A Bio-CNG developer in Haryana may shortlist industrial land, obtain quotations for digesters and gas-upgrading equipment and even identify a potential buyer before discovering that one basic part of the project has not been settled: its pollution category.
That issue now matters more than many promoters realise.
For a Bio-CNG plant setup in Haryana, HSPCB approval cannot be planned only from the plant’s gas-production capacity. The present regulatory framework also examines the feedstock, wastewater generation, by-product route and other process characteristics. CPCB revised the CBG/Bio-CNG classification in March 2025, and Haryana subsequently adopted the revised Red, Orange, Green, White and Blue framework for consent management.
The practical starting point is therefore not machinery procurement. It is a technically defensible project report that establishes what the plant will process, how it will operate and which approvals apply.
A proposed CBG/Bio-CNG project should normally begin with five checks:
Additional approvals or registrations may apply depending on waste source, gas compression/storage arrangement, land, labour, fire risk, groundwater, boilers and other equipment. These should be mapped from the final project configuration rather than copied from a generic licence list.
Older online articles may still refer to a Haryana CBG categorisation based around Red, Orange and Green categories and a 100 KLD wastewater threshold. That position originates from the state’s 2022 CBG categorisation.
It should not be used as the current starting point.
CPCB issued revised directions on 25 March 2025 and divided CBG/Bio-CNG projects into five configurations under Red, Blue and White categories. Haryana then adopted the revised national classification through its 2025 consolidated categorisation order.
| Project configuration | CPCB category |
| MSW, agro-residue, energy crops, grass/weeds, animal waste, press mud and other listed non-industrial feedstocks, with wastewater of 50 KLD or more | Blue |
| Same broad non-industrial feedstock group with wastewater below 50 KLD | Blue |
| Same feedstock group, no wastewater discharge, and prescribed manure/by-product or briquette/pellet processing using fuel | Blue |
| Same feedstock group, no wastewater discharge, and prescribed manure/by-product or briquette/pellet processing using electricity | White under the CPCB 25 March 2025 classification |
| CBG plant based on industrial/process waste | Red |
The CPCB direction also attaches conditions concerning applicable environmental guidelines and the treatment of FOM/LFOM or enriched manure.
There is, however, an important Haryana-specific qualification. HSPCB issued another White-category order on 27 October 2025 that replaced/expanded the state’s White-category list. A Haryana developer should therefore not assume a White-category exemption simply because the project appears to match CPCB row 67.4. The latest HSPCB list and portal treatment should be checked for the actual process before construction decisions are made.
That category review should be recorded in the DPR.
A sensible approval dependency map is:
Project concept -> feedstock study -> land review -> category check -> process design -> DPR -> HSPCB CTE where applicable -> civil work and installation -> CTE-condition audit -> first CTO where applicable -> gas/offtake readiness -> commercial operation
HSPCB currently provides its clearances through online systems including HROCMMS/Invest Haryana.
The sequence matters. If the plant is covered by consent management, obtaining a machinery quotation does not substitute for CTE. HSPCB’s published CTE declaration requires the applicant to confirm that construction of the plant and installation of machinery have not commenced before obtaining CTE.
Before committing to a long lease or land purchase, the promoter should establish:
HSPCB’s CTE checklist itself seeks land records or allotment documents according to location and can require land-use permission/NOC from the competent planning, municipal or local authority where applicable.
There is no single land area that can responsibly be quoted for every Bio-CNG plant. Land requirement changes with feedstock volume, retention time, storage days, preprocessing, manure handling, wastewater treatment, gas dispatch and safety layout.
For a consent-managed project, CTE is not merely a form saying that the business wants to establish a plant.
HSPCB’s published checklist requires technical and documentary information such as the manufacturing/process flow, land evidence, capital-investment details, pollution-control design and a layout showing relevant pollution-control and waste-management infrastructure.
For a Bio-CNG project, the technical package should therefore explain at least:
A major mistake is allowing the machinery vendor, lender’s DPR and HSPCB application to contain different capacities or water figures.
Use one controlled “master project data sheet” for every authority and stakeholder.
A project report for regulatory and financing purposes should do more than calculate gas revenue.
HSPCB specifically requires process information, pollution-control designs and layout-related evidence in its consent documentation. The wider financial and engineering sections below are practical recommendations for making the DPR useful to lenders, investors and project teams.
Project definition
Legal entity, promoter background, proposed location, project objective, feedstock, processing capacity and intended CBG output.
Feedstock study
Source, seasonal availability, competing uses, distance, contamination, moisture/solids characteristics, procurement arrangement and fallback feedstock strategy.
