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For Peer Review END-OF-LIFE VEHICLE MANAGEMENT IN AN INDIAN CITY Journal: Waste Management & Research Manuscript ID: WMR-13-0042.R1 Manuscript Type: Original article: 35,000 characters Date Submitted by the Author: n/a Complete List of Authors: Santhanam, Satakopan; Centre for Environmental Studies,College of Engineering Guindy, Anna University, Department of Civil Engineering Joseph, Kurian; Centre for Environmental Studies, College of Engineering Guindy, Anna University, Department of Civil Engineering Keywords: End-of-life vehicles management, ELV management, Vehicle recycling, ELV, ELV recycling Abstract: Tamil Nadu (TN) state in India, with 11.2 million registered two wheelers (2Ws) and 1.18 million registered cars in 2011, has the second highest vehicle population in India and stands first in the 2Ws population. With 15 years as average vehicle on-road life in Indian conditions, approximately 440,000 end-of-life 2Ws and 35,000 end-of-life cars are generated annually in the state, which must be properly managed. This paper analyzes the vehicle-related Indian legal framework to identify existing setup for end-of-life vehicle (ELV) classification/management. In addition, it explores the prevailing ELV management practices in the Metropolitan city of Chennai, the capital of TN state. Also, material recovery potential and energy savings have been estimated, based on the projected annual ELV generation rate in TN and vehicle recyclability rate. Based on inputs from key stakeholders and review of international ELV management policies and practices, an ELV management plan has been suggested. http://mc.manuscriptcentral.com/wmr Waste Management Research
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For Peer Review END-OF-LIFE VEHICLE MANAGEMENT IN AN INDIAN CITY Journal:Waste Management & Research Manuscript ID:WMR-13-0042.R1 Manuscript Type:Original article: 35,000 characters Date Submitted by the Author:n/a Complete List of Authors:Santhanam, Satakopan; Centre for Environmental Studies,College of Engineering Guindy, Anna University, Department of Civil Engineering Joseph, Kurian; Centre for Environmental Studies, College of Engineering Guindy, Anna University, Department of Civil Engineering Keywords: End-of-life vehicles management, ELV management, Vehicle recycling, ELV, ELV recycling Abstract: Tamil Nadu (TN) state in India, with 11.2 million registered two wheelers (2Ws) and 1.18 million registered cars in 2011, has the second highest vehicle population in India and stands first in the 2Ws population. With 15 years as average vehicle on-road life in Indian conditions, approximately 440,000 end-of-life 2Ws and 35,000 end-of-life cars are generated annually in the state, which must be properly managed. This paper analyzes the vehicle-related Indian legal framework to identify existing setup for end-of-life vehicle (ELV) classification/management. In addition, it explores the prevailing ELV management practices in the Metropolitan city of Chennai, the capital of TN state. Also, material recovery potential and energy savings have been estimated, based on the projected annual ELV generation rate in TN and vehicle recyclability rate. Based on inputs from key stakeholders and review of international ELV management policies and practices, an ELV management plan has been suggested.

http://mc.manuscriptcentral.com/wmrWaste Management ResearchFor Peer ReviewRespected Reviewers, First, we would like to express our sincere thanks to every one of you for carefully reviewing our paper and sending us valuable comments, which will help to improve the paper to a great degree. As this study is the first of its kind carried out in Chennai City, we have tried our best to make the changes suggested by you. We have highlighted the replies for the reviewer comments below in red color for your reference. Reviewer Questions: This article should really undergo a major revision. There are many unclear statements and wrong conclusions. I will name only some of them: Page 5, 3.2 Customer perception: When was this survey done ? How was the respondents picked out ? Were they still "owners" or were their two-wheeler/car an ELV ? This survey was carried out as a part of the study itself. The survey was based on set of questions asked to the vehicle owner.The respondents are vehicle owners owning either a new vehicle or an older one.In the past they had sold their previous vehicles to mechanics.But they had no idea on the subsequent state of those vehicles. I assume that "Rs" i Indian money - this should be transformed to dollars or euro too. The US equivalent was incorporated as mentioned by the reviewers assuming an average exchange rate of 1 USD = Rs. 60.

