Comments On State Suggestions 26102015

State/Agency
Maharashtra
Section #
2a
Maharashtra
2b
Maharashtra
2b
Point #
14
21
Maharashtra
Maharashtra
Maharashtra
Maharashtra
12-13
State Comment
The Single Window platform/framework should be proposed for Manufacturing/Industries only, as
business would cover many aspects which include non-industrial set-ups. Thus, the questions related to
Single Window should be changed to Setting up an Industry
Response
The scope of Ease of Doing Business covers all business,
including industrial and commercial activities. Thus business
reforms must support the growth of all business.
DIPP is developing and promoting the E-biz platform for State approvals also. The E-Biz platform is
expected to Go-Live from early 2016 for L1 and L2 integration for the critical industry approvals. If this is
the mandate and way forward, States should not be expected to develop their own Single Window
System and should only use E-Biz, Therefore, questions pertaining to this section may be removed.
States that implement eBiz so that it meets the objectives of

this Action Plan will receive credit for these interventions. eBiz
is a platform that states may choose to implement to provide
single window services.
CAF should be used to only populate the majority of information regarding entrepreneur and investment.
These fields should be taken from most of the department application forms to cover the common fields.
It is not practical to populate every field across all industry approval form, else the CAF would become
unwieldy. DIPP should clarify this.
As a part of ease of doing business, States should have minimum number of mandatory approvals for
setting up an Industry. The revised assessment framework doesnt emphasize on this aspect.
DIPP will circulate knowledge from other states that have

already implemented this, so that all states will be able to
learn from each other's experience
This may be considered for future years
The draft regulations for inviting and publishing public comments should be limited to regulations related Suggestion accepted and addressed
to industry approvals only by government departments.
Although there are number of approvals required for setting up an industry, the critical ones that
This is an issue for the assessment of state reform
typically cause delay relate to:
implementation next year, and this may not be relevant to the
State Action Plan.
a. Acquiring Land
b. Environment Clearances
c. Labour Approvals
d. Infrastructure Development permissions for water, power
The framework should address these concerns and give higher weightages for questions/interventions
related to the above clearances.
Ease of Doing Business is related to industrial development and supplementing Make in India
campaign by GoI and DIPP. Since, for industries, most of states would receive maximum number of
applications at their respective Industrial Development Corporations, the questionnaire should clearly
highlight this and focus on responses from this organization only.
In addition, there are several cases, especially for large, ultra and mega projects, wherein industries need
to be set-up in rural areas. There should be separate questions for such scenarios, as unlike IDC, multiple
agencies are involved in giving approvals (Gram Panchayat, Collector, Town Planning, etc.)

State/Agency
Maharashtra
Section #
Point #
Maharashtra
State Comment
Through various investor interactions in the recent past, government has realized that it is essential to
increase awareness and disseminating information related to key reforms implemented by the Centre
and States. In this context, DIPP should introduce a structured framework to judge effectiveness of
implementation of reforms on an ongoing basis.
Response
State Action Plan.
Policy on attracting investments, providing enabling infrastructure and giving exemptions/incentives is a This may be considered for future years
critical aspect of industrial development. Aspects pertaining to Industrial Policy and few focus sectors like
Automobiles, ESDM, IT, Aerospace and Defence, should be included for comparative benchmarking.
Also factors like availability of skilled labour, number of mandays lost due to strikes/unrest, etc. may be
factored in the revised assessment.
Maharashtra
MSMEs require special focus and benefits. For this sector, there should be a separate regime of ease of This may be considered for future years
doing business for faster clearances, exemptions and lower cost of service delivery from government. The
revised Assessment must factor clearances/approvals needed for them separately.
Maharashtra
Maharashtra
Maharashtra
2a
16
There should be a uniform criteria for Inspections/Approvals/Exemptions for classifying industries various
into Red/Orange/Green categories, while giving consent for environment related approvals. This should
be standardized at a pan India level.
DIPP should empanel professional agencies across the country who would undertake mandatory (third
party) inspection/certification at affordable cost for Boilers. The services of these agencies must be made
available till the district level
If all the required decision making powers are delegated to the single window body, the bureau will run a
parallel government for industry approvals. Also, to facilitate inspections and send field officers for survey
and data collection and routine industry visits, a large team would need to be seconded to the Bureau.
Hence, it may not be a feasible proposal to vest all the powers under one agency.

