Adani Violation File Notings

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i x 10 U9/240% AL b + Response wat. the report ofthe committe for inspection of Ms Adani Port and Sk Limited, Mundra Gujarat Ministry hud granted Environ Mis Adani Port and SEZ, Limited (Formerly Mon the development of Port fecilities at Munda, Disitiet Kutch, Gu Limited) fr i 2. On representat Bharat Patel, General Secretary, Machehihi ‘Mat Adbikar Sunga istry conducted a site inspection on 06-07" December, 2010, n revealed certain violations related 49 construction of aixport, township, and hospital without prior HC/CRZ, clearance and destruction of mangroves, On 15.12.2010, a show eis: notice was issued fo the project authorities. Further, the Ministry issued direotions on 23° Febranrs, 2011 to project authorities not w undertake any reclamation activity and wot i> initiate any new construction work inthe CRY, area, 2. Meantime, Kheti Vikas Sowa ‘Trust have fled a PHL, 12 of 2011 in the High Coutt of Gujarat alleging, violation of Kavironnac Adan Port and SEZ. Limited. The Ligh Court passed an order dirceting inquiry Yo the allegation of destruction of mangroves by projet suit and imposed on development works, The inquigy was condicted by Member Secretary, Gujarat Coastal Zone (GCZMA) and PCE. Based onthe report of the conmitte, dhe High Court passed an interim order according b \whieh project authority can cary out development in certain portions. The arew in which work can be eared out and the areas in which prohibition will remait ‘were marked on a mp, mentioned in the Ligh Court order, “ 4. Inthe affidavit filed by the Ministry in the Hon'ble cout of Gujaat, it was Stated that “the issues rvlated to mangroves destruction, shore-fine change dc to reclumnation, seismic/tsunami events, socio-economic implications ete. noed to be ‘examined by a multi ~isciplinary committee of experts relevant institutions S. Complaints have been received from Kin severe impact upon environment safely and Limited in Mudra, Kuteh eo Vikas Sewa ‘Trust regarding sity in Mnadra Port and SEZ, mitted by Mas Adlani Port snl SEZ. Ld, 6. In view of the severity of the issuce involved in the mater, Ministry had constituted a committee under the chaiepersouship of Ms. Sunita Narain 10 1¢ the allegations and submit a report. ‘The Committee has submitted Hie Fepont on 18.04.2013. Chapter 7 of the report provides Summary of Observations and Recommendations under this Chupter, Section 7.1. deals with, overal observations ane! Assessment and Section 7.2. provides Recon fective deterrence for nomcompliance and! remedi nmendations oF the report, responses of M/s APS! are given below: The nel sugested action 7A Overall Observations and Assessinent 7.Aali Cases of procedural lapses Observations “..jn Phase IT of TPP, the company’ asked for exemption saying that the project is within a notified power SIZ, This is even thouh the power SEA did not have EC clearance, which woud have allowed this exeanption® Suggested Action Pan: May be seal to LAI (1) for further Observation: “Ihe EAC on April 23-24, 2009, exempted the hearing, but put a strict condition that the project coming in 8 undergo procedure as. per projects constructed withi The C in fate shall VA notification 2006. This wowd imply. that all the SH should have HC 4s per ELA notification 2006, mpany has not adbered to this eanition, It is clavitied that though the HAC hal insisted public hearing and PP conducted the PH. nended the exemption, Ministry ‘he sirstripfacrodrome is HZ having an HC part of SEZ and it was constructed 1k is cavtied that the non-commercial airstrips are not covered under the BIA Notification, Hence, do nt require prior RC. DP has informed that Necessary NOC for the Airstrip has been obtained from Pollution Control Bos 74.2: Cases of violations and non-compliance Qbservation, i Blocking ot er Committces which have visited the site during construction, have noted violations by the company in the matter of blocking. of crecks. In 2006, the GC/MA committee bat recorded that the company had built bunds in intertidal region and blocked many erecks. Is important to note that in the period that the 3C/MA committee visited the site, the company had not received any environmental cearantee, other than the development of Navinal port aod related infrastructure, This could even mean that the company hed slaeted work prior to ving environmental clearance. But it ecrtainly suggests Ut there was work Ding done at the site, which was affecting creeks and mangroves. Similarly, the 2010 Mol¥ inspection Commitee had also found obstruction of ereck system and obstmiction of natural Now of seawater because of reelan this Committee earied ont based on satellite imagery Gandsat 5 TM) and Google arth imagery froma efferent years elearly shows: + Bovadi Mats ereck has witnessed « distinet change at its mouth where the creck meets the sca, In 2005, the ereek mouth had natural outfall into the sea. In 2010, the ereck opening, shifled andl got constricted. This is clearly beeause of construction for the Water Front Dovelepment Project. Under the EC conditions, no changes in ereek or ercck mouth ave allowed. If no medial action is taken urgently, there és danger of closing of the creek south due to aceretio branches is the proposed Noxth port site have completely ed over the years. ‘This is bound to have sa impact on the tion in the area in addition to the ehiuge in hycrologieat regi + goneral accretion is observed in Koti Creek, which could be due 10 construction in the nearby inter-tidal area, ‘This has led to widening of the inouth, ‘There does not however appear to be any major change in the Kodi eveck network. Su has teen mentioned in the report that shifting of ereek ‘opening and its constrietion has been ubserved on comparing the imagery of 2005, h that of 2010, It has besn recommended by the committee to take remedial action, as there is danger of closing af the ereeke mouth die to accretion and also. that the opening of Baad) Mata creck should be kept protected so that it is not damaged or blocked. His therefore recommended that PP should camry out regular inspeetiowimonitoring, of the site through a dicated monitoring. cell 1 keep cheek on the accretion of sund/silt at the mouth of the ereek. Inno ease the aceretion should take place at the: mouth of the ereck. GCZMA shall also on, ‘The analysis of £ © development at any location may have sone impacts on environment which are considered in the. studies and Envitonnent Management Play Is-prepared accordingly to mitigate the impacts. Additionally some compensatory measures ase also suggested by MoBIE, APSHZI. has so far curried nr mangrove afrestation in an ates of more than 1550 ia out ofits commitment of 1800 tt at arious coasalJocations within Ciujara. APSE had signed a MoU with Gujrat Heological Commission for carrying out mangrove pli the area of 250 I inthe year 2013-14, * APSHZL. has also born the tolal cost for plantation of 300 ha mangrove area in we Forest urea oF Munda region. © While granting diversion of 1840 ha of forest lund for the purpose of development of SEZ, MoE has given a condition of protecting Baradimats Lill which is biodiversity hot-spot. Fencing work had been eampleted for Baradimata hill covering total length of 13 Kr. © Px-situ stady ha iphery of 1840 hi of fand for assessment of flors-fauna und its preservation, The same bis been already completed und subynitted to sate forest department + APSE. has signed a MoU with Cente for Environment Hducation ( GPCH for the project "Paryava regerding marine ecology and bring sustainability in schools kan eoas of Gujarat and 1600 Km coast of Queensland, Australi ‘and © Committee ha required in thi not observed any blockage of creck and no restoration work are regard Which is to be carried out by AP # APSHZL. is carrying out its CSR activities theough Ack Foundation has been actively working in association community, + In addition to this Adani Four ively working in four thematic areas i.e. Community Health, Pducation, Rural Infrastructure Development & Sustainable Livelihood development. Therefore, in view of the above, APSHZAI. believes that there ix no need lo create separate fund. However APSLZL. is proposing the framework oP action as per below: ‘© Haumark fds on a yearly basis with timelines for earrying aut activities to improve and proteot the environment through its current environment inxutagement practices as well as corporate socal responsibilty * Submit detailed plan of action for implementation te sirengthen the aves to address environmental / CR7, concerns in the project arces as woll as programmes to enhance the support for community by ereuting, nocd based infiastructure and livelihood facilites, ‘© Allocating Rs, 10 crores por year for the period covering next 10 years to exceute the plan for improvement in the environmental and ecological conditions at Mundra, Suggested Action Plan: ‘The recommendation of the commnitice may be aceepled. A connmittee under the Principal Seey Hnvt, Govt of Gujarat may be set ‘up by Govt of Gujarat including the representative of MaBF(RO, Bhopal). ‘Comittee should work out the action plan and modalities to operate the fand on the above recommendation and periodically report of te action taken / progress to the Seey (P&P), GOL 7.2.2, Cancel environmental lear se of North Port There must be an inerease in the mangrove conservation area to ensure ological balance in this coastal zane. To do this, North port, whieh has received cayiroamental clenranee under the waterfront project, should be cancelled. The proposed North port ison the other side of Bock island. Already. ship movement to and fo Navinal post, which borders the island, has had serious deleterious impact on the protected mangroves. ‘This is visible, both in terms ot the loss of mangroves in the vivinity of the Navinal port as well as the loss 0 ‘voyetation and land area of Bocha island, APSI -L submission: Suggested Action Phin : Separate SC GMB to submit their explanation and ma and 12.4 Specific recommendations by the Committee on key remedial aetion 1 Creeks and inter-tdal sy The North port area, adjoining, Boch has counceting erecks, eritieal fr maintaining inter-tial getion of the region, ‘This area should be protected and xt cerecks and waterbodies restored and brought to pre-200S status including, thet reclaimed by GMBIAPSEZL. ‘he entire area should be declared x a o ‘vane, 16 it is contiguous to Bocha iskmd and its important nangrove system. This conservation zone should be glearly earmarked ani demareated using tat-long,so that monitoring is possible, ‘The opening of Baradi Mata ereck should be kept protected so tha slarnaged oF blockeal This must be done forall other eruek systems, AUS: Formed that «© “The observation of committee with respect fo spread of material was due 0 incomplete work of breakwater which would not allow any spread. ‘The remaining breakwater bund alignment work is already completed as per the 5° ‘which is now fully protceting the seea from any feakage of the material used for reclamation, ‘Therefore, there is no danger of blockage of mouth of Baradimata IT ereck and the aren adjacent to South Port, + ILis evident that APSEZL has not filled up any ereck and has taken required measures by providing breakwater, culverts and bridges to proteet the credk system andl keep the erecks flowing, The ereeks are open and flowing naturaly without any obstacle. In add APSEZE, has made all efforts ty providling to Keep the ereek flowing, Suggested Aetion Plan: Declaration of conservation zone may be agreed. FP ‘may be asked fo ensure that the opening of Baradi Mata Creek is and other creck systems is Kept protected and it isnot damaged or blocked, Bocha island ancl its eonservation zone mvust be pi re is a possibility of further degradation of the remaining, conservation zone, ‘The Committee has identified Oe contiguous conservation area, which includes portions of the North port. ‘This ssiggested increased conservation arca hs bon plotted oa a map (see seetic mangroves). Based on the maps prepared by the Committee, the area of Buck should be geo-referenced with Iat-longs, This should be put in the pubie should be regutar monitoring on the status of the land mass and tation ofthe island, ted at al eos. e@ The mangrove conservation area near the mouth of Baradi Mata must be protected and regenerated, An embankment fo slop soil deposition into the erech ‘with buller between the mangrove area and reelaimed land, should be made. All identified mangrove conservation areas as per the EC of January 2009 rust be protected with adequate measures against erosion. These areas should be Tat-long so that regular monitoring for comptianee, based an high: marked wi resolution maps, can be made publicly available. An aetion plan for proteeting, of all mangrove conservation areas ineluding the proposed mangro tea may be prepared and put in public domain, wi ‘monitoring, conserva months, for thr cervation as per EC of WEDP. ‘the loss of 68 hu of ea near Noxth port which is not part of identified for sparse mangroves inchides the conservation area as per WEDP I © However, we are committed to protect the Bocha conservation arca and we are prepared to take all the required preeautions to protect the same as per the ‘guidance of MoBE ‘+ In rospoct to the area near North Port, APSLZL had clarified during the visit of ‘committee that the Ian proposed for the development of North Pot does not bolong to APSEZE and it has not started any activity inthe North port area. © AC South Port Baradimata mangrove conservation area, the observation of ‘committee with respect to spread of material was due to incomplete work of shwater which would not allow any spread. The remaining breakwater bund minent work is already completed as per the EC which is now fully protecting the area from any leakage of the material used for yeclamation, Therefore, there is no danger of degradation of mangroves wear niouth of aradimata Il ereck and area adjacent to South Port # A 400 meter vide mangrove belt is ereated west of Navinal ereck which wns shown (o the committee during, the site visit. Therefore, this is not a case of ‘non compliance with the EC condition granted in the year 1995. «IC important to mention that mangrove cover in Mundra as per CHESS 2011 ‘mappings is more than 2000 ha as compared to 1800 hit which was reported by [NIO in their study 2008, ‘This shows increase in the overall mangrove cover a Munda, APSEZL, is also engaged in mangrove afforestation activit the coast of Gujarat and so far we have completed mangrove plantation in more than 1550 ha area. ‘Suggested! Action Plan : recommendation may be agreed. at Fly ash Manag ad Disposal GPC should set up a robust monitoring systom, which is in the public domain that tacks and reports on the quantunt of fly ash generated by all the phases of the Adani thermal power plant, which vill vary based on the source and ‘quality ofdomestie coal snd verily andl auc the atl iy ash ‘the Company should submit a revised fly ash utilization plan to Mo, ‘which doesnot provide far its use in reclamation, This is because iis not possible ‘to monitor and verify that domestic coal fly ash is not being disposed or used for reclamation in low-lying areas, jions fron transport and disposal of Ny er near the fly ash dyke ancl pond