Mass balance
The document should reconcile:
feedstock received -> rejects/preprocessing losses -> digester feed -> biogas -> upgraded CBG -> CO2/removal streams -> digestate -> FOM/LFOM/other outputs
Every tonne entering the site should have a plausible route.
Water balance
Freshwater, recycled process water, feedstock moisture, equipment washing, floor washing, condensate, domestic use, treatment, reuse and final discharge should be separately calculated.
This is particularly important because wastewater generation is expressly one of the variables in CPCB’s present CBG classification.
Process and technology
Feed preparation, digestion technology, hydraulic/solids retention assumptions, gas cleaning, upgrading, compression, storage, instrumentation and safety systems.
Environmental management
Wastewater treatment, odour control, leachate collection, paved/impervious handling areas where necessary, drainage separation, solid rejects, used oil or other regulated waste, noise, DG/boiler emissions and emergency controls.
Digestate and manure plan
Quantity, liquid/solid separation, storage, drying or processing, quality route, buyer/user strategy and monsoon inventory.
Layout
The DPR layout should be the same layout used for environmental and safety planning. Moving the compressor, storage cascade, ETP, digestate storage or feedstock shed after approval can create a mismatch at the operating-consent stage.
Commercial model
CAPEX, OPEX, feedstock cost, transport, manpower, energy, consumables, maintenance, manure realisation, gas revenue, debt servicing and downside scenarios.
Government support should be shown separately from the base business case until project eligibility and sanction are established.
Water is not only a utility calculation for a CBG plant.
Under CPCB’s March 2025 classification, the distinction between 50 KLD or more, below 50 KLD and no wastewater discharge forms part of the CBG categorisation for non-industrial feedstocks.
The DPR should therefore distinguish:
Do not design the treatment system first and manufacture a water balance later to fit it.
The calculation should drive the equipment.
One of the biggest weaknesses in Bio-CNG feasibility studies is treating digestate as guaranteed revenue.
The CPCB classification itself refers to FOM, LFOM and enriched manure in specified configurations, with applicable fertilizer-related conditions.
The DPR should therefore answer:
A manure revenue figure without a storage and market route is not a bankable assumption.
A Bio-CNG project can complete anaerobic digestion successfully and still face a commercial delay if gas dispatch has not been engineered properly.
The developer should decide whether the intended route is:
MoPNG extended the CBG-CGD Synchronisation Scheme to 31 December 2047 in March 2026 and expanded its scope to include CBG injection into gas pipeline networks in accordance with the applicable Direct Pipeline Injection framework.
Where cylinders, cascades, filling systems or pressure vessels are involved, the project’s gas-safety approval route should also be mapped before the layout is frozen. PESO maintains the statutory Gas Cylinders Rules, 2016 and associated approval systems, but exact requirements depend on the equipment and storage/filling configuration.
Once the plant and environmental infrastructure have been installed, a consent-managed unit moves toward first CTO.
HSPCB’s first-CTO checklist covers matters including the online application, authority letter, applicable consent/testing fee, capital-investment evidence, layout, effluent-disposal information and specifications/capacities of installed ETP/STP, air-pollution-control and applicable waste-management facilities.
HSPCB’s published procedure states that a covered project should apply for first CTO before commissioning and even before trial production.
Before filing CTO, compare the installed plant with the CTE line by line:
CTE capacity = installed capacity
CTE feedstock = actual proposed feedstock
CTE water balance = final water balance
approved layout = installed layout
approved ETP/APCM = installed systems
approved waste route = actual waste route
If a material change has occurred, resolve the appropriate consent/amendment route before treating CTO as a routine final step.
HSPCB issued an Office Order on 13 October 2025 directing applications for clearances under the Water Act, Air Act and applicable environmental rules to be processed and decided within 21 working days when the application is complete. For an incomplete application, an additional 15 days may be taken to obtain clarifications or further information. The order applies to applications received on or after 1 November 2025.
This should not be marketed as “guaranteed approval in 21 days.”
The clock does not eliminate:
The best way to protect the schedule is to improve application readiness before filing.
Haryana’s published fee structure includes a special provision for projects/units covered under the Haryana Bio-Energy Policy 2018, showing nil CTE and CTO consent fees under the Water and Air frameworks. The 2018 Haryana Air Rules amendment also expressly added nil consent fees for qualifying projects under that policy.
The important phrase is “projects/units covered under Haryana Bio-Energy Policy 2018.”