DIPP would be pleased to support state reforms with any
required support to reforms at the Centre.
Also, if DIPP wishes to pursue the proposed framework of a single bureau, please provide the following
inputs:
How long (duration) the senior level officials will be appointed through deputation?
What powers will they have?
What will be the role of the Senior level official in the Single Window clearance?
Will respective departments, from which such officers are drawn, cease to give any industry related
approvals?
Maharashtra
3c
55
This is a mammoth task. Land Records exist across districts and not every region/taluka may have 100% DIPP will circulate knowledge from other states that have
digitization and accuracy, despite more than a decade of effort. To integrate with judicial database, which already implemented this, so that all states will be able to
may not exist in automated format for even large cities, would not be feasible.
State/Agency
Maharashtra
Section #
7a
Point #
182
Maharashtra
10
328
Maharashtra
8c
210
Maharashtra
250
Maharashtra
Maharashtra
4c
81-85
State Comment
How will this initiative address Ease of Doing business for investors is not clear.
Response
This measure, similar to other measures covered in this
section, relates to certainty regarding the quality of electricity
coverage. Ensuring investor certainty about electricity quality
can assist in planning for mitigating measures and steps.
Judiciary reforms are the prerogative of the Central Government. Questions related to these enablers
should not be used for State assessment

DIPP may propose a structure/reform for States for Industrial Disputes, with timelines and roles and
responsibility that could be adopted.
Traditionally check posts for Sales Tax has not been implemented in Maharashtra since beginning i. e.
1960. The information about transactions is verified on the basis of books of accounts, transport
documents etc. thus, questions pertaining to this parameter should be removed.
This parameter is present in many other states, and they must

take action if relevant
For large states like Maharashtra, submission of inspection report within 48 hours for VAT registration is
not possible. This should be extended to atleast 15 days.
The use of increased risk assessment and self/third-party

certification for low/medium risk industries may allow the
time and workload for inspectors to be better balanced
Questions pertaining to the urban department doesnt specify whether answer should be sought from
single or multiple ULBs. Each ULB will have different degree of automation, with a higher degree of IT
maturity within cities and lower penetration of technology in rural areas. There cannot be a uniform
responses at the state level.
Industrial Development Corporations should be designated the tree authority for their jurisdiction
whereas Forest dept. should be designated the tree authority for areas outside industrial estates.

In addition, if land has been acquired for industrial development, tree cutting is bound to happen. DIPP
may propose removing this approval for all States and in lieu, corporates may be mandated to plant new
trees in designated areas to ensure conservation.
Maharashtra
For ease of doing business, it is important to provide critical infrastructure in the industrial estates. Also, This may be considered for future years
keeping in line with climate change and clean energy, States must adopt measures for promoting Reforms
for use of clean energy and establishing common affluent treatment plants for discharge of Hazardous
wastes. Such measures, may be included in the Assessment.
State/Agency
Maharashtra
Section #
Point #
State Comment
There are several instances wherein old factories, lying unused for several years are bought by investors
to re-start operations. However, there is no defined procedure and timeline for such steps as labour
dues is a sticky issue as no authority has the clear status on total dues pending and responsibility of
settling dues and ensuring payment is also no clearly established. Thus, due to pending litigations, new
investors are unable to start operations and investments do not accrue.
Response
DIPP in co-ordination with Labour Ministry is requested to lay down guidelines for the same.
Maharashtra
8h
198, 204, Since entertainment tax is not applicable for the Industry, questions pertaining to the same should be
232-236 removed from the revised framework.

Maharashtra
8i
196, 202, Since Luxury tax is not applicable for the Industry, questions pertaining to the same should be removed
237-241 from the revised framework

Maharashtra
Entertainment tax and Luxury tax are typically applicable for commercial establishments like multiplexes The scope of Ease of Doing Business covers all business,
and hotels respectively. These taxes are not applicable to industries (manufacturing). Therefore, these
taxes should not form part of the proposed Single Tax ID.
Maharashtra
4a
71
Completion certificate has lot of significance for an industry to get into production and should be issued
by government only. Third party architects should be used for inspections.
Occupancy certificates are typically issued by the government

for industries to get into production. Completion certificates
in many states are already issued by the architect as a
prerequisite for occupancy certificates.
Maharashtra
4a
72
This may be only possible in the long term, but concrete steps
in the right direction must be taken immediately.
Rajasthan
4a
72-74
To conduct plot wise survey of trees would be a time consuming and expensive proposition, which would
not facilitate ease of doing business. Since the objective is to move to self-certification and plant trees (in
lieu of cutting trees), Government may propose norms of tree plantation based on area of plot, terrain
conditions, built up area, etc.
The state IDC RIICO allots the land to an enterprise after development only. The development of land
includes leveling, construction of roads and demarcation of plots. Therefore the felling of trees related
points are not relevant in the context of business reforms
Rajasthan
4c
81-85