must be fugitive mda The concern abou ash ancl eontaranation of the gx 7 takeu seriously by the regulating agencies anal buble monitoring systems aust he ‘volved to check for contamination anon the sek Pond in particular, APSEZL submission: * Site inspction of GPCI wax canied out on April 8, 2011, when none of the Suche se were in operation, The frst ont oe Phase-IIT (Unit?) was ryt monized on October 2, 2011, The conditionet Phase-tIt on ash uti a sees should not be compared vn Arey 8, 2011. Reclams vols og tovement of matra, dedicated water aera for spraying water on ’sh transportation and dicated mobil ical road snchine for cleaning the area, * Till March, 2012 there was 100% ize fly ash Cor disposal in a lization of Ay ash and thece wat no ‘dyke. Disposal of unuttized fy ash inte 2012 and same has been submitied to n the complianee reports, Therefore these 0 mismatch of data, * [ate ae le unis at Munda ‘Thermal Psser Out of Which three nits (Uni ‘Unii9) are in Pluase-Hl, AM ning unite Provided with aUliaate LSP aud separate Fly Ash Silos un) dry disposal facility for Phase units are topether on the wen Sido of the Power Plat, I 2 Rewible and easly posible to oles he Fly Ash Silos of Phase-ill and IMNintan separate records for Phase, which wil ba Verifiable and auitahe, * IRE lation of fy ash from Phase and Phase AU by way of reclamation of low lying urcas should not be prohitlied sures 10 Aly and contamin By tee Plan: GPCI and PU may be asked to take necessary aetion 9 ‘comply the recommendation, rthuake/ suman Droject clearance {ie Hosue OF coastal safety is @ mater of great concen. Tsunami ant farihauakes ste threats tothe area owing toe geological settings. But there hae {wen no comprehensive assessnent oe ns ofrisk+hazard analysis, me gcivetnment should carry out an pact Study especially in tight of the apam tsunanoi fo 2011, Also, the Ug tanagement plan of the differom Manageretinents of MPSEZL should he twee the ‘Distiet Disaster Mavagervat Pia. This wil be inthe heat of the vulnerable people in and ‘round the project arca to carly warning pructices, The Committe also recommen earying cus Petiodic mock dkills along with district ‘wdovinisteaion in and around the project ae Suggested Act nnocessaty action, Flaw: we may agree and State Govemment m WY nsw % Sal of storage pond/intake snd outfall "he intake and outfall eham has impervious Ti oud mm must be reconsiructed/eepaircd so dal it '8 at the bottom and sides, "The YAW Water reservoir/guard also be recoustructed/repaired so that it he impervions lining atthe @ bottom and side. ‘The Company should install network of piezometers with coordinates in the project arca for monitoring of groundwater quality ane! water levels in all the seasons. These reports should be put in public domain, inehudin its poriodieal submissions to GPCB and RO, MoliF, Bhopal. An independent study should be undertaken every five years to study saline water intrusion and to Suggest remedial action. ‘he Company should continue with elased eyele cooking, system and recycling of FGD wastewater so 4s to rechice diseharge and remain in the discharge eapaeity of the outfall channel APSEZL submissior + The Clearance for Intake and Outfall Channels were granted as part of the Waterfront Development Project (WFDP) and Raw Water Reservoir was obtained as a part of Phase-I TPP. These is no condition of providing any lining in the HC: ‘Thus, there is no violation of any condition in this repard. However, the outfall channel has been stone-lined and the Reservoir has been provide! with Shéet-Pitng all around and elay King at the bottom. ‘+ API_ has already initiated the process of installing network of piezometers with ‘coordinates in the project area for monitoring of groundwater quality and water levels in oll the seasons, ‘Suggested Action Plan : Intakefoutfall channel/Rescrvoir shall Tining amundra/Sterting, Mol should review and reassess ly take up this matier with GCZMA and ask for nt of the matter. This assessment should be bused on Fess collection of coordinates, through a joint team. GCZMA should he dirceted to (ake necessary actions based on this visi. The map should be available in the public domain so tha it ean be verified and the matter closed satisfactorily, Suggested Action Plan : recommendation may be agreed vii, jermen livelifwod snd access to fish ls Ero here must be a specific plan for Cishers: access ankl their Tivell addeess all these concerns, APS prepare this settlement.vvise pi {6 months with a clear schedule of implementation and monitoring. The exclusive fishing harbor proposed at Bhadreshwar should be built so that there is fueility for livelihoad support. This faitity shoud be built within a time period of two years. | addition, all fishers settlements located in the Waterfront (port) area iudequate facilities For earrying out their ceonomic netivity APSEZL submission: + APSEZI. has provided four (4) accesses to the fish sea for fishing aetivity at Juna Bandar, Luni, Bavdi Bandar and Zarpara. his ‘was finalized through fishermen consultative process, + APSHAL is actively working with all the fishermen community at all locations ‘nd providing all required support for their livelihoods axl other concems which have ben already presented to the committee daring their visi + Committe has visited Juna Bandar and interacted with fishermen community, Community had! explained the committee about the support received through ‘dani Foundation and told very clearly that they don’t have any problems with respect to access to the sea and other developmental aetivities by the company. + No grievance made by fishermen at Juna Bandar, | | | + APSIZ has not stated any activity at Bhadreshwar and therefore, there is npact to fishermen at Bhadreshar duc to APSKZ. *® ‘The instance of blockage of uecess to sea is near outfall ehannel of COPL, (Fata Power) which is far away from APSEZ snd APL axea. ‘* As per the provisions of SRZ. Act and Rules, any person enteting into notiied ‘SEZ, area has to take appropriate authorisation from the office of Development Commissioner, Ministry of Commerce. The DC office is even providing Permanent identity cards to the pedestrians who are frequently entering ito / passing through SHZ, area, This being a compliance issue of SEZ. Act and ules, APSIZ. is not empowered to relax this requirements and everybody t the personals of APSLYZ are required to comply with it © ‘The report regarding developmental activities proposed for upliftment of fishermen community is already submitted tothe committee. issue is not belonging only to APSRZL.. However APSI:ZL, has already prozetively suggested for the ezeation of fishing harbour For livelihood support through PPP model. ‘The said facility can be developed under the support fiom Central Government, State Gover Local community ant Corporste. APSEAL. will provide necessary support of its part for the same * All the information with sespeet to creation of fishing hactour thro ‘model with technical details have been sleeady submitted to the commie Suggested Actin to prepare the selilement-vise plan wi implementation and monitoring. AUl fishers settlements located in the Waterfront (port) area mast got adequate facilities for carrying out their economic setivity ‘State Government may initiate necessary ation 10 built exelusive fishing harbour for the livelilwod support of the fishermen of Bbadreshwar in a period of 80 years. Plan: recommendation may be agreed. APS 6 months with a clear schedule of viii, Village common ta hae) ‘The state government should roview the poliey of wequisition and transfer ‘of village common fands, not just inthe specific ease of APSHEZL, but also in ober Wand aso