Inclusive, Resilient, and Sustainable Housing for Urban Poor

Initial Environmental Examination

Document Stage: Draft Project Number: 53067-004 July 2021

IND: Inclusive, Resilient and Sustainable Housing for the Urban Poor Sector Project in Tamil Nadu (IRSHUPSP) – Kalanivasal Subproject

Prepared by the Tamil Nadu Slum Clearance Board for the Asian Development Bank.

CURRENCY EQUIVALENTS

(as of 22 July 2021)

Currency Unit – Indian rupees (₹) ₹1.00 – $0.0134 $1.00 = ₹74.446

ABBREVIATIONS

ADB – Asian Development Bank ASI – Archaeological Survey of India CPCB – Central Pollution Control Board CtE – Consent to Establish

CtO – Consent to Operate

EA – Executing Agency

EAC – Expert Appraisal Committee

EARF – Environmental Assessment and Review Framework

EC – Environmental Clearance

EHS – Environmental Health and Safety

EIA – Environmental Impact Assessment

EMP – Environmental Management Plan

ESS – Environmental and Social Safeguards GOI – Government of India

GoTN – Government of Tamil Nadu GHG – Greenhouse Gases GRM – Grievance Redress Mechanism IA – Implementing Agency IEE – Initial Environmental Examination

MOEFCC – Ministry of Environment, Forests and Climate Change

NOC – No Objection Certificate

PMU – Project Management Unit

PCR – Physical Cultural Resources

PID – Project Implementation Division

PPE – Personal Protective Equipment

REA – Rapid Environmental Assessment

RF – Resettlement Framework

RoW – Right of Way

SEIAA – State Environmental Impact Assessment Authority

SPS – Safeguard Policy Statement

STP – Sewage Treatment Plant

TNPCB – Tamil Nadu Pollution Control Board

TNSCB – Tamil Nadu Slum Clearance Board

ULB – Urban Local Body

WHO – World Health Organization

WEIGHTS AND MEASURES

C – Degree Celsius

dBA – A-weighted decibels LAeq – Equivalent Continuous Sound Pressure Level KLD – Kilo Liters per Day km – kilometer km2 – square kilometer LPCD – liters per capita per day m – meter m2 – square meter Mgd – million gallons per day MLD – million litres per day

mm – millimeter nos. – numbers μg/m3 – Micrograms Per Cubic Meter

NOTE

In this report, "$" refers to United States dollars.

This initial environmental examination is a document of the borrower. The views expressed herein do not necessarily represent those of ADB's Board of Directors, Management, or staff, and may be preliminary in nature. Your attention is directed to the “terms of use” section on ADB’s website. In preparing any country program or strategy, financing any project, or by making any designation of or reference to a particular territory or geographic area in this document, the Asian Development Bank does not intend to make any judgments as to the legal or other status of any territory or area.

http://www.adb.org/terms-use

CONTENTS

Pages

EXECUTIVE SUMMARY ....................................................................................................... i

I. INTRODUCTION ........................................................................................................... 1

A. Background ............................................................................................................. 1

B. Subproject Scope and Location ............................................................................... 2

C. Purpose/ Objectives of IEE ...................................................................................... 8

D. Report Structure ...................................................................................................... 9

II. POLICY, LEGAL AND ADMINISTRATIVE FRAMEWORK ........................................... 10

A. ADB Safeguard Policy Statement (2009) ............................................................... 10

B. National and State Environmental Regulations ...................................................... 11

C. Applicable International Standards and Best Practices .......................................... 18

D. International Treaties/Conventions/Declarations on Environment Management .... 22

III. DESCRIPTION OF THE PROJECT ............................................................................. 24

A. Subproject Overview ............................................................................................. 24

B. Proposed Subproject Interventions at the Resettlement Site.. ............................... 26

C. Proposed Subproject Interventions at the Encroachment Sites Identified for Relocation

41

IV. DESCRIPTION OF THE ENVIRONMENT (BASELINE DATA) .................................... 49

A. Area of impact ....................................................................................................... 49

B. Methodology used for environment baseline study ................................................ 49

C. Physical Environment ........................................................................................... 49

D. Biological Environment .......................................................................................... 58

E. Socio-economic Environment ................................................................................ 60

V. ANALYSIS OF ALTERNATIVES .................................................................................. 64

VI. ANTICIPATED ENVIRONMENTAL IMPACTS AND MITIGATION MEASURES .......... 70

A. Assessment of Environmental Impacts .................................................................. 71

B. Pre-construction Impacts and Mitigation Measures ............................................... 71

C. Construction Impacts and Mitigation Measures ..................................................... 74

D. Post-Construction Impacts and Mitigation Measures ............................................. 78

VII. INFORMATION DISCLOSURE, CONSULTATION AND PARTICIPATION .................. 81

A. Consultation and Participation ............................................................................... 81

B. Public Consultation ................................................................................................ 81

C. Information Disclosure and Future Consultations .................................................. 84

VIII. GRIEVANCE REDRESS MECHANISM ....................................................................... 85

IX. ENVIRONMENTAL MANAGEMENT PLAN .................................................................. 89

A. Environmental Management Plan .......................................................................... 89

B. Implementation Arrangements ............................................................................. 145

C. Monitoring and Reporting .................................................................................... 152

D. EMP Implementation Cost ................................................................................... 154

X. CONCLUSION AND RECOMMENDATIONS ............................................................. 157

LIST OF TABLES

Table 1: Details of Subproject Scope

Table 2: Encroachment sites Identified for Relocation

Table 3: Environmental Guidelines for Subproject Selection under Output 1

Table 4: Environmental Regulatory Compliance for Kalanivasal Subproject

Table 5: Clearances and Permissions Required by the PMU for Project Construction

Table 6: Clearances and Permissions Required by the Contractor for Project Construction

Table 7: National Ambient Air Quality Standards and WHO Guidelines

Table 8: National Noise Standards and WHO Guidelines

Table 9: National Drinking Water Quality Standards and WHO Guidelines

Table 10: International Treaties/ Conventions/ Declarations on Environment

Table 11: Salient Features of the Kalanivasal Resettlement Site

Table 12: Plinth Area Details of Proposed Residential Units at the Resettlement Site

Table 13: Built-up Area Details of the Buildings at the Resettlement Site

Table 14: Proposed Land use of the Resettlement Area

Table 15: Subproject Interventions at the Resettlement Site

Table 16: Power Requirement at the Resettlement Site

Table 17: Water Requirement at the Resettlement Site

Table 18: Rainwater estimate

Table 19: Solid Waste Generation at the Resettlement Site

Table 20: Proposed interventions

Table 21: Existing Condition of the Encroachment Sites Identified for Relocation

Table 22: Rainfall Information for Sivaganga District

Table 23: Monthly Rainfall of Sivaganga District (in mm) during 2004 - 2013

Table 24: Surface Water Quality in Karaikudi, 2015

Table 25: Groundwater Quality in Karaikudi, 2015

Table 26: Groundwater Quality Tested by the TNSCB at Kalanivasal Resettlement Site

Table 27: Ambient Air Quality in Karaikudi

Table 28: Ambient Noise Levels in Karaikudi

Table 29: Details of Protected Monuments near the Subproject Sites

Table 30: Recharge structures

Table 31: DWATS Salient Features

Table 32: Alternative Approach in Building Plan

Table 33: Outcome of the Analysis of Alternatives

Table 34: Meetings/Discussions between various stake holders

Table 35: Environmental Management Plan for Construction Site - Kalanivasal, Sivaganga

District

Table 36: Environmental Management Plan for Operation and Maintenance - Kalanivasal,

Sivaganga District

Table 37: Environmental Management Plan for Building Demolition Works (Encroachment Sites

Identified for Relocation)

Table 38: Environmental Management Plan for Water Body Restoration Works

Table 39: Pre-construction & Construction Stage Environmental Monitoring Plan

Table 40: Operation Stage Environmental Monitoring Plan

Table 41: Institutional Roles and Responsibilities for Safeguards Implementation

Table 42: Outline Capacity Building Program on EMP Implementation

Table 43: Indicative EMP Budget

LIST OF FIGURES

Figure 1: Map Showing Sites Chosen for Relocation and Resettlement

Figure 2: Map Showing Exiting Public Amenities around the Resettlement Site

Figure 3: Subproject Sites and Area within 10 km Radius from the Resettlement Site

Figure 4: Photograph of the Resettlement Site

Figure 5: Proposed Master plan of Kalanivasal Resettlement Site

Figure 6: Proposed Sewer Line and STP

Figure 7: Proposed Storm Water Drain

Figure 8: Proposed Water Supply Line

Figure 9: Proposed Green Belt Area

Figure 10: Green Belt Map of Kalanivasal Resettlement Site

Figure 11: STP Process Flow Diagram and SBR Structure – Water Balance for Kalanivasal

Resettlement Site

Figure 12: Rainwater Harvesting Structure

Figure 13: Typical Cross Section for Approach Road and Internal Roads

Figure 14: Construction Schedule Bar Chart

Figure 15: Locations of the Subproject Sites

Figure 16: Elevation Profile for the Resettlement site at Kalanivasal

Figure 17: Average Annual Rainfall of Karaikudi

Figure 18: Subproject Area in Seismic Zones Map of South India

Figure 19: Landuse Pattern (Bhuvan Landuse map and Google earth image) of the Subproject

Area

Figure 20: Groundwater Prospects for the Subproject Area

Figure 21: Location of Vettangudi Bird Sanctuary

Figure 22: Snap Shots from the FGDs conducted at Water Body Encroachment sites

Figure 23: Grievance Redress Process

APPENDICES 1 : Confirmation letter from the Karakudi Commissioner for the Encroachments in the

water bodies 2 : Landuse Classification and Enter Upon Permission Issued to TNSCB by the District

Collector, Sivaganga (Translated English Version) 3 : Rapid Environmental Assessment (REA) Checklist 4 : Environmental Clearance from SEIAA 5 : Salient Features of Major Labor Laws Applicable to Establishments Engaged in

Construction of Civil Works 6 : Certification for the resettlement site (Encumbrance free site) 7 : Confirmation letter from the Tamil Nadu Electricity Board (TNEB) 8 : Confirmation letter from Taluk office on the flood situation in the encroachment sites 9 : Land Transfer certificate 10 : Certificate indicating the Kalanivasal site is not vulnerable for flooding 11 : Acceptance letter for collection of Municipal Solid Waste 12 : Permission letter for discharge of treated sewage 13 : Tamil Nadu Water Supply and Drainage Board (TWAD) acceptance/ acknowledge for

the supply of water to Kalanivasal resettlement site 14 : Confirmation Letter for Collection and disposal of Sludge generated from STP

installed at Kalanivasal Resettlement site 15 : Submission of Compliance Matrix for the EC conditions 16 : Groundwater Quality Test Results at Kalanivasal Resettlement Site 17 : IBAT Study for the subproject area 18 : Health and Safety Plan/ Response and Measures for COVID-19 19 : Sample Grievance Form 20 : Sample Environmental Site Inspection Report 21 : Quarterly Environmental Monitoring Report Template 22 : Outline of Daily Monitoring Sheet for Contractors

EXECUTIVE SUMMARY

Project Background. Tamil Nadu is one of the largest states in India with acute housing shortage. It has 5.8 million slum residents, most slum residents come from the EWS and the LIG. Slum areas are prone to disaster, environmental degradation and health risks. In Tamil Nadu, TNSCB has been identified as the entity responsible for implementing PMAY (Urban). As per the recent study the actual demand for affordable housing is 1.4 million units. Affordable housing also needs to be made accessible to low-income migrant workers, working women and female-headed low-income households for sustainable urban development. In view of this, the proposed project will promote access to an inclusive, resilient, and sustainable housing and urban development in Tamil Nadu. The project covers 3 proposed components as follows:

• Output 1: Affordable Housing for Vulnerable Communities • Output 2: Affordable Housing for Urban Poor and Migrant Workers • Output 3: Regional Planning

This subproject proposed under Output 1 is for (i) the construction of 900 residential housing units and associated facilities at the resettlement site at Kalanivasal in Sivaganga district; (ii) demolition of 900 structures located in 10 encroachment sites identified for relocation to Kalanivasal; and (iii) restoration of 10 water bodies. It is estimated that 900 households will be relocated to Kalanivasal site. Executing and implementing agencies. The Government of Tamil Nadu through the Housing and Urban Development Department (HUDD) will be the executing agency (EA) and responsible for overall project management and compliance with loan assurances. The Tamil Nadu Slum Clearance Board (TNSCB) will be the Implementing Agency for Output 1. TNSCB will also be responsible for the management, coordination and execution of all subproject activities funded under IRSHUPSP. The TNSCB has set up a Project Management Unit (PMU) that will be responsible for overall supervision and coordination during subproject implementation. The PMU will be supported by Project Implementation Circle located at Salem and three Project Implementation Divisions (PIDs) are located at Madurai, Salem and Villupuram and they will be responsible for day-to-day activity and compliance with safeguards during project implementation. The PMU will be headed by Joint Managing Director/ Project Director and will be assisted by the Chief Engineer and the Superintending Engineer. They will be supported by technical, financial, safeguards and administrative staff. An Executive Engineer will head each PID. PIDs will be responsible for the implementation, management and monitoring of the subprojects. Subproject Scope: The Kalanivasal subproject scope of work includes: (i) construction of 900 residential housing units at new settlement site, (ii) demolish 900 housing units identified for relocation across 10 encroachments, (iii) Regeneration works across 10 water bodies (that were encroached). The subproject scope of work is enclosed in Table 1.

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Table 1: Details of Subproject Scope

Source: TNSCB

Sl.no Subproject Subproject Interventions

1 Construction, operation and maintenance of 900 residential units and supporting services

• Pedestrian Pathway

• Connecting Pathways

• Green belt (15.93%)

• Bus Bay

• Open Space Reserve (OSR) (10.30%)

• Sewage Treatment Plant

• Parking area

• Seating Gazebo

• Convenience Shops

• Market

• Ration Shops

• Anganwadi

• Livelihood Center

• Library

• Nurture/ Active courtyard

• Outdoor Board Games

• Walking Landscape

• Badminton court

• Outdoor Gym

• Engage/ Functional Courtyard

• Stimulate/ Outdoor living

• Livestock Shelter

• Productive Landscape

• Community Gathering

• Outdoor Gym

• Thrive/ Play Courtyard

• Pretend Pay

• Play park

• Tactile Play

• Flexi Play

• Community Hall

• Milk Booth

• Health Sub Centre

2 Demolishing structures in the encroachment site (prone to flooding)

• Demolition of 900 structures in the 10 encroachment sites

• Provide fencing to prevent further encroachment

3 Water body restoration • Clearance and fencing

• Restoration of water bodies, which were encroached

• Provision for public parks/ recreation areas as per the community’s requirement

• Avenue plantation/ landscaping

• re-greening / re-vegetation along water body / canal banks

• clearing and preventing new solid waste / sewage disposal in water bodies / channels

• implementation of site-specific plans in close coordination with ULBs or Public Works Department (PWD) e.g., waste management plan, sewerage collection and management plan, etc.

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Project Categorization. The due diligence has confirmed the project Environment Category is “B” requiring an Initial Environmental Examination (IEE) including Environmental Management Plan (EMP) in accordance with ADB Safeguard Policy Statement (SPS, 2009) and requirements of the Environmental Assessment Review Framework for IRSHUPSP – Table 1.3 (Key Exclusion Criteria) and Table 1.4 (Environmental Guidelines for Subproject Selection under Output 1). Based on the project activities, a consolidated IEE and 4 EMPs ((i) EMP for construction phase (C-EMP), (ii) EMP for operation phase, (iii) EMP for demolishing works (D-EMP) and (iv) EMP for regeneration works (R-EMP)) cover environmental impacts and associated risks in the project area of influence. The IEE and EMPs have been prepared based on the detailed engineering designs and will be updated where necessary to further meet the final detailed engineering designs. This project mandates Environmental Clearance (EC) as per the EIA notification 2006 (under category B2 and project schedule 8(a) for Building and Construction Projects and accordingly the Form 1 and Form 1A have been submitted to the State Environment Impact Assessment Authority (SEIAA) and the EC for the same has been obtained. Other statutory requirements including (i) Compliance to the conditions (General and Specific Conditions) as stipulated in the Environmental clearance obtained for Kalanivasal Resettlement Site (, ;(ii) Update the IEE based on the water source sustainability study report (including water quality) from TWAD and (iii) Consent to Establish and Consent to Operate under air and water acts for the hot mix plant /batching plant, Construction (workers) camps and proposed STP. Other project-related permissions/consents to be obtained by the Contractor are detailed in the IEE report. Project Benefits. The key objective of this project is to provide affordable housing for the people who are living in the encroached areas (encroached water bodies), which is prone for seasonal flooding. This project also benefits, the low-income families, female-headed households. Based on the climate risk assessment and heat modelling, the building plan has been developed to withstand the climate change including the high temperature. The proposed infrastructures including provision of toilets, water supply arrangement, electric connection, community centre, play area shall provide an improved standard of living. Description of the Environment. The Kalanivasal resettlement site (10°5'39.80"N, 78°45'21.19"E) and demolition sites are located in Sivaganga District. The maximum elevation of the resettlement site is 97 m AMSL and the lowest is 94 m AMSL. Soil type of the project area is laterite soil, which is low in fertility. Maximum temperature experienced in the district is 40.2°C in the month of May and minimum is 17°C in the month of January. Annual rainfall of the district is 905 mm. Wind speed is normal throughout the year ranging between 3 to 5 km/hr. Seismic zone of the subproject site is Low Damage Risk Zone II. There is an irrigation tank located near the resettlement site. The ground water is slightly acidic and apart from that all other parameters are within the drinking water specification (IS 10500: 1991). There are no protected areas, eco sensitive zones or ecologically sensitive areas notified by MoEF&CC within a radius of 10 km from the Kalanivasal resettlement site. According to the 2011 census, Karaikudi Municipality had a population of 106,714 with a sex-ratio of 1,000 females for every 1,000 males, much above the national average of 929. A total of 10,619 were under the age of six, constituting 5,405 males and 5,214 females. There are no protected monuments in the near vicinity to the subproject area. Water supply will be provided by the TWAD to the subproject area. The subproject site is well connected by the railway, national highway and state highways. Potential Environmental Impacts and Mitigation Measures. The subproject is unlikely to cause significant adverse impacts that are irreversible, diverse or unprecedented because: (i) the components will involve straightforward construction and operation, so impacts will be mainly site specific and localized; and (ii) there are no significant sensitive environmental features in the subproject sites although careful attention shall be taken to minimize disruption to the community.

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Land acquisition related issues are not envisaged in this project, because the proposed resettlement site belongs to TNSCB. The primary areas of impact are (i) sites for proposed project components; (ii) main routes/intersections which will be traversed by construction vehicles; and (iii) quarries and borrow pits as sources of construction materials. The secondary areas of impact are: (i) other than the delineated primary impact area; and (ii) new resettlement site (Kalanivasal) and the 10 encroachment sites in terms of over-all environmental and socioeconomic improvement. Pre-construction impacts are associated with (i) shifting of utilities (including water supply, electricity, etc.) in the 10 encroachment sites, which are chosen for relocation. Utility shifting is not envisaged at the Kalanivasal resettlement site due to lack of habitation in the surrounding areas. (ii) Sourcing of construction materials. Construction materials have to be identified before any construction commences and a proposed mitigation measure is to procure construction materials from the government authorised / permitted quarries and vendors. This will significantly reduce environmental impacts. (iii) Demolition of structures in the 10 encroachment sites that are chosen for resettlement. It will generate significant quantity of construction debris, which shall be disposed in the authorised areas in consultation with the Urban Local Bodies (ULBs). (iv) Site selection of construction work camps, stockpile areas, storage areas, and disposal areas. These should be located 500 m away from the nearby settlements. Residential areas will not be considered for setting up construction camps to protect the human environment (i.e., to curb accident risks, health risks due to air, water and noise pollution, social conflicts and shortage of amenities). (v) Increase in traffic. Since most of the work areas are accessible from the existing roads, potential impacts will be of short-duration, localized and can be mitigated. Construction related impacts are standard and site specific to the construction activities and not expected to be significant. Key impacts during construction are envisaged on the following aspects: (i) transportation of materials, (ii) dust generation, air and noise pollution from construction activities, (iii) sourcing of water for construction activities, (iv) handling of construction materials at site and, (v) adoption of safety measures during construction. There are no water bodies surrounding the resettlement site and hence impact due to runoff from the construction site is not envisaged. However, the demolition sites (10 encroachment sites) are surrounding water bodies and hence demolishing activity and runoff from the sites will have significant impact to the water bodies. Hence a mitigation measure has been proposed to use silt trap to prevent pollution of water bodies. Air quality impacts due to the construction activity in the resettlement site is not expected to have a major health impact to the surroundings, because of the lack of human habitat/ settlement in the project area. However, for the resettlement site as well as the 10 encroachment sites, the movement of construction vehicles transporting construction materials and debris/materials to be disposed may cause increase in air pollutants within the construction zone. These are inherent impacts which are site-specific, low magnitude, short in duration and can be easily mitigated. For noise and vibration impacts, with exemption to piling works, most of the construction activities (including construction and demolishing works) shall be done manually with minimum use of machinery and equipment and with necessary safety precautions, for example, barricades around demolition sites, restricting pedestrian and vehicular movements. Noise from demolition works should not exceed the noise standards as set by CPCB. Hence noise and vibration impacts are not expected to be significant. However, for the piling operation, Piling Rig will be used, it will generate noise and vibration to the surrounding, since there are scattered habitations (the nearest settlement is located at a distance of 250 m), the anticipated noise and vibration impacts shall be

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minimal. The demolition activities shall not have any impact on the physical cultural resources since no heritage buildings are located near the encroachment sites or the resettlement site. During the project construction and operation, there is a moderate negative impact anticipated on the water resources. This is due to the utilisation of water for construction purposes and use of water for domestic purpose during operation, this activity will have a moderate stress on the available water resource. For construction purposes, the water shall be sourced from the ULB’s/ Tamil Nadu Water Supply and Drainage Board (TWAD). During the operation phase of the project, TWAD will supply water to the Kalanivasal resettlement sites. The estimated water demand of 640 KLD will be sourced from Sakkottai Master Storage Reservoir (MSR), which is located at a distance of 7 km from the Kalanivasal resettlement site. TWAD will also carry out all the various methods / procedures for groundwater recharge, which includes Check dams, Percolation ponds, Artificial recharge pits, Recharge trench, Ooranies (artificial lakes), Recharge shaft etc., Hence the anticipated impact on the groundwater shall be minimised. For the resettlement site rainwater harvesting structures including 19 rainwater collection pits and rainwater collection trench for a length of 985 m has been provided. It is estimated that 34.5 lakh litres of rainwater will be collected within the resettlement site. Impact on the flora and fauna due to the project construction works and demolishing works will be negligible. This is because tree cutting is not required in the Resettlement Site and there are no protected areas or environmentally sensitive areas surrounding the subproject sites. However, few trees are observed in the encroachment areas (demolishing work sites), which shall be preserved and included in the landscaping design during the water body restoration works. Impact on occupational, health and safety including exposure to work-related chemical, physical, biological and social hazards are likely to occur during proposed construction and demolishing works. Potential impacts are negative and short-term but reversible by mitigation measures including provision of PPEs, preparation of comprehensive site-specific health and safety (H&S) plan (including asbestos material management) provided with a management strategy (including training) and applying practices that are intended to eliminate or reduce fatalities, injuries and illnesses for workers. Major post construction impacts are specific to site clean-up activities including backfill of any excavation and trenches; reuse of topsoil; re-establishing the drain pattern if impacted; and removal of all tools, equipment, barricades, surplus materials, debris and rubbish. Major project operation impacts are specific to (i) municipal solid waste generation, and (ii) wastewater generation from the resettlement site. (iii) health and safety issues (including communicable diseases, fire hazard etc.) and (iv) operation of infrastructures/ amenities including STP, rainwater harvesting structures and maintenance of lawn/ green belt. For the identified impacts the TNSCB has already obtained necessary permissions from the competent authority (Town Panchayat) for handling the municipal solid waste (MSW) and the discharge of the treated sewage. Hence the impact anticipated during the project operation is negligible. TNSCB has obtained confirmation for the supply of water to the resettlement site from TWAD. Since water will be supplied by the TWAD, the IS 10500 drinking water standard shall be maintained. The supply of estimated water demand of 640 KLD shall not have detrimental impact on the total water supply estimated for the Karakudi Municipality. The main project risk is the low institutional capacity of the PMU, PIDs and contractors and their failure to implement the EMP effectively during construction and operation stages. These risks will be mitigated by: (i) hiring of environmental specialists at PMU and PID level; (ii) providing

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training and capacity building on environmental and social safeguards to the PMU, PIDs, contractors and workers, (iii) developing and implementing site specific EMPs (C-EMP/ D-EMP/ R-EMP) and Standard Operation and Maintenance Plans (SOMPs), (iv) following appropriate project implementation, mitigation, monitoring and reporting arrangements, and (iv) adequate site supervision including audits of contractor’s environmental, health and safety (EHS) performance. Monitoring parameters will be identified in the environmental monitoring plan to check the effectiveness of EMP measures and to ensure any unidentified impacts can be readily addressed. The project risks will also be mitigated through inclusion of environmental specifications in contracts, bids and tenders for contractors. For the identified impacts, mitigation measures have been developed to reduce all negative impacts to acceptable levels for pre-construction, construction, post-construction and project operation phases. Mitigation will be assured by a program of environmental monitoring to be conducted during construction and operation phases. The environmental monitoring program will ensure that all mitigation measures are implemented and will determine whether the environment is protected as intended. It will include observations on- and off-site, document checks and consultation with workers and beneficiaries. Any requirements for corrective action will be reported to the ADB. Relocated vulnerable population, especially low-income households will be the major beneficiaries of the project. The most noticeable net environmental benefits to the population will be observed for those residing surrounding the restored water bodies. Environmental Management Plan. The identified potential environmental impacts can be managed through effective implementation of the Environmental Management Plan (EMP). An EMP is included as part of this IEE, which includes (i) mitigation measures for environmental impacts identified during the implementation stage; (ii) an environmental monitoring program, and the responsible entities for mitigating, monitoring and reporting; (iii) public consultation and information disclosure procedure; and (iv) grievance redress mechanism. A number of impacts and their significance have already been reduced by amending the designs. The EMP will be included in the civil work bidding and contract documents. The EMP Budget has been estimated to be ₹54.74 lakh (USD 75,838). Consultation, Disclosure and Grievance Redress. During the course of preparing this IEE, meetings with departmental officials and other relevant government stakeholders have been conducted. The subproject components and associated clearances/ permissions/ NoCs requirement as well as the way forward for the project were discussed. Focus Group Discussions (FGDs) were also conducted with the affected peoples in the encroachment sites located at (i) Malaikadu Kanmai, (ii) Chellam Chetti Oorani, (iii) Thangachi Oorani, (iv) Vaith Oorani, (v) Kilaku Oorani, (vi) Veeraiyan Kanmai, (vii) Athi Thitavida Kanmai, (viii) Kuruchi Kanmai, (xi) Kudikatha Nenthal Kanmai, and (x) Vadaku Oorani. These FGDs were informal but were attended by both women and men of the affected communities. Baseline socio-economic surveys were also undertaken with the affected peoples and have been incorporated into this report as required. Further consultations were hampered by the ongoing coronavirus (COVID-19) pandemic and as such additional formal consultations will be undertaken once it is safe to do so and before construction commences. These additional consultations will be incorporated into the draft IEE. The feedback and suggestions from the consultations that were collected to date were utilised in the design of the project, environmental impact assessment and the resettlement plan preparation. Consultations will continue throughout the project implementation period. The draft and final IEE and EMP will be disclosed on TNSCB and ADB websites.

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The IEE summary will be made available at public locations in the town and the Draft IEE report will be disclosed to a wider audience via the ADB and TNSCB websites. The consultation process will be continued and expanded during project implementation to ensure that stakeholders are fully engaged in the project and have the opportunity to participate in its development and implementation. A Grievance Redress Mechanism (GRM) is described within the IEE to ensure any public grievances are addressed quickly. The PIDs (Environmental / Social Cell) will set up a 3-tier common GRM acceptable to ADB at project and divisional levels to address any environmental and / or social issues that arise due to subproject activity. The GRM will constitute a suitable systematic process to receive, evaluate and facilitate resolution of affected persons and other stakeholder’s complaints and grievances about subproject environmental (and social) safeguards performance. It will aim to provide a time-bound, trusted and transparent mechanism to voice and resolve issues and concerns associated with the subproject implementation. The GRM will address concerns and complaints promptly via a transparent process. Complaints and their resolution will be documented and reported in quarterly project progress reports and annual safeguard reports to ADB. Monitoring and Reporting. The key institutions involved in the IEE and EMP implementation will be the PMU and PIDs. To ensure effective implementation of environmental safeguards procedures, the PMU and PIDs will include designated and trained staff and focal point persons. The PMU will be responsible for the overall supervision and compliance with (i) environmental safeguards requirements including resubmission of revised documentation for ADB concurrence, (ii) coordinate the project GRM, (iii) coordinate with line ministries to ensure smooth implementation of the project,1 (iv) supervise the procurement process, and (v) report to the ADB. In particular, the PMU will ensure consistency of safeguard documents with government policy, legal and administrative framework across all jurisdictions national, state and local level. The PIDs will be responsible for day-to-day activity and compliance with safeguards during project implementation in the field including engaging in project GRM, meaningful consultations, and oversight of the contractors or any third-party consultants. The PMU will be responsible for overall safeguards reporting and monitoring, including final approval of the site-specific environmental management plan (SEMP) prepared by the contractors. The PIDs (Environment Cell) with support of the PMU (Environment Team) will conduct environmental monitoring for each subproject and provide the environment input into reporting based on site inspections, compliance checks and prepare the subproject Quarterly Progress Reports (QPRs) for submission to the PMU for final submission to ADB till the project completion report is issued. Monitoring will also encompass tracking progress on regeneration works undertaken by the PMU of previously encroached water bodies / channels and surrounding areas. The environmental monitoring report for submission to ADB shall be on a quarterly basis during construction and on an annual basis during operation. Environmental monitoring reports will be required to be submitted to ADB within 30 days from the end of the relevant period. The environmental monitoring reports will be publicly disclosed on ADB public website. Reporting to ADB will continue until a project completion report is completed.

1 The PMU will ensure that subproject activities are synchronized between the project Resettlement Plan and EMP

implementation. The PMU will also ensure that no physical or economic displacement of affected persons will occur until: (i) compensation at full replacement cost has been paid to each affected person for subproject or sections of subprojects that are ready to be constructed; and (ii) other entitlements listed in the Resettlement Plan are provided to the affected persons.

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The PIDs will be responsible for safeguards monitoring and implementation, including initial review of the contractor’s SEMP before submission to PMU for final approval. The PIDs, will coordinate and interact with the PMU on compliance to ADB safeguards requirements and with relevant government agencies and local authorities on permits and clearances and update and finalize the IEE and EMP as needed. During the project implementation, the PIDs will conduct field visits and for the any identified noncompliance (with reference to EMP implementation) a suitable Action Taken Report (ATR) with a time bound corrective action plan will be prepared. The ATR will be shared with the Contractor for effective implementation of the EMP and included in the quarterly safeguard monitoring reports. After completion of the construction stage, the facility operator/ contractor will continue to submit monthly progress reports to PIDs for the first year of the operation and quarterly progress reports thereafter; these will inform the annual safeguards monitoring reports. Conclusions and Recommendations. The proposed subproject is unlikely to cause adverse environmental impacts. The potential impacts that are associated with design, construction and operation can be mitigated without difficulty through proper engineering design and the incorporation or application of recommended mitigation measures and procedures. Based on the findings of the IEE, there are no significant impacts and the classification of the subproject as Category “B” is confirmed. No further study or detailed environmental impact assessment (EIA) needs to be undertaken to comply with ADB SPS, 2009 or Government of India EIA Notification, 2006. This draft IEE is based on preliminary detailed design and will be submitted to ADB for concurrence and disclosure. However, this draft IEE will be updated based on final detailed design and will also need to be updated every time detailed design is changed or updated. The updated IEE will be submitted to ADB for final review and disclosure.

I. INTRODUCTION

A. Background 1. Tamil Nadu is one of the largest states in India with acute housing shortage. According to the Government of India, the State’s housing deficit accounts for 6.66% of the national housing shortfall. Based on the income levels, the housing shortage mapping reveals that the Economically Weaker Section (EWS) adds to 56%, which is followed by Lower-Income Group (LIG) of 39%and MIG by 4%. Tamil Nadu has 5.8 million slum residents, with the most slum residents from the EWS and the LIG. Slum areas are prone to disaster, environmental degradation and health risks. Informal settlements and slums are often situated in hazardous areas, which are congested and lack appropriate services (i.e., electricity, piped water supply, and sanitation/waste facilities). 2. As per National Urban Housing and Habitat Policy (NUHHP), several comprehensive urban initiatives have been undertaken. The most recent initiative is the Pradhan Mantri Awas Yojana-Housing for All (PMAY-HFA). In Tamil Nadu, TNSCB has been identified as the entity responsible for implementing PMAY (Urban). It aims to provide 1 million houses for slum families by 2022. In its recent survey, TNSCB estimated the total demand for affordable housing at 1.4 million units. Affordable housing also needs to be made accessible to low-income migrant workers, working women and female-headed low-income households for sustainable urban development. 3. In view of this, the proposed project will promote access to an inclusive, resilient, and sustainable housing and urban development in Tamil Nadu by supporting the state in (i) relocating vulnerable communities living in high-risk areas to safe shelter; (ii) providing affordable and proper housing for urban poor households as well as for migrant workers from the economically weaker section (EWS) and lower-income group (LIG); and (iii) in regional development planning. The project covers 3 proposed components as follows: 4. Component 1: Affordable Housing for Vulnerable Communities. The project will support the resettlement of slum households vulnerable to hazards to safe relocation sites. The project will work with government to introduce gradual changes in the delivery of affordable housing to the urban poor through: (i) improved design including robust O&M mechanisms including women’s participation in design, (ii) increased beneficiary consultation and participation, and (iii) a graduation approach to sustain vulnerable relocated households.2 The output will include protection of cleared waterways to restore ecological functions and prevent re-encroachment.3

2 The graduation approach is a holistic, time-bound, and carefully sequenced set of interventions to place households

on an upward trajectory from poverty. This includes four key components: (i) social assistance to support immediate needs such as subsistence and health services during transition in the relocation site; (ii) livelihood promotion through localized market assessment and household-level enterprise/employment matching; (iii) financial inclusion through financial literacy and improving access to savings and financial services to promote economic resilience; and (iv) social empowerment by improving social dynamics, including gender relations, in the families and communities.