The references in the text should be written - as an example: (Wang et al.,2011)References are cited as mentioned by the reviewers at the appropriate places. Page 8, 3.3.1 Management of..........: I believe this i s a description of the status i Tamil Nadu State, but why then refer to a Chinese study (13) ? Page 9, line 25: Why refer to a Chinese investigation (11) when describing Tamil Nadu State? The ELV management in India had many common issues as in China. For example, absence of necessary infrastructure, absence of tools, ELV waste management aspects etc. In China, the ELV recycling policy had recently been implemented. Hence, Chinawas considered in this study. The ELV management is carried outinformally throughout India, as highlighted by Mr. Mohan Ram (please see references in article). And Chennai is one of the biggest cities in India where ELVs are processed in a large scale as highlighted by Mr. Mohan Ram. Also the ELV recycling policy is only in the evolving stages.Hence we referred to Chinese investigation though our work was carried out in Tamil Nadu state. Page 1 of 24http://mc.manuscriptcentral.com/wmrWaste Management Research123456789101112131415161718192021222324252627282930313233343536373839404142434445464748495051525354555657585960For Peer Review In line 46 the author refer to Figure 3b and says that you can see spillage "like lead and mercury" - this is not correct: You can see spillage, but not what it is ! Lead i found i batteries, and mercury is not common in ELVs! Discussion with the Automobile Demo Recycling Plant at Oragadam revealed that Mercury switches were used in vehicles (in ABS etc.). Also dismantlers mentioned that mercury was used in lighting applications in vehicles. But, no separate management of mercury is presently carried out. We have changed the figure caption accordingly as oil spillage. In table 1 the no. of ELVs is said to be around 350000/year. OK lets say 300000 pc. - then something is wrong in table 4, where the total quantity of tonnes is said to be app. 40000 tonnes ???The table 4 is the material recovery/energy savings potential estimated for the year 2012. The calculation has been explained as follows:For 2 Wheelers, the ferrous composition varies from 64-77% and similarly aluminium composition varies from 7-15%. For cars average ferrous and aluminium compositions were 68% and 6% respectively. The average weights of moped, scooter, motorcycle and car were taken as 66, 96, 115 and 900 kg respectively. Also from the discussions with dismantlers and from recyclability study we found the following: For 2 wheelers 50% of the total ferrous parts are reusable and the remaining fractions sold for recycling. In addition, about 40-55% of aluminium components are reusable while the remaining fractions are sold for recycling. For cars only 40% of total ferrous parts are reusable and the remaining 60% (mainly car hulk) are recycled. As far as aluminium is concerned, 45% of total aluminium parts are reusable while the remaining fractions are sold for recycling. These details along with the ELV generation rate are used to calculate the material/energy savings. An example:In 2012, the numbers of ELVs are 84851 (motorcycles), 52701 (scooters), 214722 (mopeds) and 23313 (cars), respectively. Hence the total % of ferrous fractions that can be recyclable =(0.5*0.64*115*84851) + (0.5*0.7*96*52701) + (0.5*0.77*66*214722) + (0.6*0.68*900*23313) = 18909 t The table title has been changed accordingly to indicate its only for 2012. The conclusion section has been added with the average values for material recovery and energy savings potential. This is a few comments, but there are many other vagueness . Reviewer(s)' Comments to Author: Reviewer: 1Comments to the AuthorComment:1. Add more facts in ELV recycling in the context of all over the country of India.Page 2 of 24http://mc.manuscriptcentral.com/wmrWaste Management Research123456789101112131415161718192021222324252627282930313233343536373839404142434445464748495051525354555657585960For Peer ReviewAs indicated by Mr. Mohan Ram (kindly see reference section in article), the ELV recycling in other parts are carried out in informal way along the roadsides. Chennai is one of the important cities where ELV recycling is carried out informally in a large scale. The established the Auto Demo Recycling facility at Oragadam near Chennai is the only authorized facility carrying out ELV recycling for evolving a recycling plan for Indian conditions. 