APSEZI. should consider the veluntary relum of grazing la wvest in improving precuetivity of this land with villagers. APSEZL submission: + After discussion with local people of Zampara village, APSLZ. has decided 1 sive back 400 acres of land to Zarpara village for gauche purpose, in spite of Ue fact that the Supreme Court has dismissed the appeal of villagers challenging the allotment of gauchar land. ‘These 400 acres of land has been already identified in the presence and confirmation with Gram Panchayat ad necessity procedure to give back the said land is in progress, + There isnot a single instance that Stage Govt. has alloted the land to APSH:4L ‘without following the preseribed procedure. Such allotment has also been held valid by the Courts of Law repeatedly. However, being a responsible Corporate, APSI:ZL is also in the process of voluntarily consideting the request of some villages and identifying the land which ean be given back to other villages for the purpose of gauchar, The said process is on in aetve consultation with village people an necessary procedures will be done as cacly as possible, formation on fodder management and suppor is already submitted gested Action Plan: We may aggce and State Government ma necessary action, kG ative impacts of power plants and port projects Mo should commission a comprchensive study on the cumulative impacts of prajects, which have already been granted clearance, This study should be uscd to assess and mitigate impxets inthe region, All future port and power plant projects should be assessed for clearance based on cumulative impacts APSHZL submission + 1 is important to mention hat APSEZL. is the only company who ts developed master plan for its both projeet i.e. WRDP and SEZ for the next 25 years and have assessed impact accordingly. Public Nearing, was also ‘conducted for both the projects separately for its entire area as per master pl ‘+ We believe that development is essential at the seme Protection is also important. ‘The MoEP while granting environmental clearance imposes certain conditions which are always keeping in mind the baseline conditions and likely impacts due to the upeoming, project and therefore environment management plan is prepared and implemented accordingly, iegested! Action Plan: we may agvee and may ask the PP to e mpact assessment studies under the supervision of the il as per the TOR approved by Mol yout 7.3. Specific recommendations on reform of CRZ regulations Theve should be an urgent review of the functioning and. scientific protocols used by the agencies authorised by Mole 49 undertake CRY demarcation. There should be common guidelines for their operations so that there is uniformity and reproducibility of the work that ig done. All gades of ‘operation, including rates to he eharges should be reviewed and mate uniform Fox all agencies New authorised agencies should be added to undertake this work, inchiding state remote sensing agencies. All reports wl maps prepared by the ‘agencies should be put in the public domain. We would recommend that ll digitized maps at 14000 scale prepared by the agency for a project proponent should be sent to te National Centre for Sustainable Coastal Management, ‘The Centre should collate all specifie project maps on a national map, based on the lat Jong andl publish this on a national CRZ. map inthe public domain, The project-level ITLL demateation, paid for by the proponent should be replaced by state level exer Ib is fnded by the ‘govemment. This will require greater clarity about the seales that will be used to do the lncatiproject level map and the CZMP map. ‘The current mapping guidelines, al vo very different seales (1:25,000 nel :4000) will nt allow for verification ofthe FITTALTL maps, 1also does not allow for assessment based! on al" HITLALTL and cheek for deviation or distortions. ‘There is a need to decide on the issue of the “original” HTT A101. and hove policy ca and should reflect the dynamic nature ofthe coastline MoLE shoul relook at_the current mapping work being done i i the country, in terms of the need for this poliey elarity. Under the Matt Survey of India has mapped the country's coasts aan aecnracy of 10 ems for the hivard line demarcation, In addition, there ave current exercises being, i Ie ‘undertaken at the state level for prepatation of coastal zone management plans. But because these ate being done using different methodologies and Uifferent seates, the use of these efforts for uniform national poliey aed p is not possible. I is critical at this stage, when allthis is being done, than there is eatefi! potiey guidance so that the CRZ maps eam he used fn both the statewise napping an! classification and the project level HHT. dexareation, Mol should ensure that dese maps are pat in the pa Currently, there is enormous resistance fiom defence and estublishments to the public use of these maps. But given the fact that C a regulated zone, its critical there is transparency about developments on the coast. Regulation and monitoring is not possible without this, domain APs We may agree and NCSCM 10 examine the above issues ant work oxt the unitorn methodology for demarcation of EVELINTL 7A Recommendations on clearance br me 7 11 is our assessment that the cument regulatory system i not able hnundie the complexity and size of projects of this nature, There is an urgent il (o strengthen the monitoring abilities and to bring in public aversigh, The monitoring and auditing of such a large project is anly possible, if the clearance conditions are specific and detailed, geo-referenced snd there is a lonelsat imagery analysis to benchmark the project acca, pre-consteueti Without these bencinaeks, it fs not possible, to ascertain the extent and sade 1d operation phase, Mere at all monitoring, data is vessible by local communities to use anel comprehend in terms of importantly, a systems should be developed $0 widely impacts there is « need to ereate a monitoring system to ensure that corrective action suggested by this report is taken within a time- bound manner. Abs may be agreed. duly 6, 20.3 Donte 9) ‘Phis Plann: en he etn Og ee eee ena : eet veel bmg, nga 7 DitoR ae Notes of IS(MS) at pro page refer: Regarding the suggested monitoring system it may be mentioned that a monitoring ‘system comprising of joint quarterly visits by GCZMA, ‘and RO, Bhopal may be ppt in place for a least 2 years or as per requirement, ‘The aetion points are encapsulated in the following table: jon/Itecommendation ‘Scetion of the report [ Observ: "Tit Gases af in Phase W oF FPP. the company] May be sent to TATU) procedural lapses | asked for exemption saying that | for further ceo the project fs within a notfed power SEZ, This is even though the power SEZ did not have ee, which woul have ved this exemption” AL prajees constructed the SEZ should have EC EIA not Ministry insisiod aublk Hearing and Phas cconuucte the PH, The sirstripvactodrome is yeut of | The won” Commercial SEZ and it was constructed | airstrips are not cover without SE Funder the BA, Notification as amended 2009 ence >not require prior PP has. informed that Necessary NOC far the Airsirip hay boon obtained from Pollution EE IEEE ic Control Board. litocking of ereels, including | No action bas bee kona | sugpested wart | changes + Bardi Mata creek witnessed a distinet change at ils | order to protect the mouth where the ereck meets the mouth, it has beer sea. fn 2005, the ereck mouth fuel | suggested tot | natural outfall into the soa. In | remedial action against 2010, the creek opening shifted | likely accretion. and "got constsicied, This is | clearly because of construction |'To ensure thi, PP for the Water Front