3 Removing encroachments in waterways will have the benefit of restoring capacity to absorb water and reduce future flooding, recharge groundwater, and potentially be alternative sources of water in water-scarce areas. Regeneration of urban areas can also result from creating public spaces. Impacts of investing in the subsector can be further increased by improving TNSCB’s design and implementation practices and policies, and further strengthening the institution. Protecting cleared areas ensures that it will not revert back to a slum. The works from protecting the cleared areas including the re-greening of banks can provide temporary construction employment for beneficiary households and provide an initial market for transport services.

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5. Component 2: Affordable Housing for Urban Poor and Migrant Workers. The project will support the government’s shelter fund by piloting a public-private partnership (PPP) structure and will provide industrial housing and working women’s hostels for low-income and migrant workers. Financing will be deployed as Government of Tamil Nadu’s equity into the shelter fund, which may be provided as catalytic first loss capital instrument. The shelter fund would leverage the Government of Tamil Nadu equity (including the loan proceeds from ADB that would be injected as equity into the fund) to attract private sector investment into specific special purpose vehicles (SPVs) that would be established to deliver affordable housing for working women and industrial workers.

6. Component 3: Regional Planning. The project will support regional planning that integrates existing and proposed development plans and makes provisions for economic development and affordable housing to balance growth throughout the State with regard to infrastructure development, environmental protection, and disaster risk management.4

B. Subproject Scope and Location 7. Tamil Nadu Slum Clearance Board (TNSCB) have taken initiatives to relocate vulnerable communities living alongside the water bodies across the state. In Karaikudi Taluk of Sivaganga District, TNSCB has identified 10 locations (refer Error! Reference source not found.2 and Figure 1) where the vulnerable communities are living under high risk due to the flooding of water bodies. Accordingly, a screening survey has been conducted and the number of households that would be affected were identified. It was estimated to relocate 900 households (refer Appendix 1) to a safe location. However, the actual number of households being affected will be assessed after the social survey. This draft IEE will be updated following this and submitted to ADB for final review and disclosure. 8. Based on the land availability (preferably government land) in Karaikudi Taluk, the TNSCB has selected Kalanivasal site (Geo-coordinates: 10°5'39.80"N, 78°45'21.19"E) as a potential resettlement site. Upon clearance of the old settlement sites/ encroachment sites, adequate measures shall be taken to prevent any encroachment and the water body catchment area shall be restored.

Table 2: Encroachment Sites Identified for Relocation

Sl. No. Location No. of

Households Geo-coordinates

1 Malaikadukanmai 11 10°4'45.55"N 78°45'49.71"E

2 ChellamchettiOorani 33 10°4'44.24"N 78°45'37.88"E

3 ThangachiOorani 58 10°3'23.50"N 78°45'50.99"E

4 VaithOorani 38 10°3'42.67"N 78°46'47.12"E

5 KilakuOorani 51 10°5'5.39"N 78°45'55.45"E

6 Veeraiyan Kanmai 576 10°3'22.92"N 78°46'15.79"E

7 Athi thiravadia kanmai 6 10°4'44.24"N 78°45'37.88"E

8 Kurchi Kanmai 66 10°4'0.65"N 78°46'35.42"E

9 Kudikatha Nenthai kanmai 4 10°2'46.93"N 78°46'5.96"E

10 Vaduku Oorani 57 10°5'10.36"N 78°45'50.08"E

TOTAL 900 Source: TNSCB

4 Land use regulation plays an important part in determining the pattern of service land and housing occupation in

urban areas. It should be ensured that housing is provided where it is needed, rather than supporting segregation (for example at the periphery of cities) is critical in policy. Policy should provide diversity of housing at scale, typology, and price.

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Figure 1: Map Showing Sites Chosen for Relocation and Resettlement

9. Subproject Selection Criteria. As per the Asian Development Bank (ADB) Safeguard Policy Statement (SPS) 2009 and prevailing rules and regulations, the subproject selection criteria have been prepared and included in the Environmental Assessment and Review Framework (EARF), which shall act as a guideline for subproject selection. The following table highlights the environmental guidelines for subproject selection.

Table 3: Environmental Guidelines for Subproject Selection under Output 1 Guidelines for Subproject Selection Remarks

I. All Subprojects including supporting services

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Guidelines for Subproject Selection Remarks

Complies with key exclusion criteria5 The subproject activities proposed at the resettlement site (Kalanivasal), 10 encroachment sites that are proposed to be demolished and the water bodies proposed for renovation comply with the key exclusion criteria.

Complies with ADB SPS 2009, EARF and the national and state legal and regulatory framework

The subproject activities proposed at the resettlement site, 10 encroachment sites and the water bodies comply with ADB SPS, 2009, EARF and the national and state legal and regulatory framework.

The primary environmental criteria for selecting subproject sites to be relocated is vulnerability to flooding of targeted non-titled project beneficiaries without tenure security residing in encroachments (i.e., water bodies / waterways). No new development sites in flood areas, areas with a history of flooding or areas zoned for coastal protection

Since the 10 encroachment sites to be demolished are located in encroached land of water bodies (tanks/ponds), they are vulnerable to flooding. The resettlement site has no history of flooding and it is not prone to flooding.

The selected subprojects (new development / resettlement sites) should have sufficient land for the accommodation of all project beneficiaries / resettled households and community members in line with housing space and design ratio considerations.

It is estimated to demolish 900 dwelling units in 10 encroachment sites and it is proposed to construct 900 residential units, which is more than actual requirement. The buildings are designed in line with housing space and design ratio considerations based on the TNSCB guidelines.

The selected subprojects (new development / resettlement sites) should be within one-hour travel time on public transport from existing encroachments such that project beneficiaries / resettled households and community members have continued access to livelihood generation activities.

The selected resettlement site (Kalanivasal) is within 5 km aerial distance from all the existing settlement sites except Kudikatha Nenthal Kanmai (5.4 km) and within one-hour travel time on public transport from all existing settlement sites.

The selected subprojects (new development / resettlement sites) should be within a 2.5 km radius of public amenities or be within prescribed social infrastructure access norms.

Public amenities are located within 2.5km radius of the resettlement site. The existing public amenities along with distance have been depicted in the Error! Reference source not found..

The selected subprojects (new development / resettlement sites) are greenfield; therefore,

The residential units are designed as per the building norms adopted by the TNSCB and they are located near

5 Subproject Exclusion Criteria: 1. Environment Category A subprojects. 2. No subprojects to be located within 10 km of a national park, sanctuary, wetland, mangroves, coastal zones,

backwaters, recognized biodiversity hotspots and/or within reserved forests, village forests, protected forests. 3. Subprojects that involve activities in the ADB Prohibited Investment Activities List (ADB SPS, 2009, Appendix 5). 4. Subprojects that are highly complex and sensitive. 5. Subprojects that are category A or have adverse impacts on indigenous people safeguards. 6. Subprojects which result in significant adverse impacts on any sensitive natural and human receptors e.g., species

or habitat of high conservation value, significant number of trees of economic value (such as fruit bearing trees), water bodies (such as wetlands, backwaters, rivers, lakes or ponds), existing host communities / neighbourhoods, schools and/or Physical Cultural Resources (PCRs).

7. Subprojects in unsafe proximity of existing electricity substations, high voltage transmission lines, underground cables, solid waste dumping yards, Oil /Gas pipelines, Coastal Regulatory Zone hazard line and/or polluting (heavy emissions / noisy) industrial activities.

8. Subproject sites in flood prone areas, areas with a history of flooding. 9. Subprojects that are not technically, financially, or economically viable.

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opportunity should be taken to ensure that these are connected to existing neighbourhoods / host communities, provide comprehensive infrastructure and supporting services, generate new optimally sited open spaces of adequate size, and community spaces.

an existing neighbourhood. All required infrastructure and supporting services are proposed at the resettlement site. As per the proposed design, green belt is 15.93% and Open space reserve is 10.30% that is in compliance to the subproject selection criteria of open space / green zone equivalent to 10 to 25 percent of total area.

The selected subprojects should have access to or include supporting services (within the scope of the EARF) at new development / resettlement sites for project beneficiaries / resettled households and community members for better environmental outcome.

The resettlement site (Kalanivasal) is proposed to have the following infrastructure facilities:



• Green belt (15.93%)

• Bus Bay

• Open Space Reserve (OSR) (10.30%)

• Sewage Treatment Plant

• Parking area

• Seating Gazebo


• Market

• Ration Shops

• Anganwadi

• Livelihood Center

• Library




• Badminton court

• Outdoor Gym






• Outdoor Gym


• Pretend Pay

• Play park

• Tactile Play

• Flexi Play

• Community Hall

• Milk Booth Health Sub CentreCurrently there are no supporting services present at the site. Hence EHS audit in line with the ADB SPS is not required.

If there is no access to supporting services, then the subproject shall integrate supporting services in the subproject detailed engineering design for the new development / resettlement sites and for any other housing plans under consideration in the immediate vicinity of new resettlement sites.

Resettlement of project beneficiaries shall only take place after all supporting services are available and operational at new development / resettlement sites.

As per the TNSCB policy, the resettlement process shall start only after completion of the construction activities (including all the amenities/ infrastructure facilities). Before resettlement, appropriate meaningful consultation shall be conducted.

Subprojects will conform to land use classification and relevant development control regulations and municipality approved master plan. Subprojects (new development /

Land use classification of the resettlement site is mixed residential (Refer Appendix 2).

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resettlement sites) not covered by the master plan will require further due diligence for consideration for subproject selection as long as it meets the key exclusion criteria and prescribes to the environmental guidelines for subproject selection.

Will not involve the use or installation of hazardous materials including asbestos, PCBs, lead based paint

The implementation of the subproject C-EMP ensures that Asbestos, Mercury, PCBs and lead based paints are not used in this project. This includes asbestos cement, gaskets, lead pipe and solder, fluorescent tubes etc. The contractor shall prepare SOPs for each material if potentially exposing workers to asbestos, PCB’s and lead.

No new construction of landfills will be supported under this sector loan

There is no proposal for new landfill sites. The municipal solid waste shall be collected and disposed Sangarapuram Panchayat.

No new electricity generation / electricity high voltage transmission line and distribution substations will be supported under this sector loan

Electricity shall be provided by Tamil Nadu Electricity Board (TNEB).

Subprojects will need to utilize water sources at sustainable levels of abstraction only (i.e., without significant reductions in the quantity or quality of the source overall), avoid polluted water sources, avoid water use conflicts by not abstracting water that is used for other purposes and ensure water quality provided complies with national drinking water standards at all times through regular monitoring.

During the construction phase, the contractor has been requested to procure water from the TWAD or the ULB, who is following various methods / procedures for groundwater recharge. During operation phase, water will be supplied by the TWAD to the resettlement site. The required quantity of water (640KLD) will be sourced from the Sakkottai Master Storage Reservoir (MSR), which is located at a distance of 7km from the Kalanivasal resettlement site. In the Feasibility Study Report on the source sustainability, which is submitted by the TWAD, it is was declared that surplus water will be supplied to the resettlement site. Hence there will not be any conflicts. The supplied water shall meet the drinking water standard IS 10500. Hence the implementation of this subproject will not have significant impact on the available water sources. Based on the findings from the final water source sustainability study, this IEE has to be updated.

Subprojects should locate sewerage treatment plants as far as possible from inhabited areas, ensure sewerage is treated to national wastewater discharge standards, ensure no discharge of wastewater occur where it could be a hazard to downstream users and include measures for the safe disposal of sewage sludge.

It is proposed to install Sewage Treatment Plant (STP) for 0.6MLD capacity, the STP is designed to have the latest SBR technology to treat the sewage to the required disposal standard (PART A as per schedule VI of Environmental Protection Rules 1986) as stipulated by the CPCB. The treated sewage water shall be utilised for landscaping purpose as well as for RWH purposes. The STP is fitted with a Sludge digester which will treat sludge to reduce any pathogens level for safer disposal along with the organic waste to the authorized MSW disposal facility. The discharge of excess treated water from the STP will be through an underground drain located approximately 450m from the Kalanivasal resettlement site.

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II. Demolition works for all subprojects

Demolition works at encroachments will

• exclude religious structures e.g., chapels, temples, mosques, etc.; and if cannot exclude, then replace or compensate for the religious structures in consultation with the relevant stakeholders

• involve clearance and fencing

• avoid cutting of trees

• avoid disturbance to PCRs

• repair any structure that has been inadvertently damaged

• fencing around the water body perimeter or along channel banks6

The EMP prepared for the demolishing works shall be implemented to minimise the impacts, further details shall be addressed in the subproject specific Social Impact Assessment (SIA) / Resettlement Action Plan (RAP). Retaining of the Physical Cultural Resources (PCRs) or shifting of the PCRs shall be based on public consultation.

III. Regeneration works for all subprojects

Regeneration works7 at cleared encroachments will include at a minimum

• re-greening / revegetation of banks along water bodies / channels,


The final plan for regeneration of the water bodies will be decided by the concerned ULBs with potential TNSCB input. However, based on the activities required for water body regeneration works, an EMP has been prepared and included in this IEE, which shall assist the ULBs in minimising the impacts during regeneration works. The IEE and EMP will need to be updated once detailed design is available and the relevant EMP will have to be adopted by the contractor. TNSCB will retain responsibility for clearing the site after demolition and fencing in coordination with relevant agencies. These impacts are covered under the EMP prepared for demolition works.

6 Fencing to ensure that re-encroachment of cleared spaces does not revert back to slums and is kept as green open

space to realise ecological and public benefits from the cleared and restored waterways. 7 Regeneration works of the cleared encroachments will be undertaken such that it does not revert back to slums and

is kept as green open space to realize ecological and public benefits from the cleared and restored waterways.

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Figure 2: Map Showing Exiting Public Amenities around the Resettlement Site

C. Purpose/ Objectives of IEE8 10. ADB requires the consideration of environmental issues in all aspects of the Bank’s operations, and the requirements for environmental assessment are described in ADB’s Safeguard Policy Statement (SPS), 2009. The potential environmental impacts of the subproject have been assessed using ADB rapid environmental assessment checklist for Urban Development Projects (Appendix 3). The potential negative impacts were then identified in relation to (i) pre-construction, construction and operation of the Resettlement Site (Housing Project), (ii) demolition of the structures in the relocated sites and (iii) restoration of water bodies in the relocated sites. The results of the assessment shows that the subproject is unlikely to cause significant adverse impacts that are irreversible, diverse or unprecedented. Thus, this initial environmental examination (IEE) has been prepared in accordance with the EARF and ADB SPS, 2009 requirements for environment category B projects. 11. This IEE is based on the Detailed Project Report (DPR) prepared by Tamil Nadu Slum Clearance Board (TNSCB). The IEE is based mainly on field reconnaissance surveys and secondary sources of information. No baseline environmental monitoring was conducted to prepare the IEE. However, the environmental monitoring program developed as part of the Environmental Management Plan (EMP) will require the contractor to establish the baseline environmental conditions prior to commencement of civil works. The results of which will be reported in the final IEE as part of the revision of the baseline environmental section and also as part of the environmental monitoring report. It will be the basis to ensure no degradation will happen during subproject implementation. Stakeholders consultation is an integral part of the IEE, due to the ongoing COVID-19 pandemic, planned stakeholders consultation has not been

8 This IEE is based on the preliminary detailed design for the construction of the resettlement site and demolishing &

fencing works proposed for the relocated slum / encroachment sites. Hence this IEE have to be updated once the detailed design has been completed for both the subproject components (including resettlement site and demolishing and fencing works at slum / encroachment sites).

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conducted and hence, there is a need to undertake further stakeholders consultation, when it is safe to do so. D. Report Structure 12. This report contains the following 10 sections including the Executive Summary at the beginning of the report:

(i) Executive summary (ii) Introduction (iii) Policy, Legal, and Administrative Framework (iv) Description of the Subproject (v) Description of the Environment (Baseline Data) (vi) Analysis of Alternatives (vii) Anticipated Environmental Impacts and Mitigation Measures (viii) Information Disclosure, Consultation and Participation (ix) Grievance Redress Mechanism (x) Environmental Management Plan (xi) Conclusion and Recommendation

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II. POLICY, LEGAL AND ADMINISTRATIVE FRAMEWORK

A. ADB Safeguard Policy Statement (2009)

13. ADB requires the consideration of environmental issues in all aspects of ADB’s operations, and the requirements for environmental assessment are described in ADB SPS, 2009. This states that ADB requires an environmental assessment of all ADB investments. 14. Screening and Categorization: The nature of the environmental assessment required for a project depends on the significance of its environmental impacts, which are related to the type and location of the project; the sensitivity, scale, nature and magnitude of its potential impacts; the availability of cost-effective mitigation measures. Projects are screened for their expected environmental impacts and are assigned to one of the following four categories.

(i) Category A. a proposed project is classified as category ‘A’ if it is likely to have significant adverse environmental impacts that are irreversible, diverse, or unprecedented. These impacts may affect an area larger than the sites or facilities subject to physical works. An Environmental Impact Assessment (EIA) is required.

(ii) Category B. a proposed project is classified as category ‘B’ if its potentially adverse environmental impacts are less adverse than those of category ‘A’ projects. These impacts are site-specific, few of them are irreversible, and in most cases, mitigation measures can be designed more readily than for category ‘A’ projects. An Initial Environmental Examination (IEE) is required.

(iii) Category C. a proposed project is classified as category ‘C’ if it is likely to have minimal or no adverse environmental impacts. No environmental assessment is required although environmental implications need to be reviewed.

(iv) Category FI. a proposed project is classified as category ‘FI’ if it involves an investment of ADB funds to or through a Financial Intermediary (FI). An Environmental and Social Management System (ESMS) is required.

15. Analysis of Alternatives. The best fit option should be identified for the implementation of the project in terms of location, design, technology and/or components that would avoid, and, if avoidance is not possible, minimize adverse environmental impacts and risks. 16. Anticipated Adverse Impact Mitigation and Management. When the potentially significant adverse impacts and risks cannot be avoided or prevented, appropriate mitigation measures and management actions have to be identified so that the project / subprojects are designed, constructed, and operated in compliance with ADB SPS, 2009. 17. Environmental Management Plan (EMP): An EMP, which addresses the potential impacts and risks identified by the environmental assessment, shall be prepared. The level of detail and complexity of the EMP and the priority of the identified measures and actions will be commensurate with the project’s impact and risks. 18. Public Consultation. Carry out meaningful consultation with affected persons and facilitate their informed participation. Ensure women’s participation in consultation. Involve stakeholders, including affected persons and concerned NGOs, early in the project preparation process and ensure that their views and concerns are made known and understood by decision makers and taken into account.

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19. Grievance Redress Mechanism (GRM). Establish a grievance redress mechanism (GRM) to receive and facilitate resolution of the affected person’s concerns and grievances regarding the project’s environmental performance. 20. Public Disclosure: ADB will post the safeguard documents on its website as well as disclose relevant information in an accessible manner in local communities:

(i) Final or updated IEE upon receipt; and (ii) Environmental monitoring reports submitted by the implementing agency during project

implementation upon receipt. 21. The ADB guidelines, stipulate addressing environmental concerns, if any, of a proposed activity in the initial stages of project preparation. For this, the ADB Guidelines categorizes the proposed components into categories (A, B or C) to determine the level of environmental assessment required to address the potential impacts. This subproject under the IRSHUPSP has been categorized as “B” and accordingly this IEE has been prepared to address the potential impacts, in line with the recommended EARF/ IEE content and structure for Category “B” projects. B. National and State Environmental Regulations 22. Environmental assessment. Government of India EIA Notification of 2006 (replacing the EIA Notification of 1994) sets out the requirement for Environmental Assessment in India. This states that Environmental Clearance is required for specified activities/projects, and this must be obtained before any construction work or land preparation (except land acquisition) may commence. Projects are categorized as ‘A’ or ‘B’ depending on the scale of the project and the nature of its impacts.

(i) Category A projects require Environmental Clearance from the central Ministry of Environment, Forests and Climate Change (MoEF&CC). The proponent is required to provide preliminary details of the project in the prescribed manner with all requisite details, after which an Expert Appraisal Committee (EAC) of the MoEF&CC prepares comprehensive Terms of Reference (TOR) for the EIA study. On completion of the study and review of the report by the EAC, MoEF&CC considers the recommendation of the EAC and provides the Environmental Clearance if appropriate.

(ii) Category B projects require environmental clearance from the State Environment Impact Assessment Authority (SEIAA). The state-level EAC categorizes the project as either B1 (requiring EIA study) or B2 (no EIA study) and prepares TOR for B1 projects within 60 days. On completion of the study and review of the report by the EAC, the SEIAA issues the Environmental Clearance based on the EAC recommendation. The Notification also provides that any project or activity classified as category “B” will be treated as category “A” if it is located in whole or in part within 10 km from the boundary of protected areas, critically polluted areas, eco-sensitive areas or interstate or international boundaries.

23. The subproject involves construction of 900 residential units at Kalanivasal. As per the DTCP approved Plan, residential units with three types of floor plans with average plinth area (including common area) of 37.67 m2 are proposed to be constructed in eight types of blocks. Total plinth area of the proposed residential units is 8603.49 m2. Total Built-up area of the residential buildings is 34,413.96 m2 and the total built-up area of other amenities is 1791.58 m2. Total built-up area of buildings at the resettlement site is 38,258.94 m2, which is less than the

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stipulated area (1,50,000 m2) for the projects mandating EIA. Hence, the proposed project is classified as Category B2 and it does not warrant an EIA study. However, Environmental Clearance (EC) is required from the SEIAA.

Table 4: Environmental Regulatory Compliance for Kalanivasal Subproject Law, Policy, Regulation

Description Requirement

Environmental Impact Assessment Notification, 2006

The Notification imposes restrictions and prohibitions on new projects or activities and also on the expansion or modernization of existing projects or activities based on their potential environmental impacts.

As per the EIA notification, this subproject is categorised as B2 and mandated Environmental clearance from SEIAA is necessary (Refer Appendix 4).

ADB’s Safeguard Policy Statement 2009

Categorization of project components into A, B or C and developing required level of environmental assessment for each component.

This project has been “Categorized as B and accordingly this IEE has been prepared “

Central Ground Water Authority Notification, 1997

It provides for regulation and control of ground water development and management

Permission for the extraction of Groundwater from Central Groundwater Board (CGWB)

The Environment Protection Act, 1986 The Environment Protection Rules, 1986

Emissions and discharges from the facilities to be created or refurbished or augmented shall comply with the notified standards

To comply with applicable notified standards (including Water Act 1974, Air Act 1981 and acts relating to Biological Diversity)

Water (Prevention and Control of Pollution) Act of 1974, Rules of 1975, and amendments

Act was enacted to provide for the prevention and control of water pollution and the maintaining or restoring of wholesomeness of water. Control of water pollution is achieved through administering conditions imposed in consent issued under to this Act. All pollution potential activities will require consent to establish (CtE) from Tamil Nadu Pollution Control Board (TNPCB) before starting implementation and consent to operate (CtO) before commissioning.

To obtain CtE and CtO prior to the start of construction for (i) hot mix plant /batching plant; (ii) construction (workers) camps and (iii) proposed STP Compliance to the conditions and effluent disposal standards stipulated in CtE and CtO

Air (Prevention and Control of Pollution) Act, 1981, amended 1987 and its Rules, 1982.

The Act was enacted to achieve prevention, control and abatement of air pollution activities by assigning regulatory powers to CPCB and SPCB’s for all such functions. Establishes ambient air quality standards

To obtain CtE and CtO prior to the start of construction for (i) diesel generators; (ii) hot mix units / batching units; (iii) vehicles emitting air pollutants and (iv) construction (works) camps. Compliance to conditions and emissions standards stipulated in the CtE and CtO.

Noise Pollution (Regulation and Control) Rules, 2000 and further amended

It provides for regulations to control ambient noise levels in public places from sources such as industries/ construction works/ community events, etc.

To comply with the noise standards (refer Table 8).

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Law, Policy, Regulation


The Hazardous Wastes (Management, Handling and Transboundary Movement) Rules, 2008

It provides for regulation and control of indiscriminate disposal of Hazardous waste; and its sound management to reduce risks to environmental and human health

Applicable for the subproject if it deals with generation/ handling/ storage/ processing of hazardous waste which should take cognizance of the provisions/schedules of these Rules and obtain authorization from the TNSPCB.

Municipal Solid Waste Management Rules, 2016

Rules to manage municipal solid waste generated; provides rules for segregation, storage, collection, processing and disposal.

Solid waste generated at the proposed facilities / construction camps / housing units shall be managed and disposed in accordance with the MSW Rules

Construction and Demolition (C&D) Waste Management Rules, 2016

Rules to manage construction and waste resulting from construction, re-modelling, repair and demolition of civil structure. Rules define C&D waste as comprising of building materials, debris resulting from demolition / re-modelling or repairs

Construction and demolition waste generated due to civil works at subproject construction site and/or demolition of existing civil structures at encroached areas shall be managed and disposed as per these Rules

The Ancient Monuments and Archaeological Sites and Remains Act, 1958, and the rules, 1959

Provide guidance for carrying out activities, including conservation, construction and reuse in and around the protected monuments.

Not applicable. The subproject site is not close to any of the archeological / protected monuments

Tamil Nadu State Ground Water (Development and Management) Act, 2003

This Act is to protect groundwater resources and provide safeguards against groundwater overexploitation, and to ensure its planned development and management; notifies areas for development, regulation and control of groundwater; prohibits digging of wells and groundwater transport in notified areas without prior permission of the designated authority; requires all wells to be registered.

Groundwater abstraction in any of the notified areas will be subject to the provisions of this Act.

Labor Laws The contractor shall not make employment decisions based upon personal characteristics unrelated to job requirements. The contractor shall base the employment relationship upon equal opportunity and fair treatment and shall not discriminate with respect to aspects of the employment relationship, including recruitment and hiring, compensation (including wages and benefits), working conditions and terms of employment or retirement, and discipline.

Appendix 5 provides applicable labor laws including amendments issued from time to time applicable to establishments engaged in construction of civil works, which will need to be followed by the subproject.

http://asi.nic.in/pdf_data/6.pdf




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Law, Policy, Regulation


The contractor shall provide equal wages and benefits to men and women for work of equal value or type.

Minimum Wages Act, 1948

The employer is supposed to pay not less than the minimum wages fixed by appropriate government agency as per the provisions of this Act if the employment is a “scheduled employment” such as construction of Roads, Runways, and Buildings.

All construction / operation and maintenance workers should be paid not less than the stipulated wages under this Act.

Equal Remuneration Act, 1979

The Act provides for payment of equal wages for work of equal nature to male and female workers and for not making discrimination against genders.

Inter-State Migrant Workmen (Regulation of Employment and Conditions of Service) Act, 1979

Act is applicable to any establishment that employs 5 or more inter-state migrant workers through an intermediary (who has recruited workers in one state for employment at an establishment situated in another state).

Contractor for subprojects to register with the Labour Department in case of hiring of inter-state migrant workers. Adequate and appropriate amenities and facilities to be provided to workers including housing, sanitation, portable water, medical aid, traveling expenses from home to workplace, etc.

Building and Other Construction Workers (Regulation of Employment and Conditions of Service) Act, 1996

It regulates the employment and conditions of service of building and other construction workers and provides for their safety, health and welfare.

The subproject shall comply with the provisions of this Act

Tamil Nadu Minor Mineral Concession Rules, 1959 (amended up to 31 March 2001)

Applicable for sand mining, quarrying and borrow areas

All projects/activities being implemented and/or funded under the sector loan shall take cognizance and comply with the provisions of this Act

Tamil Nadu Protection of Tanks and Eviction of Encroachments Act, 2007

An Act to provide measures for checking the encroachment, eviction of encroachment in tanks which are under the control and management of Public Works Department, protection of such tanks and for matters incidental thereto.

Cleaning of encroachments / regeneration works

Tamil Nadu Building and Other Construction Workers’ (Regulation of Employment and Conditions of Service) Act, 1996 and Rules, 2006

Regulates the employment and conditions of service of building and other construction workers and to provide for their safety, health and welfare measures; Provides various benefits for the registered workers

The subproject shall comply with the provisions of this Act

Source: MoEF&CC, CPCB, Government of Tamil Nadu

15

24. Clearance/Permissions to be obtained by the Project Management Unit (PMU). The following table depicts the statutory clearances/permissions (but not limited to) for the use of land, providing public utility services to the resettlement site. The PMU shall verify and support PIDs to ensure all necessary clearances/permission have been obtained prior to the start of construction. Any condition given as part of the clearance/permission should be complied and accordingly the IEE (including the EMP) should be updated.

Table 5: Clearances and Permissions Required by the PMU for Project Construction Sl. no

Permission/ Clearances/ Declaration

Competent Authority

Remarks Status Reference

1. Environmental Clearance as per the EIA notification 2006

State Environment Impact Assessment Authority (SEIAA)

As per the EIA notification, this subproject is categorised as B2 and mandates Environmental clearance from SEIAA is necessary

Obtained Appendix 4

2. Confirmation on the encroachments located in the water bodies

Karakudi Municipal Office

The Commissioner Karakudi Municipality have declared/ confirmed that the slums have been encroached in the water bodies

Obtained Appendix 6

3. Permission for Land Transfer to TNSCB

Collector office Sivagangai District

Land Transfer to TNSCB has been issued by the Collector office, Sivagangai District. This also includes change in land use pattern/ land use classification.

Obtained Appendix 2

4. Certification for the resettlement site (Encumbrance free site)

Karakudi Taluk Office

Certificate has been issued by the Karakudi Taluk officer for” Enter Upon” into the resettlement site as well as encumbrance free assurance for the site.

Obtained Appendix 6

5. Confirmation letter from the Tamil Nadu Electricity Board (TNEB)

TNEB, Karakudi

TNEB has accepted the request from TNSCB, provided with some condition for installation of sub stations etc.,

Obtained Appendix 7

6. Confirmation letter from Taluk office on the flood situation in the encroachment sites


The Karakudi Taluk Office has issued the certificate by confirming that the 10 encroachment sites identified for relocation suffers from seasonal flood

Obtained Appendix 8

7. Land Transfer certificate


Land transfer certificate has been issued by the karakudi Taluk Office to TNSCB

Obtained Appendix 9

16

Sl. no


Competent Authority


8. Certificate indicating the Kalanivasal site is not vulnerable for flooding

Tahsildhar, Karaikudi

Tahsildhar Karaikudi has issued certificate by indicating the Kalanivasal resettlement site is not prone to flooding

Obtained Appendix 10

9. Acceptance letter for collection of Municipal Solid Waste

Sangarapuram Panchayat office

Sangarapuram Panchayat office has accepted for collection and transportation of Municipal Solid Waste generated from Kalanivasal Resettlement site.


10. Permission letter for discharge of treated sewage

Sangarapuram Panchayat office

Sangarapuram Panchayat office has given permission for discharge of treated sewage into the nearest Underground Drain (UGD)


11. Tamil Nadu Water Supply and Drainage Board (TWAD) acceptance/ acknowledge for the supply of water to Kalanivasal resettlement site

TWAD TWAD has confirmed the supply of water to the Kalanivasal Resettlement site. The acknowledgement for the same has been included in the Appendix 13. Once detailed design for this associated activity is available a revised IEE and subsequent EMP for this activity should be submitted to ADB for concurrence.


12. Confirmation for Collection and disposal of Sludge generated from STP installed at Kalanivasal Resettlement site

Karaikudi Municipality

Confirmation letter indicating that Karaikudi Municipality will undertake the collection and disposal of sludge generated from the STP.


13. Submission of Compliance Matrix for the EC conditions

SEIAA/ TNPCB Compliance matrix for the requested General conditions and Specific conditions have been prepared by the TNSCB, which will be submitted to the SEIAA/ TNPCB. Any comments/ changes given by the SEIAA/ TNPCB have to be incorporated in the modified compliance matrix and accordingly it has to be included in the IEE and relevant EMP.

Prepared and ready for submission

Appendix 15

17

Sl. no


Competent Authority


14. + Source sustainability study for supply of water to the Kalanivasal resettlement site

TWAD Study on the source sustainability has been conducted by TWAD to balance water demand against water source availability. The study includes testing the water quality

Ongoing Appendix 13

25. Other Environmental Clearance conditions requirements. TNSCB will have to obtain approval for the STP design by an Independent approved third party or by an independent expert / reputed Academic institution for its adequacy and a report in this regard should be submitted to the SEIAA and incorporated into the IEE before contract award or commencement of construction. 26. Clearances/permissions to be obtained by the Contractor. Following table shows the list of clearances/permissions (but not limited to) required for project construction. The contractor should ascertain the requirements prior to start of the construction and obtain all necessary clearances/permission prior to start of construction.

