RECDs for Shopping Malls: Coordinating DG Retrofits Across Tenants

In most buildings, fitting a Retrofit Emission Control Device (RECD) is a conversation between the owner, the facility team and a vendor. In a shopping mall, it is a conversation with dozens of parties at once. The landlord owns the central generators. An anchor store may own its own set on the service deck. The multiplex runs late shows. The hypermarket has cold rooms that cannot warm up. The food court tenants want their exhaust hoods working. And forty line shops simply want the lights on and no surprise charges on their next invoice.

The engineering is the same as anywhere else. What makes a mall different is coordination: who owns which set, who pays for which device, who must be told what, and how to schedule work around a retail calendar that never really stops.

This guide is organised around people rather than pipes. It starts by mapping who is involved, then settles who is responsible for what, works out the money, and finally sets out how to schedule and communicate the work.

Short answer: Build a supply map that links every DG set to the tenants it feeds, settle ownership and cost responsibility for each set before ordering anything, bundle tenant-owned sets into one procurement where tenants agree, and schedule the work zone by zone in the early morning before opening, avoiding festive and sale periods.

Why Malls Cannot Leave This to Individual Tenants

Enforcement looks at the premises, not the lease

In Delhi NCR, CAQM’s Direction No. 76 sets upgrade routes for existing diesel sets by capacity: dual fuel for small sets, dual fuel or an RECD from 125 kW to 800 kW, and an RECD above 800 kW. Enforcement has been real. In 2024, The Tribune reported that CAQM ordered DG sets in 11 Palwal units to be sealed after an inspection found they had not been upgraded, with environmental compensation to be calculated from the missed deadline.

An inspector walking the service deck of a mall sees generators, not leases. A tenant’s unfitted set on the mall’s roof can lead to notices, sealing and uncomfortable questions for the property owner even if the lease says the tenant is responsible. Our article on what happens when a DG set is sealed shows the practical fallout.

GRAP hits malls at the busiest time of year

Under the revised Graded Response Action Plan, as Down To Earth reported, uncontrolled diesel sets face restrictions from Stage II. For NCR malls, those stages tend to arrive in October and November, the same weeks as Dussehra, Diwali and the start of wedding shopping. See our GRAP rules guide for the stages.

Step 1: Draw the Stakeholder Map

List everyone who owns a generator, depends on one or will be affected by the work.

Stakeholder	Typical DG relationship	What they care about
Mall owner or management	Owns central sets for common areas and tenant backup	Compliance, cost recovery, no trading loss
Anchor stores and hypermarket	Sometimes own a dedicated set; always have cold chain or heavy lighting load	Cold rooms, trading hours, brand standards
Multiplex	Often a dedicated set or a large share of central backup	Late shows, projection and HVAC
Food court and restaurants	Kitchens, exhaust hoods, cold storage on backup	Service hours, food safety
Line shops and kiosks	Backup from central sets, billed as DG charges	Lights, billing systems, predictable charges
Entertainment zones and gaming	High load, weekend peaks	Weekend trading
Common area services	Escalators, lifts, fire pumps, smoke extraction, parking lights, HVAC	Safety and footfall
Facility management company	Operates and maintains sets	Clear scope, access and schedules

Build the supply map

Next, link every generator to what it feeds. This is the single most useful document in the project.

DG set	Rating	Owner	Feeds	Tenants affected if offline	Backup path
DG-1	1250 kVA	Mall	Common areas, Zone A tenants	22 line shops, food court	DG-2 through bus coupler
DG-2	1250 kVA	Mall	Common areas, Zone B tenants	18 line shops, entertainment zone	DG-1 through bus coupler
DG-3	1010 kVA	Mall	Multiplex	Multiplex	None; temporary set needed
DG-4	320 kVA	Anchor tenant	Anchor store only	Anchor store	Tenant’s arrangement

Your facility team can build it from single-line diagrams and panel schedules. If some tenant sets lack documents, see specifying an RECD when original DG documents are missing, and collect nameplate photos for every set.