Development | should carry ant regular Project, 1f no remestial action is | monitoring, of the site taken urgently, there is danger of | through a desbeated Closing. of the ereok mouth duc to | monitoring. cell and aceretion. lake remedial action as and when required to prevent accretion of ndfsitt atthe mouth of sek. GCZMA shall the creek site to ki Watch on the aceretion ‘nd direst the PP, if required, for removal of anne age yoy =n - | Me nercted sans Tnerease of salinlly because of ‘may be asked to Tine suard pond/intake and outfall | the channels, 12.1 Moki Sh | substantial — deterrent for effective deterrence mmplinnce and violation fry emcomplianes | rough. the ereation of «an | Secy (am) Geen 3 remedial Gujarat may bes -asures by Govt of Gujarat wiltee recommended | inctutin that the #nvitonment Restoration | representative of Mot und should be 1 per cent of the | (RO, Bhopal) to work Iroject cost (including the cast of {out "the ction plan, the ‘thernal power plant) or Rs | modalities and oversee 200 crore, whichever is higher | the operation of the fund and chermte, under the | and periodically repmet Chairmanship of Sceretary (&F). | the progress. to the Secretary (L&E). A committee under the Pr Caneel ” cnvironmenial | Separaie “shaw case nee of Novth Port notices may be issu to both APSIZ/L. and GMB. to submit their ‘and F23Specitic ~~} 5. “Creeks a linet aysie eonservation zone may The cmlite area should be | be agreed. PP may be Ney remetiat netion declare! as « conservation zone, aked te casire ty tte itis contiguous to Bocha istand | opening of Barc’ Mate Hand its important mangrove | Creek and other croek system, systems is. kept Drotected, not damaged The opening of Baradi Mata {or blocked. k should he kept protected s0 ot damaged or blocked, This must be done for all other ‘reek systems, = rove conservation fon” may Bocha Island and its conservation one must be protected at ‘The mangrove conservation near the mouth of oust be | around the project area, regenerated. ‘An action plan for protecting all mangrove conservation areas including the proposed mangrove conservation area maybe prepared and put in public domain, within three months, for iquake/ tsunami wna project elearanee ‘The disaster management plan of the different projeet proponents of MPSZL, should be linked to the 'Distict Disaster Management Play. The Committee also recommends eurtying out periodic mock drills along with district administration ian because of storage “ponul/ntalee and outta The intake and outfall channel ‘ass impervious lining atthe bottom and sides. Mol should urgently take up this matter with GCZMA and ask Jor review and reassessment of) Fly ash nl Disposal GPCB should setup a robast monitoring system {0 track and teport on the quantum of fy ash fpenerated by all the phases of the Adan’ thermal power plant. “The Company show sabmit a revised fly ash ui MoEF, whieh does for its use in oelamation, The concern about fugitive emissions from transport and disposid of fly ash and contatnination of the proundwater rear the fly ash dyke and pond must be taken seriously vik Fis hermen -fiveiiond| PP may “be asked to provide lining. Recommendation “niay be agroedd and PP may be asked to like necessnry action to comply. the recommendation 73. Specific recommen reform of regula livelihood to a cancers, APS! inyplementation and_monitor The exclusive fishing . harbor proposed at Bhadreshwar should for | be built so that there is facility livelihood support, ‘This. fai should be built within a time ppesiod of two years, In ak all fishers settlements located the Waterfiont (port) area im ") The state goverment should review the policy of ac ‘and transfer of village common specific case bat also in other lands, of APS justin th APSEZI. should consider voluntary retuen of grazing hand fest in. improv projects MoEP should commission ive study on compet cumulative which have already been gran clearance, ‘This study should used to assess and mi impaets in the region. All future port and power plant projects should be assessed for clea based on cumulative impacts. 1 must prepare this settlement-vise plan within 6 | oniths with 1 clear schedule of ty of this land with imutative Topas of povwer plants and port impacts of project ty must pet adequate facilities for enerying ‘out their economie activity, the the ned be K be agreed. APSE: ust prepare the settlemontwise plan within 6 months with & clear schedule of All fishers nents located in the Waterfront (port) ‘area must_get_adequate facilities for earrying out their economic. activity. © Government may le necessary action to built exclusive fishing harbour for the livelihood support of the men or Bhadreshwar in « period of two years, may agres and State Government may ensire newessary action. bP nay be asked to carryout cumulative impact assessment studies under the supervision of the State Government and ws per the Tol approved by MoER, ‘As decided in tho 37" Meeting of NCZMA, NCSCM has been asked i i i | { i : I i i | i ~~ etna for domaeaton of HITLALTL so as to mike the domawcation 7 procedure un i 74 a need to erate al A | | Recommendations on | monitoring system to ensure that | comprising of joint | J project” clearance | corrective action suggested by | quarterly visits by | | eouditions and post | this report is taken within a time- | GCZMA, GPCR and | | elearanee monitoring | bound manner RO, Bhopal may be put ' in place for al kat 2 vat i Submitted please (Lali Kapur) Director (LK) , July9, 2013) Sins) i an The observations and assessment of the Report of the Committee for Inspection of M/s Adani Port and SEZ Lid., Mundra, Gujarat-may be perused from pages 1 to 11/n. at The observations/ regommendations and * nts rave been tbulteotSet pag 12 to 16/n. 3. Put up for directions/ approval of the sugse the suggested action ested action plan. Lge rote Bog Joint Secretary 10.07.2013 Cutt 1 7 Is: Notes from page 1 nay pease be seen We may accept the recommendations ofthe Committee subject t the fllowing ly brought out major violations of conditions of ingot (‘The Commitee cnvionmental clearance suchas blocking of reeks. ine! rd consivicton of mouth oF Baradi Mata ereek aryl Blocking of other 4 Sir te consrae al Talat nevie deesoonce aT a oi Brito rte popes Nonh Poe i a ak ee ee 5 ne Aegradation of mangroves near Baradi Mata mouth, nites as male specific recommendations thot the Nom Port area aud Bocks Island sould 90 Alelared a conservation zone and thatthe are sill be protected axl al “Greeks, water ies and retained lal shoul be restored pre 2005 status. The Commitee has supgosted clearance of Newt Por a “i sin view the recommen! ‘cluded inthe Janaary 12, sme and also. 01 account tampa. volatons Spread ver & large en as rioly rer to above, the nee del January 12, 2009 granted to MU Mun Be kept in aboyanes, Simulloncoy, we may dicot ths p suit ind pln, slong, wih cost esti Imangiowe, ceeks, Wate bles and recall “This Reiow plan should also contain provision’ for conservation and ‘maintenance ofthe restored ecosystems The vetion pla wy by sratnive by the concemed EAC in Mel nd, upon approval, monitored during, iupplerentation by the concerned pial office of Mal Fi i Gi nese oF procedural pss, cos pine oat tht the projet Bes proponent ha clsimederomplicn fem public bering based on er aa reson tt Pye ofthe poe plat would eects mated po as: Siz Wo may ie ayaa wk the pues ee HG gota br pase 19 ie Thana Poe further in 1A Die. for appropriate action the projet proponent may he dtected to tke actions as supgsstedl by Committee Gx) In respect of salinity caused by storage pon ava (Ranga Seetaantt) sa 201 Office of the Minister of State (VC) for Environment & Forests | accept the recommendations of the Sunita Narain Committes. In | additions to the specific recommendations already referred to at "x" Page 48, the following is important to highlight. | hereby record that | have carefully examined the representation made by the project proponent APSEZL, in response to the Sunita Narain Committee report, and thal | {ind no mori in their contentions. 