Table 6: Clearances and Permissions Required by the Contractor for Project Construction

Sl.no Construction Activity

Statutory Authority

Statute under which Clearance is Required

Implementation

Supervision

1. Tree Cutting District Revenue Department

Clearances from the authorities as per the Tamil Nadu Timber Transit Rules, 1968 or latest.

PID PMU

2. Batching plants, Crushers and Hot mix plants

Tamil Nadu Pollution Control Board (TNPCB)

Consent to establish and consent to operate under Air Act, 1981

Contractor PID

3. Discharges from Construction activities

TNPCB Consent to establish and consent to operate under Water Act, 1974

Contractor PID

4. Storage, handling and transport of hazardous materials

TNPCB Hazardous Wastes (Management and Handling) Rules. 1989 Manufacturing, Storage and Import of Hazardous Chemicals Rules, 1989

Contractor PID

5. Sand mining, quarries and borrow areas

Department of Geology and Mining, Government of Tamil Nadu

Contractor to obtain material from the existing government licensed mines/quarries; Contractor will require prior approval of PID for obtaining material from

Contractor PID

18

Sl.no Construction Activity

Statutory Authority

Statute under which Clearance is Required

Implementation

Supervision

a particular source. PID to review and approve only existing licensed mines

6. Groundwater extraction

Public Works Department

Tamil Nadu Groundwater Development and Management Act 2000

Contractor PID

7. Disposal of Construction and Demolition waste

TNPCB Construction and Demolition (C&D) Waste Management Rules, 2016

Contractor PID

Source: MoEF&CC, CPCB, Govt of Tamil Nadu

C. Applicable International Standards and Best Practices

27. During the design, construction and operation of the project the PMU and Project Implementation Divisions (PIDs) will apply pollution prevention and control technologies and practices consistent with international good practice, as reflected in internationally recognized standards such as the International Finance Corporation’s (IFC) Environmental, Health and Safety (EHS) Guidelines Guidance Notes and standards of the World Health Organization (WHO). These standards contain performance levels and measures that are normally acceptable and applicable to projects. When Government of India regulations differ from these levels and measures, the PMU and PIDs will achieve whichever is more stringent. If less stringent levels or measures are appropriate in view of specific project circumstances, the PMU and PIDs will provide full and detailed justification for any proposed alternatives that are consistent with the requirements presented in ADB SPS, 2009. 28. The following IFC (World Bank Group) EHS and WHO Guidelines will be adopted in the EMP for the subprojects such as:

(i) WHO Guidelines on Air Emissions and Ambient Air Quality, Noise Management, Wastewater and Ambient Water Quality,

(ii) Guidelines for Construction and Decommissioning (2007) (iii) Guidelines for Hazardous Material Management and Waste Management (iv) Good Practice Note: Asbestos: Occupational and Community Health Issues, May

2009 (v) Guidance Note on Workers Accommodation: Processes and Standards, August

20069 (vi) Guidelines on Occupational Health and Safety and Community Health and Safety

(2007)

29. Comparison of national emissions standards and International Standards / Best Practices are provided in Table 7, Table 8 and Table 9. Due to different measuring conditions, the emission values are not directly comparable. However, IFC Guidelines / WHO standards are stricter than the national standards if converted to comparable values.

9 IFC Guidance Note: Workers Accommodation

https://www.ifc.org/wps/wcm/connect/topics_ext_content/ifc_external_corporate_site/sustainability-at-ifc/publications/publications_gpn_workersaccommodation

19

Table 7: National Ambient Air Quality Standards and WHO Guidelines WHO Air Quality Guidelines National (µg/m3)

Applicable Per Ambient Air Global

Location a

Quality Update Second ADB SPS Parameter Standards b 2005 c Edition 2000 d (µg/m3) e

Particulate Industrial 60 (Annual) 20 (Annual) - 20 (Annual)

Matter PM10 Residential, Rural and Other Areas 100 (24-hr) 50 (24-hr) 50 (24-hr)

(µg/m3) Sensitive Area 60 (Annual) 20 (Annual) - 20 (Annual) 100 (24-hr) 50 (24-hr) 50 (24-hr)

Particulate Industrial 40 (Annual) 10 (Annual) - 10 (Annual)

Matter PM2.5 Residential, Rural and Other Areas 60 (24-hr) 25 (24-hr) 25 (24-hr)

(µg/m3) Sensitive Area 40 (Annual) 10 (Annual) 10 (Annual) 60 (24-hr) 25 (24-hr) 25 (24-hr)

Sulfur Industrial 50 (Annual) 20 (24-hr) - 50 (Annual)

Dioxide SO2 Residential, Rural and Other Areas 80 (24-hr) 500 (10-min)

20 (24-hr) 500 (10-min)

(µg/m3) Sensitive Area 20 (Annual) 20 (24-hr) - 20 (Annual) 80 (24-hr) 500 (10-min) 20 (24-hr) 500 (10-min)

Nitrogen Industrial 40 (Annual) 40 (Annual) - 40 (Annual)

Dioxide NO2 Residential, Rural and Other Areas 80 (24-hr) 200 (1-hr)

80 (24-hr) 200 (1-hr)

(µg/m3) Sensitive Area 30 (Annual) 40 (Annual) - 30 (Annual) 80 (24-hr) 200 (1-hr) 80 (24-hr) 200 (1-hr)

Carbon Industrial 2,000 (8-hr) - 10,000 (8-hr) 2,000 (8-hr)

Monoxide CO Residential, Rural and Other Areas

4,000 (1-hr) 100,000 (15-min)

4,000 (1-hr) 100,000 (15-min)

(µg/m3) Sensitive Area 2,000 (8-hr) - 10,000 (8-hr) 2,000 (8-hr) 4,000 (1-hr) 100,000 (15-min) 4,000 (1-hr) 100,000 (15-min)

Ozone Industrial 100 (8-hr) 100 (8-hr) - 100 (8-hr)

(O3) (µg/m3) Residential, Rural and Other Areas 180 (1-hr) 180 (1-hr)

Sensitive Area 100 (8-hr) 100 (8-hr) - 100 (8-hr) 180 (1-hr) 180 (1-hr)

Lead (Pb) Industrial, 0.5 (Annual) - 0.5 (Annual) 0.5 (Annual)

(µg/m3) Residential, Rural and Other Areas 1.0 (24-hr) 1.0 (24-hr)

Sensitive Area 0.5 (Annual) - 0.5 (Annual) 0.5 (Annual)

1.0 (24-hr) 1.0 (24-hr)

Ammonia Industrial 100 (Annual) - 100 (Annual)

(NH3) Residential, Rural and 400 (24-hr) 400 (24-hr)

(µg/m3) Other Areas

Sensitive Area 100 (Annual) - - 100 (Annual) 400 (24-hr) 400 (24-hr)

Benzene Industrial 5 (Annual) - - 5 (Annual)

(C6H6) (µg/m3) Residential, Rural and Other Areas

20

WHO Air Quality Guidelines National (µg/m3)

Applicable Per Ambient Air Global

Location a

Quality Update Second ADB SPS Parameter Standards b 2005 c Edition 2000 d (µg/m3) e

Sensitive Area 5 (Annual) - - 5 (Annual)

Benzo(o) Industrial 1 (Annual) - - 1 (Annual)

Pyrene (BaP) Residential, Rural and Other Areas

(ng/m3) Sensitive Area 1 (Annual) - - 1 (Annual)

Arsenic Industrial 6 (Annual) - - 6 (Annual)

(As) (ng/m3) Residential, Rural and Other Areas

Sensitive Area 60 (Annual) - - 60 (Annual)

Nickel (Ni) Industrial 20 (Annual) - - 20 (Annual)

(ng/m3) Residential, Rural and Other Areas

Sensitive Area 20 (Annual) - - 20 (Annual) a Sensitive area refers to Ecologically sensitive areas notified by the India Central Government

b http://cpcb.nic.in/uploads/National_Ambient_Air_Quality_Standards.pdf

c WHO Air quality guidelines for particulate matter, ozone, nitrogen dioxide and sulfur dioxide. Global update 2005. WHO. 2006.

d Air Quality Guidelines for Europe Second Edition. WHO 2000.

e As per ADB SPS, the government shall achieve whichever of the ambient air quality standards is more stringent. If less stringent levels or measures are appropriate in view of specific project circumstances, the executing agency of the government will provide full and detailed justification for any proposed alternatives that are consistent with the

requirements presented in ADB SPS.

Table 8: National Noise Standards and WHO Guidelines

Noise Level WHO Guidelines Value

For Noise Levels Measured Applicable Per

Standards a Out of Doors b ADB SPS c

Receptor/ (dBA) (One Hour LAeq in dBA) (dBA)

Source Day Night 07:00 – 22:00 22:00 – 07:00 Day time Night time

Industrial area 75 70 70 70 70 70

Commercial area 65 55 65 55

Residential Area 55 45 55 45 55 45

Silent Zone 50 40 50 40 a Noise Pollution (Regulation and Control) Rules, 2002 as amended up to 2010 (http://cpcb.nic.in/displaypdf.php?id=Tm9pc2UtU3RhbmRhcmRzL25vaXNlX3J1bGVzXzIwMDAucGRm) b Guidelines for Community Noise. WHO. 1999. c As per ADB SPS, the project proponent shall achieve whichever of the ambient air quality standards is more stringent.

If less stringent levels or measures are appropriate in view of specific project circumstances, the project proponent will provide full and detailed justification for any proposed alternatives that are consistent with the requirements presented in ADB SPS, 2009.

Table 9: National Drinking Water Quality Standards and WHO Guidelines National Standards for Drinking Water a, b WHO Guidelines

for Drinking Water Quality, 4th

Edition, 2011c Applicable Per ADB SPS d, e Group Parameter Unit

Max. Concentration

Limit

Physical Turbidity NTU 1 (5) - 1 (5)

pH 6.5 – 8.5 None 6.5 – 8.5

Color Hazen Units 5 (15) None 5 (15)

Taste and Agreeable - Agreeable

http://cpcb.nic.in/uploads/National_Ambient_Air_Quality_Standards.pdf

https://asiandevbank-my.sharepoint.com/personal/cliau_adb_org/Documents/Project/Tamil%20Nadu%20Housing/Interdeparmental%20Review%20RRP/After%20Joanna's%20review/(http:/cpcb.nic.in/displaypdf.php?id=Tm9pc2UtU3RhbmRhcmRzL25vaXNlX3J1bGVzXzIwMDAucGRm)

21

National Standards for Drinking Water a, b WHO Guidelines for Drinking Water

Quality, 4th Edition, 2011c

Applicable Per ADB SPS d, e Group Parameter Unit

Max. Concentration

Limit

Odor

TDS mg/l 500 (2,000) - 500 (2,000)

Iron mg/l 0.3 - 0.3

Manganese mg/l 0.1 (0.3) - 0.1 (0.3)

Arsenic mg/l 0.01 (0.05) 0.01 0.01

Cadmium mg/l 0.003 0.003 0.003

Chromium mg/l 0.05 0.05 0.05

Cyanide mg/l 0.05 None 0.05

Fluoride mg/l 1 (1.5) 1.5 1 (1.5)

Lead mg/l 0.01 0.01 0.01

Ammonia mg/l 0.5 none established 0.5

Chemical Chloride mg/l 250 (1,000) none established 250 (1,000)

Barium mg/l 0.7 None 0.7

Sulphate mg/l 200 (400) None 200 (400)

Nitrate mg/l 45 50 45

Copper mg/l 0.05 (1.5) 2 0.05 (1.5)

Total mg/l 200 (600) - 200 (600)

Hardness

Calcium mg/l 75 (200) - 75 (200)

Zinc mg/l 5 (15) none established 5 (15)

Mercury mg/l 0.001 0.006 0.001

Aluminum mg/l 0.1 (0.3) none established 0.1 (0.3)

Anionic mg/l 0.2 (1.0) None 0.2 (1.0)

Detergents

Phenolic mg/l 0.001(0.002) None 0.001(0.002)

Compounds

Residual mg/l 0.2 5 0.2

Chlorine

Microbial E-coli MPN/100ml Must not be detectable in any 100 ml sample

Must not be detectable in any 100 ml sample

Must not be detectable in any 100 ml Sample indicator Total Coliform MPN/100ml

a http://cgwb.gov.in/Documents/WQ-standards.pdf. b Bureau of India Standard 10500: 2012 (Indian Standard, Drinking Water — Specification (Second Revision). c Health-based guideline values. d As per ADB SPS, the government shall achieve whichever of the drinking quality standards is more stringent. If less

stringent levels or measures are appropriate in view of specific project circumstances, the executing agency of the government will provide full and detailed justification for any proposed alternatives that are consistent with the requirements presented in ADB SPS, 2009.

e Figures in parenthesis are maximum limits allowed in the absence of alternate source.

30. Effluent Discharge Standards for Sewage Treatment Plants set by Central Pollution Control Board, Ministry of Environment, Forests and Climate Change, Government of India, Dated 15th April 2015 are provided in Appendix 15 of EARF. 31. The Guidelines for Reuse of STP effluent and sludge are provided in Appendix 16 of EARF. 32. The Central Pollution Control Board notifications and guidelines for operation of DG sets (that may be used for supporting services) are available at: https://cpcb.nic.in/genset-notifications/

http://cgwb.gov.in/Documents/WQ-standards.pdf.

https://cpcb.nic.in/genset-notifications/

22

33. Core Labor Standards. ADB is committed to due consideration of Core Labor Standards (CLS) in the design and implementation of subprojects. A CLS handbook has been developed by ADB with cooperation of International Labor Organization (ILO). The TNSCB PMU will ensure compliance to applicable CLS of ADB-ILO during project implementation including:

(i) Freedom of association and the effective recognition of the right to collective bargaining

(ii) Elimination of all forms of forced or compulsory labor (iii) Effective abolition of child labor (iv) Elimination of discrimination in respect of employment and occupation

D. International Treaties/Conventions/Declarations on Environment Management

34. India is a signatory to the following international treaties/ conventions/ declarations on environment, social, safety and occupational issues that are relevant for the subproject. The list of international agreements is provided in Table 10.

Table 10: International Treaties/ Conventions/ Declarations on Environment Sl. no

International Treaties/ Conventions/ Declarations

Description

1. United Nations Conference on the Human Environment - Stockholm 1972

To coordinate global efforts to promote sustainability and safeguard the natural environment

2. Convention on International Trade in Endangered Species of Wild Fauna and Flora (CITES), 1975

Its aim is to ensure that international trade in specimen of wild animals and plants does not threaten their survival

3. Ramsar Convention, 1971, 1975 The Convention on Wetlands is the intergovernmental treaty that provides the framework for the conservation and wise use of wetlands and their resources

4. The Basel Convention on the Control of Transboundary Movements of Hazardous Wastes, 1989

The Convention aims to protect human health and the environment against the adverse effects resulting from the generation, transboundary movements and management of hazardous wastes and other wastes

5. Strategic Approach to International Chemicals Management (SAICM)

SAICM is an international non-binding policy framework to support efforts to achieve the Johannesburg Plan of Implementation (WSSD) goal for chemicals, notably “achieve by 2020 that chemicals are used & produced in ways that lead to the minimization of adverse effects on human health & the environment”

6. United Nations Conference on Environment and Development (UNCED), 1992, 2002

The conference had three objectives (Agenda – 21, Rio Declaration and Millennium Development Goals), to secure renewed political commitment for sustainable development, to assess the progress and implementation gaps in meeting previous commitments, and to address new and emerging challenges

7. United Nations Framework Convention on Climate Change (UNFCCC), 1992

• Kyoto Protocol, 1997

It operationalizes the United Nations Framework Convention on Climate Change by committing industrialized countries to limit and reduce greenhouse gases (GHG) emissions in accordance with agreed individual targets

23

Sl. no

International Treaties/ Conventions/ Declarations

Description

8. The Vienna Convention, 1985

• Montreal Protocol on Ozone depleting substances, 1992

It sets binding progressive phase out obligations for developed and developing countries for all the major ozone depleting substances, including chlorofluorocarbons (CFCs), halons and less damaging transitional chemicals such as hydrochlorofluorocarbons (HCFCs)

9. Convention on Biological Diversity, 1992

• Cartagena Protocol on Biosafety, Ratified on 17th January, 2003

It is an international treaty governing the movement of living modified organism (LMO) resulting from modern biotechnology from one country to another

10. Convention to Combat Desertification, 1996

It is the only binding international agreement linking environment and development to sustainable soil management

11. Rotterdam Convention on Prior Informed Consent Procedure for certain Hazardous Chemicals in International Trade, 2002

It is a multilateral treaty to promote shared responsibilities in relation to importation of hazardous chemicals

12. Stockholm Convention on Persistent Organic Pollutants (POPs), 2001

It aims to eliminate or restrict the production and use of Persistent Organic Pollutants (POPs)

24

III. DESCRIPTION OF THE PROJECT

A. Subproject Overview 35. The subproject will be in implemented in Karaikudi Taluk of Sivaganga District where TNSCB has identified 10 encroachment sites located around 10 tanks/ponds that are vulnerable to flooding. Based on the land availability (preferably government land) in Karaikudi Taluk, TNSCB has identified Kalanivasal (10°5'39.80"N, 78°45'21.19"E) in Karaikudi Taluk as a resettlement site. Coordinates of the 10 encroachment sites are presented in Table 2 in Chapter 1. 36. Figure 3 shows the map of the locations of 10 encroachment sites chosen for relocation, and location of the resettlement site at Kalanivasal. Area within 10 km radius of the resettlement site is also shown in the map. There are no environmental sensitive areas including protected areas, eco sensitive zones or ecologically sensitive areas notified by the MoEF&CC located within 10 km radius of the resettlement site.

Figure 3: Subproject Sites and Area within 10 km Radius from the Resettlement Site

37. The selection of sites was based on the following ADB EARF screening criteria:

25

(i) Key Exclusion Criteria. Kalanivasal resettlement site, 10 encroachment sites and 10 water bodies (proposed for regeneration) are not falling under the exclusion criteria as suggested in the EARF. (a) None of the subproject activities (construction, demolition and

regeneration) are falling under the Environmental category “A” (b) The subproject areas are not located within the 10km radius national park,

sanctuary, wetland, mangrove reserve, biodiversity hotspot, reserve or protected forest area and CRZ zone.

(c) The subproject is not falling under the ADB Prohibited Investment Activities List (ADB SPS, 2009, Appendix 5)

(d) The subproject is not highly complex and sensitive10 (e) The subproject activities do not affect the PCRs e.g., local heritage sites /

archaeological sites,11 places of worship, etc., (f) The subproject is not located near electricity substations, high voltage

transmission lines, underground cables, solid waste dumping yards, Oil /Gas pipelines, Coastal Regulatory Zone hazard line and/or polluting (heavy emissions / noisy) industrial activities

(g) Subproject sites are in flood prone areas, areas with a history of flooding.

(ii) Environmental guidelines for Subproject Selection criteria. The subproject activities including the Construction, Demolishing and Regeneration of water bodies are as per the following environmental guidelines for subproject selection criteria: (a) The encroachment sites chosen for relocation are vulnerable for flooding

and occupied by the slum dwellers (b) The resettlement site proposed at Kalanivasal will host 900 dwelling units

for the 900 HH to be evicted from the 10 encroachment sites, which is sufficient to accommodate project beneficiaries / resettled households and community members in line with housing space and design ratio considerations

(c) New site should be within one-hour travel time on public transport from existing settlement sites / encroachments). The resettlement site at Kalanivasal meets this criterion. Figure 1 in Chapter 1 shows that the resettlement site is located within 5 km from the sites chosen for relocation and they are well connected by roads. Hence the travel time will be less than 1 hr.

(d) New site should be within a 2.5 km radius of public amenities or be within prescribed social infrastructure access norms. The resettlement site at Kalanivasal meets this criterion. The existing public amenities around the resettlement site have been depicted in Error! Reference source not found. in Chapter 1.

(e) The subproject is designed to have 10% OSR and 15% green belt area

10 Projects that ADB deems as highly risky or contentious or involve serious and multidimensional and generally

interrelated potential social and/or environmental impacts. 11 ASI clarification is requested for the ancient wall like structure located near to the encroachment site. Based on the

recommendations/ suggestions care shall be taken to preserve the wall from damages.

26

(f) New site should provide comprehensive infrastructure and supporting services, generate new optimally sited open spaces of adequate size, and community spaces including space for training and community enterprise.

(g) Kalanivasal resettlement site is in conformation to the land use classification, relevant development control regulations and DTCP approved master plan

(h) No new construction of Landfills, electricity generation/ electricity high voltage transmission line and distribution substations are proposed under this subproject

(i) Water source sustainability is maintained through supply of water by TWAD and the quality of the water is as per the IS 10500 (drinking water standard),

(j) 0.6 MLD capacity Sewage Treatment Plant is proposed to treat the sewage generated from the Kalanivasal resettlement site, the treated water shall be utilised for gardening, rainwater harvesting and excess treated water shall discharged through an underground drain. The sludge generated in the STP shall be further digested to remove the pathogens and the dried sludge will be disposed along with the organic waste in the Karaikudi Municipality MSW disposal facility

(k) Demolition works at 10 encroachment sites will

• exclude religious structures e.g., chapels, temples, mosques, etc.;

• involve clearance and fencing around the water body / canal banks12

• avoid cutting of trees

• avoid disturbance to PCRs

• repair any structure that has been inadvertently damaged

(l) Regeneration works at cleared encroachments includes

• re-greening / re-vegetation along water body / canal banks


• implementation of site-specific plans in close coordination with ULBs or Public Works Department (PWD) e.g. waste management plan, sewerage collection and management plan, etc.

• Restoration of water bodies that were encroached.

• provision for public parks/ recreation areas as per the community’s requirement

• avenue plantation/ landscaping

38. The scope of this subproject covers (i) construction, operation and maintenance of 900 residential units and associated facilities at the resettlement site at Kalanivasal; (ii) demolition of 900 structures located in 10 encroachment sites have been identified for relocation to Kalanivasal; and (iii) restoration of 10 water bodies, which were encroached by the people needs to be relocated.

12 Fencing to ensure that re-encroachment of cleared spaces does not and to derive public benefits from the cleared

and restored waterways.

27

B. Proposed Subproject Interventions at the Resettlement Site 39. Salient Features of the resettlement site are presented in Table 11. Photograph of the resettlement site is presented as Figure 4.

Table 11: Salient Features of the Kalanivasal Resettlement Site Features Description

Plinth Area 34,413.96 m2

Built-up Area 36,205.54 m2

Total Housing / Residential Units

900

Total Occupancy 4950 persons

Administration area The proposed resettlement site falls in Kalanivasal Village in Karaikudi Taluk of Sivaganga District

Topography Site is located on plain land

Road Connectivity It is well connected to NH 210 and located at a distance of 5 km from Karaikudi bus stand.

Site nearby North side of the site is a residential area, east side is Aavin dairy farm, and south and west sides are open lands.

Distance from resettlement site to encroachment sites

All the encroachment sites proposed for relocation to this new resettlement site are located at a distance of 5 km except one site which is located at 5.4 km (refer Figure 1).

Environmental sensitivity

No sensitive natural or human receptors in close proximity to the proposed relocation site.

Electricity TNEB have confirmed to provide electricity to the Kalanivasal resettlement site for which 10 transformers will be provided within the resettlement site

Health facilities Primary health care center is located at a distance of 1.8 km.

Water supply Water supply is proposed to be provided by Tamil Nadu Water Supply and Drainage (TWAD) Board. The estimated water demand of 600KLD will be sourced from Sakkottai Master Storage Reservoir (MSR), which is located at a distance of 7 km from the Kalanivasal resettlement site.

Rainwater Harvesting Structures

As per the regulatory requirements, rooftop rainwater harvesting has been proposed for all the blocks. [. Accordingly, TNSCB have designed 19 RWH structures/pits and with rainwater harvesting trenches in the project area. Through this 34.5 lakh litres of rainwater shall be collected.

Wastewater treatment

0.6 MLD STP will be constructed within the resettlement site for treating wastewater (grey water and black water) generated from the resettlement site. It is proposed to have Sequencing Batch Reactors (SBR) for treating wastewater. SBR is a variant of Activated Sludge Process (ASP) technology and is essentially a batch treatment through the combination of primary settling, aeration, secondary settling and decanting the treated sewage in a series of sequences. The treated wastewater quality will meet the requirement of the CPCB wastewater discharge standard. The treated water will be utilised for flushing, landscaping purposes and for groundwater recharge. The remaining excess treated water shall be used to recharge the groundwater through via the rainwater harvesting pits and structures and supplied to the village panchayath (if needed) or it shall be disposed to the nearby Underground Drain (UGD).

Solid waste management

Sangarapuram Panchayat have agreed to provide Municipal Solid Waste (MSW) collection, transportation and disposal to the existing solid waste dumping site, which is owned and operated by the panchayat, for which a dedicated location will be provided for collection of MSW generated within the resettlement site. Segregation of waste at source will be adopted.

Treated Sewage Discharge

Sangarapuram Panchayat have agreed to discharge the treated sewage into the nearest underground drain (UGD).

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Features Description

STP sludge management

It is proposed to have sludge digester tank (anaerobic sludge digestion) in the STP to digest the sludge into dry sludge for further disposal. The treated sludge shall be stored in the sludge drying bed and when it reaches its full capacity, it shall be disposed along with the organic waste in the Karaikudi Municipality MSW disposal facility, which will cause no harm to the surrounding environment.

29

Figure 4: Photograph of the Resettlement Site

40. The number of families to be relocated is 900 (refer Table 2), however, as a buffer to accommodate more families under unavoidable circumstances, 19 blocks of G+3 Structures with 900 residential units has been proposed. Residential units with three types of floor plans with average plinth area (including common area) of 37.67 m2 are proposed to be constructed in eight types of blocks (block type A through H). Total plinth area13 of the proposed residential units is 8603.49 m2. Total Built-up area14 of the residential buildings is 34,413.96 m2 and the total built-up area of other amenities is 1,791.58 m2. Total built-up area of buildings at the resettlement site is 36,205.54 m2. Plinth area details of the residential units are presented in Table 12 and built-up area details of the buildings at the resettlement site are presented in Table 13.

Table 12: Plinth Area Details of Proposed Residential Units at the Resettlement Site

Block Type No. of

Units per Floor

No. of Floors

No. of Blocks

Total No. of Units

Plinth Area per Unit (m2)

Plinth Area per Block

(m2)

A 11 4 7 308 38.98 12006.68

B 13 4 4 208 38.37 7980.64

C 10 4 2 80 36.45 2915.76

D 10 4 2 80 36.45 2915.76

E 18 4 1 72 38.64 2782.28

F 11 4 1 44 38.43 1691.04

G 14 4 1 56 38.02 2128.88

H 13 4 1 52 38.33 1992.92

Total 19 900 34,413.96

Plinth area shall mean the built-up covered measured at the floor level of the basement or of any storey

Source: TNSCB Layout Drawing for Kalanivasal Subproject

Table 13: Built-up Area Details of the Buildings at the Resettlement Site

Sl. No. Building Built-up Area (m2)

1 Residential Buildings 34,413.96

2 Other Amenities

2.1 Convenience shop 218.27

2.2 Ration shop 49.71

13 Plinth area shall mean the built-up covered measured at the floor level of the basement or of any storey. 14 Built-up area is the carpet area plus the thickness of outer walls and the balcony.

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Sl. No. Building Built-up Area (m2)

2.3 Anganwadi 51.78

2.4 Milk booth 67.33

2.5 Community Hall 650.86

2.6 Livelihood Center and Library 306.42

2.7 Health Sub Centre 87.72

2.8 Market 259.96

2.9 Livestock shelter 99.53 Sub Total 1,791.58

Grand Total (1+2) 36,205.54 Source: TNSCB Layout Drawing for Kalanivasal Subproject

Figure 5: Proposed Master plan of Kalanivasal Resettlement Site


31

Figure 6: Proposed Sewer Line and STP


32

Figure 7: Proposed Storm Water Drain


33

Figure 8: Proposed Water Supply Line


34

Figure 9: Proposed Green Belt Area


41. Proposed master plan for the resettlement site is shown in Figure 5 with the proposed services layout shown in Figure 6 to 9. Figure 10 indicates the proposed green belt areas. The total area of the resettlement site is estimated to be 4.48 ha with the proposed land use land allocation given in Table 14.

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Table 14: Proposed Land use of the Resettlement Area Sl. no Description Area (%) Area (m2) Area (ha)

1. Residential 19.20 8603.49 0.86

2. Internal Road 27.20 12170.20 1.22

3. Green Belt Area 15.93 7139.93 0.71

4. Open Space Reserve Area 10.30 4606.78 0.46

5. Public Purpose 24.67 11074.01 1.11

6. Space reserved for STP (including sludge drying bed)

2.70 1225.70 0.12

Total Area 100.00 44820.11 4.48 Source: TNSCB Layout Drawing for Kalanivasal Subproject

Figure 10: Green Belt Map of Kalanivasal Resettlement Site

Source: Google Earth Image

42. Based on consultations, the design requirement for the communities have been identified and accordingly TNSCB with ADB assistance have engaged consultants in the preparation of master plan for the Kalanivasal resettlement site. As per the concept master plan, the following infrastructure has been proposed at the resettlement site.

Table 15: Subproject Interventions at the Resettlement Site Sl.no Subproject Subproject Interventions

1 Construction of 900 residential units and supporting services



• Green Buffer (15.93%)

• Bus Bay

36

Sl.no Subproject Subproject Interventions

• Open Space Reserve (OSR)

• Sewage Treatment Plant (Including sludge drying bed)

• Vehicle Parking area

• Market


• Ration Shops

• Anganwadi

• Livelihood Center and Library




• Badminton court

• Outdoor Gym






• Outdoor Gym


• Pretend Pay

• Play park

• Tactile Play

• Flexi Play

• Community Hall

• Milk Booth & Anganwadi

• Health Sub Centre Source: TNSCB Layout Drawing for Kalanivasal Subproject

43. Power Requirement. The power requirement during the project construction will be met through a temporary connection from TANGEDCO by the contractor and power generators may be used as a backup unit (ranging between 5 kW to 200 kW). The generators having emission under control certificates will be permitted in the construction site. The power requirement during operation is about 1000 KW and it will be sourced from the TNEB grid (refer to Appendix 7 for Acknowledgement from TNEB for the supply of electricity to the resettlement site) via 11 kV lines and the final electrification to buildings (including residential units) will be 11/0.4 kV distribution transformers within the premises with an end user connection voltage of 240V. Street lights will be solar powered, providing an energy saving of approximately 6 kW.

Table 16: Power Requirement at the Resettlement Site Sl. no Particulars Quantity Unit

1 Residential Use

No. of residential units proposed 900 Nos.

Power requirement per residential unit (Assuming 1 kW per 1 residential unit)

900 kW

2 Pump Room

No. of Pump Rooms 4 Nos.

Power requirement for the Pump Room (Assuming 16 kW per Pump Room)

64 kW

3 STP

Power requirement for STP is in the range of 33 kW to 35 kW

35 kW

37

Sl. no Particulars Quantity Unit

4 Streetlight

No. of streetlights 20 Nos.

Power required for the streetlights (Assuming 50 W per Street Lamp)

1 kW

Total Power Requirement 1000 kW Source: Conceptual Plan, TNSCB

44. In the event of power outages, an onsite Diesel Generator (DG Set) of 80 KVA, 415V, 3 Phase, 50 Hz @ 1500 RPM will be used to support STP operation. Stack height of 2 m shall be maintained for 80 KVA DG Set as per TNPCB norms, the height of the stack should be 2 m from the height of the building (height of the building +2 m). 45. Water Requirement and Supply. The total water requirement during construction is estimated to be 100L/Day, the source of water for construction shall be arranged by the Contractor through the ULB or the TWAD. The water requirement during operation is estimated to be 640 KLD, which shall be supplied by the TWAD and relevant calculations can be found in Table 17 (Refer Appendix 13 for the commitment letter issued by the TWAD for the supply of water). The water will be sourced from Sakkottai Master Storage Reservoir (MSR), which is located at a distance of 7 km from the Kalanivasal resettlement site. 46. The wastewater generation from the project is estimated to be about 542.8 KLD, which will be treated in a proposed Sewage Treatment Plant (STP)15 with a capacity of 600 KLD. Treated wastewater will be reused for flushing and gardening. The assumptions for estimating the water requirement is given in the following table.

Table 17: Water Requirement at the Resettlement Site

S No Project Components No of Units Occupancy rate@ Total Occupancy

Nos

1 Residential 900 5 persons per unit 4500

2 Floating Population 10% of Residential 450

3 Convenience shop 10 5 persons per unit 50

4 Ration shop 1 5 persons per unit 5

5 Anganwadi 2 40 persons 80

6 Staff & Visitors 1 10% of the Total Residential population

8

7 Milk Booth 1 40 persons 40

8 Staff & Visitors 1 10% of the Total Residential population

4

9 Community hall 1 100 Persons per uni 200

10 Livelihood centre 1 75 persons per unit 150

11 Library 1 20 persons 20

12 Health Care Centre 1 5 persons per unit 5

Total 5512

As per the National Commission on Integrated Water Resources Development (NCIWRD) norms rural area shall be provided with 75 to 150 Litre Per Capita Per Day (LPCD) have been recommended for the year 2025 and 2050. For this subproject 100 lpcd has been proposed. Hence the estimated water requirement is 0.55 MLD.