Step 2: Settle Who Owns Which Problem

Three ownership models

Model	How it works	Compliance responsibility	Coordination effort
Central only	Mall owns all sets; tenants take backup through metered supply	Mall	Lowest
Tenant-owned sets	Anchors or large tenants own dedicated sets on mall premises	Set owner, subject to lease terms and consent conditions	Highest
Hybrid	Central sets for most; a few tenants own dedicated sets	Split	Medium to high

Most Indian malls are hybrid. The practical question is not “who is legally responsible?” alone, but “who will make sure it happens before October?”

A RACI for the project

RACI stands for Responsible (does the work), Accountable (owns the outcome), Consulted and Informed.

Task	Mall management	Facility contractor	Anchor with own set	Line shop tenants	RECD vendor
Build supply map	A	R	C	I	C
Retrofit central sets	A	R	I	I	R
Retrofit tenant-owned sets	C	C	A, R	I	R
Approve work windows	A	R	C	I	C
Tenant circulars	A, R	C	I	I	I
Commissioning and tests	A	R	C for own set	I	R
Documents for inspection	A	R	R for own set	I	C

Share the RACI with anchor tenants early. It prevents the “we thought you were doing it” conversation in September.

Read the lease before you write to tenants

Look for clauses on:

• Use and maintenance of tenant-installed equipment on common areas or roofs
• Compliance with statutory requirements by the tenant
• The landlord’s right to require upgrades to equipment on the premises
• Recovery of capital costs through common area maintenance (CAM) or service charges
• DG power tariff and how it can be revised

Where leases are silent or unclear, a negotiated approach usually works better than a legal notice. Take proper legal advice before relying on a clause.

Tenant sets that are old, idle or undocumented

Every mall survey turns up a few awkward generators: a set left behind by a tenant who moved out years ago, a small unit a restaurant installed without telling anyone, or an anchor’s set with no surviving paperwork. Deal with them early:

• Abandoned sets. If nobody claims a set, it is effectively the mall’s problem. Decide whether to retrofit, decommission or remove it. An unused set with a fuel tank on a roof is also a fire and structural question.
• Unapproved small sets. Ask the tenant to confirm registration and consent. If the set cannot be made compliant, agree a date to remove it and offer supply from the central sets instead.
• Sets without documents. Rebuild the evidence from rating plates, engine serial numbers and OEM records before a vendor can size a device. Allow extra weeks in the plan for these.
• Sets due for replacement. If a tenant plans to replace an old set within a year or two, the replacement should be a compliant model, and the retrofit money may be better spent there. Get that plan in writing with a date.

Recording each decision on the supply map keeps the whole property’s position clear when an inspector asks about every generator on the premises.

Step 3: Work Out the Money

Central sets

The mall pays upfront. The question is recovery. Common approaches:

1. Absorb it as a capital cost of keeping the asset legal. Simplest, and avoids tenant friction.
2. Recover through CAM over a period, if leases allow capital items in CAM.
3. Adjust the DG power tariff per unit to cover device cost and servicing over several years.

Illustrative example. A mall retrofits two 1250 kVA sets and one 1010 kVA set. Suppose the all-in project cost is ₹60 lakh, and the mall decides to recover it through the DG tariff over five years. If tenants consume around 4,00,000 units a year from the DGs, recovery of ₹12 lakh a year works out to about ₹3 per unit. The figures are placeholders to show the method. Explain the arithmetic in the tenant circular; a clear sum is far easier to accept than an unexplained tariff revision.

Tenant-owned sets

The owner of the set normally pays. The mall can still help:

• Bundle procurement. Offer tenants the chance to join the mall’s order. Vendors usually price better for a larger order and one site mobilisation.
• Share the survey. One site survey by the vendor covering every set saves each tenant a separate visit.
• Offer windows. Let tenants use the mall’s scheduled work windows and crane bookings.

Do not forget the recurring cost

RECDs need periodic servicing. Decide now whether device care goes into the facility contract for central sets and whether tenants can buy into the same arrangement. Our comparison of in-house maintenance vs AMC helps frame the choice.