4) The Committee has found that the Project Proponent has "been less than serious about reporting on compliance with the conditions set at the time of clearance. In many cases, non compliance with reporting conditions has been observed, For eg it is an EC condition to monitor tho effluent discharge temperature to ensure that it does not exceed 7°C. Itis stated that the inlet and outlet temperature should bo measured daily and the difference be within stipulated limits. Temperature records onclosed ‘as an annexure with the compliance report are not avaliable. ‘Fishermen in the area allege thal hot water released into the sea io affecting thoir small fish catch”, Thus itis important that reporting by the company which is perfunctory and non committal, should now be governed by regular and transparent monitoring, and EC conditions stictly adhered to: Tho Committee has stated as follows. | quote “Recommendations for offective deterrence for non-compliance and remedial measures. In the Committee's assessment there is incontrovertible evidence of ation of EG condition and non-compliance. It must also be recognized iiiat the Company has by passed environmental procedures in certain cases. ‘The question bofore the Committee is to determine the fulue course of action. One option would be fo recommend the cancellation of clearanees, where procedures have been bypassed. In addition, lega proceeding could be initiated against non-compliance and violations of EC conditions. But itis also cloar that these steps, however, harsh they may sound, aro in the nature of baing procedural and would only lead to delay without any gains to the environment and the people. ‘The Committee is cognizant of the fact that large scale development has already beer Undertaken and It is not possiblo or prudent at this stage to halt or cease its operations, | | therefore, the Committee has docided to recommend a differen: | couse of action, which is both intended to be an effective deterrent and {also suggests the way for future remedial action to improve the nvironment. i Given this the Commitee recommends the following: 1 MoEF. should impose a substantial deterront for non: | compliance and violations through the creation of an Environment | Rostoration Fund. It The Commitee is aware that it is practically difficult to assign | tangibto and intangibte costs to non-compliance and violations. However, | the inability to quantify these costs should not deter us from setting | precedence for the fulure. This will only result in the issue remaining i unresolved and conflicted and will delay action to improve the environmert ‘and the livelinoods of people. >) * Considering the scale of the project, the Committee would fecommeng that the Environment Restoration Fund should be 1 per ent of the project cost (including the cost of the thermal power plant) or Rs. 200 crore, whichever is higher. + Tho Envitonment Restoration Fund should operao under the chairmanship of the Secretary, MoEF and be used specifically for Femodiation of environmental damage in Mundra and also. for strengthening the regulatory and monitoring systems. * The purpose of the Fund should be the following: Protection of marine ecology; Protection and conservation of mangroves, including development of new mangrove conservation area ©. Restoration and conservation of creeks; Independent studies and monitoring of the entire project areas, including cumulative impacts and public data disclosure systems, ©. Social infrastructure and livelihood support for fishors community, including developmont of access of fishers from thelr temporary settioments to villages”, Further in view of the committee recommendations file noting at (i) Pq 18, show cause notice may be given to the Project Proponont why EG siven fo the North Port should not be cancelled, 2) Orders should issue to GPCB regarding fly ash manage disposal as follows: Ely ash management and disposal + GPCB should set up a robust monitoring system, which is in the Public domain that tracks and reports on, one, the quantum of fly ash generated by all the phases of the Adani thermal powar plant and two, that can verily and audit the utilization fly ash, + Tho Company should submit a rovised fly ash ulilization plan to MOEF, which does not provide for ils use in reclamation. ‘This is because it is not possible to monitor and verify that domestic coal fly ash is not being disposed for-used for reclamation in low lying areas, * Tho concem about fugitive emissions from transport and disposal of fly ash and contamination of the groundwater near the fly ash dyke and pond must be taken seriously by the regulating agencies and public monitoring systems must be evolved to check for Contamination around the ash pond in particular ‘nt and 2) Regarding Samundra/Stering the recommendations of the Committee are accepted and GCZMA directed to review and ro-assexs the maltes. New and vorifiable coordinates should be mapped and ‘Supplied to MOEF, and also put in the public domain for verification, 4), Reaarding fishermen and their livelihood, APSEZL should prepare a clear statement wise pian within 6 months, which contains a specific plan for fishermen, their access and protection of their livalinood. ‘The plan should include a clear schedule of implementation and monitoring, Further the exclusive fishing harbour proposed at Badreshwar should be built fo ensure facility for livelihood support, and adequate facilities (or fishers to carry on their economic activity 5) Regarding the policy of Gauchar or village common land, the Stato Govt. is advised to review this policy in general with specific roference to environmental impact and livelihood, ~ 22) 6) Pata 7.1.1 of the Committee roport dotalls procedural lapses particularly in respect of public heering and obtaining statutory clearances The Committee observes that while on April 23-24, 2009, the EAC exempted the SEZ from public hearing ON THE STRICT CONDITION tha: projects coming in the SEZ in fulure shall undergo procedure as per the EIA Notification 2006. This means that all projects constructed within the SEZ should possess EC under the EIA Notification of 2008. ‘The Projec: Proponent should be addressed in this regard, and details vorified. If any lapses are found, action under law should follow, Ihe Committee also observes that an airstriplaerodrome, a part of the SEZ was constiucted without FC. Here too, the Project Proponen: should be addressed, details verified, and action under law initiated, in the vent of violation. The Committee has made specific recommendations regarding‘ ‘work thal needs to be undertaken by MOEF with regard to reform of CRZ regulations and recommondations on post clearanco conditions and post cleuranco monitoring (7.3 and 7.4 of the report) I direct that the Gepartments of MoEF responsible for these areas should implement the recommendations in a time bound fashion. In view of tha above, | direct the following, in addition to the directions already mentioned in the file notings above and at ‘X’ Page 18, ) Show cause notice be issued to the project proponent for cancellation of EC given to the Nosh Post. Until then, the EC given {o the North Port be kept in abeyance with immediate offect b) Show cause notice be issued to the PP, why EC granted for Phase of the Thermal Power