State/Agency
Rajasthan
Section #
9d
Point #
258-262
Haryana
4a
62
Haryana
4a
63-65
Haryana
5a
93-94
Haryana
8a
195
Haryana
8a
197
Haryana
8b
201
Haryana
8b
203
Haryana
8c
210
Haryana
8f
222-226
Haryana
10
328-344
FICCI
FICCI
FICCI
FICCI
[New]
State Comment
Response
* Building plan approval by the departments whether Urban local bodies or HSIIDC or Town & Country
Suggestion accepted and addressed
Planning or HUDA is granted in accordance to the bye-laws applicable in their department. As far as code
is concerned National building code already exists.
* Comprehensive Formal Building Code to be developed by the T&CP department/State Government
shall be followed by HUDA.
* Yes; Building code and building bye laws are two different things. So here instead of building code
building bye laws should be put in place.
* Comprehensive Formal Building Code to be developed by the T&CP department/State Government
shall be followed by HUDA.
Agree on this point if the Central Govt. may amend the provision in the Act.
Not Applicable. Professional Tax not levied in the State
Not Applicable due to Litigation
Not Applicable due to Litigation
Not applicable. There are no check posts in the State
Agree on this point if Central Govt. can ensure direction to the High Court for implementation.
Could be covered under taxation
These are enablers for business start-up and so are included
here
here
here
Add action: Ensure that the process of clearance/permission is mapped with each and every stage and
This is addressed in the suggestions below
the status of permission can be tracked online on real time basis. The timelines should be defined for
each and every step involved in the permission process with a provision for alert at the senior levels for
any delays.
State/Agency
FICCI
Section #
4c
Point #
83
State Comment
Add tracking and monitoring functionality to system
Response
FICCI
4d
88
FICCI
5b
99
FICCI
5c
104
FICCI
5d
109
FICCI
5e
114
FICCI
5f
119
FICCI
6b
127
FICCI
6c
132
FICCI
6d
137
FICCI
6e
142
FICCI
6f
147
FICCI
6g
152
FICCI
6h
157
FICCI
6i
162
FICCI
6j
167
FICCI
6k
172
FICCI
6l
177
FICCI
7b
192
State/Agency
FICCI
Section #
8d
Point #
214
State Comment
Response
FICCI
8e
219
FICCI
8f
224
FICCI
8g
229
FICCI
8h
234
FICCI
8i
239
FICCI
10b
[New]
Add action: Design and implement a system to allow for e-payments
Question 343 has been amended to include e-payments
Right of way for power distribution cables

Approval of R&R scheme for land acquisition
Forest Rights Act 2006- For every diversion of forest area certificate of compliance against Schedule
Tribes & Other Traditional Forest Dwellers (Recognition of Forest Rights) Act has to be obtained prior to
submission of diversion proposal
NOC for soil excavation/filling
NOC for blasting by explosives and establishment of magazine under Explosives Act & Rules

Grant of Right of Way for tower erection and lines for power supply
Approval for electrical equipment installed at the site and commissioning the electrical system under
Electricity Act 2003 and Indian Electricity Rules 1956
Permission for Highway Crossing, access road through highway, right of way etc under Section 278 of the
Highways Act 1980
Approval for cutting of footpath/road/road crossing lane/Right of Way
Indian Forest Act, 1972- Notification to constitute any land a reserved forest. As per the guidelines of
MoEF, Government of India, the non-forest land which is transferred and mutated in favour of the State
Forest Department for the purpose of compensatory afforestation, should be declared as RF/PF under
the Indian Forest Act, 1972 section 4
Wildlife Management Plan approval/Clearance
Coastal Regulation Zone Legislation- Recommendation for the project to MoEF/SEIAA for establishing
project in coastal zone
Coastal Regulation Zone Legislation- Clearance for captive berth and sea water

FICCI
FICCI
FICCI
FICCI
FICCI
FICCI
FICCI
FICCI
FICCI
FICCI
FICCI
FICCI
FICCI



State/Agency
FICCI
FICCI
FICCI
FICCI
FICCI
FICCI
FICCI
FICCI
FICCI
FICCI
FICCI
FICCI
FICCI
FICCI
FICCI
Chhattisgarh
Section #
Point #
State Comment
Authorization required from State Pollution Control Board for generation, transportation, collection,
treatment, disposal, sale etc of Hazardous waste under Hazardous Waste (Management & Handling &
trans-boundary movement Rules, 2008 (amended upto 2009) (Hazardous Waste Rules)
Response
Authorization under Bio-Medical Waste (M&H) Rules applicable to all persons who generate, collect,
receive, store, transport, treat, dispose or handle biomedical waste under the Bio-Medical Waste
(Management and Handling) Rules, 2011
NOC for Sewage water treatment and associated plumbing
Permission/Clearance for drawing ground water for industrial purpose
Apply for sewerage connection and deposit inspection fees
Approval for Registration of the establishment under the Inter State Migrant Workmen Act under the
Inter State Migrant Workmen Act, 1979;The Inter State Migrant Workmen Rules, 1980
Permission for storage of fuel oil and chemicals