2. In Tab 4., it should be incorporated the following generic datum as: (1) the benchmark energy consumption and CO2 emissions from primary and secondary production of metals in INDIA (not UK), (2) the determined annual ELV generation rate for Tamil Nadu State in India, (3) the recyclability of ELV, as well as the results of energy savings and CO2 reduction potential you have derived.At this point of time, we are unable to find specific reports for Indian scenario on energy savings and CO2 reduction during primary and secondary material production. However, the processes involvedin primary metal production from ore were the same in India too. Hence, this data was used as baseline for calculation. 3. Does the content of ELV management plan (in fig 4) and stakeholders responsibility (in Tab 5) consult with government administration or with SIAM? If not, my suggestion is to contact and discuss with them, because to charge ELV recycling fee is not an easy issue. Then, necessary update is required.After discussions with the concerned people at the Auto Recycling Facility at Oragadam and also with members from SIAM, we developed the ELV management plan. However as ELV recycling policy is still in development stages clear cut data on recycling fee to be charged is presently not available. Reviewer: 2Comments to the Author(There are no comments.) Reviewer: 3Comments to the Author The paper deals with an extremely relevant topic for waste management, the recycling of end of life vehicles in quickly developing countries like India. The figures presented in the first chapters show that the amount of ELV will dramatically increase in the next years and the description of the current situation infrastructures shows a significant lack of suitable collection, dismantling and recycling infrastructures, from a technical point of view but also with regard to the legal framework and economic incentives. The paper seems to be based on an interesting case study with extensive empirical results for the city of Tamil Nadu. Nevertheless it needs to be significantly improved, especially with regard to the scientific standard. Partly the paper is rather descriptive and lacks a specific research question. In these descriptive parts (e.g. page 10, line 1-24) the origin of these data has to be clarified in much more detail. Surveys are mentioned and it is absolutely not clear who has conducted them and why. Page 3 of 24http://mc.manuscriptcentral.com/wmrWaste Management Research123456789101112131415161718192021222324252627282930313233343536373839404142434445464748495051525354555657585960For Peer ReviewIn contrary the second part is quite normative and proposes an ELV management plan. It should be elaborated in much more detail how this plan has been developed, if it is just a scientific proposal or how these stakeholders have been involved.During the field study conducted, we observed that the electronic parts were broken down into pieces. Also the same were reported by Junjun Wang and Ming Chen in China (kindly see reference 16). Surveys were conducted based on questionnaires by the authors themselves. ELV management developed based on inputs from SPCB, Demo Automobile recycling facility inputs, discussion with manufacturers and review of international ELV regulations from literature. We have accordingly modified the article with the explanations. In order to be published in a scientific journal the transparency and replicability of the results have to be improved significantly. Also the English should be checked by a native speaker.We have tried our best and rewritten the article incorporating the necessary changes suggested by the reviewers. Specific comments p. 2, line 36: the optimization problem should be specifiedAs this was an initial study on this issue and also first of its kind carried out, we do not have sufficient data to carry out the optimization study. As a continuation, optimization problem can be taken for further research as suggested by the reviewer. p. 3, chapter 2: as mentioned the methodology should be elaborated in much more details: what was the role of the author?