5512 x 100 lcpd = 0.55 MLD

Green area Development/ landscaping

15 The technology for the STP shall be selected based the suggestions from the SEIAA. However, it is proposed to

have a STP having SBR technology.

38

S No Project Components No of Units Occupancy rate@ Total Occupancy

Nos

Actual water requirement for Gardening purpose = Area for Green belt development × 3.5 lts/Sqm = 7139.93 * 3.5lts/Sqm= 24.98 KLD= 25 KLD (Rounded)

25 KLD

Source: Conceptual Plan, TNSCB

47. The water supply for domestic purposes (640 KLD) shall be provided by TWAD Board. For the wastewater generated from the resettlement site a 600 KLD (0.6 MLD) capacity STP with SBR technology has been proposed. The SBR will have two reactors for treating wastewater. The STP process flow chart and SBR structure is given in Figure 11. Nearly 100 KLD of treated water will be used for green belt area/ landscaping purposes. From the remaining 500 KLD, nearly 35% of the treated water (after ultra-filtration) will be recycled for flushing and gardening purposes with the remaining 65% to be disposed into the rainwater harvesting pits for groundwater recharge or if the village panchayat or any industries in the surrounding area requests water for their use, it can be provided.

Figure 11: STP Process Flow Diagram and SBR Structure – Water Balance for Kalanivasal Resettlement Site

39

48. However, in discussion with the local panchayat, the requirement for usage of treated wastewater is not envisaged, hence any excess treated wastewater will be discharged into the nearest Underground Drain (UGD), which is located at a distance of 450 m from the Kalanivasal Resettlement Site (Appendix 12). 49. Rainwater Harvesting Structures. As per the Government of Tamil Nadu requirements, amendments made to Section 215 (a) of the Tamil Nadu District Municipalities Act, 1920 and Building Rules 1973, have made it mandatory to provide Rainwater Harvesting (RWH) structures in all new buildings. In view of this, and as per the conditions given by the SEIAA on the Environmental Clearance obtained for the Kalanivasal Resettlement site, TNSCB have designed 19 RWH structures/pits and with rainwater harvesting trenches in the project area. The following sections will detail the assumptions and estimations that underpin the design.

(i) Rainwater volume estimation

(a) As per the secondary information (refer Chapter 4 Description of the Environment) the project district receives annual rainfall of 904.70 mm

(b) The rainfall intensity has been estimated to be 2.47 mm /day (c) The total built-up area is worked out to be 8802.11 m2 (d) Assuming the coefficient of runoff (c) to be 0.90 for concrete surface area,

it is expected that Q=c.i.a= 0.90 x 2.47 x 8802.11= 17.25m3/day

40

50. Based on the estimated rainwater volume, 19 RWH structures / pits and 985m of rainwater trenches are proposed. The design specifications for the RWH are as follows:

(i) Rainwater Harvesting Structure. It is proposed to construct 19 RWH structure/pits with a diameter of 1.2 m (clear) and height of 2.40 m. Each residential block will be connected to the RWH structure/pit. (a) The total volume of rainwater that can be collected by a RWH structure/ pit

is estimated to be 2.71 m3, hence 19 RWH structures/ pits will collect 51.57 m3 of rainwater. The structure of the RWH is shown in the Figure 12.

Figure 12: Rainwater Harvesting Structure

(ii) Rainwater Harvesting Trenches. The resettlement site will be provided with 985m of rainwater harvesting trenches along the perimeter of the site. The trench will be 1 m wide by 1.5 m deep filled with pebbles. The volume of rainwater that can be collected in the trench is estimated to be 1477.50m3.

(iii) Paver block all-around the buildings. It is proposed to provide paver block for the walkway, parking area and surrounding the buildings above a filling of 45cm. The gaps between the paver block will not be sealed, which will allow the rainwater to percolate further into the ground. The total area of the paver block is estimated to be 4264 m2. The volume of rainwater that can be collected by this system is estimated to be 1918.80m3.

41

Table 18: Rainwater estimate Sl.no Infrastructure Quantity Volume of rainwater that can be

Collected

1. Rainwater Harvesting Structures/Pits 19 nos. 51.54 m3

2. Rainwater Harvesting Trenches 985 m 1477.50 m3

3. Paver block all-around the buildings 4264 m2 1918.80 m3

Total 3447.84 m3 = 34.5 Lakh Litres Source: TNSCB

51. Green area development/ landscaping. It is proposed to have landscaping in an area of around 7139.59 m2, which constitutes 15.93 % of the total area. The allocated green space is indicated in the Figure 9. It is estimated that 25 KLD of water is required for landscaping purposes which shall be met through the use of treated wastewater after ultra-filtration. The master plan presented in Figure 5 shows the green areas proposed at the resettlement site. 52. Solid Waste Management. Wastes generated from the households will be segregated into bio-degradable waste and non-biodegradable waste at the source itself (by the occupants) in separate bins. The wastes from such bins will be collected separately on daily basis and taken to a separate centralized collection facility by the Sangarapuram Panchayat dealing with collection and disposal of garbage (refer Appendix 11). It is also estimated to generate 165 kg of sludge waste per day from the STP. This sludge is considered a hazardous waste without treatment. Hence a sludge digester with a digestion tank will be provided in the STP. This will treat the sludge into a dry form, which will be pathogen free. A sludge drying bed with an area of 78.67 m2 has been earmarked for drying and storage of treated sludge. The treated sludge from the STP will be stored in the sludge drying bed to its maximum capacity, once the capacity is saturated, the sludge will be disposed along with the organic waste. The following table illustrates the quantity of solid waste likely to be generated during the operation phase.

Table 19: Solid Waste Generation at the Resettlement Site

S No

Project Components

Total Occupanc

y Nos

Per capita Generation (kg/day)

Total Solid waste

generation (kg/day)

Total Biodegradabl

e Waste (kg/day)

Total Non-Biodegradabl

e Waste (kg/day)

1 Residential 4500 0.6 2700 1620 1080

2 Staff & Visitors 450 0.2 90 54 36

3 Convenience shop 50 0.2 10 1.2 0.8

4 Ration shop 5 0.2 1 0.6 0.4

5 Anganvadi 80 0.2 16 4.8 3.2

6 Staff & Visitors 8 0.2 1.6 0.48 0.32

7 Milk Booth 4 0.2 0.8 4.8 3.2

9 Community hall 200 0.2 40 24 16

10 Livelihood centre 150 0.2 30 18 12

11 Library 20 0.2 4 2.4 1.6

12 Health Care Centre

5 0.2 1 0.6 0.6

13 Sludge from STP 165 165 0

Total 3059.4 1895.88 1154.12 Source: Conceptual Plan

53. Approach Road. The approach road and internal roads have been designed for 4.5 m width (two lane) which shall have earthen shoulders. The road configuration shall have sand gravel mix

42

(150 mm thickness), Grade II and III water bound macadam (WBM) of 75mm each, which is followed by 20 mm premix carpet.

Figure 13: Typical Cross Section for Approach Road and Internal Roads

54. The proposed unit plan and details with respect to the blocks and other amenities are detailed in the master plan presented as Figure 5. C. Proposed Subproject Interventions at the Encroachment Sites Identified for Relocation 55. The following table depicts the proposed interventions for the encroachment sites and the water bodies.

Table 20: Proposed interventions Sl.no Subproject Subproject Interventions

1 Demolishing structures located in the encroachment sites (prone to flooding)

• Demolishing of 900 structures located in the 10 encroachment sites

• Providing fencing to prevent further encroachment

2 Water body restoration • Clearance and fencing

• Restoration of water bodies, which were encroached

• Deepening of the ponds/ tanks to restore the water storage capacity

• Restoring the catchment area

• Provision for public parks/ recreation areas as per the community’s requirement

• Avenue plantation/ landscaping

56. Existing condition of the encroachment sites identified for relocation. All the encroachment sites identified for relocation are located around water bodies (tanks or ponds) in Karaikudi Municipality. These water bodies have been encroached. Coordinates of the encroachment sites are provided in Table 2 in Chapter 1. A survey has been conducted at all the sites identified for relocation. The observations from the sites are presented in the following table.

43

Table 21: Existing Condition of the Encroachment Sites Identified for Relocation Sl.no Location Observations Site Photographs

1. Chellam Chetti Oorani

(i) Patta (land ownership record) is not available

(ii) UGSS has been provided in the encroachment area

(iii) As per the consultation, the pond was seen last flooded in the year 1992 and 1994

(iv)

(v) Encroachers are staying for more than 40 years

(vi) Most of them are working as daily labours and housemaid workers

(vii) Government schools are located at a distance of 3km

(viii) Water supply is provided by Karaikudi municipality

(ix) Proper toilet facilities (provided with septic tank) are not available, the waste water is discharged into the pond

2. Malaikadu Kanmai

(i) Patta is not available

(ii) Desiltation/ Deepening of pond (under the Government of Tamil Nadu initiation for restoring the water bodies across all districts in Tamil Nadu state) has been observed

(iii) As per the consultation, the pond was seen flooded in the year 1992, 1994 and 2005

(iv) Encroachers are staying for more than 40 years

(v) Most of them are working as daily labours and housemaid workers

(vi) Government schools are located at a distance of 3km

(vii) Water supply is provided by the Karakudi municipality

(viii) Proper toilet facilities (provided with septic tank) are not available, the waste water is discharged into the pond

View of Chellam Chetti Pond

Enrocahments on the bank of the Pond

Desiltation/ Deepening in progress

Encroachments on the bank of the Pond

44

Sl.no Location Observations Site Photographs

3. Vadaku oorani

(i) Kodimaram Scheme (rejuvenation of surface water bodies under Government of Tamil Nadu Scheme) is under progress

(ii) Patta is not provided for the encroachers

(iii) Pucca and kutcha houses are observed

(iv) Proper approach road is available


(vi) Government schools are located at a distance of 1km


(viii) Proper toilet facilities (provided with septic tank) is observed in the site

4. Kilaku Oorani

(i) Patta is not provided for the encroachers

(ii) Pucca and kutcha houses are observed

(iii) For bathing, bathroom facilities are available at a distance of 1km from the site and it is maintained by the Karakudi Municipality

(iv) Proper approach road is available


(vi) Government schools are located at a distance of 1 to 1.5 km

View of Vadaku Oorani (Pond)


Wild vegetations growing in the Pond

Encroachments within the Pond area

45




5. Kuruchi

Kanmai (i) Patta is not available


(iii) Proper approach road is available

(iv) Most of them are working as daily labours and housemaid workers

(v) Government schools are located at a distance of 3 km

(vi) Water supply is provided by the Karakudi municipality

(vii) Proper toilet facilities (provided with septic tank) is observed in the site

6. Vaith

oorani (i) Patta is not available


(iii) Most of them are working as daily labours (construction labours) and housemaid workers


(v) Based on the consultation, it is observed that some third-party agents have sold the land

(vi) Government schools are located at a distance of 2 to 3 km

(vii) Some of the houses are provided with borewell facility. Others have to depend on the water supply from Karakudi Municipality


View of Kuruchi Kanmai (Pond)


View of Vaith Oorani (Pond)


46



7. Veeriyan Kanmai




(iv) Some of the encroachers are found to be carrying out businesses and others are working in government organisations/ departments

(v) Out of 4 outlets from the water body, 2 outlets have been completely closed due to the encroachment.

(vi) Encroachers are staying for more than 40 years

(vii) Government schools are located at a distance of 2 to 3 km

(viii) Some of the houses are provided with borewell facility. For others, they have to depend on the water supply from Karakudi Municipality

(ix) Sewage water is directly discharged in to the pond

(x) During the consultation, some of the encroachers showed their willingness to relocate, but some of them have shown their restriction for relocation

8. Kudikatha Nenthal Kanmai


(ii) Semi pucca and kutcha houses are observed

(iii) Most of the houses remain closed and only one house is occupied

(iv) Milk business is the source of income for the encroachers

(v) Encroachers are staying for more than 40 years

(vi) Government schools are located at a distance of 5 km

View of Veeriyan Kanmai (Pond)

Sewage water discharged into the Pond


View of Kudikatha Nenthal Kanmai

47


(vii) Groundwater is used for drinking and domestic purposes

(viii) The encroachers are not interested in relocating to Kalanivasal

9. Thangachi Oorani





(v) Government schools are located at a distance of 6 km

(vi) Water is supplied by the Karakudi municipality once in 3 days for 30 minutes

(vii) The encroachers are not interested in relocating to Kalanivasal

10. Athi Thitavida Kanmai





(v) Government schools are located at a distance of 2 to 3 km

(vi) Water is supplied by the Karakudi Municipality twice a week for 30 minutes

(vii) Sewage water is directly discharged in to the pond

(viii) The encroachers are not interested in relocating to Kalanivasal

Encroachments within the pond area

Consultation with the Encroachers

Wild vegetations growing in the Pond

View of Athi Thitavida Kanmai (Pond)

Sewage water discharged into the Pond

48


57. Demolition Works. The 10 encroachment sites having 900 dwelling units identified for relocation shall be demolished manually. The demolished waste shall be disposed in the location identified by the ULB. The evicted area shall be fenced and a monitoring mechanism will be in place to prevent further encroachment. Further revision in the estimated dwelling units in the encroachment sites or change in the approach toward the demolishing activities should be reflected in the IEE and accordingly the EMP also has to be revised. 58. Regeneration Works. The water bodies located within the 10 encroachment sites and its catchment area, which was encroached shall be regenerated and restored. In addition, the inlet to the water body shall be cleared of obstructions and deepening of the water body shall be done. Based on the assessment, enhancement measures like provision of walkway, recreation area, public park area, children play area shall be explored to make the water body usable to the public. The enhancement measures shall be identified based on the public consultations. 59. Climate Resilience Measures. A study on the Climate Change Risk and Vulnerability Assessment (CRVA) for the IRSHUPSP has been conducted for Climate Risks, Climate Adaptation and Climate Finance. As per the study the resettlement site (Kalanivasal) does not have physical constraints such as flooding, wildfire and tropical cyclones. This is due to the resettlement site being located away from major rivers and as the site is a dry open area that is relatively flat with little or no vegetation. As per the proposed layout, the Kalanivasal resettlement site is designed to have more open space and includes: open green area (15.93%), shaded courtyards, green buffer around the site, livestock shelters and access to water in functional courtyards which contribute to sustainable building credentials. The suggested adaptation measures or mitigation measures are as follows:

(i) Water Supply (a) Level of consumption of water may be lowered further using more water

efficient appliances, taps, and showerheads; (b) Use drought-tolerant plants to reduce the need for watering the

landscaping, increasing water efficiency; (c) Community-based messaging/campaigns to promote water efficiency; (d) To use swales and ponds on parts of the site for effective rainwater

harvesting; and (e) To incorporate natural drainage channels and lakes into storm water

management plan. (ii) Provision of green space, community farming, livestock

(a) Explore improved shading opportunities for community recreation areas, market and milk booth

(iii) Roads and pavement areas

Encroachments on the bank of the pond

49

(a) Reduce area of impermeable surfaces to minimise run-off. (b) Use of pavement materials to ensure resilience to extreme temperatures. (c) Use of permeable materials that provide additional cooling benefits.

60. Project Implementation Schedule. The construction period for Kalanivasal resettlement site is expected to take 24 months, which will be followed by 5 years of maintenance period. The expected construction schedule can be seen in Figure 14. For demolition works the scheduled time period will be 6 months and for water body regeneration works the scheduled timeframe varies with respect to the type of proposal (water body beautification, embankment strengthening, restoring the catchment area etc.), from the ULB or Municipality. However, based on standard routine activities for water body regeneration works it is expected to take between 6 months to 12 months.

Figure 14: Construction Schedule Bar Chart

50

IV. DESCRIPTION OF THE ENVIRONMENT (BASELINE DATA)

A. Area of impact 61. The primary areas of impact are (i) sites for proposed project components; (ii) main routes/intersections which will be traversed by construction vehicles; and (iii) quarries and borrow pits as sources of construction materials. The secondary areas of impact are: (i) other than the delineated primary impact area; and (ii) new resettlement site (Kalanivasal). B. Methodology used for environment baseline study 62. Data collection and stakeholder consultations. Data for this study has been primarily collected through comprehensive literature survey, discussion with TNSCB, and field visits to the proposed subproject sites. The literature survey has broadly covered the following:

(i) Project details, reports, maps and other documents prepared by TNSCB; (ii) Discussions with technical experts of the ADB team, TNSCB, and other relevant

government agencies; (iii) Secondary data from project reports and published articles; and (iv) Literature on land use, soil, geology, hydrology, climate, socioeconomic profiles,

and other planning documents collected from government agencies and websites.

63. Ocular inspection. Several visits to the project sites were made during IEE preparation to assess the existing environment (physical, biological, and socioeconomic) and gather information with regard to the proposed sites and scale of the proposed project. A separate socioeconomic study was conducted to determine the demographic information, existing service levels, stakeholder needs and priorities. C. Physical Environment

1. Location, Area and Connectivity

64. The Kalanivasal resettlement site is located in Kalanivasal Village of Karaikudi Taluk in Sivaganga District in Tamil Nadu. The geo coordinates of Kalanivasal subproject site are 10°5'39.80"N and 78°45'21.19"E. It falls under the Sankarapuram Panchayat jurisdiction, in the outskirts of Karaikudi Town. The resettlement site is surrounded by NGO colony (50m for the resettlement site) in the North direction, Aavin Milk processing unit (100m from the resettlement site) in the East direction, Ram nagar (300 m from the resettlement site) in the south direction and vacant land/ area in the west direction. The 10 encroachment sites identified for relocation are located within the boundaries of Karaikudi Municipality. Except Kudikatha Nenthal Kanmai, all other encroachment sites are located in the residential areas. All the encroachment sites to be relocated except one are located within 5 km from the resettlement site. One encroachment site is located at a distance of 5.4 km from the resettlement site. Coordinates of the encroachment sites are given in Table 2 in Chapter 1. Total area of the resettlement site is 44820.11 m2 (4.48 ha). The land is owned by Government of Tamil Nadu. None of the construction sites, including Kalanivasal resettlement site and all 10 encroachment sites are located near or in the vicinity to the heritage buildings. 65. The resettlement site is well connected to other areas via National Highway 210 (Tiruchirappalli to Ramanathapuram); other interior access roads also connect the Resettlement site with Karaikudi Town. The encroachment sites to be relocated are located within the Karaikudi

51

Town and hence well connected by road network. Karaikudi town bus stand is located 5 km from the resettlement site. Nearest railways station to the resettlement site is Kottaiyur, at a distance of 3.85 km. Karaikudi Junction railway station is 7.1 km away from the resettlement site. Nearest airport is at Tiruchirappalli, 80 km away.

Figure 15: Locations of the Subproject Sites

2. Topography, Soils and Geology

66. Sivaganga district is a semi-arid zone with a flat and plain terrain. It is mostly covered with dense rocks and scrubs distributed unevenly throughout the open lands. The resettlement site at Kalanivasal is located in plain land. The maximum elevation is at 97 m AMSL and the minimum elevation is 94 m AMSL (as illustrated in Figure 16). There is a gentle slope from north end of the site towards the south end with a height difference of just 3 m over a distance of 300 m. Hence, cut and fill is not envisaged. All of the 10 encroachment sites proposed to be relocated are located in plain terrain.

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67. The predominant rock and soil types in Sivaganga district are granite, alluvium, laterite, shale, sandstone, and charnockite rocks and lateritic, alluvial & black, red soils. The rock and soil type at the resettlement site and 10 encroachment sites is laterite with the exception of one encroachment site (Kudikatha Nenthal Kanmai) that is located in coastal alluvial soil type area. Laterite soils are low in fertility, acidic poor in organic matter, nitrogen, phosphate and calcium and rich in iron oxide and potash.

Figure 16: Elevation Profile for the Resettlement site at Kalanivasal

3. Climate and Rainfall

68. The Sivaganga district generally has a spell of hot climate. The district experiences sunshine and moderate high temperature through the year with exception of low temperature in January with lowest mean daily temperature of 17ºC. Average maximum temperature is about 34.2ºC and average minimum temperature is about 23.7ºC. Average Annual Temperature is 28.9ºC. The hottest month in the district is May during which period the maximum temperature is 40.2ºC. Sivaganga district experiences extreme humidity of 79% at the start of the north east monsoon period. After this, the humidity declines and remains in the range of 63-67%. 69. Sivaganga District lies in the rainfall receiving region of the State. The district receives normal, annual rainfall of 905 mm. Most of the rainfall occurs in its monsoon period of October to December and rest of the year it remains in a dry state with very less rain.

Table 22: Rainfall Information for Sivaganga District

Season Month Normal Rainfall (Rounded to

nearest mm)

Winter January - February 45

Hot Weather March - May 136

South West Monsoon June - September 310

North East Monsoon October - December 414

Total 905 Source: Sivaganga District Disaster Management Plan

Table 23: Monthly Rainfall of Sivaganga District (in mm) during 2004 - 2013 Month 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013

JAN 0.0 0.0 20.5 1.4 0.9 1.4 4.1 6.0 5.7 13.2

FEB 0.0 24.10 0.0 4.1 51.0 0.0 0.0 11.7 0.3 46.0

MAR 6.3 28.5 70.2 1.3 255.9 0.6 0.0 3.1 2.4 52.7

APR 30.6 144.7 61.2 83.2 43.8 74.4 21.3 67.4 30.4 0.6

MAY 156.0 89.6 52.7 90.0 21.1 48.10 93.5 35.9 68.5 78.3

JUN 22.1 30.3 57.7 93.3 66.4 19.10 76.8 15.6 6.0 34.2

JUL 50.40 78.3 19.2 19.7 66.3 13.50 91.9 122.6 51.8 21.0

AUG 51.80 79.3 68.2 115.2 147.8 149.5 82.0 88.7 83.4 177.9

SEP 292.9 75.8 95.0 45.3 52.3 151.4 245.3 140.7 87.3 36.3

OCT 281.6 310.7 257.3 117.7 246.5 34.30 203.8 248.0 258.4 146.5

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Month 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013

NOV 182.5 258.8 239.6 101.0 166.8 315.4 236.3 256.7 35.3 57.3

DEC 29.0 169.1 24.3 214.4 59.0 90.40 98.5 22.3 9.5 60.8

Total 1104 1289.20

965.9 886.6 1176.8

898.1 1153.50

1018.70

639.0 724.8

Source: EIA Report of UGSS to Karaikudi Municipality, TWAD Board, January 2020

Figure 17: Average Annual Rainfall of Karaikudi

Source: EIA Report of UGSS to Karaikudi Municipality, TWAD Board, January 2020

70. In Sivaganga district, the wind speed is normal throughout the year ranging between 3 to 5 km/hr.

4. Seismicity

71. Bureau of Indian Standards, based on the past seismic history, grouped the country into four seismic zones, viz. Zone-II, -III, -IV and –V. Of these, Zone V is the most seismically active region, while Zone II is the least. Kalanivasal resettlement site and the 10 encroachment sites to be relocated are located in Low Damage Risk Zone II and as per the Modified Mercalli (MM) intensity scale, which measures the impact of the earthquakes on the surface of the earth, the project region is in MSK VI or less which indicates low intensity.

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Figure 18: Subproject Area in Seismic Zones Map of South India

5. Landuse

72. The landuse pattern of the subproject area (Kalanivasal resettlement site and encroachment sites to be relocated in Karaikudi Municipality) has been assessed using Bhuvan16 landuse map (refer to Figure 19). The encroachment sites are located in urban built-up area. The resettlement site is located in fallow agriculture land. However, the depicted imagery is based on the topo sheets prepared in the 1970’s, due to the rapid urbanisation, the changes in landuse may not be updated. As per the government land records the resettlement site is classified as government dry land (indicating no vegetation is possible). Further investigations were made via Google earth which can be seen in Figure 19, which shows that there are some built up areas surrounding the site but overall, it is empty clear land.

16 Bhuvan, is an Indian web-based utility which allows users to explore a set of map-based content prepared by Indian

Space Research Organisation.

Subproject

Area

INDIA

55

Figure 19: Landuse Pattern (Bhuvan Landuse map and Google earth image) of the Subproject Area

6. Drainage System

73. Besides River Vaigai, the other small rivers in Sivaganga district are Uppar, Manimuthar, Virusuliyar, Saruganiyar, Thennar, Palar, Kottakariyar, and Pambar which runs across the gentle slopes of the district and merge in Bay of Bengal. Out of nine rivers, the Thennar River originates from the streams flowing along the west side of Karaikudi town. It acts as a main drain in the project area. There is an artesian aquifer with natural springs known as Sambai Ootru located on the western side of Karaikudi town. The water flowing from this area is stored in many ponds connected by channels and these channels gradually become larger and form the Thennar River at the south side of Karaikudi town. It flows towards the east and joins the Bay of Bengal. There are no natural drainage system available in the resettlement site as well as in the 10 encroachment sites. However, the resettlement site has a gentle slope towards the southern

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direction where an irrigation tank is located at a distance of 950m. The runoff from the resettlement site shall have a natural flow towards the water body. In the encroachment sites, due to the presence of the structures (dwelling units), the catchment area of the water bodies has been affected.

7. Surface Water

74. There are no major lakes or reservoirs in Sivaganga district. There are 1451 major tanks (ponds) in the district. Besides this, nearly 2928 minor tanks are also available in the district, which forms the major source of water, collected from rain. There are no protected surface water bodies with the project area of influence. An irrigation tank is located at a distance of 950 m from the resettlement site. There are numerous tanks in and around Karaikudi Municipality and they are prone to pollution due to sewage and industrial discharges. The Central Pollution Control Board had tested the water quality of five tanks near Karaikudi Municipality in 2015 in connection with a case in the National Green Tribunal (NGT) regarding the water pollution in Karaikudi Municipality. The test results are presented in the following Table.

Table 24: Surface Water Quality in Karaikudi, 2015

Sl. No

Parameters (all in mg/L, except

pH and EC)

Sampling Locations (Tanks) Surface Water

Quality Standards*

Periya Kanmai

Athalai Kanmai

Shekarathi Kanamai

Karaikudi Kanamai

Sambai Ootru

1 pH 9.9 7.2 6.7 7.2 7.5 6.5 – 8.5

2 Electrical Conductivity (EC), µs/cm

6400 3330 209 1440 807 -

3 TDS 4444 2136 112 800 500 1500

4 BOD 513 - - 48 05 3

5 COD 1600 214 28 115 91 -

6 Alkalinity 1980 624 112 376 144 -

7 Total Hardness 57 336 74 222 212 -

8 Calcium 4 102 10.8 78 52.4 -

9 Magnesium 11.4 19.7 11.4 6.6 19.7 -

10 Chloride 188 245 7.8 229 143 600

11 Fluoride 2.3 0.71 0.13 0.87 0.76 1.5

12 Sulphate 1426 670 01 21 29 400

13 Sodium 1400 500 6 143 75 -

14 Potassium 16 20 7 24 6.7 -

15 Nitrate - - 0.3 3.02 0.02 50

16 Nitrite - - 0.22 0.03 0.03 -

17 Sulphide 5.3 0.6 0.03 2.04 0.2 -

18 Sodium % 97.5 75.1 13.6 55.2 42.5 -

19 SAR 80.7 11.9 0.3 4.2 2.2 -

* IS:2296 Class C (Inland surface water suitable for drinking after conventional treatment followed by disinfection)

75. In its report submitted to NGT, CPCB has stated that as seen in the above table, pH, TDS, BOD, COD, alkalinity and sulphate contents were high in Periya Kanmai which is located at the back side of Tamil Nadu Chemical Products Limited (TCP) and the contamination is due to the discharge of effluents from TCP. TCP is involved in manufacturing sodium hydrosulphite. Based on the secondary information (regarding the surface water quality) it is evident that none of the surface water bodies in Karakudi municipality are being used for domestic purposes. The water supply provided by the municipality may be a reason for the communities not using the surface

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water bodies as a result the maintenance of the of these surface water bodies have been neglected. Hence the surface water bodies including tanks and ponds have deteriorated and it is not in usable condition.

8. Groundwater

76. The important aquifer systems in Sivaganga district are created by Sandstone, Alluvium and weathered and fractured Granite and Charnockite. Pre- monsoon depth to water level is 1.18 to 10.10 m below ground level (bgl) and post- monsoon depth to water level is 0.86 to 18.25 m bgl. The water table in Karaikudi is generally at 0.91 to 1.83 m depth and rises to nearly 1 m below the ground level during rainy seasons. Based on the secondary information obtained from CGWB, it is observed that the groundwater is suitable for drinking and domestic uses in respect of all constituents except in and around Chettinadu (Karaikudi). About 50% samples are having concentration of NO3 more than the permissible limit set by Bureau of Indian Standards (BIS) for drinking water. 77. As per the information collected from the National Remote Sensing Centre (BHUVAN), Kalanivasal subproject site falls under ground water scarce area. This is depicted in Figure 20. Rainwater harvesting structures are proposed to be constructed for groundwater recharging at the resettlement site.

Figure 20: Groundwater Prospects for the Subproject Area

78. Borewells made in an artesian aquifer with natural springs known as Sambai Ootru located on the western side of Karaikudi town is the main source of drinking water supply for Karaikudi Municipality. Industrial pollution in Karaikudi is fast ruining the water quality in the region. One resident of Karaikudi approached the National Green Tribunal (NGT) in 2013 with a complaint regarding the pollution of Sambai Ootru and in its order dated 26 April 2016,17 the NGT directed that Karaikudi Municipality and all other surrounding Panchayats shall take all necessary steps to prevent untreated sewage water to enter in to the water body and the Municipality shall maintain

17http://www.indiaenvironmentportal.org.in/files/drinking%20water%20pollution%20Karaikudi%20Sivagangai%20NGT

%20order.pdf

https://en.wikipedia.org/wiki/Water_table

http://www.indiaenvironmentportal.org.in/files/drinking%20water%20pollution%20Karaikudi%20Sivagangai%20NGT%20order.pdf

http://www.indiaenvironmentportal.org.in/files/drinking%20water%20pollution%20Karaikudi%20Sivagangai%20NGT%20order.pdf

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the quality of water and the same shall be checked up periodically with the assistance of Pollution Control Board to maintain the drinking water standard. Water quality of borewell owned by Karaikudi Municipality in Sambai Ootru located 1.78 km from the resettlement site was tested by the Pollution Control Board in 2015 in connection with the case in NGT and it is presented in the following table. It shows that the water is slightly acidic and apart from that all other parameters are within the drinking water specification (IS 10500: 1991).

Table 25: Groundwater Quality in Karaikudi, 2015

Sl.no Parameters Units Results* BIS standard (IS 10500:1991)

1 pH - 5.28 6.5 to 8.5

2 Total Dissolved Solids mg/L 404 500

3 Chlorides mg/L 136 250

4 Sulphates mg/L 41 200

5 Total Alkalinity mg/L 104 200

6 Total Hardness mg/L 212 300

7 Nitrate Nitrogen mg/L 11.41 45

8 Fluoride mg/L 0.13 1 *Water sample from borewell owned by Karaikudi Municipality at Sambai Ootru tested by TNPCB

79. Though there are instructions in place from the NGT to Karaikudi Municipality and the surrounding Panchayats to prevent the entry of untreated sewage into the water bodies, the improvement on the water bodies is not evident. Through the implementation of this subproject, the encroached areas surrounding the water bodies will be evacuated and the untreated sewage from the toilets will be prevented. This is expected to have a positive impact on the water sources including the surface water as well as the groundwater (due to the proposed rainwater recharge). 80. The groundwater quality tested by the TNSCB using a third party at Kalanivasal resettlement site has been given in the following table (Refer Appendix 16). The observation shows that all the parameters are well within the IS 10500 standard for drinking water standard.

Table 26: Groundwater Quality Tested by the TNSCB at Kalanivasal Resettlement Site

Sl.no Parameters Observed

Values IS 10500: 2012 (Drinking water

standard

1 pH 6.47 6.5 to 8.5

2 Chloride (mg/l) 75 250

3 Sulphates (mg/l) 78 200

4 Alkaline CaCO3 (mg/l) 150 200

5 Acidity as Ca CO3 (mg/l) 160 -

6 Total hardness as CaCO3 (mg/l) 95 200

7 Total Solids (mg/l) 1000 -

8 Suspended Solids (mg/l) 710 -

9 Dissolved Solids (mg/l) 290 500

10 Turbidity (NTU) 0.76 1

11 Nitrate - Nitrogen(mg/l) 11 45

12 Fluoride (mg/l) 0.13 1 Source: TNSCB

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9. Ambient Air Quality and Noise Levels

81. TWAD Board had conducted an EIA study for establishing sewerage system and STP for Karaikudi Municipality in January 2020. Ambient air quality and noise levels were measured at the STP site as part of this study which is located at approximately 5.5km from the resettlement site. The data shows that the ambient air quality parameters are within the CPCB standards. A field visit undertaken as part of due diligence for this subproject indicated that air quality remains good.

