarification resolves significant confusion surrounding EC and CTE workflows. Since MoEFCC has now clearly defined the conditions under which SPCB comments are required, industries can proceed with greater confidence. Moreover, the extension to 31 January 2026 allows institutions adequate preparation time. Ultimately, this clarification enhances transparency, reduces delays, and strengthens environmental governance.

Download: PARIVESH SPCB Comment Procedure Complete Guide