Do not assume that every project marketed as renewable energy automatically receives the concession. Eligibility should be established from the current policy position, project configuration and HSPCB treatment before the financial model treats the consent fee as nil.
Professional consulting, engineering, testing, land, safety or third-party costs are separate from government consent fees.
On 6 August 2026, the Union Cabinet approved GOBARdhan – the National Circular Bioenergy Scheme with a total outlay of ₹23,731 crore for FY 2026-27 to FY 2035-36. The announced framework combines assured demand/offtake, stable pricing, capital assistance, pipeline infrastructure, credit support and technology development.
This is particularly relevant for Haryana because common potential feedstocks identified in the national framework include agricultural residue, cattle dung, press mud and municipal organic waste.
However, a Cabinet-approved scheme should not be converted into a guaranteed subsidy line in a DPR.
Until the applicable operational conditions for the specific project are satisfied, prepare:
Base case: project economics without unapproved support
Policy case: economics assuming only support for which the project is demonstrably eligible
India has also operated a unified GOBARdhan registration system for Biogas/CBG/Bio-CNG plants, with Government guidance stating that registration was a prerequisite for accessing GOBARdhan-related Government of India benefits. Given the newly unified 2026 scheme, the registration and component-specific application process should be reconfirmed at the filing stage.
Before applying for HSPCB approval, the project team should be able to answer yes to these questions:
If several answers are “no”, the project is not ready for irreversible capex even if a machinery supplier is ready to accept an advance.
The applicant copies the 2022 CBG category or selects a category from another state’s older consent system instead of reviewing the CPCB 2025 direction and current HSPCB adoption.
A project filed around cattle dung or agricultural residue later proposes to accept an industrial process waste. Under the present CPCB system, industrial/process-waste-based CBG is separately placed in Red Category.
The wastewater figure on the application does not match equipment washing, feedstock handling, leachate and recycle calculations.
The document contains a market overview and machinery brochure but does not show a regulatory layout, pollution-control design, material balance or disposal route.
HSPCB’s CTE checklist includes a declaration that regulated construction/installation will not start before CTE.
HSPCB’s published procedure requires first CTO before commissioning/trial production for consent-managed units.
Green Permits can structure the project from the compliance side before major investment is locked.
The scope can include:
The competent authorities remain responsible for regulatory decisions and final approvals.
The answer depends on the project’s current pollution category and HSPCB treatment. CPCB’s March 2025 CBG direction includes Red, Blue and a specified White configuration, while Haryana adopted the revised five-category system and subsequently amended its White-category list. The project’s feedstock, wastewater and process should therefore be checked against the latest HSPCB position before deciding its consent route.
Under CPCB’s 25 March 2025 CBG classification, CBG plants based on industrial/process waste are Red Category.
Yes. For the listed non-industrial feedstocks, CPCB distinguishes configurations with wastewater of 50 KLD or above, below 50 KLD and no wastewater discharge.
HSPCB’s checklist includes land/project documents, process flow, capital-investment evidence, pollution-control design and a plant layout showing relevant environmental infrastructure, among other project-specific documents.
HSPCB’s published consent procedure states that covered projects should obtain first CTO before commissioning and even before trial production.
No. HSPCB’s October 2025 order sets a 21-working-day processing and decision target for complete applications covered by the order. Incomplete applications may require an additional 15 days for clarification. It is not an approval guarantee.
Haryana’s published fee framework provides nil consent fees for projects/units covered under the Haryana Bio-Energy Policy 2018. Eligibility should be confirmed for the specific project rather than assumed.
A useful DPR should combine feedstock evidence, capacity, mass balance, water balance, process design, machinery, environmental systems, digestate management, gas upgrading and storage, layout, approvals, CAPEX/OPEX, revenue, sensitivity analysis and implementation planning. HSPCB’s own CTE documentation specifically supports the need for process-flow, pollution-control-design and layout information.
A Bio-CNG plant setup in Haryana should begin with regulatory and engineering clarity rather than a machinery order.
The feedstock determines more than gas yield. Wastewater, by-product handling and whether industrial/process waste is accepted can materially affect the project’s pollution category. The DPR must therefore connect feedstock, process design, mass balance, water balance, digestate management, pollution controls, gas storage and commercial assumptions into one consistent project file.
CPCB’s 2025 reclassification, Haryana’s subsequent HSPCB orders and the newly approved national GOBARdhan scheme make older generic Bio-CNG checklists increasingly unreliable.
Before purchasing major equipment or beginning regulated establishment work, confirm the project’s category, land position, environmental design and approval sequence.
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