- what kind of "discussions" have been analyzed?We performed the field study, customer survey and recyclability study.As a part of the study, discussions were carried out with ELV dismantlers, vehicle owners, regulating authorities and manufacturers. The outcomes of the discussions were discussed in each sections and they were analyzed to bring out an ELV management plan. - what kind of "management plan" was developed? is it in any way binding? Etc.Our ELV management plan is only a suggestion based on our observations as a part of this study. We have incorporated all the necessary points at the initial stages to carry out proper ELV management. However, further research is required on these points, which can be carried out in the future. However, to make it binding an ELV recycling policy is necessary. p. 5, line 20: the aspect of mandatory technical inspections does not really seem to be picked up in the later chapters on the ELV management planWe have changed accordingly based on Reviewer comments. In addition, this was one of our major conclusions. This is made a part of the ELV management plan also. Page 4 of 24http://mc.manuscriptcentral.com/wmrWaste Management Research123456789101112131415161718192021222324252627282930313233343536373839404142434445464748495051525354555657585960For Peer Review p. 5, line 32: Especially the character of the survey as foundation for the following conclusions should be specified: Who did conduct it? Who has been asked? Are the results in any way representative? Why do only consumers have been interviewed?We developed a set of questionnaires and conducted the survey. The vehicle owners were mentioned as consumers. Yes, the results were used to develop the ELV management plan suggested by us. In addition, we also had discussions with the regulatory authority, manufacturers also. They shared the views of the customers in many aspects. However recycling cost must be paid by first owner since its their decision to purchase a vehicle. p. 6: How have the results of the international comparison have been used for the development of the ELV management plan? Why are these results necessary for this paper?This gave an insight to link on-road vehicle legislations with ELV management policy. Also, details like auditing dismantling facilities, setting up of recycling targets, management of hazardous wastes were all gained from the review of these literatures. This was very helpful in developing the ELV management plan. p. 7, line 15-17: what does that mean? what about the other 65%?Others were of the view that vehicle life is less than 6 years. p. 10, line 8-24: What are the sources for all these figures?The literatures pertaining to ELV management in China indicated a similar scenario. Also, all the numerical data were collected by us by conducting the field study to know the prevailing ELV management practices. p. 10, line 44: What is the status of these recommendations? How do they differ from the ELV management plan in chapter 4?The recommendations have been provided by the Regulatory authority namely the SPCB based on their observations of ELV management. These recommendations have been incorporated into the ELV management plan. p. 11, chapter 3.4: The calculation of benefits does not really seem to match with the ecologic challenges described before. It is very focused on a resource perspective, but it does not refer to problems caused by pollutants (especially the fluids from ELVs)The recommended methods for waste management obtained from the discussions with SPCB and then incorporated in the ELV management plan. At present based on the available data, we were able to focus on material recovery potential alone, as a part of this initial study. As mentioned by the author, we will focus on the environmental problems due to pollutants as a part of future research. p. 13, line 24: The assumptions for these calculations need to be specified! Do you assume 100% collection and 100% recycling rates? Facing the relevance of energy scarcities in India it should also Page 5 of 24http://mc.manuscriptcentral.com/wmrWaste Management Research123456789101112131415161718192021222324252627282930313233343536373839404142434445464748495051525354555657585960For Peer Reviewbe discussed where these savings occur: Really in Tamil Nadu (line 26)? Or somewhere else in the production phase?Yes we have assumed 100% collection and 100% recycling rates because in India, ELV management is labor-intensive and no specialized tools and equipments were used.This figure is only a possibility if everything is happening