Table 27: Ambient Air Quality in Karaikudi

Sl. no

Parameters Values at STP Site Near

Solid Waste Dumping Yard CPCB AAQ Standard

1 Particulate Matter (PM10), µg/m3 52.18 60

2 Particulate Matter (PM2.5), µg/m3 23.63 100

3 Oxides of sulphur (SOx), µg/m3 13.41 80

4 Oxides of Nitrogen (NOx), µg/m3 24.7 80 Source: EIA Report of UGSS to Karaikudi Municipality, TWAD Board, January 2020

82. Ambient noise levels are within the notified noise standards for commercial zones.

Table 28: Ambient Noise Levels in Karaikudi

Location Leq Day Time Leq Night Time

STP site near solid waste dumping yard 62 52

CPCB Standard (commercial) 65 55 Source: EIA Report of UGSS to Karaikudi Municipality, TWAD Board, January 2020

D. Biological Environment 83. As per the information obtained from the Forest Department, Government of Tamil Nadu, there are 88 forest areas in Sivagangai district constituting a total area of 17611.68 hectares. 60 areas fall under the Reserve forest category with 10680.52 hectares and 28 under Reserve land category with 6931.16 hectares. Being a semi-arid zone, the plantation comprises mainly of drought resistant plants such as prosopis sp., cashew, eucalyptus, etc. The nearest forest to the subproject area is located at a distance of 1.8 km from the nearest encroachment site to be relocated and 2.2 km from the Kalanivasal resettlement site. It is a forest plantation, as seen in the landuse map presented as Figure 19. It is a plantation of Cashew and Eucalyptus. 84. As per the IBAT study (refer Appendix 17), the Vettangudi Bird Sanctuary is located at a distance of 10km from the Kalanivasal resettlement site, however as per the Google Earth as well as the forest maps, it is located at a distance of 25km from the Kalanivasal resettlement site. Considering the forest department information, it shall be concluded that there are no protected areas, eco sensitive zones or ecologically sensitive areas notified by MoEF&CC within a radius of 10 km from the Kalanivasal resettlement site. Vettangudi Bird Sanctuary is the nearest protected area to the subproject area, which is located at a distance of 25 km from the resettlement site which is followed by Kanjirankulam Bird Sanctuary, located at a distance of 80 km from the resettlement site. Figure 21 shows the location of Vettangudi Bird Sanctuary with respect to the subproject area. This figure also shows the landuse within 25 km of the subproject area. According to the landuse classification (refer Figure 19), the forests located within this area are plantations.

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85. Vettangudi Bird Sanctuary is a 0.384 km2 protected area, declared in June 1977 near Thirupattur in Sivaganga District that includes the periya kollukudi patti, chinna kollukudi patti, and vettangudi patti irrigation tanks. This area of small drainage basins attracts more than 8,000 winter migratory birds belonging to 217 species, mostly from European and North Asian countries. It is a breeding habitat for grey herons, darters, spoonbills, white ibis, Asian openbill stork, and night herons. It has also attracted indigenous endangered species including painted stork, grey heron, darter, little cormorant, little egret, intermediate egret, cattle egret, common teal, spotbills, pintail, and flamingos. 86. Kanjirankulam Bird Sanctuary. It is located at a distance of 80 km from the resettlement site of the subproject. It is a 1.04 km2 Protected area near Mudukulathur in Ramanathapuram District of Tamil Nadu. It is notable as a nesting site for several migratory heron species that roost in the prominent growth of babul (Acacia nilotica) trees there. The sanctuary vegetation is mostly tropical dry deciduous forest. It is dominated by babul along with Prosopis juliflora and the grasses Bermuda grass and Eremopogon foveolatus. The irrigation tank bund and the area outside the tank have tamarind trees, fig trees, neem trees, portia trees, silk trees (Albizzia amara), drumstick trees and palmyra palms. The breeding population of migratory water birds arrive here between October and February and include painted stork, white ibis, black ibis, little egret, and great egret.

Figure 21: Location of Vettangudi Bird Sanctuary

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E. Socio-economic Environment

1. Demographic Profile

87. All the 10 slums to be relocated are located in Karaikudi Municipality. It covers an area of 33.75 km2. According to 2011 census, Karaikkudi Municipality had a population of 106,714 with a sex-ratio of 1,000 females for every 1,000 males, much above the national average of 929. A total of 10,619 were under the age of six, constituting 5,405 males and 5,214 females. The average literacy of the town was 81.48%, compared to the national average of 72.99%. The town had a total of 27504 households. There was a total of 40,069 workers, comprising 244 cultivators, 314 main agricultural labourers, 1,303 in household industries, 30,836 other workers, 7,372 marginal workers, 62 marginal cultivators, 496 marginal agricultural labourers, 345 marginal workers in household industries and 6,469 other marginal workers. 88. The resettlement site at Kalanivasal is located in Sankarapuram Panchayat. According to the 2011 census, Sankarapuram Panchayat had a population of 26,536 with a sex-ratio of 962 females for every 1,000 males, much above the national average of 929. A total of 2,781 were under the age of six, constituting 1419 males and 1362 females. The average literacy of the town was 79.16%, compared to the national average of 72.99%. The panchayat had a total of 6854 households. There were a total of 9014 workers, comprising 116 cultivators, 234 main agricultural labourers, 98 in household industries, 6890 other workers, 1676 marginal workers, 22 marginal cultivators, 156 marginal agricultural labourers, 62 marginal workers in household industries and 1436 other marginal workers.

2. Socio-Economic Features

89. The economy of Sivaganga district is chiefly agro based, given its vast agricultural hinterland. The principal crop of Karaikudi is paddy. The other crops that are grown are millets, cereals, pulses, sugar cane, cashew nut and groundnut. It is also rich in mineral resources like graphite and granite that contribute to the region’s economy. 90. State Industries Promotion Corporation of Tamil Nadu Limited (SIPCOT) has developed an industrial complex in Sivaganga district at Manamadurai. Tamil Nadu Small Industries Development Corporation Limited (TANSIDCO) has established industrial estates in the district at Karaikudi, Saivaganga and Kirungakottai. The Sakthi Sugar Factory located in Sivagangai has capability of producing more than 5000 tons of sugar per day. It provides employment to more than 1000 people directly and indirectly. Videocon is setting up a ₹16,000 Million plant for colour television sets and other electronic consumer durables at Manamadurai. Including these, there are 20 large scale industries in Sivaganga district. They include textile, mining, steel, chemicals, gas filling, ethanol, spices and solar power industries. Majority of the major industries are textile mills producing cotton yarn. Tamil Nadu Chemical Products Ltd at Koviloor is the only large-scale industry situated near the subproject area in Karaikudi. It produces sodium hydrosulphite.

91. There are 9880 registered micro, small and medium enterprises in Sivaganga district out of which 19 are medium scale industries and 15 are small scale industries. The majority of them produce cotton yarn.

3. Cultural and Heritage Sites

92. Karaikudi is part of the area commonly referred to as "Chettinad" and has been declared a heritage town by the Government of Tamil Nadu, on account of the palatial houses built with limestone called karai veedu. The town is home to Nagarathar, a business community and

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Chettiars, financiers and trade facilitators. Chettinad cuisine originated in the areas around Karaikudi. UNESCO has offered to set up a Chettinad Heritage Museum in Sivaganga district recognizing the unique style of architecture in the region. Chettinad Kottan are palm leaf baskets woven by the women of the region. Chettinad Kottan has been noted for its unique style and colors and was granted a Geographical Indication tag in 2013. Chettinadu Kandangi sarees are a popular type of sarees produced in the region. Athangudi tiles are a type of tiles produced by the handicraft industry in this area. They are cement tiles used in a mosaic pattern for building palatial houses in the town. 93. The town was established in the 19th century, and the oldest known structure is the Koppudaiya Nayagi Amman Temple. Kannadasan Mandapam, Kamban Manimandapam, thousand windows house and Chettinad Raja Palace are other visitor attractions in Karaikudi. However, there are no protected monuments in and around Karaikudi Municipality. There are three protected monuments in Sivaganga district out of which one come under national monuments protected by Archaeological Survey of India (ASI) and two comes under state protected monuments. The following table depicts the protected monuments in Sivaganga district and their distance from Kalanivasal resettlement site.

Table 29: Details of Protected Monuments near the Subproject Sites Sl.no Protected Monument Location Distance from Kalanivasal

(Resettlement site) in km

National Monuments

1 Boulder stone bed and Brahmi inscriptions on the hill and rock-cut temple with inscription at the foot of the hill (Shanmughanathar Temple)

Kunnakudi (Kundrakudi)

6.50

State Protected Monuments

2 Marudupandiyar Fort Aranmanai Siruvayal

18.35

3 Brahmi Inscriptions - Jain Beds Thirumalai 33.41

Source: ASI and Department of Archaeology, Government of Tamil Nadu

94. It is evident from the given information, that none of the protected monuments are in near vicinity to the resettlement site or from the 10 encroachment sites to be relocated. Hence, implementation of the project will not have any impact.

4. Infrastructure

95. Water Supply and Source Sustainability. The Karaikudi municipality water supply is accessed through 13 existing borewells, supplying 12 MLD of water. These borewells tap from Sambai Ootru located on the western side of Karaikudi town in Sankarapuram Panchayat, just outside the Municipality. Water supply from borewells is conveyed to eight Over Head Tanks (OHTs) located in various parts of Karaikudi town and later transported through a distribution network of 186.733 km length consisting of 385 public fountains and 14,392 house service connections. On average, water supply is maintained at 112 lpcd. The estimated water demand of 640 KLD for the resettlement site shall be supplied by the TWAD. As per the information obtained from the CGWB, the net groundwater availability is 985.89 MCM. The water demand, based on the domestic usage and other water usages (including industries and irrigation) is estimated to be 157.16 MCM, which stands at 15.9% when compared with the total water availability. The stage of groundwater development is at 16% and hence the district is categorised as a “SAFE Zone”. Hence the supply of water of 640 KLD for the Kalanivasal Resettlement area shall not be a burden for the TWAD. The existing borewells shall meet the estimated water

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demand. In order to maintain the groundwater level, the TWAD has constructed 270 recharge structures.

Table 30: Recharge structures

Sl.no Recharge structure Total structures

1. Check Dam 67

2. Recharge Pit 16

3. Recharge Trench 24

4. Others 3

5. Ooranies 126

6. Recharge Shaft 10

7. Rooftop RWH 24

Total 270 Source: TWAD

96. Sewerage. Karaikudi town does not have any underground sewerage scheme at the present time. Individual septic tanks are in use for treating sewage from toilets. However, the sullage water from kitchens, bathrooms, wash basins, cloth washing etc. is directly discharged into existing roadside open drains. In places where economically weaker sections of the society reside, there are no septic tanks either and wastewater is discharged into roadside open drains, resulting in large scale pollution of existing natural water courses i.e., major storm water drains. The discharge of raw sewage/effluent into storm water drains creates unhygienic conditions around drains, lake and posing serious hazard. Therefore, Tamil Nadu Government has decided to provide an Underground Sewerage Scheme (UGSS) with an STP at Karaikudi - Devakottai road, near Devakottai Rasta, opposite to the solid waste dumping yard, Karaikudi as a part of urban development project for Karaikudi Municipality. The UGSS and STP are under construction. There is a possibility that the resettlement site may in the future be provided UGSS connectivity. 97. Storm Water Drainage. The storm water drainage network in Karaikudi Primarily consists of primary drains and roadside drains to discharge the storm water. The primary drains run to a length of 13.5 km in the town and primarily discharge into the major water bodies such as Konneri Kanmoi, Karaikudi Kanmoi, Athala Kanmoi and Veeran Kanmoi. While these are encroached upon at several locations along the run, the carrying capacity of these primary drains has reduced considerably due to siltation and dumping of debris and wastes. 98. Solid Waste Management. As per the municipal data, about 48 metric tonnes of solid waste is generated per day in Karaikudi Municipality. 58% of the waste generated is biodegradable, 31% is dry and 11% is silt. Municipality has implemented door to door collection of waste in 100% areas of the city. 90% areas are practicing source segregation of waste. Biodegradable waste is collected daily and dry waste is collected once in a week. Municipality is collecting 28 tonnes of wet waste per day. It is disposed at an open dumping yard at Devakottai Rastha, on Karaikudi - Devakottai road. The waste is disposed here without any lining system and no proper arrangements are made to collect leachate from the site. Composting of 4.5 tonnes per day of organic waste is carried out here. The solid waste management in the Kalanivasal (subproject area) has been managed by the Sangarapuram Village Panchayat, with a similar approach in waste segregation to the Karakudi Municipality being adopted and the generated MSW is dumped in a landfill of 3 acres of land belonging to the Town Panchayat in Pootai Village. 99. Transportation. The subproject area is well connected by road and rail. The resettlement site is situated near to National Highway 210 (Tiruchirappalli to Ramanathapuram). Other interior roads also connect the Resettlement site with Karaikudi Town. The encroachment sites to be

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relocated are located within the Karaikudi Town and hence well connected by road network. Karaikudi bus stand is located 5 km from the resettlement site. Nearest railways station to the resettlement site is Kottaiyur, at a distance of 3.85 km. Karaikudi Junction railway station is 7.1 km away from the resettlement site. Nearest airport is at Tiruchirappalli, 80 km away. 100. Hospitals. In addition to the Government Hospital, there are 7 private clinics and 11 private hospitals in Karaikudi Municipality. Since the Kalanivasal resettlement site is located at a distance of 5km, with a travelling time less than 11 minutes, the existing health facilities shall be utilised. 101. Educational Institutions. As of 2011, there were 18 government and private schools in Karaikudi and five colleges in the town. Alagappa University is located in this town and Alagappa Chettiar College of Engineering and Technology is the oldest college here and was established in 1953. Similar to hospitals, the education institutions located in the Karaikudi Town shall be utilised.

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V. ANALYSIS OF ALTERNATIVES

102. During project preparation, comprising of screening and design preparation, various alternatives were identified and analysed to help in decision making. A. With and Without project alternatives 103. The “With” project scenario has positive beneficial impacts on the encroachers living conditions. It will remove encroachments on existing waterways helping to improve the environment and also relocate vulnerable people into areas which are not flood prone and into appropriate housing helping to reduce their risk to disaster and improve their livelihood opportunities. In comparison, the “Without” project scenario can lead to further deterioration of the living conditions and quality of life of the present encroachers while adversely impacting the surrounding environmental conditions. Other factors like infrastructure development, and other project benefits were also taken into consideration in analysing the with and without project scenarios. B. With Project Scenario 104. The proposed Kalanivasal resettlement site project shall have 900 residential units, which will accommodate encroachers (4950 persons) from 10 encroachment sites who are at heightened risk of natural hazards due to their encroachment of existing waterways or water bodies. A number of resettlement sites were investigated with the ultimate location being determined due to its locational advantages and government ownership of land. Karakudi Town is located at a distance of 4.5km, which is accessible via State highways and National highways. There are a number of schools, hospitals and other commercial establishments located in the vicinity that can also be accessed. The resettlement site is designed to have all the essential amenities which includes:

(i) Water supply and road network (ii) Electricity (iii) Landscaping/ green area with ample OSR (as per GoTN norms) (iv) Sewage treatment plant and Municipal solid waste management (v) Children play area (vi) Convenience shop (vii) Ration shop (viii) Anganwadi (ix) Milk booth (x) Community Hall (xi) Livelihood Center and Library (xii) Health Sub Centre (xiii) Market (xiv) Livestock shelter (xv) Storm water drains

105. Subproject benefits. The proposed STP will treat the wastewater generated from the resettlement sites and has been designed to recycle the treated water for flushing and gardening purposes, which will reduce the actual water demand and have beneficial impacts on the environment (through recycling and reuse). Solar powered streetlights have been proposed within the resettlement sites, which will marginally reduce the use of TNEB power supply. Internal roads have been designed with storm water drains that will prevent flooding/ ponding of water within the

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resettlement site. It is proposed to have rainwater harvesting pits/ structures surrounding the residential blocks as well as in common areas to tap the rainwater to increase the groundwater recharge potential. It is planned to have native floral species in the green area/ landscaping areas. 50 years of periodic operation and maintenance has been proposed. 106. A graduation program shall be conducted for the relocated people to improve self-sustainability and to access to better economic opportunities that will help to improve living standards. This subproject also aims to improve the gender balance and women empowerment by assisting the women in the family, women headed households and elderly people through skill development training programs (under the Tamil Nadu Skill Development Corporation). C. Without Project Scenario 107. As per the field visits undertaken as part of due diligence, some of the problems associated with encroachers are as follows:

(i) substandard housing and lack of hygiene; (ii) significant health risks (due to mosquito breeding and spread of vector borne

diseases); (iii) They lack basic facilities like road, electricity and drinking water (iv) The illegal nature of housing makes encroachers susceptible to extortion (v) They are more prone to disasters like urban floods

108. Key Social issues. It is evident from the site visits, that none of the slum sites are provided with a household connection to water supply as a common water tap is provided for the entire community of slum dwellers at a distance of 500m to 1km (min distance). This is a difficult situation especially for women. All the encroachment sites do not have basic infrastructure facilities. The quality of life is observed to be below average, as most of them are working as daily labours. The dwelling structures do not have strength to withstand climate hazards (including heavy rain, wind and increase in temperature). The approach roads are too narrow and are without streetlights, which is not safe for the night time road users especially women. 109. Key Environmental issues. The catchment area of the water bodies has been encroached and as a result the natural drains are closed with the water bodies in a dilapidated condition. Some of the water body area has been covered by wild thorny bushes (refer Table 21) and contains solid waste from the encroachers and the general public. Proper toilet facilities are not available and untreated sewage water is discharged into the water body which deteriorates water quality and indirectly causes ground water contamination. D. Alternate Technology Adopted for STP

110. In general, for regular TNSCB projects, the Decentralized Wastewater Management Systems (DEWATS) has been used for treating wastewater generated from resettlement tenements. Being a conventional treatment system with limitations, the proposed subproject proposes to use the advanced Sequential Batch Reactor (SBR) technology. The following section discusses the pros and cons of these two wastewater treatment technologies.

(i) DEWATS. Design uses physical and biological treatment mechanisms such as sedimentation, floatation, aerobic and anaerobic treatment to treat domestic wastewater. DEWATS is designed to be affordable, low maintenance, use local materials. The Typical DEWATS will have four components for treatment (i) Settler,

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(ii) Anaerobic Baffled Reactor, (iii) Anaerobic filter and (iv) Planted Gravel Filter. Though it has advantages in treating the waste with high efficiency, due to the land constraints for TNSCB in the resettlement sites, this system may not be feasible, because it requires more space, periodic maintenance and expensive.

Table 31: DWATS Salient Features

Sl.no DWATS Components

Advantages Disadvantages

1 Settler simple, durable, underground need regular de-sludging

2 Anaerobic Baffled Reactor

simple, durable, little permanent space, high treatment efficiency

required large space

3 Anaerobic filter simple, durable, underground, high treatment efficiency

costly, filter blockage

4 Planted Gravel Filter

high efficiency, no nuisance, no wastewater on ground

need permanent space, requited intensive maintenance with expertise, relatively costly

(ii) SBR Technology. SBR aeration system is similar to an Activated Sludge Process

(ASP). The major difference is that this SBR uses one tank for all the treatment steps, rather than using different equipment for each step. As the term “sequencing” suggests, SBR uses time, rather than space, to accomplish its wastewater treatment purposes. The advantages of using SBR include its: (a) ability to adapt to different volumes of influent; (b) work with automated controls; and (c) requiring less space than a system using multiple tanks

The disadvantages of this process are: (a) that is necessitates sophisticated controls and timing units; and (b) requires more maintenance than conventional systems.

E. Alternative Approaches to the Resettlement site design

111. The following table illustrates various improvements adopted in the design of the Kalanivasal resettlement site.

Table 32: Alternative Approach in Building Plan CATEGORY Traditional TNSCB Building

Plan Proposed TNSCB Building Plan (ADB funded)

URBAN DESIGN

Overall Focus Cost efficiency, number of units Quality of life, people centric designs that are future ready (without compromising on cost and number of units)

Site Approach Design assumes site to be an independent plot of land, often with minimal connection (spatial and programmatic) with the surrounding context

Integrated, sustainable design solutions

Environmental Sustainability

Minimal solutions created to respond to the context and environmental sustainability

Providing environmentally sensitive design solutions to ensure minimum carbon footprint, while creating a healthy and comfortable living environment

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CATEGORY Traditional TNSCB Building Plan

Proposed TNSCB Building Plan (ADB funded)

Inclusive Design

Inadequate consideration of different user groups.

Creating design strategies that focus on vulnerable groups within the community such as children, differently abled, the aged, youth and women

Spatial and Circulation Hierarchy

Hierarchy of spaces absent thereby making the open spaces monotonous

Creating a hierarchy of open and community spaces with appropriate density to support diverse forms of social interactions

Vehicular movement typically prioritized; vehicular circulation paths also intersect with pedestrian paths creating unsafe environments for the residents

Promoting pedestrian circulation and networks over vehicular circulation in order to create safe spaces for all users; creating safe interactions

Open Space Design

Design approach typically treats open spaces as "left over spaces" rather than integrating them cohesively.

Spatial design that focuses on the design of shared public spaces to nurture harmony of collective action

Landscape Design

Inadequate focus on landscape design

Open spaces that integrate native, natural landscapes that are didactic, productive as well as recreational in their functions

Walkability Lack of walkable spaces Promoting Walkability- nodes typically within 3m, 5m and 7m walking radii

Block Arrangements

Standardised block patterns does not create unique identity to the communities

Enhancing a sense of identity and belonging through block design

Closely placed blocks to optimize efficiency reduces privacy

Design allows for greater distance between blocks where possible and avoids the situation where the longer side of blocks face one another

Blocks are designed close to each other with less focus on the human scale

Designing blocks that are perceivable for the human scale

Eyes on the Street

Design has leftover/ narrow alleyways/ spaces which are poorly maintained and end up being blighted unsafe regions of the community

Designing neighborhoods such that they avoid redundant areas away from sight which are prone to poor maintenance and blight; activating spaces between buildings and adding value through artwork and other design solutions

Promoting Physical and Mental Well Being

Inadequate attention to open space programming that promotes physical and mental well being

Creating programmatic interventions in open spaces that enable physical and mental recreation for different age groups

Cater to the physical and emotional needs of different groups of people in the design of spaces

Visual Quality Minimal visual quality features incorporated in the design

Emphasizing visual quality of spaces through the introduction of nodes, elevation design etc to name a few

BLOCK DESIGN

Block Orientation

Buildings are oriented without critical consideration of site features, daylight and wind paths

Building orientations to be responsive to the site conditions/ context, with a focus on improved interior thermal comfort

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CATEGORY Traditional TNSCB Building Plan

Proposed TNSCB Building Plan (ADB funded)

Façade Design Minimal intervention on facade design and almost restricted to the same style across all sites

Enhancing the external appearance of buildings through innovative façade design, with a focus on optimizing O&M costs

Openings Buildings are designed with minimal openings creating dark and long corridors and un-aesthetic built form; lack of adoption of passive surveillance

Visualising and designing blocks as a product of solids and voids to create spaces for interaction and enhance the quality of the common spaces

Block Length Blocks accommodate large number of units creating long and dark corridors

Incorporating limited housing units within each block to ensure shorter corridors that help with way finding

Building Heights

Repetitive blocks that creates a sense of monotony

Creating modulated block forms with varying heights to add to the character of the community while adding vibrancy

UNIT DESIGN

Efficiency Units are maximised to have maximum efficiency

Carpet area maximised to create a healthy living environment

Space Segregation

Minimal spaces are designed within the units without segregation of spaces

Addition of ante space and balconies to create better circulation and segregation of activities in spaces

Creating multi-functional spaces to enhance better usage of spaces while not compromising on the sizes

Storage Areas Minimal storage facilities are provided within the units

Creating multiple storage facilities within the unit for residents to store their personal belongings

F. Outcome based on the analysis.

112. Based on the observation discussed in the earlier sections, the following matrix has been developed to indicate the initiation of this subproject shall bring positive impacts and benefits to the relocated encroachers. It not only fulfils the policy requirement (housing for all) it also increases the living standards of the encroachers (urban poor) and will help to improve environmental conditions for the encroached areas.

Table 33: Outcome of the Analysis of Alternatives Sl.no Infrastructure facilities and other amenities With Project Without Project

1. Well-structured Residential Building ✓

2. Electricity ✓

3. Water supply ✓

4. Approach Road ✓

5. Convenience shop ✓ ✓

6. Ration shop ✓ ✓

7. Anganwadi ✓

8. Milk booth ✓ ✓

9. Community Hall ✓

10. Livelihood Center and Library ✓

11. Health Sub Centre ✓ ✓

12. Streetlights ✓

13. Livestock shelter ✓

14. Sewage Treatment Plant ✓

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Sl.no Infrastructure facilities and other amenities With Project Without Project

15. Solid waste management ✓

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VI. ANTICIPATED ENVIRONMENTAL IMPACTS AND MITIGATION MEASURES

113. This chapter on the anticipated environmental impacts and mitigation measures is based on the preliminary detailed design for the Kalanivasal resettlement site and proposed demolition works and water body regeneration works are based on the consultations had with TNSCB officials. The given information will have to be updated/ revised once the detailed designs are finalized for resettlement site and plans for demolition at the encroachment sites and water body regeneration works are completed. 114. Screening of potential environmental impacts is categorized into four categories considering project phases: location impacts and design impacts (pre-construction phase), construction phase impacts and operations and maintenance phase impacts:

(i) Location impacts. Impacts associated with site selection, including impacts on environment and resettlement or livelihood related impacts on communities

(ii) Design impacts. Impacts arising from project design, including the technology used, scale of operations etc.

(iii) Construction impacts. Impacts resulting from construction activities including site clearance, earthworks, civil works, etc.

(iv) O&M impacts. Impacts associated with the operation and maintenance of the infrastructure built in the project.

115. The proposal envisages (i) construction, operation and maintenance of 900 residential units and essential amenities (large scale construction activity), (ii) demolition of structures in the 10 encroachment sites chosen for relocation and (iii) restoration of 10 water bodies. The construction of residential units along with supporting urban infrastructure and services at Kalanivasal and demolishing works at the encroachment sites identified for relocations are located in the adjoining area of the existing buildings and hence this would result in some environmental impacts typical to the construction activities. The land identified for construction of residential units at Kalanivasal belongs to the TNSCB and hence it is free from any encumbrances. 116. The sites identified for demolition (encroachment sites for relocation) are located within the settlement areas. Gaining free access and movement of workers, vehicles and other construction related machinery would be an issue that will be dealt with by obtaining requisite permissions, consultations with affected stakeholders and public information dissemination before commencement of works on site. Identity cards and vehicle permits shall be provided by the contractor for all such movement to and from the construction site. Traffic Management Plan (TMP) should be prepared by the Contractor in consultation with PIDs and affected stakeholders.

117. Other impacts related to construction activities such as generation of dust and noise, removal of construction debris and demolition wastes etc. are envisaged which shall be minimized and addressed by adopting safe engineering practices and appropriate methodology for demolishing works and water body restoration works. Caution will be exercised in planning for safe construction and operations phase to minimize disturbance to the adjoining existing activities. Provision for water for construction will be made through municipal water supply or through mobile water tankers. 118. Land Acquisition and Resettlement. As indicated earlier, the land proposed for construction of residential units and associated services (4.48 ha) belongs to TNSCB, similarly the encroachment areas (proposed for demolition) are owned by Karaikudi Municipality and hence land acquisition is not envisaged. As per the Resettlement Framework (RF), the proposed

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categorisation for this subproject is Category “A”, for involuntary resettlement (IR) as it results in physical or economical displacement for 900 Households (HH). 119. Design Considerations to Avoid Environmental Impacts The following are design considerations to avoid environmental impacts:

(i) Incorporation of adequate drainage provisions (ii) Provision for adequate cross ventilation (iii) Adoption of design compatible with the natural environment and suitable selection

of materials to enhance the aesthetic appeal and to blend with the natural surroundings.

(iv) Straight lines and simple geometry in the proposed landscape and architectural features.

(v) Natural tree species in the proposed landscape. (vi) A separate area has been designated (away from the residential blocks) in the

layout plan for managing municipal solid waste generated in the resettlement site (vii) Ensure water demand can be met sustainably and reused wherever possible. The

STP and treated water is proposed to be utilised for flushing and gardening purposes by reducing the water demand.

120. The results of interventions are unobtrusive and will be integral part of the ambience of the site. The physical components have been proposed with minimalist design treatment. A. Assessment of Environmental Impacts

121. Determination of Area of Influence. The primary impact areas are (i) sites for proposed project components; (ii) main routes/intersections which will be traversed by construction vehicles; and (iii) quarries and borrow pits as sources of construction materials. The secondary impact areas are: (i) Other than the delineated primary impact area; and (ii) entire Karaikudi Municipality terms of overall environmental improvement. 122. In the case of this subproject the components will involve straight forward construction and operation, and impacts will be mainly localized, short in duration and expected only during construction period. B. Pre-construction Impacts and Mitigation Measures

123. Consents, permits, clearances, no objection certificate (NOC), etc. Necessary consents/NOC as per Table 5 will be required during pre-construction phase and before any civil works commence. A copy of Consent/Permission/Clearance/ NoC should be included in the monitoring reports and submitted to the PID and PMU. Failure in obtaining the same will result in delay of work and may lead to stoppage of works. 124. Mitigation measures. The following measures will be conducted during the detailed design phase prior to construction for the resettlement site, demolition and regeneration works:

(i) Obtain all necessary consents, permits, clearance, NOCs, etc. prior to start of civil works.

(ii) Acknowledge in writing and provide report on compliance of all obtained consents, permits, clearance, NOCs, etc.

(iii) Submission and approval of updated EMP/ SEMP prior to starting of work to the

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PID with final approval by PMU. (iv) Include in detailed design drawings and documents all conditions (e.g. the location

of the STP should be away from the settlement area and the treated water should meet the discharge standards as per the TNPCB) and provisions if necessary.

(v) The demolished materials from the 10 encroachment sites should be recycled to the maximum extent possible (3R concept should be adopted).

(vi) For asbestos material disposal, an appropriate inventory has to be carried out and proposed management measures implemented before any demolition activity occurs by the Asbestos Expert/ Environmental Specialist in the encroachment sites. Care should be taken in disposal of the asbestos materials (used as roofing materials) as per the relevant protocols/ hazardous waste management rules 2016 (refer EMP for Asbestos material management).

(vii) In compliance to the Noise Standards, the proposed construction activities should be implemented in a controlled manner, the dB(A) levels for residential area (day time noise level 55 dB(A) and night time noise level 45 dB(A)) should be maintained.

(viii) Pre-construction environmental monitoring as indicated in Table 39 will be conducted by the Contractor under the supervision of the PID. The outcome of the analysis shall be referred as baseline information for key environs (Air, Water and Noise).

(ix) Conduct consultation with the local communities and provide detail in the language that is understandable to the local community regarding project activities and the anticipated impacts as part of the project information dissemination (prior to the start of the construction and demolition activity).

125. Utilities. Interruption of services (water supply, electricity, toilets etc.) will be scheduled and intermittently related to localized construction activities. To mitigate impacts, PIDs will:

(i) Identify and include locations and operators of these utilities in the DPR to prevent unnecessary disruption of services during the construction phase.

(ii) Require contractors to prepare a contingency plan to include actions to be done in case of unintentional interruption of services.

(iii) Require contractor to obtain from the PIDs the list of affected utilities and operators;

(iv) If relocations are necessary, contractors along with PIDs will coordinate with the providers/line agencies to relocate the utility.

(v) Consult with the local communities if there is a need for interruption of services (especially during the demolition activities)

126. Social and Cultural Resources. There is a risk that any work involving ground disturbance can uncover and damage archaeological and historical remains. Though the encroachment sites to be relocated and the resettlement site are not historically or culturally important locations, the PIDs shall:

(i) Ensure the ADB SPS, 2009 requirements are met while dealing with physical cultural resources

(ii) Continually consult Archaeological Survey of India and/or State Department of Archaeology to obtain an expert assessment of the archaeological potential of the site.

(iii) Consider alternatives if the site is found to be of medium or high risk. (iv) Include state and local archaeological, cultural and historical authorities, and

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interest groups in consultation forums as project stakeholders so that their expertise can be made available.

(v) Develop a chance find protocol for use by the construction contractors in conducting any excavation work, to ensure that any chance finds are recognized, and measures are taken to ensure they are protected and conserved, this must include stopping work if any suspected cultural heritage item is found.

127. Site selection of construction work camps, stockpile areas, storage areas, and disposal areas. Priority is to locate these near the project location. However, if it is deemed necessary to locate elsewhere, sites to be considered will not promote instability and result in destruction of property, vegetation, irrigation, and drinking water supply systems. Residential areas will not be considered for setting up construction camps to protect the human environment (i.e., to curb accident risks, health risks due to air and water pollution and dust, noise, and to prevent social conflicts, shortages of amenities, and crime). Extreme care will be taken to avoid disposals near forest areas or in water bodies. 128. Site selection of sources of materials. Significant quantities of bricks, coarse aggregate and fine aggregate will be required for construction works (including the construction works in the resettlement site as well as water body regeneration works). Contractor should procure these materials only from the quarries permitted/licensed by Department of Geology and Mining. The contractor should, to the maximum extent possible, procure material from existing quarries, and creation of new quarry areas should be avoided as far as possible. If new quarries are required then the contractor will be responsible for obtaining all permissions and clearances, including environmental clearance for mining. Contractor should factor in the time required for obtaining clearances including conduct of EIA if required under the law. It will be the construction contractor’s responsibility to verify the suitability and legal status of all material sources and to obtain the approval of Department of Geology and Mining and local revenue administration, as required. 129. Erosion control. Most of the impacts will occur due to excavation and earth movements during construction phase. Prior to commencement of civil works, the contractor will be required to:

(i) Develop an erosion control and re-vegetation plan to minimize soil loss and reduce sedimentation.

(ii) Minimize the potential for erosion by balancing cuts and fills to the extent feasible. (iii) Identify and avoid areas with unstable slopes and local factors that can cause

slope instability (groundwater conditions, precipitation, seismic activity, slope angles, and geologic structure).

(iv) Minimize the amount of land disturbed as much as possible. Use existing roads, disturbed areas, and borrow pits and quarries when possible. Minimize vegetation removal. Stage construction to limit the exposed area at any one time.