Piant, based upon wrong representation by the project proponent and exemption from public hearing should not be cancelled, ©) The Project Proponent be directed to forthwith propare an aotion plan to protect the livelhood of fisheimen whose marine ecology, and catch, and accass to the sea have been seriously affocted by the violations commilted by the Project Proponent, 4) As a deterrent for non-compliance and violation, the PP should sel up on Environment Restoration fund ~ distinct and separate from CSR activities under Company Law ~ amounting to Rs. 200 crores or 1% of project cost, whichever is higher, to be used for remediation of environment damage in Munda. The Fund will be operated under the Chairmanship of Secretary E8F, and will inclu es enumerated by the Commities, “ yun’ h pan (saya Nataraa Mosic) EBF 27" August, 2013 8 Aree een? ie (MS) Fat Llosa ites) lee be oe Tie K.No.10-47/2008-18-T11(00) Subject: Recommendations of the Committee cor ‘examinati = Reg itated for Insp of alleged violations by M/s Adani Port and SEZ, Pvt I. FRI and FR2 are the reply submitted by M/s Adani Port and St Pet had ‘and GMB with respect fo Show Cause Notice issued based on the recommendations ‘of Ms Sunits Nerain Committee. 2. Mis Adani Port and SEZ Pvt Lid has stated that no reasons freve been disclosed for accepting the recommendations of the committee and also the grounds fon Which our cespanse Ins not been accepted. Also expressed willingness to mea land answer the grounds on which the response has not been accepted. However submitted point wise response. consider fo allow M/s Aduni Port and $122 ie yesponse are given below: 3. Regarding the above issue, Pvt Ltd to visit the documents. The Point_No._(i) North Port aren and Bovka tsland should be declares ‘Conservation zone aad the aren shonkd be protected. All the ereeks, water boties fand reclainted tand in these avens shonld be restored and bronght hack to pre- 2005 status within six months. Respon ‘Racha Island and area proposed for North Port is notin the possession of APS! 'APSEZI. committed to conserve 88 Ha of mangrove area of Pacha Island as per the NIA studies carried ont by NIO in terms of HC dated 12/19.1.2009 for Waterfiowt evelopment Project. on the airstripfaeradrame including the location ins ete,alony, with the details of clearances projects constructed within the SEZ should sn, 2006 ae applicable, ‘Vive details shall be Poin possess submitted, Response: AP: fm that all the projects constructed! within the SEZ will ‘onment Cleatnnee if applicable under ECA Notification, 2006. J). Prepare a specific aetion plan to prateet the livelihood of ne ecology, and entelt and aecess t the sex have been Serlonaly affected by the violation committed hy dhe Projeet Proponent within @ Months with a specifig plan for fishermen, thelr access and) protection of ‘hood, Further, APBEZ 14d, shall provide necessary support for the development of exclusive fishing arbour as Bhadreshorar, Response: APS! never restricted or created any hindrance (© amy authorized fishermen for approaching the sea For their fishing related getivities, There is 99 Tinpect on fishermen aS, APSEZ. us provided specific approach eordors, for Rermen movement though APSBZ acca, Additionally APSIEZ hs been sorting hormen groups in Mandra for providing then fivelihaod support for Their socto economic uplifiment, APSEZ. is also providing support for Healthcare Fucation ant nftasteucture facilities for ishermien eoramunity Ole saving land and also invest Responses After diseussion with local people of Zarpara village, APSEZ. hs voluntarily given back approx. 490 acres of land to Zarpara village Tor gauchar purpose, in spite of the fact that the Hon’ble Supreme Court of India has dismissed the appeal of villapers eballenging the allotment of pnuchat tad, APSEZ will always} ‘eager to help them in the best possible manner. APSE nd do the nvedfi pZ Ltd stall subnalt { projeets to the State Gov to put in place a Distriet Dis und the project wren, Response: APSEY. has alteudy prepared Disaster Management Plan for its all the nda. The sane has been ulead submitted to Stale Disaster ment Authority vide our letter dated 18" January, 2013, for non-complia ronment Restoration fund dist ny Law a ngs 10 Ls. 200 crores oF 1% of projeet | ichever is higher, to be used for remesliati 1 ‘The fund will he operated cluding activities as enume ip of Scevetary ed by the Committee. Response: As can be seen from para (i) to (vi) of pra-10 of the captioned show cause siotice that there is no non-compliance of violation of the terms of the environmental clearance dated 12/19.1.2009 by APSEZ. Therefore respectfully request the Ministry to reconsider the setup of environmental restoration fund for an. amount of 88.200 crores whieh has been subjectively arrived at, We have spent substantial amount in various aetivities for socio environment develepment. | i | 1 1 | I Ht Without preiefive to this, we are open to eretion of development fund afany substantially reduced atount voluniaily kesping i mid our CSR eontibations as well as the elatfenge fied Wy the infastactre sector in he eucent ceonomie seenaro, We will nak the fn available on yet basis spr the plans that may ! i ! i | i { i ' bbc sanctioned by the Ministy for improvement of socio-enyironment condition, We are opeu! (o suggestions of objets and purpose of ny conerete projects and proposals which may meet the iconment and well being of people at large 4. Further GME hus also submided its response. Brief response is given below: Issue: plan along with cost estimate for restorat of mangroves and ereeks in North Port site to their original status, The acti plan should also contain provision for conservation and maintenance of the stored ecosystems including dectaration of Bocha Island as conservation zone. Pending decision on the Show Cause Notice, the statws quo ante f coustructions/development in the site as an date should be maintained, Response: Wochit tslandl, didn't have much vegelation in the eat Toposheet No, 4119 aud F/10 of the Survey of India, Growth of such coastal vegetations and manyroves expand over the period and also entor in the aren of acquisition process takes long time. Such stray mangroves are sometime found luxuriant? vanished over the period along the navigation channels, wings of exis berths and anywhere where port development and oper ‘on account of impacts oF port! fishing aetivities in the vieinity creck and surrounding creck lets are extensively under necessitate maintenance dredging from 1590 as per ing, activities are prevalent Boch Island, Bocha Fisherman’ which me to time, : Board woutd like to study the said scientifie study report i? commissioned by MoLF in addition to Current Visit Report of the Committee so tha: fone can implement its recommendation as engineered solution for holistic implementation of the preventive measures. ut of 718 er of Bocha land, 211 acres (88 ha) is already reported for mangroves conservation by APSI ng about $00 acres Fad can be considered for forest lared as “Conservation Area” However, considering its importance, in addition to above, GMB is willing to carts ‘out compensatory afforestation at othcr suitable location (s) based on the findings 0° the Committee Report proval of MoLP and in consultation with Gujarat Reology Commission wi the nodal agency of Government of Gujarat for mangrove afforestation activities. ‘The existing reclamation of 396 acres is resourees which may be utilized fr permissible activities for Port after seeueing fresh Hnw/CRZ Clearance in future. con issues Tike linking Disaster submitted that the response of the State Gov ‘of exclusive fishing harbours at Bhadreshwar Management Plan of the different project proponents of APSE), to the 'Distrit, Disaster Management Plan’ and roview the policy of acquisition and transfer of ‘auchar or village common funds ete are yet to be received, Further, response fro GCZMA on reassessinent of the matter relating, to Samuda townshipserh Hospital is awaited 6 We may issue reminders to the Principal Secretary, Forests and Environmert Department and GCZMA to expedite their reply so that matter ean be examined fer issue of final order. 