as per the ELV management plan. Presently its not happening in reality. p. 13, chapter 3.5: As mentioned above, please specify if this plan is something you wish to be implemented? Or that stakeholders committed themselves to develop?We developed this plan, keeping in mind the Indian conditions and the suggestions from the stakeholders. This plan is only an initial suggestion by us in the absence of any proper system in place to manageELVs properly. p. 15: Although the paper highlights the specific challenge of two wheelers, the plan does not seem to differentiate between them and cars?We have also incorporated the changes on management of wastes from cars. Since TN state stands first in the 2 wheeler population, emphasis was laid on to address them. p. 17, chapter 4: Only the first sentence is really a conclusion, the rest is more like reasonable wishes What is the questions that has been answered by this paper? Especially the management plan and its potentials, barriers etc should be mentioned. Wehave changed the conclusion section as per the recommendations. Reviewer: 4Comments to the AuthorThe paper is somewhat lightweight for an academic paper. It has a very brief introduction (approx. 160 words), no review of any literature, a very vague and brief methodology section, results that are incomplete and poorly presented and a very brief conclusion. Below are comments on each section in turn and recommendations for improvement. Firstly, the title is inaccurate as the focus of the paper is ELV management in an Indian state, Tamil Nadu, rather than a city as suggested. The introduction is brief and superficial, particularly since there is no review of literature or general scene setting. In the introduction the authors state that they assume the average on-road life of vehicles in Tamil Nadu State is 15 years, but there is no evidence to back up this assumption. The reader only reads (on page 4) about the Indian AMP (2002) recommendation that vehicles over the age of 15yrs should be retired (which would make the average age of vehicles on the roads much less than 15yrs), however, there was no evidence that this has been enacted and enforced. Figure 1 then, is based on a questionable assumption and further, the wording could be made clearer that Fig 1 shows possible projected numbers of ELVs.There is no specific vehicle on-road life as per the Indian legal framework. As long as it passes the fitness test, it can run on the roads. Discussions with Brake Inspector at RTO revealed that average vehicle age is 15 years and Green tax concept brought to retire old vehicles > 15 years, based on Page 6 of 24http://mc.manuscriptcentral.com/wmrWaste Management Research123456789101112131415161718192021222324252627282930313233343536373839404142434445464748495051525354555657585960For Peer Reviewwhich we generated ELV rate. We have changed the figure caption as mentioned. The method section is far too brief and vague. There is no description (or basis given) as to how comparisons were made with policy instruments and practices in Japan, Denmark, Sweden, Germany and the Netherlands. In addition, two surveys were undertaken, one of the auto manufacturers and the other of customers, however, neither survey instrument is provided or detailed in the paper.There is no outline of how the surveys were conducted, the number of each group surveyed, how many valid responses were collected, response rate etc. Without this information the results are very incomplete and not particularly informative. This will be relatively easy to rectify as the authors will have all this information. We developed a set of questionnaires and conducted the survey. The vehicle owners were mentioned as consumers. We were able to collect responses from 200 2-wheeler owners and 73 car owners. The results were used to develop the ELV management plan suggested by us. In addition, we also had discussions with the regulatory authority, manufacturers also. The total number of collected responses were directly used in the article. Interactions with manufacturers are through mail discussions through which we got the necessary information. We also visited the Demo Auto Recycling Facility to discuss and understand more on the issues. Following on from this, the results are almost meaningless when the reader does not know how many manufacturers and vehicle owners were surveyed. Section 3.2 begins The response from 200 two wheeler owners and 73 car owners Are these figures your total