130. Access. Hauling of construction materials and operation of equipment on-site can cause traffic problems. Construction traffic will access most work areas from the existing roads therefore potential impacts will be of short-duration, localized and can be mitigated. The Contractor will need to adopt the following mitigation measures:

(i) Plan transportation routes so that heavy vehicles do not use narrow local roads, except in the immediate vicinity of delivery sites.

(ii) Schedule transport and hauling activities during non-peak hours.

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(iii) Locate entry and exit points in areas where there is low potential for traffic congestion.

(iv) Keep the site free from all unnecessary obstructions. (v) Drive vehicles in a considerate manner.

C. Construction Impacts and Mitigation Measures

131. The impacts during the proposed construction works are standard and site-specific to the construction activities and are not expected to be significant. The Environmental Management Plans (EMPs) specifies the necessary mitigation measures to be strictly followed by the contractor and supervised by the PIDs. Key impacts during construction are envisaged on the following aspects: (i) transportation of materials, (ii) dust generation, air and noise pollution from construction activities, (iii) sourcing of water for construction activities, (iv) handling of construction materials at site and, (v) adoption of safety measures during construction. However, the prepared EMPs (refer to chapter VIII) should be updated as construction EMPs based on the site conditions by the contractor under the supervision of the PIDs. 132. Construction Schedule and Method. As per the detailed design, construction activities in the resettlement site is expected to take approximately 24 months, demolition activities in the 10 encroachment sites shall take 6 months and the 10 water bodies regeneration works is expected to take 6 to 12 months for completion. The proposed interventions for the resettlement site will be constructed manually with minimum use of machinery and equipment and with necessary safety precautions, for example, barricades around demolition sites, restricting pedestrian and vehicular movements. Noise from demolition works should not exceed the noise standards as set by CPCB. Any damage to surrounding buildings will require work to be stopped immediately and rectified before work can recommence. The materials from the demolishing works will be reused to the maximum extent possible. Materials will be brought to site by trucks and will be stored on unused areas within the project site. The working hours will be 8 hours daily. Night works will be avoided except on an emergency basis or due to high day-time traffic as per prevailing conditions at the time of construction. This shall be further considered by the PID but only in consultation with the local communities. 133. There is sufficient space for a staging area, construction equipment, and stockpiling of materials. However, the contractor will need to remove all construction and demolition wastes on a daily basis. 134. Erosion Hazards. The resettlement site at Kalanivasal is located in a gentle slope and hence the risk of erosion is high. For the demolition sites, they are located in built-up areas and therefore the risk of erosion is low. However, the contractor will be required to:

(i) Save topsoil removed during excavation and use to reclaim disturbed areas, as soon as it is possible to do so.

(ii) Use dust abatement such as water spraying to minimize windblown erosion. (iii) Provide temporary stabilization of disturbed/excavated areas that are not active

under construction. (iv) Apply erosion controls (e.g., silt traps) along the drainage leading to the water

drains. (v) Maintain vegetative cover within unused land to prevent erosion and periodically

monitor the area to assess erosion. (vi) Clean and maintain catch basins, drainage ditches and culverts regularly. (vii) Conduct routine site inspection to assess the effectiveness and the maintenance

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requirements for erosion and sediment control systems.

135. Impacts on Water Quality. There is a seasonal irrigation tank near the resettlement site at Kalanivasal and the slope of the resettlement site is towards this tank. Further, all the demolition sites are located around surrounding water bodies. Therefore, impacts on water quality for the construction and demolishing work sites are high. Hence, the contractors will be required to:

(i) The project sites (including the resettlement site and the water body regeneration sites) are in a water scarce area where the use of groundwater is prohibited for construction purposes, hence the contractor should arrange for the water, it shall be either purchased from the ULB or the TWAD. The agreement and / or MoU has to be shared with the PID. For any other arrangements for the source of water, the evidence of the same has to be furnished to the PID.

(ii) Schedule civil works during non-monsoon season, to the maximum extent possible.

(iii) Ensure drainages within the construction zones are kept free of obstructions. (iv) Keep loose soil material and stockpiles out of drains and flow-lines. (v) Avoid stockpiling of excavated and construction materials (sand, gravel, cement,

etc.) unless covered by tarpaulins or plastic sheets. (vi) Conduct periodic Environmental Monitoring to check the water quality as indicated

in the Table 39. (vii) Use silt trap for the surface runoff to prevent sediments entering into the nearby

irrigation tank/ water bodies. (viii) Re-use/utilize, to maximum extent possible, excavated materials. (ix) Dispose any residuals at identified disposal site (PIDs will identify approved sites). (x) Dispose waste oil and lubricants generated as per provisions of Hazardous Waste

(Management and Handling) Rules, 1989.

136. Impacts on Air Quality. There is potential for increased dust, particularly during summer/dry season due to various construction activities including stockpiling of construction materials. Emission from vehicles transporting construction materials and debris/materials to be disposed may cause increase in air pollutants within the construction zone. These are inherent impacts which are site-specific, low magnitude, short in duration and can be easily mitigated. The contractor will be required to:

(i) Conduct regular water spraying on earth piles, trenches and sand piles. (ii) Conduct regular visual inspection in the construction zones to ensure that there

are no excessive dust emissions. (iii) Spreading crushed gravel over backfilled surfaces if re-surfacing of disturbed

areas cannot be done immediately. (iv) Maintain construction vehicles and obtain “Pollution Under Control” (PUC)

certificate from Emission Testing Centres. (v) Obtain CtE and CtO for batching plants, crushers, diesel generators, etc., if is to

be used in the project from Tamil Nadu Pollution Control Board. (vi) Conduct periodical environmental monitoring for ambient air as per the

Environmental Monitoring Plan (Table 39).

137. Noise and Vibration Impacts. The encroachment sites and resettlement site are not located near to any heritage buildings. With exemption to piling works, most of the construction activities (including construction and demolishing works) shall be done manually with minimum use of machinery and equipment and with necessary safety precautions, for example, barricades

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around demolition sites, restricting pedestrian and vehicular movements. Noise from demolition works should not exceed the noise standards as set by CPCB. Any damage to surrounding buildings will require work to be stopped immediately and rectified before work can recommence Hence the chances for significant noise and vibration impacts are not envisaged. Nevertheless, the contractors will be required to:

(i) Plan activities in consultation with the PIDs so that activities with the greatest potential to generate noise are conducted during periods of the day which will result in least disturbance.

(ii) Minimize noise from construction equipment by using vehicle silencers and fitting jackhammers with noise-reducing mufflers.

(iii) Create awareness among drivers not to use horns unless it is necessary to warn other road users or animals of the vehicle’s approach.

(iv) Shut off idling equipment. (v) Night time construction activities should be avoided, and only be considered on an

emergency basis or due to high day-time traffic as per prevailing conditions at the time of construction

(vi) Follow day time ambient noise levels as per Noise Pollution (Regulation and Control) Rules and conduct periodical environmental monitoring for ambient noise as per schedules given in the EMP Table 39.

(vii) Ensure vehicles comply with Government of India noise limits for vehicles. PUC should be available for every construction equipment and vehicles.

138. Impacts on Flora and Fauna. As per detailed design, tree-cutting is not required. This will be reassessed during pre-construction phase. There are no protected areas in the direct and indirect impact zones and no diverse ecological biodiversity is found within the project area (construction and demolition sites) thus there are no significant impacts on flora and fauna. But in general, the Contractor will be required to:

(i) Conduct site induction and environmental awareness. (ii) Limit activities within the work area. (iii) Do not remove or harm existing vegetation except those required under proposed

contract. (iv) Strictly instruct workers not to cut trees for fuel wood. (v) Replant trees in the area using minimum ratio of 10 trees for every 1 tree cut, if

any. Replacement species must be approved by District Forest Department.

139. Impact due to Waste Generation. Excavated materials are anticipated in the construction site at Kalanivasal. The materials will be tested for its suitability and it will be recycled as filling material. Similarly, the demolished structures will be reused to the maximum extent possible. Construction activities will produce excess excavated soils, excess construction materials, and solid wastes (such as removed concrete, wood, packaging materials, empty containers, oils, lubricants, and other similar items). These impacts are negative but short-term and reversible by mitigation measures. The contractor will need to adopt the following mitigation measures:

(i) Prepare and implement a Waste Management Plan. (ii) Manage solid waste according to the following hierarchy: reuse, recycling and

disposal. Include designated/approved disposal areas in waste management plan. (iii) Coordinate with Municipal Authorities for beneficial use of demolished materials or

immediately dispose to designated areas. (iv) Recover used oil and lubricants and reuse; or remove from the sites.

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(v) Avoid stockpiling and remove immediately all demolished materials, excess construction materials, and solid waste (removed concrete, wood, packaging materials, empty containers, oils, lubricants, and other similar items).

(vi) Prohibit disposal of any material or wastes (including human waste) into drainage, nallah, or watercourse.

(vii) Any waste that contains asbestos, or is contaminated with asbestos, must be double-bagged, labelled and placed in a covered, locked skip. This includes asbestos sheets, asbestos pipeline, asbestos cement etc. Care should be taken in disposal of the asbestos materials as per the relevant protocols/ hazardous waste management rules 2016 (refer EMP for Asbestos material management).

140. Impacts on Occupational Health and Safety. Workers need to be aware of occupational hazards which can arise during proposed construction activities. Exposure to work-related chemical, physical, biological and social hazard is likely to occur during proposed works. Potential impacts are negative and short-term but reversible by mitigation measures. Overall, the contractor should comply with all the mitigation measures as per best international practices which include but not limited to:

(i) Disallow worker exposure to noise level greater than 85 dB(A) for a duration of more than 8 hours per day without hearing protection. The use of hearing protection shall be enforced actively.

(ii) Develop a comprehensive site-specific health and safety (H&S) plan. The overall objective is to provide guidance to Contractor on establishing a management strategy and applying practices that are intended to eliminate, or reduce, fatalities, injuries and illnesses for workers performing activities and tasks associated with the project.

(iii) Include in H&S plan measures such as: (i) type of hazards during excavation works; (ii) corresponding personal protective equipment for each identified hazard; (iii) H&S training for all site personnel; (iv) procedures to be followed for all site activities; and (v) documentation of work-related accidents.

(iv) The working hours will be 8 hours daily. Night works should be avoided, however, it may be considered on an emergency basis or due to high day-time traffic as per prevailing conditions at the time of construction.

(v) Provide H&S orientation training to all new workers to ensure that they are appraised of the rules of work at the site, personal protective protection, and preventing injury to fellow workers.

(vi) Ensure that first aid kit is available at site and it should be easily accessible for all workers in terms of emergency.

(vii) Provide medical insurance coverage for workers. (viii) Secure construction zone from unauthorized intrusion and accident risks through

provision of barriers, guards and warning signs. (ix) Ensure the core labour standards are adopted (i). Universal and indivisible human

rights, (ii) Freedom from forced labour (iii) Freedom from child labour (iv) Freedom from discrimination at work

(x) Provide supplies of potable drinking water. (xi) Provide clean eating areas where workers are not exposed to hazardous or

noxious substances. (xii) Provide visitor orientation if visitors to the site can gain access to areas where

hazardous conditions or substances may be present. Ensure also that visitor/s do not enter hazard areas unescorted.

(xiii) Ensure the visibility of workers through their use of high visibility vests when

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working in or walking through heavy equipment operating areas. (xiv) Ensure moving equipment is outfitted with audible back-up alarms. (xv) Mark and provide sign boards in the construction zone, and areas for storage and

disposal. Signage shall be in accordance with international standards and be well known to, and easily understood by workers, visitors, and the general public as appropriate.

(xvi) Prior to any demolition activity an asbestos walk-over will be required to mark any potential asbestos waste and a demolition and handling protocol will be developed. Demolition activity undertaken in these areas will require appropriate PPE to be worn. Any waste that contains asbestos, or is contaminated with asbestos, must be double-bagged, labelled and placed in a covered, locked skip. This includes asbestos sheets, asbestos pipeline, asbestos cement etc. Exposure to asbestos causes Asbestosis (chronic lung disease), hence care should be taken in disposal of the asbestos materials as per the relevant protocols/ hazardous waste management rules 2016 (refer to the EMP for Asbestos material management)

(xvii) COVID-19. WHO has declared COVID-19 as a pandemic which has affected the entire world including India. In view of the prevailing COVID-19 pandemic, the contractors and workers would need to take additional measures to avoid the spread of the disease and shall follow various guidelines/guidance notes issued by the national/state government, WHO, ILO, World Bank/IFC from time to time. As described in these guidelines, the contractors shall undertake a COVID risk assessment of project area and prepare a COVID Response and Management Plan (C-R&MP) and submit to TNSCB for approval. A brief guidance on “To Do” List prepared from these documents is provided in Appendix 18.

141. Impact on Associated Infrastructure facilities. The estimated water demand of 640KLD of water shall be supplied by the TWAD. The water will be sourced from Sakkottai MSR, which is located at a distance of 7km from the Kalanivasal Resettlement Site. It is arranged through gravity for which pipeline shall be laid for a distance of 7 km. The pipeline laying activities shall have direct air and noise impacts to the public. Being an associated activity to this subproject, once detailed design information is available, the PID environmental specialist shall prepare the EMP in accordance with ADB SPS with assistance from the PMU environmental specialist. Accordingly, this IEE and EMPs will need to be revised and submitted to ADB for concurrence. The prepared EMP will need to be adopted by the contractor, who undertakes the pipeline laying works. This EMP shall be monitored and reported by both TWAD and PID. The key observations should be reflected in the quarterly project progress reports and quarterly safeguard reports to ADB. D. Post-Construction Impacts and Mitigation Measures

142. Site clean-up after construction activities (including resettlement site, demolishing sites and water body regeneration site). The Contractor will be required to:

(i) Backfill any excavation and trenches, preferably with excess excavation material generated during the construction phase.

(ii) Use remove topsoil to reclaim disturbed areas. (iii) Re-establish the original grade and drainage pattern to the extent practicable. (iv) Stabilize all areas of disturbed vegetation using weed-free native shrubs, grasses,

and trees. (v) Restore staging areas and temporary work areas. (vi) Remove all tools, equipment, barricades, signs, surplus materials, debris, and

rubbish. Demolish buildings/structures not required for O&M. Dispose in

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designated disposal sites. (vii) Request in writing from PIDs that construction zones have been restored. (viii) Solid waste (debris, excavated soils, etc.) from the demolishing sites and

restoration of water body site should be disposed by the contractor as per the guidance of the Environmental specialist of PIDs.

143. Operation and maintenance activities. The PIDs in support from the service providers will operate and maintain the infrastructure facilities at the Kalanivasal resettlement site and Karaikudi Municipality shall maintain the restored/ rejuvenated water bodies. The maintenance activities at Kalanivasal resettlement site include:

(i) Rainwater Harvesting Pit management. (a) Regular inspection and cleaning of catchment, gutters, filters and tanks to

reduce the likelihood of contamination. (b) Water from other sources should not be mixed with that in the tank. (c) TNSCB will carry out routine management of the RWH pits.

(ii) Management of the STP

(a) For initial 5 years, the construction contractor shall maintain and operate the STP. Thereafter a separate Contractor shall be engaged for operation and maintenance of STP. During the operation, the STP will be operated by a skilled operator, who will be required to wear all the essential PPE’s (including but not limited to gloves, masks, safety shoes and safety eyewear) to safeguard themselves from any hazards likely occurring from the STP.

(b) TNSCB/ Sankarapuram Panchayat will carry out regular inspection of the STP to prevent any impacts, including pollution of ground water and nearby water courses (including the irrigation tank located near to the resettlement site).

(c) The sludge generated from the STP shall be further treated in the sludge digester tank (anaerobic sludge digestion) in the STP to digest the sludge into dry sludge. The treated sludge shall be stored in the sludge drying bed and when it reaches its maximum capacity it will be disposed of along with organic waste generated from the resettlement site. The treated sludge shall be as per compost quality standard given in the Solid waste management rules 2006 (schedule II A, standards for composting) for which the O&M contractor/ service provider shall perform scheduled monitoring as suggested by the Environmental specialist from PID.

(iii) Maintenance of sanitation facilities, solid waste collection and regular maintenance of constructed amenities. TNSCB/ Sankarapuram Panchayat will carry out maintenance of the sewer system (including the pipeline, collection system etc.), carry out the regular collection of wastes, and will also ensure that: (a) Sanitation facilities do not result in pollution of groundwater. (b) Sanitation facilities do not interfere with other utilities and block access to

buildings, causing nuisance to neighbouring areas. (c) Municipal Solid Waste will be segregated as organic waste and inorganic

waste. Both organic and inorganic waste shall be collected by the Sankarapuram Panchayat, organic waste will be composted in the vermicomposting / biodegradation process and will be used a manure. The inorganic waste will be disposed off in the MSW dumping area.

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(d) No spillage will happen during the transfer of waste and all wastes will be transported to a designated solid waste treatment site.

(e) Staff collecting the MSW will be provided with necessary PPE’s (including gloves, masks and boots).

(iv) Firefighting equipment’s including the fire extinguisher and sand buckets has to be regularly maintained. Fire extinguishers have to be regularly checked for the expiry date and has to be refilled or replaced as required prior to the expiry date. Any wet sand (if any) in the bucket should be replaced with dry sand

(v) Other amenities including landscaping, children play area and streetlights shall be handed over to Sankarapuram Panchayat for maintenance and operation.

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VII. INFORMATION DISCLOSURE, CONSULTATION AND PARTICIPATION

A. Consultation and Participation

144. The active participation of stakeholders including local community, NGOs/CMROs, etc., in all stages of project preparation and implementation is essential for successful implementation of the project. It will ensure that the subprojects are designed, constructed, and operated with utmost consideration to local needs, ensures community acceptance, and will bring maximum benefits to the people. Public consultation and information disclosure is a must as per the ADB policy. 145. Most of the stakeholders have already been identified and consulted during preparation of this IEE, and any others that are identified during project implementation will be brought into the process in the future. Primary stakeholders of the subproject include vulnerable communities/ residents, shopkeepers and petty shop business people living along the water bodies, government and utility agencies responsible for provision of various services in project area, community representatives, TNSCB and ADB. 146. COVID-19 has prevented further planned consultations with affected people at the encroachment sites and around the resettlement site. Further formal consultations are expected to be held prior to construction and will be incorporated into the draft IEE. B. Public Consultation

147. The public consultation and disclosure program is a continuous process throughout the project implementation, including project planning, design and construction.

1. Consultation during Project Preparation

148. Several formal/informal consultations with each stakeholder to understand issues and cross cutting themes have been conducted. The table below lists out various meetings/ discussions between various stakeholders conducted till date.

Table 34: Meetings/Discussions between various stake holders Sl.no Date Stakeholder

Department Details

1 12th March 2019

Directorate of Town and Country Planning (DTCP)

Consultation was conducted with Mr. Krishna Moorthy, Deputy Director of Town and Country Planning. The following key points were discussed

• Various planning options in determining the landuse and its categorisation has been discussed in detail

• The preparation of the landuse map across Tamil Nadu was explained to the ADB team

2 5th December 2020

Tamil Nadu Pollution Control Board (TNPCB)

Consultation was conducted with Dr. S. Selvan, Chief Environmental Engineer, TNPCB and Mr.R.Ramasubbu Joint Chief Environmental Engineer. The followings are the key outcome of the meeting

• Disposal of Construction and Demolition waste: Various policies and regulations adopted by the TNPCB has been discussed. It was informed that Permissions/ NoC from the TNPCB is

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Sl.no Date Stakeholder Department

Details

required, if the construction and demolishing waste (C&D) is equal to or greater than 20 tons per day or 300 tons per project in a month.

• Environmental clearance for the subprojects: TNPCB informed that based on the built-up area the project will be categorised as either A or B. It was also indicated that since the built-up is less than 150,000 m2, the Kalanivasal subproject will be categorised as 8B, which requires an Environmental Clearance from the SEIAA.

• Storage and handling of Hazardous materials: It was informed that a licence is not required for storing of Diesel, if the total quantity in possession does not exceed 2500 litres in non-bulk (i.e. drums) or 1000litres in a receptacle / tank (i.e. bulk)

• Sewage Treatment Plant: TNPCB mandates the need for a STP in the resettlement site, it was informed that the project owner/ project proponent can choose any available technology for treating the wastewater, however the treated water quality parameter should meet the stipulated limits prescribed by the CPCB.

• Solid waste management: it was informed that all the corporations/ municipalities/ town panchayats are facilitated with appropriate waste collection, handling, transport and disposal system and hence it shall be managed by the ULB’s. However, the handling of waste should be as per the Municipal Solid Waste Management Rules, 2016

3 5th December 2020

Adyar River Restoration Trust

Consultation was conducted with Dr. S. Viswanathan, Senior Environmental Scientist. The procedures/ methodology adopted in restoration of the Adyar River Estuary (Adyar Poonga) has been discussed in detail.

• The resettlement issues in evacuating the encroachers from the estuary area and allocation of the resettlement sites for the project affected persons.

• Compensation measures adopted including livelihood assistance, transportation allowances and other provisions are discussed in detail.

• Restoration of the water body and its challenges.

• Restoration of the mangroves in the estuary area.

• Monitoring and reporting system for the biodiversity in the Adyar estuary area.

2. Consultations with the Affected Community

149. Informal focus group discussions (FGDs) were carried out at encroached sites (sites chosen for relocation). At the time of FGD’s the information pertaining to entitlement and

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compensation were still under preparation. Hence information dissemination about the subproject was only partially done. It was planned to conduct further formal consultations along with the social surveys, however due to the ongoing COVID 19 pandemic, the planned consultation did not go ahead. As such, whenever the situation is under control and it is safe to do so, further planned consultation shall be conducted by the TNSCB at the encroachment sites and around the resettlement site. Accordingly this consultation section will be updated and the revised IEE should be submitted to ADB for concurrence. Some of the common concerns of the PAPs expressed during the FGDs have been outlined below:

(i) Lack of basic facilities including water supply, street lights and proper approach roads;

(ii) Flooding issues during monsoon season; (iii) Encroachers have resided at the same place for 45 years; (iv) Patta is not available for the encroachers; (v) Proper toilet facilities (provided with septic tank) are not available; (vi) Most residents work as daily labours and housemaid workers; (vii) Schools/ educational institutions, hospitals are located in accessible distances; (viii) Some of the houses are provided with borewell facility. Others have to depend on

the water supply from Karakudi Municipality; (ix) Some encroachers showed willingness to relocate, but some have shown their

unwillingness for relocation. Figure 22: Snap Shots from the FGDs conducted at Water Body Encroachment sites

Chellam Chetti Oorani Vadaku oorani

Kuruchi Kanmai Vaith oorani

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Veeriyan Kanmai Athi Thitavida Kanmai

3. Consultation during construction

150. Prior to start of construction, PIDs will conduct information dissemination sessions and further consultations (that have been prevented due to COVID-19) at various places (including at encroachment sites and around the resettlement site) and solicit the help of the local community, leaders/prominent for the project work. Focus group meetings will be conducted to discuss and plan construction work with local communities to reduce disturbance and other impacts and also regarding the project grievance redress mechanism. Project information and construction schedule will be provided to the public via TNSCB website (newspapers, television, ULB websites etc,). Attendee list and meeting outcomes will be recorded and included in the revised IEE to be submitted to ADB for concurrence. A constant communication will be established with the affected communities to redress the environmental issues likely to surface during construction phase. Contractor will provide prior public information (in Tamil and English) about the construction work in the area, once 7 days prior to the start of work and again a day before the start of work via pamphlets. At the work sites, public information boards will also be provided to disseminate project related information. C. Information Disclosure and Future Consultations

151. Executive summary of the IEE will be translated in Tamil and made available at the offices of TNSCB, PIDs and also displayed on their notice boards. Hard copies of the IEE will be accessible to citizens as a mean to disclose the document and at the same time creating wider public awareness. Electronic version of the IEE in English and Executive Summary in English and Tamil will be placed in the official website of TNSCB after approval of the IEE by ADB. Stakeholders will also be made aware of grievance register and redress mechanism. 152. Public information campaigns to explain the project details to a wider population will be conducted. Public disclosure meetings will be conducted at key project stages to inform the public of the progress and future plans. Prior to start of construction, the PIDs will issue notification on the start date of implementation in the TNSCB website. Subproject information brochure/ pamphlets will be issued to the local communities for better understanding, the brochure/ pamphlets shall include the EMP cost. A board showing the details of the project will be displayed at the construction sites for the information of general public. Local communities will be continuously consulted regarding location of construction camps, access and hauling routes and other likely disturbances during construction.

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VIII. GRIEVANCE REDRESS MECHANISM

153. The PMU will ensure that (a) local level project safeguards GRM acceptable to ADB is established in accordance with provisions and within timeframes specified in the EMP and RP to consider safeguards related complaints; and (b) a task force is functioning effectively to:

(i) Review and document eligible complaints of project stakeholders; (ii) Proactively address grievances; (iii) Provide the complainants with notice of the decisions made; (iv) Prepare periodic reports to summarize:

(a) the number and types of complaints received and resolved at all levels; (b) chosen actions and time required for resolution; and (c) final outcomes of the grievances; and (d) Make the reports available to ADB as part of the regular Safeguards

Monitoring Reports. (v) Eligible complaints will include:

(a) those related to the project activities, (b) any of the service providers, (c) any person responsible for carrying out the project, (d) complaints on misuse of funds and other irregularities, and (e) grievances due to any safeguards, labor and gender issues.

154. The PIDs (Environment / Social Cell) will establish a common GRM acceptable to ADB at divisional levels for addressing any environment and/or social issues that arise due to subproject activity. The GRM will constitute a suitable systematic process to receive, evaluate and facilitate resolution of affected persons and other stakeholder’s complaints and grievances about subproject environmental (and social) safeguards performance. It will aim to provide a time-bound, trusted and transparent mechanism to voice and resolve issues and concerns associated with the subproject implementation. 155. Public awareness campaigns in the project area of influence will ensure that knowledge of the grievance redress procedures is generated. The PIDs (Environment / Social Cell) will conduct awareness campaigns to ensure that all affected persons and vulnerable households are made aware of grievance redress procedures, entitlements and anticipated environmental impacts. 156. Affected persons will have the flexibility of conveying grievances/suggestions by dropping grievance redress/suggestion forms in complaints/ suggestion boxes to be installed by the PIDs (Environment / Social Cell) or by writing in a complaint register in the PID office or by e-mail, or by registering complaints by post (as per the PMU’s existing grievance redress mechanism). Careful documentation of the name of the complainant, date of receipt of the complaint, address/ contact details of the person, location of the problem area, and how the problem was resolved will be undertaken. The PID (Environment / Social Cell) officers will have the overall responsibility for timely grievance redress on environmental and social safeguards issues and for registration of grievances, related disclosure, and communication with the aggrieved party. The proposed template of a grievance registration form is provided in Appendix 20. All the documents made available to the public will include information on the contact number, address and contact person for registering grievances, and will be disseminated throughout the project area of influence by the PIDs (Environment / Social Cell).

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157. Proposed GRM.18 In case of grievances that are immediate and urgent in the perception of the complainant, the on-site Contractor/Animator/Community Officer / Assistant Engineer /Junior Engineer from PID (Environment / Social Cell) will provide the most easily, accessible or the first level of contact for the quick resolution of grievances. Contact phone numbers and names of the concerned staff and contractors, will be posted at all construction sites in visible locations.

(i) 1st level grievance: The on-site contractor/ Animator/ Community Officer/ Assistant or Junior Engineer of the PID (Environment / Social Cell) will receive and record the complaint at the subproject site. Alternatively, the complaint can be registered by phone call, message, email, and this will be reverted to the onsite personnel for 1st level resolution. The complaint will be reviewed and on-site Contractor/Animator/Community Officer / Assistant Engineer / Junior Engineer of the PID (Environment / Social Cell) will try to resolve the issue on-site in consultation with the aggrieved party. This will be done within 7 days of receipt of a complaint/ grievance.

(ii) 2nd level grievance: All grievances that cannot be redressed within 7 days at the field (on-site) level will be brought to the notice of the Community Development Officer of the PID and the Environment Specialist of the Environment Cell in the PID. The PID Community Development Officer / Environmental Specialist of the Environmental Cell / PID Executive Engineer (PID Head) will resolve the grievance within 14 days of receipt of a complaint/ grievance with support of the PIU Circle Superintending Engineer.

(iii) 3rd level grievance: If the grievance is not resolved at PID Community Development Officer / Environmental Specialist/ Executive Engineer (PID Head) level, the grievance will be referred internally to Chief Community Development Officer / Environmental Consultant of PMU / the Chief Engineer of IRSHUPSP. The grievance at this level will be resolved within 21 days of its receipt..

158. The project GRM notwithstanding, an aggrieved person shall have access to the country's legal system at any stage. This can run parallel to accessing the GRM and is not dependent on the negative outcome of the GRM.

18 Any IRSHUPSP specific grievance which comes in through TNSCBs existing system (refer to Section 3) will be

routed back to the project specific GRM to level 1.

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Figure 23: Grievance Redress Process

159. In the event that the established GRM is not in a position to resolve the issue, the affected persons can also use the ADB Accountability Mechanism by directly contacting (in writing) the complaint receiving officer at ADB headquarters or the ADB India Resident Mission. The complaint can be submitted in any of the official languages of ADB’s Developing Member Countries. The ADB Accountability Mechanism information will be included in the project information document to be distributed to the affected communities, as part of the project GRM. 160. Record-keeping. The PID will keep records of grievances received, including contact details of the complainant, the date the complaint was received, the nature of the grievance, agreed corrective actions and the date these were affected and the final outcome. The number of grievances recorded and resolved and the outcomes will be displayed/disclosed in the PID office, as well as reported in monitoring reports submitted to ADB on quarterly basis. All resolutions shall be communicated to the aggrieved party / complainant(s). 161. Periodic review and documentation of lessons learned. The PMU will periodically review the functioning of the GRM and record information on the effectiveness of the mechanism, especially on the program’s ability to prevent and address grievances. 162. Costs. All costs involved in resolving the complaints (meetings, consultations, communication and reporting/ information dissemination) will be borne by the PID. 163. Country legal procedure. An aggrieved person shall have access to the country's legal system at any stage, and accessing the country's legal system can run parallel to accessing the GRM and is not dependent on the negative outcome of the GRM. 164. ADB’s Accountability Mechanism. If the established GRM is not in a position to resolve the issue, the affected person also can use the ADB Accountability Mechanism through directly contacting (in writing) the Complaint Receiving Officer (CRO) at ADB headquarters or the ADB India Resident Mission. The complaint can be submitted in any of the official languages of ADB’s developing member countries. Before submitting a complaint to the Accountability Mechanism, it is recommended that affected people make a good faith effort to resolve their problems by working with the concerned ADB operations department (in this case, the resident mission). Only after

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doing that, and if they are still dissatisfied, they could approach the Accountability Mechanism. The ADB Accountability Mechanism information will be included in the project-relevant information to be distributed to the affected communities, as part of the project GRM.

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IX. ENVIRONMENTAL MANAGEMENT PLAN

A. Environmental Management Plan

165. The environmental management plan (EMP) has been developed to provide mitigation measures to reduce all negative impacts to acceptable levels. Unlike other projects, four EMPs have been prepared for various subproject activities, which are planned to be implemented under four different tenders.

(i) Environmental Management Plan for Construction Site (ii) Environmental Management Plan for Operation/ Maintenance (iii) Environmental Management Plan for Demolition Works (iv) Environmental Management Plan for Regeneration Works

166. The EMP will guide environmentally-sound practices at the time of construction and operation of the subprojects and ensure efficient lines of communication between TNSCB PMU, PIDs, and contractors. The EMPs will (i) ensure that the activities are undertaken in a responsible non-detrimental manner; (ii) provide a pro-active, feasible and practical working tool to enable the measurement and monitoring of environmental performance on site; (iii) guide and control the implementation of findings and recommendations of the environmental assessment conducted for the subproject; (iv) detail specific actions deemed necessary to assist in mitigating the environmental impact of the subproject; and (v) ensure that safety recommendations are complied with. The EMPs includes a monitoring program to measure the environmental condition and effectiveness of implementation of the mitigation measures. It will include observations on- and off-site, document checks, and interviews with workers and beneficiaries. The IEE and EMP will be included in the bid and contract documents to ensure compliance to the conditions set out in this document. 167. The contractor will be required to submit to PIDs, for review and approval, a Site Environmental Management Plan (SEMP) including (i) proposed sites/locations for construction work camps, storage areas, hauling roads, lay down areas, disposal areas for solid and hazardous wastes; (ii) specific mitigation measures following the approved EMP; (iii) monitoring program as per EMP and (iv) prepare a COVID Response and Management Plan (C-R&MP). No works are allowed to commence prior to approval of SEMP. 168. A copy of the EMP and approved SEMP will be kept on site during the construction period at all times. 169. Water supply is expected to be arranged through a 7km gravity pipeline and detailed design is still underway. This is an associated activity to this subproject and once enough information is available, the PID environmental specialist shall prepare the EMP for this activity in accordance with ADB SPS with assistance from the PMU environmental specialist. Accordingly, this IEE and EMP will need to be revised and submitted to ADB for concurrence prior to appointment of the contractor by TWAD. The prepared EMP will need to be adopted by the contractor, who undertakes the pipeline laying works, and it shall be monitored and reported by both TWAD and PID. The key observations should be reflected in the quarterly safeguard reports to ADB. 170. For civil works, the contractor will be required to (i) carry out all the mitigation and monitoring measures set forth in the approved SEMP; and (ii) implement any corrective or preventative actions set out in environmental monitoring reports that the employer will prepare

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from time to time to monitor implementation of this IEE and SEMP. The contractor shall allocate budget for compliance with these SEMP measures, requirements and actions. 171. The following table shows the potential environmental impacts, proposed mitigation measures and responsible agencies for implementation and monitoring.