7. Draft Jeiters are placed for perusal and approval please, Qs (Uathirunavuldarase) sev? 30 November 2013 a) Ahoee roles of peer) omy he seen ’ beeecd upon He ve cormendadons of ny Suni} Norain! Gur) led Shea Covere, MaibeeS rere ised? to my doris PYbceud sere (el (11st ze) Ctud GHonal Martrae Bort cud Leber Jo CCEA cme Stale Cu mls Apseel dud Gm have cobupteal hen yeplrcs Jo the Choe cee At poe? bere 8 vephea fam écems cil Stele Cov} anc ‘ShN cuodbeal. oh mrp ke reerbmenh teadt reply Cosel a a2 ~ “fom CCCP i lov yw rafal “fox ckcrdanky aebor ¢ Teeons) youre) SJerling My sported 03° fo uhelfea 9 , feat) \n & Re ard por vd . A cea vnay fe taken ante Krol dey fo Mls nite atl GW baged on otha veyshes, Doron on We rssees relabeef fe “Teed > ati) Slearby HoypPal coer he taker once veplics eb, ECC MA cud. Shale Cont} aye Yeodiecel ) for uluck coe may Vsere v4 riedeng sabueltead pre eae, 1518) tg er JS (ye :) i. ufo Shs DIBA Mk, Powwnch w tsaeod fo 6C2mA ced ce d fe 6 ced Shue Coch hed al oe wud Chute 45 (oyK) ee ay ae Bofn/y DIRE CK, eof) Ae ta advedey oletals?l wot uj bebo = Oo flee C : feb ee 9 - F.No,10-47/2008-1A-11(01) Subject: Recommendations of the Committee constituted for and ex jon of alleged violations by M/s Ad SEZ Pvt Ld - Reg, spect Port aud ‘Noting on the pre-page may please be seen, Reminders sent to the Principal Scerctary, Forests and Environment Department and GC/MA fo expedite their reply. The analysis of the reply of the Mis ‘Adiaii Port wad SEZ. Ltd and GMB are given below: North Port aren and Rocha Island should be declared as + conservation zone and the area should be protected. All the crecks, water bodies il in these nreas should be restored and brought back to pre months, Response of PP: Bocha Island and area proposed for North Port is not in the possession of APSEZL APSEZL committed to conserve 88 Ha of mangrove area of Bocha Island as per he BIA studies earried out by NIO in terms of EC dated 12/19.1.2009 for Wiiterfia Development Project Response of GMB: Acquisition admeasuring 1114 acres having, 88 cers mangroves inhabited athe front of the Bocha Island has been done for the purpose of port developinent. i didn’t have mich vegetation in the early 1990 as per Toposheet No. 41F/9 and F10 of the Survey of India. ‘Tho growth of such coastal vegetations axl an expire over the period! and such stray manggoves arc sometime foun tus vanished over the period along the navigation channels, wings of exist anywhere where port develop of impacts of ord fishing activites in the vicinity. Mocha Isand, Pacha er snd sunrounding creck lets are extensively under by Fisherman which necesstue maintenance dreiging fr time to time. willbe unwise to do restoration for thase Sitay mangroves which didnot exist prior to 1980 since fish production in this area |" has increased, However, for rostoration of the same stray mangroves, itis advisiole 1 to-eany out Environmental Impact Assessment Stuies though a nationally repre id under thee guidance, restoration activities can be eartied out as the axa falls in CRZ, Gujarat Maritime Board would like to study the said scientific commissioned by MoFP in addition to Current Visit Report of the Cor aly report if ittee so fat fone can implement its rgeommnendation as engineered solution for hobsic | implementation of the preventive measures. ‘Total area of 1114 acre of land consists of (a) Rocha Island admeasuring 71 acres Out of 718 aeres of Bocha land, Lad nd ion and and (b) the adjoining land adoeasuring 396 act 211 acres (88 ha) is already reported for mangroves conservation by APSI remaining, about 500 acres land can be considered for mangroves affore be declared as “Conservation Arca”. However, considering its impor addition to above, GMD is willing to carry out compensatory allestation at other suitable location (8) based on the findings of the Conmittce Report. Same may be implemented after approval of Mol5F and in consultation with Gujarat Beolegy Commission which is the nodal ageney of Government of Gujarat for mangr afforestation activities. The existing, reclamation of 396 acres is resourees which niay be uilized for permissible activities for Port after securing fesh Finw/CRYZ Clearance in fue. Comments: GMB has not commitied on restoration of ereeks, wanted the Ministry | commence a scientific sty, requested to utilize 396 aeres for foreshore facilites. ‘Also requested fora personal discussion . A decision to be taken on all these issts ni 28 8 details on the airst neluding the location with coordinates, facilities, dimensions ete. along with the details of clearances obtained. Response: details submitted, ci focation of Sanmmelrs townshipystesting hospit the same is ansated The GCZMA was asked for reassessment of the matter relating to fal with respect to CRZ. boundary and Point No. Gil) possess KC under su L wre that all (he projects constructed within the SEZ. should |A Notification, 2006 as applicable. ‘The details shall be Response: APSPZ. e possess im that all the projects constructed within the SEZ, will 1A Notification, 2006 nvironment Clearance if applicable under ts: Nil plan to protect the livelihood of ly affected by the violatio specific plan for fishermen, their access and protection of ther, APSBZ Ltd. shall provide necessary support for the ent of exel months with livelihood, develop SEZ, has never restricted or ereated any hindrance to any authorized fishermen For appraaching the sea for their fishing related activities. These is no jermen as APSEZ. has provided specific approach corridors. for fishermen movement through APSEZ area, Additionally APSEZ has been working with all the fishermen groups in Mundra for providing them livelihood support for their socio-economic upliftment, APSEZ is also providing support for Healthcare, Edueation ane! Infiastruetare facilities for fishesmen community Comments: PP has not submitted specific action plan as sought. PP has submitted the details of the approach corridors developed for fishermen along with the year of construction and east Point No. in improvi i grazing, land and also invest 4) Shall consider the voluntary ret 1 productivity of this land with villnge Responses Alter discussion with local people of Zarpara village, APSHZ has volintitly given back approx. 400 aeres of land to Zarpara village for gauchar purpose, in spite of the fact thal the Hon'ble Supreme Court of India has dismissed xs challenging the allotment of gauchar land, APSEZ.will always in the est possible manner, APSEZ. will consider the suggestion the appeal of v eager to help the and do te need Comments: Since PP agreed, time limit may be specitied 10 the PP to comply, Point No. (vi) APSEZ Ltd shall submit Disaster Management Plan of the different projects to the State Government so as to enable the State Government to put in place a Distriet Disaster Management Plan to ensure hnuman safety in and around the project area. Response: APSEZ, has already prepared Disaster Management Plan for i's all the fopenitional area at Mundta, ‘The same has been already submitted to State Disaster ment Authority vide our letter dated 18" January, 2013. ments: Nil

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