number of consumer respondents or are these the ones saying that higher maintenance cost was the main reason for vehicle disposal?Yes. They are the total respondants. Out of the total respondents, this much percentage indicated higher maintenance cost was the main reason for disposal.Also the reader doesnt know what alternative reasons for vehicle disposal were put forward to the respondents. The same is the case for About 35% of surveyed customers indicated the total on-road life of vehicles between 8-10 years is this 35% of respondents (not those surveyed) and what other alternatives were they given, and what were the responses to these? Another example: the reader does not know the alternatives put forward as disposal channels for ELVs, we are only told that 52% preferred take-back by dealers/service centres. Nearly all results are similarly vague, so that the reader feels like they are being provided with only part of the story. The major reasons for ELV classification were taken from literatures (kindly see the reference Staudinger et al.). Some of the other options are poor vehicle performance, poor parts reliability, etc. Also, the disposal channels options from literatures of ELV manegement systems in different countries being reviewed like disposal to dealers, common collection centers, government authorized recycler were used in the Questionnaire for which the responses were recorded. I suggest that tables of the complete results from your surveys need to be provided, which you can then discuss. Section 3.1 is similarly vague when making comparisons with other countries, no clear Page 7 of 24http://mc.manuscriptcentral.com/wmrWaste Management Research123456789101112131415161718192021222324252627282930313233343536373839404142434445464748495051525354555657585960For Peer Reviewoutline is given as to how this was undertaken, or were you using the comparisons made by other authors? There is no explanation as to what the authors mean by ELV norms or proper management of ELVs. In 3.3.1 and 3.3.2 you are stating observations about practices in Tamil Nadu whilst providing references to China and then Japan. This is confusing, you would be better to make statements like As in China *13+, in Tamil Nadu State I would also suggest that the costs given (eg. in 3.3.2) are not necessary, however, if they remain, there needs to be a year given for these costs and the costs given some relevance for the international reader (say costs in relation to the cost of a new vehicle).The ELV mgmt in China has many common scenarios with Indian ELV management. So they were considered. Proper management of ELV was used in the context of ELV management according to the stringent ELV recycling policy. We have changed the article as per the recommendations of the reviewer. For Table 3, is the regulatory authority the State Pollution Control Board? If so this needs to be stated. Only half a sentence is devoted to Figure 4. The reader needs to know how it was derived (if it is original work or adapted from elsewhere) and also how to read it, as it seems to be a loop, starting and ending at the RTO in the top left corner. We have explained the ELV management plan completely. The figure starts from the last vehicle owner who is the starting point of the ELV management chain. The conclusion is also very brief and does not really say anything of significance.Conclusion has been modified incorporating significant findings from the study. A review of English grammar and tenses is required, also sometimes words like a or the are missing. Regarding the references, is there a reason why the references are not numbered numerically throughout the paper? Also I was unable to find reference to references [1] and [4] in the manuscript. Ref [19] Cassells, S. should be 2004 not 2005. We have rewritten the article as mentioned by the reviewer. Also the references are cited as per the style conventions to be followed for this journal. The year for the above reference has beenchanged as mentioned. Page 8 of 24http://mc.manuscriptcentral.com/wmrWaste Management Research123456789101112131415161718192021222324252627282930313233343536373839404142434445464748495051525354555657585960For Peer ReviewEND-OF-LIFE VEHICLE MANAGEMENT IN AN INDIAN CITY SATAKOPAN SANTHANAM*, and DR. KURIAN JOSEPH* *Centre for Environmental Studies, Anna University, Chennai, India [email protected] Abstract: Tamil Nadu (TN) state in India, with 11.2 million registered two wheelers (2Ws) and 