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Table 35: Environmental Management Plan for Construction Site - Kalanivasal, Sivaganga District

Sl.no Environmental Issues Mitigation Measures Indicators and Targets

Responsibility for

Implementation

Responsibility for

Supervision

1. Location Impacts

1.1 Location impacts pertain to siting of facilities for construction of new buildings/ dwelling units at Kalanivasal, Sivaganga District

• Clearing of wild vegetation

• Maintain slope for natural drain

• Excess earth disposal

• The siting of facilities will be in line with the DTCP approved Master Plan.

• The site allotted for the construction of new buildings / dwelling units at Kalanivasal belongs to Tamil Nadu Slum Clearance Board (TNSCB). Hence there are no LA Issues anticipated.

• The land is vacant and located in a plain area having gentle slope towards southern direction. Hence levelling operations have to be conducted for the construction purpose. By doing so it is anticipated to generate excavated excess earth/ soil (cut and filling), which has to be disposed in an authorised/ identified landfill or disposal area. If the site is a new disposal area, then it has to be approved by the PIDs.

• There are a few trees identified in the project site, which have to be preserved through design considerations or it shall be transplanted to the designated landscaping area.

• List of tree species

• Tree cutting permit / permission from the competent authority

• Identification of Disposal site for disposing debris and excavated soil

PID PMU

1.2 Lack of sufficient planning to assure long term sustainability of the developments

• In accordance with the provisions in the sub-project selection criteria, the sub-project design shall include adequate provisions for ensuring effective maintenance and protection of the assets created so as to ensure the long-term sustainability of the sites.

• The designs will be worked out and implemented in accordance with the provisions.

• DPR and designs Approved from competent authority

• Work plan prepared and approved by PIDs

PID PMU

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Responsibility for

Implementation

Responsibility for

Supervision

• No construction activity of any kind shall be taken up in the OSR area

1.3 Land acquisition (Socio economic Impacts)

• No additional land will be required, the proposed project (construction of 900 residential units) at Kalanivasal is designed to be implemented within the available 4.49 ha land area

• Resettlement and/or land acquisition problems are not anticipated in the construction activities.

• In case of any additional land acquisition, the compensation as per the Entitlement matrix given in the Resettlement Framework (RF) shall be adopted.

• Revenue records PID PMU

1.4 Clearing of trees/ Removal of vegetation

• All reasonable measures shall be undertaken to ensure that no native fauna is harmed or placed at risk during the course of the clearing activities

• As per the proposed design, felling of trees is not envisaged at any stage of the project. However, under unavoidable conditions if any of the trees are required to be cut/ felled, then prior permission as per existing procedure from Forest department, ensuring appropriate compensation including compensatory plantation at 1:10 ratio as stipulated by the High Court of Madras (WP No 7811/2010 and MP No 1/2010 dated 25/06/2010).

• Tree count information and compensation ratio

PID PMU

2. Design and Pre-Construction Impacts

2.1 Increased storm water runoff from alterations of the site’s natural drainage patterns due to excavation works in the Kalanivasal site, construction

• Design of proposed building components will enable efficient drainage of the sites and maintain natural drainage patterns. The siting of

• Site drainage plan to be prepared and applied

PID PMU

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Responsibility for

Implementation

Responsibility for

Supervision

of residential units, Anganwadi, Community hall, Ration shop, addition of paved surfaces and approach roads.

the project components, involving physical construction shall be done to ensure no disruption of natural drainage patterns or flows into the nearby drain/nallah.

• Construction activities (including excavation and trenching works) shall be restricted during the monsoon season.

• The Contractor shall discuss with the PID to carryout necessary construction activities in the monsoon season by providing appropriate safety measures to the satisfaction of the PID.

• Construction of drains to prevent water logging at site during rains

2.2 Consents, permits, clearances, NOCs, etc.

• All the necessary approvals/ permissions/ clearances/ NoCs as given in the Environmental Clearance (EC) for Kalanivasal Resettlement Site should be obtained by the PID and verified by PMU before start of the construction activities or as per the conditions given in the EC. This includes STP design approval from a third party.

• The findings and recommendations from the source sustainability study19 has to be completed and incorporated into the IEE prior to a contractor being appointed by TWAD.

• Meaningful consultations with communities to keep them informed of anticipated activities and associated impacts

• General Conditions and Specific Condition as mentioned in the Environmental Clearance

• Source sustainability study

• Consultation meeting outcomes and records

PID PMU

19 The water source sustainability study should indicate the project shall utilize water sources at sustainable levels of abstraction only (i.e. without significant

reductions in the quantity or quality of the source overall), avoid polluted water sources, avoid water use conflicts by not abstracting water that is used for other purposes and ensure water quality provided complies with national drinking water standards at all times through regular monitoring. This requires identification of all users of the water source and that the water source can be appropriately recharged. The water source sustainability study to be conducted should be incorporated into the relevant IEE and EMP.

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Responsibility for

Implementation

Responsibility for

Supervision

2.3 Water supply pipeline laying activities shall have direct air and noise impacts to the public as well as other construction impacts.

• The impacts of the water supply pipeline will need to be assessed once enough information is available and this IEE and EMP should be revised and submitted to ADB for concurrence prior to a contractor being appointed.

• The contractor appointed for water supply will be required to adopt the EMP.

• Revised IEE and EMP

• Contractor records

PID and TWAD PMU

2.4 Selection of materials and construction technologies, if not carefully chosen, will adversely impact the visual appeal of the buildings

• Designs to be worked out in such a manner that exposed steel and concrete structures are avoided

• The design brief for all building components proposed will strictly conform to the TNSCB requirements.

• Any new landscaping elements will only utilize native species to protect local biodiversity

• list of approved quarry sites and source of material

• List of trees/ shrubs for landscaping

• List of materials to be procured for construction works included in BOQ

PID PMU

2.5 Integration of energy efficiency and energy conservation programs in design of building components

• The detailed designs for the building components shall ensure that environmental sustainability principles, including energy efficiency, resource recycling, waste minimization etc. are integrated, and designs accordingly worked out.

• All the electrical and mechanical equipment used in the construction works shall be energy efficient and ISO certified as per BOQ provisions.

• DPR and designs approved from competent authority

• Use of energy efficient and ISO certified equipment in construction works

• PUC for all construction vehicles

PID PMU

2.6 Odour / smell from Sewage Treatment Plant, Solid waste collection area

• The detailed design/ layout should have designated STP and the MSW areas, which should be located away from the settlement to prevent the odour nuisance

• DPR and designs approved from competent authority

• MSW should be collected frequently

• STP should be maintained

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2.7 Noise pollution from the pumps used for lifting water to the OHTs

• Pump house should be located away from the residential blocks and it should be acoustic proof

• Regular maintenance is required

• conducting frequent Noise monitoring

PID PMU

2.8 Sourcing of water for construction activities

• Contractor shall purchase water from ULB or TWAD for the construction activities. The agreement/ MoU has to be shared with the PID.

• Use of groundwater for construction purpose is prohibited

• Water demand during construction should be reduced by use of premixed concrete, curing agents and other best practices prevalent.

• Tapping of surface water from river sources should not affect the downstream water users (appropriate permission for the same from the TWAD/ PWD should be obtained)

• Tapping of surface water from tanks/ ponds should be in consultation with the local communities and the same records should be submitted to the PID and PMU.

• For any other arrangements for the source of water, the evidence for the same has to be furnished to the PID

• Regular monitoring is required

• Feedback from the local communities

Contractor and PID

PMU

2.9 Installation of Diesel Generators

• As per the CPCB norms, place the Diesel Generators (DG’s) in an acoustic enclosure or other sound insulation

• Place the DG’s at least 100 m from the nearest new building for housing

• Low Sulphur Diesel shall be used for operating diesel generator

• Standards prescribed by the CPCB

• Conducting frequent noise monitoring

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• Ensure DG sets comply with the noise standards prescribed by the CPCB

3. Pre-Construction Activities by Contractor

3.1 Submission of updated EMP / SEMP; EMP implementation and reporting

• Appoint Environment, Health and Safety Supervisor to ensure EMP implementation

• Submission of updated EMP/ SEMP prior to starting of work,

• Timely submission of monthly monitoring reports including documentary evidence on EMP implementation such as photographs and consultation records.

• SEMP documents shall include information about site restoration, noise and dust control, wastewater management, spills response, community and site health and safety, traffic control, tree cutting, construction of labour camps, storage areas, hauling roads, regulatory permissions, disposal areas for solid and hazardous wastes, sensitive features like schools and hospitals

• Provide project-related information to stakeholders, communities and/or affected people before and during construction works including at least 7 days prior to the start of works and again at least 1 day prior to works through issuing a pamphlet booklet to affected persons.

Unsatisfactory compliance with EMP Contractor consultation records

Contractor and PID

PMU

3.2 Consents, permits, clearances, NOCs, etc.

• Obtain all necessary consents, permits, clearance, NOCs, etc. prior to the award of civil works.

• Ensure that all necessary approvals for construction to be obtained by the

All the project related clearances should be obtained as indicated in the Table 5, Table 6 and para 54 and 55

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contractor are in place before the start of construction

• Acknowledge in writing and provide a report on compliance of all obtained consents, permits, clearance, NOCs, etc.

3.3 Sources of construction materials (Impact on natural land contours, vegetation, disturbance to natural drainage patterns, water logging, and water pollution.)

• Maximize the re-use of earth-cut materials, spoils, and construction & demolition debris / wastes

• Specify materials that are recycled, have recycled content or are from sustainable sources

• Obtain construction materials only from government-approved quarries with prior approval of PID

• PID to review, and ensure that proposed quarry sources have all necessary clearances/ permissions in place prior to approval

• Contractor to submit to PID the documentation every month with the details of the material obtained from each source (quarry/ borrow pit)

• Avoid the creation of new borrow areas, quarries, etc., for the project; if unavoidable, contractor to obtain all clearances and permissions as required under law, including Environmental Clearance (EC) prior to approval by PID

Contractor to prepare a list of approved quarry sites and sources of materials with the approval of PID before any construction commences

Contractor/ PID PMU

3.4 Construction Camps – Location, Selection, Design and Layout

• The construction camps will be located at 500m away from settlements and water bodies. The construction camps including separate female and male sanitation facilities, shelter, electricity, canteen, potable water (as per IS 10500), first aid, health care, day crèche facilities must be adequately drained,

• Location of construction camp approved by PID

• Construction camp having all the basic amenities with proper sanitary

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and must not be subject to periodic flooding.

• The camps must be located such that the drainage from and through the camps will not risk any domestic or public water supply.

• All sites must be graded, ditched and rendered free from depressions such that water may not get stagnant and cause a nuisance.

• The contractor shall provide the dispenser for the disposal of Sanitary Napkins

• MSW and domestic sewage generated from the construction camp should be disposed on day to day basis. The collection of waste and sewage shall be done by Sankarapuram Panchayat for which the contractor should get approval from the Panchayat with the assistance from the PID.

• Potable water (as per IS 10500 standard) to the labours/ construction workers should be provided by the Contractor

• Comply with the ban on one time use and throwaway plastics under Tamil Nadu Government Order

• First Aid Room shall be provided in the project site during the entire construction and operation phases of the project

conditions drainage and watery supply

3.5 Stockpiling of materials • Storage of construction material confined to work sites in a way to ensure that there is no obstruction to natural drainage pattern, efficient drainage is maintained


• Approved materials management plan

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• Stockpiles to be covered to reduce dust generation

• Develop and implement the Materials Management Plan (including warehouses / storage)

3.6 Establishment of baseline environmental conditions prior to start of civil works

• Conduct documentation of location of components, areas for construction zone (camps, staging, storage, stockpiling, etc.) and surroundings (within direct impact zones), locations of environmental monitoring Include photos and GPS coordinates

• The monitoring parameters and the frequency of the monitoring should comply with the Environmental Monitoring Plan (Table 39)

• Baseline environmental profile including ambient air, noise, water quality as per the standards indicted in the monitoring plan (Table 39)

Contractor and PID

PMU

3.7 Drinking water availability and water arrangement

• The contractor will be responsible for arrangement of water in every workplace at suitable and easily accessible place for the whole construction period.

• Sufficient supply of cold potable water (as per IS 10500) to be provided and maintained.

• If the drinking water is obtained from an intermittent public water supply then, storage tanks will be provided.

• Records of drinking water supply to workers

• Feedback from workers

Contractor and PID

PMU

3.8 Identification of disposal sites • Location of disposal sites will be finalized by the Environmental Specialist of the PID and he will confirm that disposal of the material does not impact natural drainage courses or surface water bodies or low-lying areas and that no endangered / rare flora is impacted by such materials

• Disposal site selected and approved by PID

• Records of materials disposed at disposal site

• Log book maintained for debris disposal

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• The disposal sites shall be identified in consultation with Sankarapuram Panchayat

• Information on the disposal site should be included in the IEE (update/ revise it accordingly)

3.9 Shifting of Utilities • Identify and include locations and operators of these utilities in the detailed design documents to prevent unnecessary disruption of services during the construction phase.

• Require contractors to prepare a contingency plan to include actions to be done in case of unintentional interruption of services.

• Obtain from the PID the list of affected utilities and operators;

• If relocation is necessary, Contractor will coordinate with the providers to relocate the utility and communicate the dates and duration in advance to affected communities / persons / businesses.

• List showing utilities to be shifted

• Contingency plan for services disruption

Contractor and PID

PMU

3.10 Social and Cultural Resources

• No cultural properties or religious structures shall be removed or relocated without the knowledge and written consent of the concerned parties or communities and local administration as the case may be. Sites for the relocation of these religious structures shall be identified following the choice of the community

• As far as possible, the architectural elements of the structure should be conserved/reflected/translated into the design of new structures following the wishes of the community

• Chance find protocol

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• For any Chance find, consult Archaeological Survey of India (ASI) or Tamil Nadu Archaeology Department to obtain an expert assessment of the archaeological potential of the site.

• Consider alternatives if the site is found to be of medium or high risk.

• Include state and local archaeological, cultural and historical authorities, and interest groups in consultation forums as project stakeholders so that their expertise can be made available.

• Develop a protocol for use by the construction contractors in conducting any excavation work, to ensure that any chance finds are recognized and measures are taken to ensure they are protected and conserved.

3.11 Circulation plan during construction in the densely populated areas

• Prior to mobilization and commencement of site activities, contractor has to prepare site work plan approved by Engineer20 so that no works or activities shall interrupt safe passage of local residents/ road users during construction stage, including development of alternative access routes, traffic regulations, signage etc., during construction.

• The sensitive receptors like residential settlements, schools and hospitals in the close proximity of the resettlement site have to be consulted to discuss the site work plan for their suggestions and feedback, accordingly the plan shall be modified.

• Site work plan prepared by contractor and approved by PID

• Traffic plan and records of road signage’s

Contractor and PID

PMU

20 Engineer refers to Project Implementation Division (PID)

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• The Contractor with support of the PID will carry out dissemination of these information

3.12 Access • Traffic congestion near the entry and exit points from the roads adjoining the proposed project site must be avoided

• Plan transportation routes (NH-210) so that heavy vehicles do not use narrow local roads, except in the immediate vicinity of delivery sites.

• Schedule transport and hauling activities during non-peak hours.

• Locate entry and exit points in areas where there is low potential for traffic congestion.

• Keep the site free from all unnecessary obstructions.

• Drive vehicles in a considerate manner.

• Temporary Traffic management Plan

Contractor and PID

PMU

3.13 Occupational health and safety

• Comply with IFC EHS Guidelines on Occupational Health and Safety

• Develop comprehensive site-specific health and safety (H&S) plan. The overall objective is to provide guidance to Contractors on establishing a management strategy and applying practices that are intended to eliminate, or reduce, fatalities, injuries and illnesses for workers performing activities and tasks associated with the project.

• Include in H&S plan measures such as: (i) type of hazards in the construction

site; (ii) corresponding personal protective

equipment for each identified hazard;

• Health and safety (H&S) plan

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(iii) H&S training for all site personnel (including labours);

(iv) procedures to be followed for all site activities; and

(v) Documentation of work-related accidents.

• Provide medical insurance coverage for workers.

• Contractor to nominate an on-site environment, health and safety officer.

• Contractor shall undertake a COVID risk assessment of project area and prepare a COVID Response and Management Plan (C-R&MP) and submit to PID for approval

3.14 Site clearance activities including delineation of construction areas

• Commencements of site clearance activities shall be undertaken after permissions of PID to minimize environmental impacts.

• All areas used for construction and camp activities shall be restored to their former conditions after project completion and no impact to the baseline environment indicators have been confirmed.

Construction and workers camp sites should be restored as per the original situation

Contractor and PID

PMU

3.14 Excessive disturbance to communities due to prolonged construction

• Meaningful consultations with communities to keep them informed of anticipated activities, in particular those that may result in disruption with respect to area access, utilities, and noisy or dust-generating activities that are likely to result in significant disturbance

• Identify and adhere to strict construction schedule

• Liaise with schools that are in close proximity to construction sites on school examination periods and scale down

Community Health and Safety Plan Contractor consultation records

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construction activities and avoid noisy activities (including piling) during such periods

• Alert communities and residents if night time construction work shall occur nearby (no night time construction within 500 m of the nearest household) and ensure safe alternative access is provided

• Ensure communities are aware of Grievance Redress Mechanism (GRM) entry points

• Create awareness of health & safety risks of transmittable diseases (HIV/AIDs / COVID-19), child labor, bonded labor or forced labor

• Develop and implement the Community Health and Safety Plan

4. Construction Impacts

4.1 Improper stockpiling of construction materials cause impacts starting from obstruction of drainage, disturbance/ safety hazard etc.

• Adequate safety precautions will be ensured during transportation of quarry material from quarries to the construction site.

• Vehicles transporting material will be covered to prevent spillage.

• Operations to be undertaken by the contractor as per the direction and satisfaction of Engineer.

• Proper stockpiling of construction materials

• vehicles transporting construction materials covered to prevent spillage

Contractor and PID

PMU

4.2 Impacts due to Batching Plant operation

• Batching plant shall comply with the requirements and specifications of the relevant current emission control legislation.

• Batching plant shall be located within the project construction area and as far as possible from

Batching Plants should be kept/ stationed away from residential /settlements and at least 300m in the downwind direction

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residential/settlements/commercial establishments, at least 300m in the downwind direction.

• The Contractor shall submit a detailed layout plan for all such sites and seek prior approval of PID before entering into a formal agreement with a landowner for setting-up such sites.

• Actions by PID against any non-compliance shall be borne by the Contractor at his own cost.

• Arrangements to minimize dust pollution through the provision of windscreens, mist spray units, and dust encapsulation shall have to be provided at all such sites.

• Specifications of batching plant shall comply with the requirements of the relevant current emission control legislation and Consent / NOC for such plant shall be submitted to the PID

• No such installation by the Contractor shall be allowed till all the required legal clearances are obtained from the competent authority and the same is submitted to the PID.

from nearby sensitive receptors.

4.3 Quarry, borrow areas operations

• If quarry, borrow areas are exclusively opened for the project, contractor shall ensure that they qualify all the legal conditions to operate such areas.

• Consent to Operate (CtO) for quarry sites has to be taken from Tamil Nadu Pollution Control Board (TNPCB) and a copy of the same has to be kept in record and submitted in PID.

• list of approved quarry sites and sources of materials

• CtE and CtO certificated obtained by contractors for quarry sites, batching plant and DG sets and submitted to PID

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• Contractor has to comply all the conditions stipulated in Consent to Operate document.

• If contractor purchases the materials from other party, he has to ensure that quarry has obtained the necessary clearance from Tamil Nadu Pollution Control Board (TNPCB) and should take a copy of it and submit in PID.

4.4 Stripping, stocking and preservation of top soil

• The topsoil from areas of cutting and areas to be permanently covered (proposed site construction of building) will be stripped to a specified depth of 150mm, trans located and stored in stockpiles.

• The stockpiles will be covered with gunny bags or tarpaulin. It will be ensured by the contractor that the topsoil will not be unnecessarily trafficked either before stripping or when in stockpiles. Such stockpiled topsoil will be returned to cover the disturbed area and cut slopes.

• Top soil preservation plan prepared and approved by PID

• Record of top soil excavated, preserved and reutilized

Contractor and PID

PMU

4.5 Soil and water pollution due to storage of fuels, lubricants, construction vehicles and construction wastes

• Fuel and lubricant storage areas shall be designed in such a way that oil may not contaminate soil or water.

• The floor of storage area shall be protected by impermeable membrane and covered by roof so that it is not affected by rain.

• Oil pumps should be used to take out the oil from the container and no oil spillage shall take place.

• All the construction waste should be disposed properly after end of the day so that it may not create nuisance at site.

• Proper storage of fuel and lubricants

• Impermeable membrane used in flooring of storage yard to prevent soil and water pollution

• Construction waste disposal records

• Waste management plan

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• Soil and water pollution parameters shall be monitored as per the monitoring plan.

• Dispose waste oil and lubricants that have been generated as per provisions of Hazardous Waste (Management and Handling) Rules, 1989.

• Inspect all vehicles daily for fluid leaks before leaving the vehicle staging area, and repair any leaks before the vehicle resumes operation

• Strictly prohibit open defecation by workers in nearby areas

4.6 Siltation of drains/ water bodies due to spillage of construction wastes

• Silt fencing to be provided at construction sites during rain period to prevent sediments from the construction site to enter into the watercourses/ nearby settlements. The number of units of silt fencing to be installed is to be decided by the Engineer.

• Haul roads on the site and approaches to the watercourse (or drains leading to watercourses) will be regularly cleaned to prevent the build-up of mud; areas of bare soil will be kept to a practical minimum to reduce silt runoff.

• Extraneous construction wastes will be transported to the pre-identified disposal site for safe disposal.

• Site fencing

• Numbers of Silt traps constructed at site

• Proper drainage system provided at site

• Regular cleaning of drains during rain period

Contractor and PID

PMU

4.7 Emission from Construction Vehicles, Equipment and Machinery

• The discharge standards promulgated under the Environmental Protection Act will be strictly adhered to.

• All vehicles, equipment and machinery used for construction will conform to the relevant Standard.

• PUC available for all vehicles

• maintenance record of construction vehicles and equipment

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• All vehicles, equipment and machinery used for construction will be regularly maintained to ensure that pollution emission levels comply with the relevant requirements.

• All the construction vehicles shall have Pollution Under Control (PUC) certificates to check air pollution.

4.8 Erosion Hazards The resettlement site has a gentle slope and hence the risk of erosion is anticipated. Hence the Contractor will require to:

• Save topsoil removed during excavation and use to reclaim disturbed areas, as soon as it is possible to do so.

• Use dust abatement such as water spraying to minimize windblown erosion.

• Provide temporary stabilization of disturbed/excavated areas that are not active under construction.

• Apply erosion controls (e.g., silt traps) along the drainage leading to the water drains.

• Maintain vegetative cover within unused land to prevent erosion and periodically monitor the area to assess erosion.

• Clean and maintain catch basins, drainage ditches and culverts regularly.

• Conduct routine site inspection to assess the effectiveness and the maintenance requirements for erosion and sediment control systems

• Slope stability

• Frequent monitoring during the piling operation

• Monitoring noise and vibration

Contractor and PID

PMU

4.9 Pilling Operation (Noise and Vibration Impacts)

The Contractor should perform construction activities in a phased manner especially during drilling the piles, which

• Frequent monitoring during the piling operation

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may disturb the surrounding area due to vibration

• Monitoring noise and vibration

4.10 Generation of Dust • The contractor will take every precaution to reduce the levels of dust at construction sites to the satisfaction of the Engineer.

• All earth works to be protected / covered in a manner acceptable to the satisfaction of the Engineer to minimize dust generation.

• Clearance will be affected immediately by manual sweeping and removal of debris, or if so directed by the Engineer, the road surfaces will be hosed or watered using necessary equipment.

• Construction site shall regularly be wetted by sprinkling of water during dusty conditions especially during summer seasons and winds.

• Ambient Air Quality monitoring has to be performed as per the Environmental Monitoring Program as indicated in the Table 39.

• records of housekeeping

• records of water sprinkling at site

• vehicles carrying excavated soil covered

• AAQ parameters (Particulate matter (PM10 & PM2.5), SOx, NOx, CO) to be monitored (Table 39)

Contractor and PID

PMU

4.11 Noise from construction activities and equipment

• The Contractor will ensure appropriate noise monitoring is carried out continuously especially during piling works.

• Prior to any heavy equipment/machinery /piling works the contractor should inform surrounding areas as well and it will be prohibited at night. Specify the limit for noise for the piling works.

• Maintenance of vehicles, equipment and machinery will be regular and to the satisfaction of the Engineer, to keep noise from these at a minimum.


• exhaust silencers working properly

• use of proper PPEs as work sites

• Records of noise monitoring as per EMP and as set out in Table 39.

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• All vehicles and equipment used for construction will be fitted with exhaust silencers. During routine servicing operations, the effectiveness of exhaust silencers will be checked and if found to be defective will be replaced.

• Noise limits for construction equipment used in this project (measured at one metre from the edge of the equipment in free field) such as compactors, rollers, front loaders, concrete mixers, cranes (movable), vibrators and saws will not exceed 75 dB (A).

• Notwithstanding any other conditions of contract, noise level from any item of plant(s) will comply with the noise standards specified by CPCB.

• If specific noise complaints are received during construction, the Contractor may be required to implement one or more of the following noise mitigation measures, as directed by the Engineer:

• Shut off idling equipment.

• Reschedule construction operations to avoid periods of noise annoyance identified in the complaint.

• Notify nearby residents whenever extremely noisy work will be occurring.

• The Contractor shall provide necessary PPEs as per the direction of the environmental specialist (PID)

• The Contractor shall adopt IS 5121-1969 (Indian standard Safety Code for Piling and Other Deep Foundation Works) to

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ensure safety is maintained during the piling operations

• Ambient Noise levels has to be monitored as per the Environmental Monitoring Program

4.12 Impacts on flora and fauna • Strictly instruct workers not to cut trees for fuel wood

• Do not harm existing vegetation in the area except for those indicated in site plan

• Limit activities within the work area.

• Strictly prohibit poaching of birds and animals in the vicinity of work sites

• Baseline information of the flora and fauna for the project area

Contractor and PID

PMU

4.13 Material Handling at Site • All workers employed on mixing asphaltic material, cement, concrete etc., will be provided with protective footwear and protective goggles. Workers, who are engaged in welding works, will be provided with welder’s protective eye-shields. Workers engaged in stone breaking activities will be provided with protective goggles and clothing and will be seated at sufficiently safe intervals.

• use of proper PPEs as work sites

• records of PPEs procured and issued for use

Contractor and PID

PMU

4.14 Disposal of Construction Waste /Debris / Cut Material

• The waste generated will be reused in the construction activities, either as a fill material or otherwise, based on its suitability of reuse to the maximum extent possible.

• Safe disposal of the extraneous material will be ensured in the pre-identified disposal locations. In no case, any construction waste will be disposed around the project locations indiscriminately.

• records of excavated soil and

• records of reuse and disposal of excavated soil

• disposal site identified and approved

• AAQ parameters (Particulate matter (PM10 & PM2.5),

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• Burning of municipal solid waste or hazardous waste will be prohibited.

SOx, NOx, CO) to be monitored

4.15 Safety Measures During Construction

• Personal Protective Equipment (PPE) for workers on the project and adequate safety measures for workers during handling of materials at site will be taken up.

• The contractor has to comply with all regulations regarding safe scaffolding, ladders, working platforms, gangway, stairwells, excavations, trenches and safe means of entry and egress.

• Appropriate safety measures (including hard barriers) have to be adopted for the construction during the night time (Lux level shall be equivalent to a minimum of two 500 watt flood lights)

• use of PPEs


• compliance of all regulations regarding scaffolding, ladders and work at height

Contractor and PID

PMU

4.16 Risk caused by Force Majeure

• All reasonable precaution will be taken to prevent danger of the workers and the public from fire, flood, drowning, etc.

• All necessary steps will be taken for prompt first aid treatment of all injuries likely to be sustained during the course of work.

• records of first aid facilities at site

• records of safety training to workers

Contractor and PID

PMU

4.17 Malaria Risk • The Contractor will, at his own expense, conform to all anti-malarial instructions given to him by the Engineer; mosquito prevention at site should be done

• The frequency of the testing for malaria should be increased during the monsoon season

• records of use of mosquito prevention measures at site and work camps

• anti-malaria instructions to workers

Contractor and PID

PMU

4.18 Clearing of Construction Camps & Restoration

• Contractor to prepare site restoration plans for approval by the Engineer. The plan is to be implemented by the contractor prior to demobilization.

• restoration plan for site and work camps prepared

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• On completion of the works, all temporary structures will be cleared away, all rubbish should be removed, all rubbish should be removed, excreta or other disposal pits or trenches filled in and effectively sealed off and the site left clean and tidy, at the Contractor’s expense, to the entire satisfaction of the Engineer.

• restoration of site and work camps as per plan

4.19 Influx of migrant workers

• Local labourer’s to be given preference for job opportunities and each contractor should be bound by this commitment

• The Contractor has to adopt a Code of Conduct for the migrant labour to resolve any issues with locals

• Ensure labour-related regulations are met

• In case of hiring outside labour, ensure that their working conditions as well as camps meet local regulations and the best practices of the industry (refer to IFC Workers' Accommodation: Processes and Standards)

• Health and safety risks

• Chances of spread of sexually transmittable diseases like AIDS

• Water pollution

• Health & Safety Risks due to Transmittable diseases (HIV/AID and Covid-19) / awareness plan

Contractor and PID

PMU

Table 36: Environmental Management Plan for Operation and Maintenance - Kalanivasal, Sivaganga District


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1. Operation and Maintenance Impacts

1.1 Solid waste (debris, excavated soils, etc.)

• Re-establish the original grade and drainage pattern to the extent practicable.

• Restore access roads, staging areas, and temporary work areas.

• Pre-existing condition

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• Remove all tools, equipment, barricades, signs, surplus materials, debris, and rubbish. Demolish buildings/structures not required for O&M. Dispose in designated disposal sites.

• Request in writing from PID that construction zones have been restored.

1.2 Proposed Buildings/ Dwelling units may result congestion, increased pollution.

• Creating awareness through Consultation

• The 3 Rs (Reduce, Reuse, and Recycle) approaches have to be explained to the settled communities in order to reduce the pollution level (waste minimisation, water minimisation etc.,)

• The environmental monitoring action plan during the operation stage will result in monitoring of the environmental impacts after project implementation.

• Conducting regular consultations

• Monitoring plan during project operation

Social Team PID TNSCB/ Sankarapuram Panchayat

PMU

1.3 Rain water Harvesting Pit management

• Regular inspection and cleaning of catchment, gutters, filters and tanks reduce the likelihood of contamination.

• Water from other sources should not be mixed with that in the tank.

• Storm water drains will be maintained periodically to maintain free flow of storm water without any obstacles

• Monitoring plan during project operation

TNSCB/ Sankarapuram Panchayat

PMU

1.4 Management of the STP

• TNSCB/ Sankarapuram Panchayat will carry out regular maintenance of the STP to prevent any impacts, including pollution of ground water and nearby water courses.

• TNSCB shall appoint an Environmental Engineer with necessary qualification for the operation and maintenance of the STP, All the necessary PPE’s should be provided to the STP operator.

• proper sanitation and solid waste management


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• It is the sole responsibility of the TNSCB that the treated sewage water disposed (as per PART A Schedule VI of the Environmental Protection Rules 1986) for green belt development/ avenue plantation should not pollute the soil/ ground water/ adjacent canals/ lakes/ ponds, etc.

• The excess treated water will be discharged into the Underground Drainage system

• Any sludge after anaerobic treatment and drying will be disposed with the municipal solid waste (organic waste). The treated sludge shall be as per compost quality standard given in the Solid waste management rules 2006 (schedule II A, standards for composting).

• Workers who interact with any sludge will be provided all appropriate PPE’s including gloves, safety shoes, protective eyewear and masks.

1.5 Unhygienic condition due to poor maintenance of sanitation facilities and irregular solid waste collection in the project site necessitate regular maintenance of constructed amenities.

• TNSCB/ Sankarapuram Panchayat will carry out maintenance of the sewer system (including the pipeline, collection system etc.,), and carry out the regular collection of wastes, and will also ensure that Sanitation improvements proposed do not result in pollution of groundwater.

• Sanitary facilities do not interfere with other utilities and block access to buildings, cause nuisance to neighbouring areas.

• Household hazardous waste such as batteries, small electronics, CFL bulbs, expired medicines and used cleaning

• proper sanitation and solid waste management


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Implementation

Responsibility for

Supervision

solvent bottles should be segregated at source, collected once in a month from residences and disposed as per the SWM Rules 2016.

• Municipal Solid Waste will be segregated as organic waste and inorganic waste. Both organic and Inorganic waste will be collected by the Sankarapuram Panchayat, Organic waste will be composted in the vermicomposting / biodegradation process and will be used as a manure. The inorganic waste will be disposed off in the MSW dumping area.

• The transfer of waste will also ensure no spillage and all wastes will be transported to a designated solid waste treatment site.