Budget line items for a mall project

Tenants and owners find it easier to accept a budget when it is broken down. A typical project sheet includes:

Line item	Central sets	Tenant-owned sets
Devices, sized per set	Mall	Set owner
Installation, supports and exhaust changes	Mall	Set owner
Crane or lifting equipment	Mall, shared where tenants join the schedule	Share of mall booking
Temporary generator for sets with no backup path	Mall	Set owner, if needed
Load bank for commissioning	Mall	Set owner or shared
Structural check of roof or service deck	Mall	Mall, as building owner
Project management and tenant communication	Mall	Mall
Annual servicing	Facility contract	Set owner or buy-in to mall contract

Setting the table out this way also makes clear which costs the mall is carrying for the common good, such as structural checks and coordination, which helps when tariff or CAM recovery is discussed.

Step 4: Choose the Route and the Devices

RECD or dual fuel?

Many malls have piped gas for food courts, which makes dual fuel worth a look for sets in the middle band. Sets above 800 kW in NCR go the RECD route. Compare both in our RECD vs dual fuel kit article.

One device per engine

Some malls have exhausts from several sets joined into a common flue on the roof. Each engine still needs its own device before the merge. Read whether two generators can share one RECD before anyone proposes a single large unit on the common stack.

Plan for tenant churn

Anchor tenants leave and take their equipment. If a tenant’s set moves with them, will the device move too? Our article on transferring an RECD to another generator explains when that works. Record in the tenant agreement who owns the device on exit.

Vendor and sizing

Choose a vendor who can serve every set in the mall, central and tenant-owned. Our guide on choosing a CPCB-approved RECD vendor lists the checks. Typical device information is on the 1250 kVA, 1010 kVA and 320 kVA RECD pages. If your original sizing logic is unclear, see how to size a generator for a commercial building.

Step 5: Schedule Around the Retail Calendar

The mall’s day works in your favour

Unlike hotels or hospitals, malls have a long closed period. A typical schedule:

Time	Mall status	Suitability for work
06:00 to 10:30	Closed to shoppers; housekeeping and deliveries	Best window for lifting and noisy work
10:30 to 13:00	Opening, low footfall	Quiet finishing tasks only
13:00 to 22:00	Trading peak, especially evenings	No work on sets feeding open zones
22:00 to 01:00	Mall closing; multiplex late shows and some restaurants still open	Work only on sets not feeding them
01:00 to 06:00	Mostly closed; cold chain running	Possible for quiet work; supervision is harder

The early morning window suits most tasks. Lifting and crane work on a roof or service deck should finish before shoppers and delivery trucks start competing for the same space.

The mall’s year works against you in autumn

Avoid these periods:

• Festive season from Dussehra to Diwali
• End-of-season sales, usually in January and July
• Christmas and New Year weeks
• Long weekends and school holiday peaks

For NCR malls, the practical window is February to early September, finishing before the smog season. Tuesdays and Wednesdays are usually the quietest trading days.

Sequence by zone

Take one set at a time, starting with the one whose tenants can most easily be covered by another set through a bus coupler or changeover. Leave sets with no backup path, such as a dedicated multiplex set, until a temporary generator is booked.

Example sequence for the supply map above:

1. DG-1, Tuesday early morning. DG-2 covers common areas through the coupler. Zone A tenants are told backup may be limited that morning.
2. DG-2, the following Tuesday, with DG-1 now covering.
3. DG-3 (multiplex), on a Wednesday morning with a rental set connected the evening before. The multiplex confirms no morning shows.
4. DG-4 (anchor-owned), in the same week, using the mall’s crane booking under the anchor’s supervision.

The detailed site sequence for each set is described in our RECD installation process guide.

Protect life safety supply throughout

Fire pumps, smoke extraction, emergency lighting and fire lifts must stay on an available supply during every work window. The Bureau of Indian Standards’ National Building Code sets expectations for standby power to these services. Get your fire officer to sign the work schedule.