1.18 million registeredcarsin2011,hasthesecondhighestvehiclepopulationinIndiaandstandsfirstinthe2Ws population.With15yearsasaveragevehicleon-roadlifeinIndianconditions,approximately440,000 end-of-life2Wsand35,000end-of-lifecarsaregeneratedannuallyinthestate,whichmustbeproperly managed.Thispaperanalyzesthevehicle-relatedIndianlegalframeworktoidentifyexistingsetupfor end-of-lifevehicle(ELV)classification/management.Inaddition,itexplorestheprevailingELV management practices in the Metropolitan city of Chennai, the capital of TN state. Also, material recovery potential and energy savings have been estimated, based on the projected annual ELV generation rate in TN and vehicle recyclability rate. Based on inputs from key stakeholders and review of international ELV management policies and practices, an ELV management plan has been suggested. Keywords: End-of-life vehicles management; ELV recycling; ELV management; end-of-life; vehicles.1. INTRODUCTION Tamil Nadu (TN) state in India, with 11.2 million registered two wheelers (2Ws) and 1.18 million registered cars in 2011, has the second highest vehicle population in India, next to Maharashtra, and stands first in the2Wspopulation[DEAR2009].Chennaicity,thestatesCapital,havingahugeregisteredvehicle population of about 2.58 million 2Ws and 0.57 million cars in 2011 [STA 2011], has been chosen for the study.AccordingtoStaudingeretal.(2001),avehiclebecomesanend-of-lifevehicle(ELV)whenthe vehicle owner discards it due to loss of structural/mechanical integrity, poor reliability of parts/components ordegradedvehicleperformance.TheaccurateELVgenerationrateintheStateisnotknownasthe ELV,thoughscrapped,arestillaccountedinthestatevehicleregister.However,withtheexisting scenarioofhaving15yearsastheaverageon-roadvehiclelifeinIndianconditions,theannualELV generationrateinTNhasbeencalculatedanddepictedinFig.1.Oncethevehicleownerdecidesto scrapthevehicle,itposesachallengingresourceoptimizationproblemfromaneconomicaswellas environmentalperspective[Staudingeretal.2000,DEH2002].AsstatedbyMohanRam(2007),the Page 9 of 24http://mc.manuscriptcentral.com/wmrWaste Management Research123456789101112131415161718192021222324252627282930313233343536373839404142434445464748495051525354555657585960For Peer Reviewexisting ELV management systems, dependent on unorganized roadside operators, would not be able to cope up with the increasing ELV scrap volumes. They require upgraded technology, processes and setup ofmodernfacilitieswithgreatercapacitytodealwithexpectedincreaseinvolumeofELVs,which increases material recovery potential and conservation of depleting natural resources [Mohan Ram 2007]. Figure 1. Projected annual ELV generation rate in TN. Thisworkinitiallyreviewsthevehicle-relatedIndianlegalframeworkforELVclassification criterion. Next, the customer perception on ELV management, obtained by means of conducting surveys with vehicle owners, has been discussed. We conducted the field study to understand the prevailing ELV management practices in the Chennai city. We estimate and present the material recovery potential and energysavingsfromELVmanagement.Finally,anELVmanagementplanhasbeensuggestedforthe city.Necessarypolicyinstruments/practicesfrominternationalELVmanagementscenarios,obtained from the review of literature, have been incorporated into the above ELV management plan. 2. ELV RELATED LEGAL FRAMEWORK AND POLICIES We reviewed the vehicle-related Indian legal framework, namely, the Motor Vehicles Act (MVA) 1988, the CentralMotorVehicleRules(CMVR)1989,theTNMotorVehicleRules(TNMVR)1989andtheIndian AutomotiveMissionPlan(AMP)2002,toobtaintheexistingELVclassification/managementcriteriaand summarizeinTable1.Presentlythevehicleownersdonotderegistertheirvehiclesbeforescrapping. ThislackofformalELVderegistrationrequirementscontributestoinefficienciesincollectionand treatmentoftheELVs[DEH2002].Also,thelegislationdoesn'tmandateaproperdisposalchannelfor Page 10 of 24http://mc.manuscriptcentral.com/wmrWaste Management Research123456789101112131415161718192021222324252627282930313233343536373839404142434445464748495051525354555657585960For Peer ReviewELV which are mostly sold to an informal dismantler, for scrapping, in return for an incentive. There is a definite need for enforcement of continuous vehicle licensing system that makes owners liable to pay the tax until a certificate of disposal (CoD) is presented to remove the vehicle from the motor vehicle register [Cassells 2004]. To bridge the gaps (Table 