Approval from Traffic & Coordination Department (Municipal) when the project involves disruption of
general traffic movement/circulation pattern temporarily or permanently during and after the
construction of the project
Approval of weights and measuring instrument intended to be used; Under Standards of Weights and
Measures Act, 1976 (Act) and the Standards of Weights and Measures (General) Rules, 1987 (General
Rules)
Registration as packers under Legal Metrology (Packaged Commodities) Rules 2011
MMDR Act 1957 & Mineral Concession Rule 1960- Grant of Reconnaissance Permit; Prospecting License
or Mining lease
NOC if project site near the monuments etc
Permission required if the project site is within the jurisdiction of the Port Trust
Tribal Development Plan approval/Clearance
NOC from Department of Fisheries for hydro project
It is requested that ample reference, wherever required/applicable, be provided to the States/Uts for
standardisation of user experience. In the previous exercise, this was not done due to which, the form of
representation was subjective and left to interpretation, which caused confusion during assessment. For
instance, a sample document to act as a benchmark may be shared for recommendation points like
"Ensure information on the procedure and a comprehensive list of all documents that need to be
provided are available on the web site".



DIPP will circulate a vision/guide document to help states
understand what needs to be done. In addition, DIPP would
be pleased to facilitate state-level workshops with
departments to explain the vision/guide for each of the
actions.
State/Agency
Chhattisgarh
Section #
9
Point #
Chhattisgarh
There are some inspection-related questions that seek random allotment of inspectors as part of EoDB. Authorization of inspecting authorities is with the State
This is not possible across the board. For example, in case of Tree-Cutting NOC, only the appropriate
Governments and necessary changes may be made by them
Revenue department officer is authorised to do field inspection and submit report. In such a case, there is to facilitate random allocation.
no way in which random allotment of inspecting authority is possible or practically feasible, because the
Tehsildar/SDM of that area alone is the authorized person to do field inspection and submit report. In
such cases of one-to-one mapping of authority inspection, its kindly submitted that exception has to be
made from the mandate of random inspection.
Chhattisgarh

Chhattisgarh
10
Considering the number of inspectors in the State, the requirement of mandating online submission of
inspection report within 48 hours and the mandate that same inspector will not inspect the same
establishment twice consecutively may not be feasible. It is therefore requested to keep the timeline at
72 hours, as like the previous year's recommendations.
Commercial dispute resolution and paper-less courts are progressing under the guidance of High Courts.
Therefore, considering the limited role of department, the associated questions may be suitably
revised/dropped. In fact, for all legal/court related points, it is further suggested that they be clubbed and
taken up by DIPP, with the Union Law Ministry directly.
There are always certain questions that may have been done away with, altogether, by a State. They
should all, be treated as a "Yes" rather than as a N/A because doing away with a requirement under a
question altogether is better than automating for it. Also, there should be positive oriented cut-off (such
as "no later than") rather than an arbitrary commencement cut-off (such as "not before"). Certain states
might have initiated reform on certain questions well before the time-lines envisaged by the EoDB
framework. Such early-bird reform must gain advantage due to it and not suffer different treatment vis a
vis other States taking such reforms in more recent times.
In light of the introduction of Udyog Adhar memorandum (UAM), the recommendation may be suitably
modified

This has already been done. Questions 179-184 relate to
distribution; questions 185 to 189 relate to electricity
connection.
Thank you
Chhattisgarh
Chhattisgarh
2b
41
Chhattisgarh
7a
181-189
Delhi
State Comment
It is suggested that for those inspections, which are to be done under the prevailing law, computerized
risk assessment may not be included. Since its mandatory, option of skipping any inspection or leaving it
to an assessment framework might not align with legal requirements. For example, at the first instance of
installing a boiler, inspection is mandatory under Boiler Act. Subsequent inspections (for renewal) may be
subject to a computerized risk assessment.
Recommendations relating to Obtaining Electricity Connection (section 7a) may be further segregated
into points relating to obtaining electricity connection and those relating to distribution.
I am directed to inform you that Govt. of NCT of Delhi agrees to Business Reform Action Plan 2016
formulated by the Government of
India, Ministry of Commerce and 'Industry, New Delhi.
Response