A 12-Week Project Plan

For a mid-size mall with four to six sets, including one or two tenant-owned sets, a realistic plan looks like this:

Week	Activity
1 to 2	Build supply map; collect nameplate photos and documents for every set
3	Meet anchors and multiplex; share RACI and cost approach
4	Joint vendor survey of all sets; invite tenants to join procurement
5	Bids compared; order placed for central sets and participating tenant sets
6	Tenant circular issued; work windows and crane bookings fixed
7 to 9	Device manufacture and delivery; temporary generator booked for sets with no backup path
10 to 11	Installation, one set per morning, zone by zone; load tests after each
12	Documents filed for all sets; servicing arrangements confirmed; close-out note to tenants

Manufacturing lead times vary, so confirm them at order stage and slide the later weeks as needed. The key discipline is that the supply map, RACI and circular come before the order, not after.

Step 6: Communicate in Layers

Layer 1: Anchor tenants and the multiplex (meetings)

Meet each one in person. Share the supply map, RACI, proposed dates and cost approach. Ask them to confirm their own set’s plan in writing if they own one.

Layer 2: Food court and restaurants (focused briefing)

Kitchens care about hoods, cold rooms and gas. Give them the exact dates and times when their zone’s backup is limited, and ask them to schedule deliveries and prep accordingly.

Layer 3: All tenants (circular)

Send a written circular three to four weeks before the first work window.

Tenant Circular: DG Set Emission Control Upgrade Dear Tenant, as required under applicable air quality directions, the mall will fit emission control devices on its central DG sets between [dates]. Work will be done between 6:00 am and 10:30 am on [days], one set at a time. During these windows, DG backup to [zones] may be limited to essential loads if a power cut occurs. Common area lighting, lifts, escalators and fire systems will remain on backup. There will be no change to trading hours. The cost will be [absorbed / recovered as follows: explanation]. Tenants who own DG sets on mall premises are requested to confirm their compliance plan by [date]; the mall’s vendor is available for a joint survey. Contact: [name, number]. Mall Management

Layer 4: Shoppers (usually nothing)

If work stays within the morning window, shoppers should notice nothing. Signage is needed only if a service road, parking level or entrance is affected.

Step 7: Commissioning, Documents and Inspection

Test each set under load

After fitting, each set runs at increasing load while back pressure, leaks and the device display are checked. Many mall sets run lightly on normal days, so a load bank may be needed. Schedule these runs in the morning window too.

Collect documents for every set, including tenants’

Inspectors will ask about all generators on the premises. Keep one file with each set’s device certificate, serial number and commissioning report, including tenant-owned sets. Our guides on what happens during a pollution control board inspection, DG set registration in Delhi NCR and renewing a DG set pollution certificate explain what to keep ready.

Set up ongoing care

Put device checks into the facility contract and ask tenant set owners to share their service records each quarter. The RECD maintenance guide sets out a typical schedule.

Common Coordination Mistakes

• Ordering devices for central sets and ignoring tenant-owned sets until an inspection
• Sending a tariff revision without explaining the arithmetic
• Scheduling work on a Saturday because the vendor’s crew is free
• Forgetting the multiplex’s late shows when planning night work
• Letting a departing anchor remove a set without clarity on the device
• Keeping documents only for the mall’s sets

Frequently Asked Questions

Who is responsible for an anchor tenant’s DG set?

Normally the owner of the set, subject to the lease and consent conditions. In practice the mall should track it, because enforcement starts with what is found on the premises.

Can the mall charge tenants for RECDs on central sets?

That depends on the lease, especially CAM and DG tariff clauses. Many malls recover the cost gradually through the DG tariff, with the calculation shared openly.

Can all mall sets be fitted in one day?

It is possible for small malls with good redundancy, but one set per morning is safer. It keeps backup available and lets lessons from the first set improve the rest.

Do shoppers need to be told?

Usually not, if the work stays in the pre-opening window and does not block entrances or parking.

What if a tenant refuses to upgrade their own set?

Document your requests, share the enforcement risk and involve the mall’s legal team. Many malls find that offering bundled procurement and shared windows resolves most refusals.

One Map, One RACI, One Calendar

Mall retrofits succeed when coordination comes first. Map every set to its tenants, agree who owns what, explain the money clearly and use the early morning window across a quiet stretch of the retail year.

For help surveying central and tenant-owned sets together, or for sizing across the whole property, share your supply map through our RECD product page or contact the Aceget team.