1), the Indian AMP had recommended measures to modernize thevehiclefleetbyretirementofvehiclesmorethan15yearsofage,maketheperiodicfitness certification compulsory for all vehicles and develop a centralized registration system that will help in the enforcement of ELV recycling policy in the future. Table 1. Indian legal framework pertaining to ELV. LegislationCriteriaExisting PracticesComments MVA ELV classification criteria and vehicle age Cancel registration of vehicles beyond reasonable repair or incapable to use or not satisfying legal requirements Central Government to fix age of vehicle as per legal requirements No strict enforcement/ lesser fines for defaultersNo enforced age limit for vehicles in practice MVA, CMVR and TNMVR Validity of vehicle registration and its renewal Initial vehicle registration valid for 15 years and registration renewal extended for a period of another five years Green Tax collected during renewal of registration to phase out old vehicles > 15 years of age MVA, CMVR and TNMVR Technical Inspection of vehicles Road-worthiness test annually conducted for commercial vehicles and conducted only during renewal of registration (after 15 years) for 2Ws and cars.Can be used as ELV classification criteria Necessarypolicyinstruments,fromliteratures,havebeenreviewedfromtheELVmanagement policiesincountriesliketheNetherlands,Sweden,Denmark,Germany(Cassells2004,Forslind2003, Smink2007)andJapan(Kanarietal.2007,DBJ2003,JED2006),comparedwiththeIndianscenario and summarized in Table 2. As can be seen from Table 2, the legislations governing the on-road vehicle usage in these countries are integrated with the ELV recycling policy. Hence, the vehicle owners are left onlywithtwochoiceseithertoundergoperiodictechnicalinspectionoftheirvehicles,paytheperiodic vehicletax,andrenewtheirvehicleregistrationortodisposetheELVtoauthorizeddismantlers, inreturnforanincentive,andrelievefromthetaxliability. Page 11 of 24http://mc.manuscriptcentral.com/wmrWaste Management Research123456789101112131415161718192021222324252627282930313233343536373839404142434445464748495051525354555657585960For Peer Review Table 2. Policy instruments for ELV management across different countries.Policy InstrumentNetherlandsGermanySwedenDenmarkJapanIndia ELV Recycling Policy YesYesYesYesYesNo Authorization of ELV Dismantling Facilities MandatoryMandatoryMandatoryMandatoryMandatoryNot Required Monitoring of ELV Dismantling Facilities Auto Recycling Nederland Independent auditors Admin body of local County Municipal Authorities Japan Automobile Recycling Promotion Center Unorganized facilities ELV Take-back responsibility ProducerProducerProducer Producer and last vehicle owner ProducerNo responsibility Recycling/Recovery Targets for ELV Recycling 86% by 2000 and 95% by 2015 Recovery 85% by 2002 and 95% by 2015 Recovery 85% by 2002 and 95% by 2015 Recycling 80% by 2003 and Recycling 85% by 2015 Recovery 85% by 2002 and 95% by 2015 No formal targets. Informal recycling rate up to 85%Deregistration of ELV before scrapping CoD issued after deregistration CoD issued after deregistration CoD issued after deregistration CoD issued after deregistration Permanent Deregistration done before scrapping Not performed before scrapping of ELV Fluids and hazardous components removal from ELV Mandatory pretreatment before dismantling Mandatory pretreatment before dismantling Mandatory pretreatment before dismantling Mandatory pretreatment before dismantling Mandatory pretreatment before dismantling Fluids and hazardous components not managed separately Payment of recycling fees/Product disposal charge First vehicle owner Vehicle makers or importers Vehicle manufacturer or importer Manufacturer or importer First vehicle ownerVehicle Dismantler Incentives to the last owner of vehicle No incentives to the last owner Paid for ELV with positive value Paid from the Car scrapping fund Paid from the Recycling-fund Paid from the vehicle tax Paid for ELV with positive value Page 12 of 24http://mc.manuscriptcentral.com/wmrWaste Management Research123456789101112131415161718192021222324252627282930313233343536373839404142434445464748495051525354555657585960For Peer Review 3. CUSTOMER PERCEPTION ON ELV CLASSIFICATION AND MANAGEMENT We have conducted surveys (questionnaire-based) with 200 2W owners and 73 car owners to know their perceptiononELVclassificationandmanagement.About35%ofrespondentsindicatedtheaverage vehicleon-roadlifebetween8to10years,whiletherestindicatedvehiclelife