State Action Plan.
State/Agency
West Bengal
Section #
2a
Point #
15
State Comment
the necessity of establishing a single window mechanism through legislation could
perhaps be reyiewed. Any such law would necessarily have to be harmonised with the
existing statutes, particularly in sectors like environment, labour and electricity. To give
an example, section 25(1) of the Water (Prevention and Control of' Pollution) Act, 1974 which vests the
power to issue CFE I CFO with the PCB, may need to be amended to
I 1J allow further delegation to a single officer. A corresponding provision, Section 21(l) of the Air
(Prevention and Control of Pollution) Act, 1981, may also have to be amended. We believe that what will
matter in EODB will be administrative and political will, not just a fresh enactment.
Response
West Bengal
6a
124

West Bengal
9a
243
while liberalizing the norms for the renewals of factory licences, we need to carefully calibrate it with
safety requirements of the public and workers. A ten year period may see significant changes in
production processes and associated risk mitigation requirements, it might not be very wise to allow such
a long period between renewals.
self-certification in lieu of physical inspection under all labour laws is also fraught with worker safety
implications. This requirement too, would need to be re-examined.
West Bengal
2a
West Bengal
9n
West Bengal
9o
West Bengal
7a
MSMES occupy a significant position at the state level and often have requirements that
differ sharply from those of the larger industries. It may thus be appropriate to allow the states to
operate more than one single window mechanism.
similarly, to allow seIf certification and/or 3rd party verification under environment
laws, amendments to section 21(3) of the Air (Prevention and Control of Pollution) Act,
1981 and section 25(3) of the Water (Prevention and Control of Pollution Act. 1974, may have to be
made.
similarly, to allow seIf certification and/or 3rd party verification under environment
laws, amendments to section 21(3) of the Air (Prevention and Control of Pollution) Act,
1981 and section 25(3) of the Water (Prevention and Control of Pollution Act. 1974, may have to be
made.
the items relating to power connections need to be reworked in consultation with an
expert in distribution issues. In a scenario of overall power deficit and wide-spread
load-shedding in most states, insistence on matters like automatic outage tracking and
service restoration, providing information regarding supply reliabilities and outage
compensation, will really have little impact on business.


In the next Doing Business report by the World Bank, India's

rank will be based in part on Delhi and Mumbai's experience
with these elements. Other states should implement these
steps as well, to ensure that a conducive regulatory
environment for business is offered throughout the country.

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State/Agency

States that implement eBiz so that it meets the objectives of

DIPP will circulate knowledge from other states that have

The scope of Ease of Doing Business covers all business,

DIPP will circulate knowledge from other states that have

DIPP would be pleased to support state reforms with any

This parameter is present in many other states, and they must

The use of increased risk assessment and self/third-party

DIPP will circulate knowledge from other states that have

The scope of Ease of Doing Business covers all business,

The scope of Ease of Doing Business covers all business,

Occupancy certificates are typically issued by the government

The scope of Ease of Doing Business covers all business,

The scope of Ease of Doing Business covers all business,

Add tracking and monitoring functionality to system

Suggestion accepted and addressed

Add tracking and monitoring functionality to system

Suggestion accepted and addressed

Add tracking and monitoring functionality to system

Suggestion accepted and addressed

Add tracking and monitoring functionality to system

Suggestion accepted and addressed

Add tracking and monitoring functionality to system

Suggestion accepted and addressed

Add tracking and monitoring functionality to system

Suggestion accepted and addressed

Add tracking and monitoring functionality to system

Suggestion accepted and addressed

Add tracking and monitoring functionality to system

Suggestion accepted and addressed

Add tracking and monitoring functionality to system

Suggestion accepted and addressed

Add tracking and monitoring functionality to system

Suggestion accepted and addressed

Add tracking and monitoring functionality to system

Suggestion accepted and addressed

Add tracking and monitoring functionality to system

Suggestion accepted and addressed

Add tracking and monitoring functionality to system

Suggestion accepted and addressed

Add tracking and monitoring functionality to system

Suggestion accepted and addressed

Add tracking and monitoring functionality to system

Suggestion accepted and addressed

Add tracking and monitoring functionality to system

Suggestion accepted and addressed

Add tracking and monitoring functionality to system

Suggestion accepted and addressed

Add tracking and monitoring functionality to system

Suggestion accepted and addressed

Add tracking and monitoring functionality to system

Suggestion accepted and addressed

Add tracking and monitoring functionality to system

Suggestion accepted and addressed

Add tracking and monitoring functionality to system

Suggestion accepted and addressed

Add tracking and monitoring functionality to system

Suggestion accepted and addressed