1.6 Fire fighting / Emergency preparedness

• Fire fighting equipment’s including the fire extinguisher and sand buckets has to be annually maintained. Fire extinguishers have to be checked regularly for the expiry date and has to be refilled or replaced accordingly. Wet sand (if any) in the bucket should be replaced with dry sand

• Fire mock drills should be conducted as a part of emergency preparedness to create awareness among the residents

• Fire extinguisher expiry date

• Emergency preparedness plan

• Training records

Contractor (during the DLP) TNSCB/ Sankarapuram Panchayat

PMU

Table 37: Environmental Management Plan for Building Demolition Works (Encroachment Sites Identified for Relocation)

Sl.no Environmental Issues Mitigation Measures Indicators and Targets Responsibility for

Implementation

Responsibility for Supervision

Pre-construction Stage

118


Implementation


1. Consent, NOCs, Permissions and SEMP

• Contractor should obtain Permissions/ NoC from the TNPCB if the construction and demolishing waste (C&D) is equal to or greater than 20 tons per day or 300 tons per project in a month

• Before the dumping of the demolition waste, an agreement with the municipality/ panchayat and concerned agencies to dispose the debris should be obtained and be included in the EMP/SEMP.

• Contractor shall undertake a COVID risk assessment of project area and prepare a COVID Response and Management Plan (C-R&MP) and submit to Karakudi Municipality/PID for approval

• Obtain labour insurance and labour licences for workers involved in the demolishing activities which should be included in the SEMP.

• Submission and approval of updated EMP/ SEMP prior to starting of work to the Karakudi Municipality/PID.

• Conduct consultation with the local communities and provide detail in the language that is understandable to the local community regarding project activities and the anticipated impacts as part of the project information dissemination (prior to

• Estimated quantity of the Construction and Demolition Waste

Demolition Contractor / Municipality

PID/PMU

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Implementation


the start of the demolishing activity).

• Display the project related information including the GRM details at the project (demolishing) site.

2. Clearing of trees/ Removal of vegetation

• All reasonable measures shall be undertaken to ensure that no native fauna is harmed or placed at risk during the course of the demolishing activities However, under unavoidable conditions if any of the trees are required to be cut/ felled, then prior permission as per existing procedure from Forest department, ensuring appropriate compensation including compensatory plantation at 1:10 ratio as stipulated by the High Court of Madras (WP No 7811/2010 and MP No 1/2010 dated 25/06/2010).

• Tree count information and compensation ratio


PID/PMU

3. Assessment of Environmental Parameters

• Baseline parameters for Water quality and Soil quality have to be assessed prior to commencement of work.

• Water and Soil quality parameters


PID/PMU

4. Asbestos containing materials (ACM)

• Hire an Asbestos Expert to undertake training for all workers / contractors in identifying existing ACM and on Occupational Environment, Health and Safety related to potential hazardous material exposure (refer to TOR included as an Appendix 12 of EARF)

• Conduct detailed walk over survey by ACM expert to

• Inventory of structures using Asbestos as celling or roofing materials

• Estimation of quantity of ACM

• Disposal mechanism / plan under the guidance of the Asbestos Expert.


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Implementation


ascertain the location of any ACM prior to any demolition activity

• Demolition works conducted without disturbing any ACM

• Support contractor assigned person (Contractor ACM) in conducting site assessment (across selected encroachments), developing inventory of existing ACM including tagging and marking locations of existing ACM in all site maps.

• Develop ACM management plan /protocol for compliance with asbestos policies of major

international agencies21 and national requirements

• Submission of site assessment, inventory, and ACM management plan to TNSCB PMU for review and approval

• Contractor-ACM to carry out general awareness campaigns on ACM exposure for field staff and community

• Conduct training of workers on

ACM during orientation / induction

Construction Stage

5. Potential adverse impact on sensitive receptors

• Demolition works to avoid sensitive receptors such as Physical Cultural Resources

• List including a map with (geo-cordinates) showing PCRs in the demolition area


PID/PMU

21 In the USA, standards and approaches for handling asbestos are prescribed by the Occupational Health and Safety Administration (OHSA) and the Environmental

Protection Agency (EPA) and can be found at http://www.osha.gov/SLTC/asbestos

121


Implementation


(PCRs) and will specifically exclude: o Religious structures e.g.

chapels, temples, mosques, etc.

o Avoid cutting trees o Any damage to surrounding

or properties needs to be rectified immediately

• Preparation of Contingency plan for conservation of the PCRs

6. Air, noise and dust pollution during the dismantling of the building

• Prior information to the adjacent settlements/ residence regarding the demolishing process, scheduling of the activities etc.

• Water spraying at the demolition site

• Fencing / Install barriers (GI sheets, geo-net) especially at the building facing the road side) to shield from dust and aggregates

• Avoid usage of machines/equipment with extra noise;

• Do not accumulate and burn waste at the site

• Carry out demolition activities stage wise, give adequate notice and information of activities to the adjoining stakeholders

• Provide project-related information to stakeholders, communities and/or affected people before and during construction works including at least 7 days prior to the start of works and again at least 1 day prior to works through issuing a

• records of housekeeping




• Covered vehicles carrying the excavated soil

• records of Noise and Air Quality monitoring as per EMP as listed out in Table 39.

• Contractor consultation records


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Implementation


pamphlet booklet to affected persons

• Manual demolition methods shall be preferred and only if justified due to safety issues minimal use of machinery and equipment with safety precautions will be utilised.

• Erecting barricades around demolition sites and restricting pedestrian and vehicular movements.

• Any damage to surrounding buildings will require work to be stopped immediately and rectified before work can recommence.

• Noise level from any item of plant(s) or machinery will comply with the noise standards specified by CPCB.





• Noise level measurements shall be taken once before the start of the demolition works to establish

123


Implementation


the baseline; and daily during demolition works


7. Impacts on the existing public utilities

• Public utilities like road, electric poles, telecom poles will not be disturbed from the demolition activities. However, if it is disturbed, the Contractor should inform the appropriate agency and immediately the issues should be rectified. Till that time the demolition activity should be put on hold.

• List showing utilities in the demolishing area

• Contingency plan for services disruption

Demolition Contractor/ Municipality

PID/PMU

8. Land and Water Pollution • Identify proper location to dispose wastewater from demolition and other activities in consultation with respective local bodies

• Silt fencing should be provided surrounding the water body to prevent surface runoff from the demolishing site entering the water bodies

• Dispose the waste water in identified location considering the environment and safety aspects

• Prohibit the contamination of groundwater

• Hazardous waste (Asbestos) should be stored separately and it should be handed over to the authorised Hazardous waste handling agency (as approved by TNPCB)

• Site fencing

• Numbers of Silt traps constructed at site

• Proper drainage system provided at site

• Regular cleaning of drains during monsoon period

• Inventory details of the Hazardous waste (Asbestos)

• Use site photographs and baseline information (chapter 4) for selection of site for dumping construction and demolishing wastes


PID/PMU

124


Implementation


• Before the dumping of the demolition waste, an agreement with the municipality/ panchayat and concerned agencies to dispose the debris should be obtained prior to any demolition activity occurring.

• Designated site for disposal should be identified in coordination with ULB

9. Waste generation (including demolition debris/ waste) and improper disposal

• Develop and Implement Waste Management Plan for demolition works in consultation with Municipality / Panchayat

• Demolition stage: o Transport of recyclables

/scrap/ discarded equipment either to identified depots or to be handed over to subproject beneficiaries for use or re-sale

o Store all refuse and construction & demolition debris / waste generated on demolition sites away from water bodies / water sources / drainage and in designated areas and remove them from these locations for disposal to approved disposal sites or re-use for backfilling / site reclamation

o Maximize the re-use of spoils, construction & demolition debris / wastes to minimize waste disposal

• records of excavated soil and


• Identification and approval of disposal site

• Waste Management Plan


PID/PMU

125


Implementation


o For construction & demolition debris / waste, licensed companies will be hired to collect, transport and dispose of wastes at licensed dump facilities

o Biodegradable waste such as cleared vegetation may be provided to local communities for use

o The proponent shall provide the dispenser for the disposal of Sanitary Napkins

o Waste burning will be prohibited

o No final waste disposal on site / off-site unless in approved disposal facilities / landfills

o Comply with the ban on one time use and throwaway plastics under Tamil Nadu Government Order

10. Disturbance to the local Population and pedestrians

• Install corresponding signs, hoarding boards, organization of bypasses (as per the MoRTH specifications).

• Install barriers (GI sheets, geo-net) especially for the building facing the road side to shield from dust and aggregates

• Provide adequate street lighting, hard barricading at demolition site for the night to prevent accident

• Conduct consultation with the local communities and provide detail in the language that is

• Site work plan prepared by Demolition Contractor and approved by ULB

• Traffic plan and records of road signage’s


PID/PMU

126


Implementation


understandable to the local community regarding project activities and the anticipated impacts as part of the project information dissemination (prior to the start of the demolishing activity).

• Display the project related information including the GRM details at the project (demolishing) site.

• Demolition activity should not be carried out in the night time (as per the labour law and 8 hours working time should be adopted)

11. Noise and Vibration Impact • Precaution will be taken while using the machines and equipment, during demolition

• Before any works commences, conduct situation analysis in the subproject area of influence for checking structural integrity of nearby building that may be affected by vibration during demolition works. This includes taking appropriate photos and videos.

• Noise level measurements shall be taken once before the start of the demolition works to establish the baseline; and daily during demolition works

• Contractor will be responsible for creating awareness among the operators to ensure careful handling of machines and equipment and heavy vehicles


• records of noise monitoring as per Table 39

• contractor site and consultation records


PID/PMU

127


Implementation


like excavators and dump trucks during mechanical demolition

• The contractor will inform the surrounding settlements/ residences and community in prior to operations that bear the risk of nuisance and accidents.

• The contractor shall maintain the records of the consultations including dates, names and actions agreed to.

• The contractor will be responsible for compensating if there are any damage to structures due to vibration resulting from demolition.

• Any damage to surrounding buildings will require work to be stopped immediately and rectified before work can recommence.


12. Traffic and pedestrian road congestion

• Traffic congestion near the entry and exit points from the roads adjoining the proposed project site must be avoided

• The transportation vehicles will be parked within the premises of demolishing site

• Prohibit the parking of the transportation vehicles outside the demolition site

• Put hoarding board to inform the pedestrian, road users and


• contractor site specific plan


PID/PMU

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Implementation


adjacent commercial shops/ offices about the activities The mitigation activities should be recorded and documented.

13. Safety for the Demolition Workers

• Prepare H&S plan and include the measures such as (i) type of hazards during demolishing works; (ii) corresponding personal protective equipment for each identified hazard; (iii) H&S training for all site personnel; (iv) procedures to be followed for all site activities; and (v) documentation of work-related accidents

• An environment, health and safety site officer should also be nominated by the demolition contractor.

• Make mandatory the use of safety gears/ PPEs (helmets, safety belts, masks, gloves and boot) by workers depending on nature of work.

• Necessary planning and safety approach will be made for rescue during emergency.

• The ULB will have to check whether the provisions made in the Construction Safety Plan are implemented accordingly.

• Workers will be provided with first aid and health facilities at the site.

• There will be provision for group accidental insurance for the workers.

• use of PPEs


• EHS training records

• compliance of all regulations regarding ladders, work at height etc


PID/PMU

129


Implementation



• Child labour is strictly prohibited in all the activities executed by the Contractors

• penalty for non-compliance to be tied with payment withholding and/or termination of contract

• Respective provisions will be included in the contract document with contractor.

14. Impacts due to the Transportation from the Demolition area

• The transportation of the waste and other materials should be in safe manner considering the rule of road traffic.

• The schedule for the transportation should be made not to coincide during peak traffic hours,

• Safety measures to be considered while transporting the materials

• Covering the trucks with plastic sheets to prevent dust pollution and other hazards

• Temporary Traffic Management Plan


PID/PMU

15. Site selection of waste disposal

• The waste from the demolition activities will be disposed on the prescribed area in consultation with municipality/ panchayat.

• The waste disposal should not be near to any type of water resource or environmentally sensitive area

• Disposal area should be far from the community and settlement

• Disposal site selected and approved by ULB

• Records of materials disposed at disposal site

• Log book maintained for debris disposal


PID/PMU

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Implementation


• The disposal of waste should not further deteriorate the surrounding environment.

• The identified site should be approved by the ULB

16. Construction Site Restoration

• Contractor to prepare site restoration plans for approval by the PID. The plan has to be implemented by the contractor before demobilization

• On completion of the works, all rubbish/ construction debris, other disposal pits or trenches filled in and effectively sealed off and the site left clean and tidy, at the Contractor’s expense, to the entire satisfaction of the PID.

• Visual observation (before and after site photos for record)


PID/PMU

17. Labour Requirements • The Contractor, for any unskilled labour, should draw from the local communities to avoid any additional stress on the existing facilities (medical services, power, water supply, etc.)

• The Contractor shall provide training to build the skills of locally-recruited labour.

• As per the contractual obligations


PID/PMU

18. Social and Cultural Resources

• No cultural properties or religious structures shall be removed or relocated without the knowledge and written consent of the concerned parties or communities and local administration as the case may be. Sites for the relocation of these religious structures shall be identified following the choice of the community.

• Chance find protocol Demolition Contractor / Municipality

PID/PMU

131


Implementation


• As far as possible, the architectural elements of the structure should be conserved/reflected/translated into the design of new structures following the wishes of the community

• For any Chance find, consult Archaeological Survey of India (ASI) or Tamil Nadu Archaeology Department to obtain an expert assessment of the archaeological potential of the site.

• Consider alternatives if the site is found to be of medium or high risk.

• Include state and local archaeological, cultural and historical authorities, and interest groups in consultation forums as project stakeholders so that their expertise can be made available.

• Develop a protocol for use by the

construction contractors in

conducting any excavation work,

to ensure that any chance finds

are recognized and measures are

taken to ensure they are

protected and conserved.

132

Table 38: Environmental Management Plan for Regeneration Works Sl.no Environmental Issues Mitigation Measures Indicators and

Targets Responsibility

for Implementation


1. Pre-Construction

1.1 Assessment of Environmental Parameters

• Baseline parameters for Water quality and Soil quality have to be assessed prior to commencement of work.

• Water and Soil quality parameters

Contractor / Municipality

PID/PMU

1.2 Consent, NOCs, Permissions and SEMP

• Contractor should obtain Permissions/ NoC from the TNPCB if the desilting material is equal to or greater than 20 tons per day or 300 tons per project in a month

• Before the disposal of the desilting materials/ silt waste, make an agreement with the municipality/ panchayat and concerned agencies to dispose the debris.

• Obtain labour insurance and labour licence for the workers involved in the demolishing activities

• Submission and approval of updated EMP/ SEMP prior to starting of work to the Karaikudi Municipality

• Operation and maintenance plan should also be prepared prior to completion of construction

• Estimated quantity of the Construction and Demolishing Waste

• Operation and maintenance plan

• Written agreement on disposal of construction and demolition waste

• Approved SEMP by PID

Contractor/ Municipality

PID/PMU

1.3 Workers camp / labours accommodation

• Provide water and sanitation facilities (situated separately for men and women); regular cleaning and disinfection of site

• Provide adequate electricity / lighting

• Provide potable water / storage tanks

• Conduct regular health check-up / provide access to medical care


• The proponent shall provide the dispenser for the disposal of Sanitary Napkins


• Construction camp having all the basic amenities with proper sanitary conditions drainage and watery supply


PID/PMU

133


Responsibility for

Implementation


• Provide solid waste bins and collection; no final disposal on-site or burning of wastes is allowed in the workers camp / labours accommodation

• Comply with the ban on one time use and throwaway plastics under Tamil Nadu Government Order

• Discharge construction / workers camp sewage / wastewater into onsite septic tanks or connect to local public sewer system

• Contractor health and waste disposal records

1.4 Lack of sufficient design and planning to ensure long term sustainability and protection of assets created

• Develop and Implement Regeneration Works Standard Operation & Maintenance Plan (SOMP), including a minimum: o Clearance and fencing o Re-greening / re-vegetation of banks

/ land along water bodies and channels

o New plantations with native species o Implement site specific plans in close

coordination with municipality e.g. waste management plan, sewerage collection and management plan, etc

o Preference should be given to low GHG embedded materials.

o The possibilities of using local materials or recycled materials should be explored.

• Detailed design/ master plan for regeneration works


PID/PMU

2. Construction Stage

2.1 Permissions from various departments

• During construction, the permits obtained by the contractor shall be periodically examined and validity be ensured. This includes the Consent for the Batching plants from where the contractor sources the concrete, Labour License, insurances etc.

• Maintain record for validity information with respect to the permissions/ NoCs


PID/PMU

134


Responsibility for

Implementation


2.2 i. De-silting of lakes ii. Construction of

diversion drains iii. Strengthening of

bunds

• The desilted earth should be disposed in a designated area in consultation with the Municipality/ Panchayat

• The Contractor should make sure that no appreciable change to the drainage course shall occur due to the construction of diversion channel.

• Wetting of soil before trench excavation, wetting of brick, metal and sand before handling

• Construction residues such as metal cuttings/ shavings, wood, packing materials and containers should be disposed as per applicable legal requirements (please refer Table 4)

• Maintain record of de-silted soil quantity

• Record for solid waste management at site


PID/PMU

2.3 Transportation of Construction materials

• Traffic congestion near the entry and exit points from the roads adjoining the proposed project site must be avoided

• Vehicles transporting construction materials prone to fugitive dust emissions should be covered

• Trucks carrying sand should be provided with tarpaulin sheets to cover the bed and sides of the trucks

• Idling of delivery trucks or other equipment should be avoided during loading and unloading operations

• Sprinkling of water (for materials such as blue metal, sand and brick) before unloading to suppress dust generation

• Adequate care should be taken to prevent spillage of earth or construction materials offsite and in haul routes. Any such spillage should be removed immediately, and the area cleaned

• Maintain records of housekeeping

• records of water sprinkling

• covered vehicles carrying Construction materials


PID/PMU

135


Responsibility for

Implementation


2.4 Storage of construction materials

• Construction materials should be stored within the project area, without affecting the traffic and other common utilities.

• Storage of materials for regeneration works should be confined to work sites, so that there is no obstruction to natural drainage pattern at site; and they should be covered to reduce dust generation

• Maintain register for construction materials


PID/PMU

2.5 i. Management of Excavated silt

ii. Construction debris and excavated materials

• The excavated silt should be transported in covered trucks and register should be maintained at the site.

• Excavated silt is removed from the site every day preventing storage

• Location for disposal of excavated silt should be identified in consultation with the Municipality/ Panchayat

• Floating materials like plastics, weeds should be sent to the SWM (composting and plastic segregation) facility of the municipality.

• The Contractor should ensure that silt is dry during transportation to the disposal site and dripping shall not be permitted.

• Maintain records of excavated soil


• disposal site identified and approved


PID/PMU

2.6 Traffic Management • Traffic management should be in place by the Contractor with adequate placement of traffic signals and traffic control personnel, when the vehicles are passing through the local roads and near the project sites. Transportation of the construction materials to project sites and excavated silt/ wastes for disposal covered trucks shall be during non-peak hours

• Temporary Traffic Management Plan


PID/PMU

2.7 Nuisance to neighbourhood community

• If possible, the materials should be transported through the temporary approach road formed without disturbing the neighbourhood community

• maintenance record of construction


PID/PMU

136


Responsibility for

Implementation


• Safety hard barricading should be provided while construction of drains near the structures restricting entry to work place and signages should be placed.

• Work site lighting during night where ever required should be provided during the implementation.

• Adequate slope gradient should be maintained while strengthening the bund while working in the boundary of the site

• Storage of materials should be within the earmarked areas of project area, without disturbing the nearby community

• Conduct consultation with the local communities and provide detail in the language that is understandable to the local community about project activities and the anticipated impacts as part of the project information dissemination (prior to the start of the demolition activity)

• Display the project related information including the GRM details in the project (demolishing) site.

• Demolition activity should not be carried out at night (as per the labour la and 8 hours working time should be adopted)

vehicles and equipment

• records of noise monitoring as per EMP

• contractor consultation records

2.8 Operation of construction machinery

• All construction vehicles should comply with emission standards and be maintained properly. Wind shields or barriers (GI sheets, geo-net) should be installed all along the site boundary to abate the dust carried over to the neighbouring areas.

• Use of ready-mix Concrete wherever possible shall be explored. In the case of use of Concrete Mixer, Concrete Mixer

• PUC available for all vehicles


• records of water sprinkling


PID/PMU

137


Responsibility for

Implementation


should be mounted on shelter with top and sides closed.

• Sprinkling of water on metal & sand should be carried out before handling

2.9 Dust Pollution near settlements

• All earth work should be protected/ covered to minimize generation of dust.

• Area under construction should be covered & equipped with dust collector.

• Construction material should be covered or stored in such a manner so as to avoid spreading of dust by wind.

• Unpaved haul roads near / passing through residential and commercial areas to be watered thrice a day.

• Trucks carrying construction material to be adequately covered to avoid the dust pollution and to avoid the material spillage.

• Maintain records of housekeeping




• covered vehicles carrying excavated soil

• records of Air Quality monitoring as per EMP


PID/PMU

2.10 Vehicular noise pollution at residential / neighbouring settlements

• Maintenance of vehicles, equipment and machinery should be regular to keep noise from these at a minimum.

• All vehicles and equipment used for construction should be fitted with exhaust silencers. During routine servicing operations, the effectiveness of exhaust silencers should be checked and if found to be defective, it should be replaced.

• Notwithstanding any other conditions of contract, noise level from any item of plant(s) will comply with the noise standards specified by CPCB.

• Maintenance record of construction vehicles and equipment

• Exhaust silencers working properly

• Records of noise monitoring as per EMP


PID/PMU

138


Responsibility for

Implementation






2.11 Chance finds • Construction contractors to follow these measures in conducting the excavation work o All fossils, coins, articles of value of

antiquity, structures and other remains or things of geological or archaeological interest discovered on the site shall be the property of the Government and shall be dealt with as per provisions of the relevant legislation.

o The contractor will take reasonable precautions to prevent his workmen or any other persons from removing and damaging any such article or thing. He will, immediately upon discovery thereof and before removal acquaint the ULB of such discovery and carry out the instructions for dealing with the same.

o Stop work immediately to allow further investigation if any finds are suspected;

o Create awareness among the workers, supervisors and engineers about the chance finds during excavation work.

• Maintain record for the Chance find


PID/PMU

139


Responsibility for

Implementation


The ULB will inform State Archaeological Department if a find is suspected and seek direction from the Department prior to recommencing the work.

o Develop a protocol for use by the construction contractors in conducting any excavation work, to ensure that any chance finds are recognized and measures are taken to ensure they are protected and conserved

2.12 Pollution from Fuel and Lubricants

• Contractor shall ensure that all vehicle/machinery and equipment operation, maintenance and refuelling will be carried out in such a fashion that spillage of fuels and lubricants does not contaminate the ground.

• Contractor will arrange for collection, storing and disposal of oily wastes to the pre-identified disposal sites

• Proper storage of fuel and lubricants

• Impermeable membrane used in flooring of storage yard to prevent soil and water pollution


PID/PMU

2.13 Site clearance/ levelling • Sprinkling of water to reduce dust generation.

• All vehicles, equipment and machinery to be procured for construction shall confirm to the relevant Bureau of Indian Standards (BIS) Norms and relevant emission/safety norms and/or standards

• Maintain record for water sprinkling and

• Records of PUCs for construction vehicles and equipment


PID/PMU

2.14 Identification and selection of Quarries

• The Contractor will identify materials from existing licensed quarries

• Maintain record of MoU/ NOCs/ Consent from TNPCB for the quarries


PID/PMU

2.15 Labour requirements and facilities

• The contractor should engage local labours to avoid conflict with local communities

• Maintain labour register


PID/PMU

140


Responsibility for

Implementation


• The contractor has to adopt a Code of Conduct for the migrant labours to sort out any issues with the locals

• Labour camp (if any) should be provided with water and sanitation facilities.

• All the basic amenities as mentioned in the Factory Act, BOCW Act and Safety, Health & Welfare at Work (Construction) Regulation 2013, should be provided by the contractor

2.16 Occupational health and Safety

• Prepare H&S plan and include the measures such as (i) type of hazards during demolishing works; (ii) corresponding personal protective equipment for each identified hazard; (iii) H&S training for all site personnel; (iv) procedures to be followed for all site activities; and (v) documentation of work-related accidents

• An environment, health and safety site officer should also be nominated by the contractor.

• Workers should be provided with necessary occupational health and safety equipment such as protective face mask, head gear, eye shields / protective goggles and safety gloves etc.

• Emergency contact numbers including Ambulance should be displayed at the project site and labour accommodation. First aid will be made available at site.

• Health check-up for the labourers should be carried out periodically due to exposure to slushy soil.

• Maintain records on accidents, near misses

• Approved health and safety plan


PID/PMU

141


Responsibility for

Implementation


• Elevated platforms should be equipped with handrails, toe boards and non-slip surfaces

• Personal Floatation devices (life vests), First Aid Kits, Fire Extinguisher, Tow rope, etc. shall be provided on vehicles / floats while working near water filled portions of the water body

2.17 Safety Measures During Construction

• Personal Protective Equipment (PPE) for workers on the project and adequate safety measures for workers during handling of materials at site will be taken up.

• Adequate strutting should be provided to avoid collapse of soil.

• The contractor has to comply with all regulations regarding safe scaffolding, ladders, working platforms, gangway, stairwells, excavations, trenches and safe means of entry and egress.

• The used construction materials including nails, wooden pieces and other waste generated should be immediately removed from the work site after completing the construction work

• Wherever required, signages, reflectors and work site lighting should be provided

• use of PPEs


• compliance of all regulations regarding scaffolding, ladders and work at height


PID/PMU

2.18 Barricading site • The construction site should be barricaded with adequate marking, flags, reflectors etc. for safety of general traffic movement, neighbouring settlements and pedestrians

• Maintain record and to replace the damaged / broken reflector/ barricade tapes


PID/PMU

2.19 Clearing of site and restoration

• On completion of the works, the left-over construction materials should be removed by the contractor from project site for reuse/ proper disposal.

• Site photographs, before and after completion of the works


PID/PMU

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Responsibility for

Implementation


• All temporary structures will be cleared away, all rubbish cleared, excreta or other disposal pits or trenches filled in and effectively sealed off and the site left clean and tidy, at the contractor’s expenses, to the entire satisfaction of the ULB.

• Site inspection report

Table 39: Pre-construction and Construction Stage Environmental Monitoring Plan

Monitoring Field Monitoring Location Monitoring Parameters Frequency Responsibility

Construction

disturbances,

nuisances, public and

worker safety

All work sites ((i) Construction

site at Kalanivasal, (ii)

Building Demolition Works

(11 sites) in Karaikudi and (iii)

Water body Restoration

Works (11 sites) in Karaikudi

(i) Implementation of

construction stage EMP

including dust control,

noise control, traffic

management, and safety

measures.

(ii) Site inspection checklist

to review implementation

is appended at Appendix

20

Weekly during

construction

Contractor under the

supervision of PID

(sampling locations shall be

identified by the

Environment specialist of

PID)

Ambient air quality Pre-Construction Stage: one

sample at each location

Construction stage: two

samples at each location

Sampling locations:

(i) Construction site at

Kalanivasal,

(ii) Building Demolition Works

(11 sites) in Karaikudi

(iii) Water body Restoration


• PM10, PM2.5 NO2, SO2 and CO

(i) Once before start of

construction (pre-

construction)

(ii) Monthly monitoring

during peak

construction activity,

which will be followed

by quarterly

monitoring (till the

project completion).


supervision of PID


identified by the


PID). The environmental

specialist (PID), shall

decide the frequency of the

monitoring as per the

construction schedule

143


Sampling method:

At the work sites during pre-

construction stage and 50 m

downwind direction near the

work sites during the

construction stage

Ambient noise Similar to ambient air quality

locations and sample size

including methodology.

• Day time and night time noise levels

(i) Once before start of

construction (pre-

construction)

(ii) Monthly monitoring

during peak

construction activity,

which is followed by

quarterly monitoring

(till the project

completion). For

demolition this will be

daily during the

construction period.


supervision of PID


identified by the


PID). The environmental

specialist (PID), shall

decide the frequency of the

monitoring as per the

construction schedule

Surface water quality Pre-Construction Stage: one


Construction stage: One


Sampling locations:

(i) At the irrigation tank near

construction site at

Kalanivasal,

(ii) Building Demolition Works

(11 sites) in Karaikudi

(iii) Water body Restoration


• pH, Oil and grease, Cl, F, NO3, TC, FC, Hardness, Turbidity BOD, COD, DO, E-coli, Total Alkalinity, Heavy metals and Pesticides.

Every quarter during

construction stage (till

the project

completion)


supervision of PID


identified by the


PID)

Environmental

statement for each

TNSCB official website • As per Environment (Protection) Rules, 1986

Annual (Financial

Year)

PID/ PMU

144


financial year ending

31 March in Form V

Table 40: Operation Stage Environmental Monitoring Plan

Monitoring field

Monitoring location Monitoring parameters Frequency Responsibility

Ambient air

quality

Two samples at Kalanivasal

resettlement site

Sampling method:

one sampling location should be

located at 50 m downwind

direction from the Kalanivasal site

and another sampling location

should be located within the

premises

• PM10, PM2.5 NO2, SO2 and CO Every quarter

during

operation (for 2

years)


supervision of PID during

the DLP

Ambient noise Similar to ambient air quality

location and sample size and

same methodology.

• Day time and night time noise levels Every quarter

during

operation (for 2

years)



the DLP

Surface water

quality

One sample at the irrigation tank

near Kalanivasal resettlement site

One sample at each water body

restoration site

• pH, Oil and grease, Cl, F, NO3, TC, FC, Hardness, Turbidity BOD, COD, DO, E-coli, Total Alkalinity, Heavy metals and Pesticides.

Every quarter

during

operation (for 2

years)



the DLP

Water quality

(potable water

supplied by

TWAD)

Operation Stage: One sample at

each water sump

• pH, Oil and grease, Cl, F, NO3, TC, FC, Hardness, Turbidity BOD, COD, DO,E-coli, Total Alkalinity ,heavy metals and pesticides.

Monthly

monitoring

TWAD under the

supervision of PID’s (Cost

for monitoring should be

borne by the TWAD)

STP (Treated

Water)

Operation Stage: Two water

samples to be collected at (i) Inlet

and (ii) outlet from the STP.

• Total suspended solids, pH, Oil and grease, Ammonical nitrogen, Biochemical Oxygen, Dissolved

Monthly

monitoring

STP service provider/ third

party monitoring under the

supervision of PID’s (Cost

for monitoring should be

145

Monitoring field

Monitoring location Monitoring parameters Frequency Responsibility

One sludge sample should be

collected

Oxygen, and Phenolic compounds (as C6H5OH)

• Sludge sample should be tested for Fecal Coliforms/ pathogenic bacteria

borne by the STP service

provider)

Environmental

statement for

each financial

year ending 31

March in Form V

TNSCB official website • As per Environment (Protection) Rules, 1986

Annual

(Financial

Year)

PID/ PMU

146

B. Implementation Arrangements

172. TNSCB will be responsible for the management, coordination and execution of all subproject activities funded under IRSHUPSP. The Government of Tamil Nadu has approved the formation of the Project Management Unit (PMU) for the project vide G.O.(2D) No.27, H&UD(SC2(2)) Department, dated: 12.02.2019. The PMU will be headed by Joint Managing Director/ Project Director and be supported by technical, financial, safeguards and administrative staff. 173. Project Management Unit (PMU). The PMU will be headed by Joint Managing Director/ Project Director and will be assisted by the Chief Engineer, Superintending Engineer and the Executive Engineer. The PMU will design the infrastructure, manage the tendering of contracts, supervise the construction / demolition process, assure the technical quality of design and construction, provide advice/ assistance on institutional capacity development and ensure subproject compliance to ADB 2009, EARF, RF and loan covenants. The PMU shall appoint the contractors to build the infrastructure elements and will manage the construction and commissioning activities. The PMU will seek Government clearance for submission and disclosure of the environmental, social and resettlement monitoring reports to ADB. To ensure effective implementation of environmental safeguards procedures, an environmental consultant will be assigned to the environmental team of the PMU. The environmental consultant will be supported by an Assistance Executive Engineer and two (2) Assistant Engineers who will be full time employees of the TNSCB. The PMU will be responsible for the following environmental safeguard activities:

(i) Ensure subproject compliance to GOI, GoTN statutory and legal environmental requirements, ADB SPS 2009, the project EARF, and loan covenants

(ii) Ensure subprojects conforms to exclusion criteria and subproject selection guidelines as stipulated in the EARF

(iii) Review and approve subproject category for environment (iv) Review and approve subproject IEE studies and reports and EMPs; ensure that

updated subproject IEEs and EMPs reflect final subproject detailed design and submit to ADB for approval

(v) Check whether all relevant permits / environmental clearances /approvals as per GoI and GoTN are obtained in a timely manner

(vi) Ensure that full IEE studies and EMPs are included in bidding documents, contract clauses and civil works

(vii) Ensure an efficient subproject implementation in line with IEE studies and reports and EMPs with adequate budget

(viii) Review and approve quarterly environmental monitoring reports submitted by PIDs (Environment / Social Cell) and submit to ADB

(ix) Support the preparation of quarterly and annual monitoring reports and submit to ADB

(x) Ensure effective GRM set up and monitor grievances redress process and ensure timely redress

(xi) Ensure adequate awareness campaigns, information disclosure and additional consultations are held within affected communities / host communities to minimize resistance and ensure hassle free transition for the project beneficiaries to new resettlement sites.

(xii) Periodical review of safeguards related loan covenants, and the compliance in project implementation

147

(xiii) Organize periodic capacity building and training programs for subproject staff in safeguards

(xiv) Ensure that subproject activities are synchronized between the RPs and EMP implementation

(xv) Ensure that any damage to areas and infrastructure outside the agreed work sites (Corridor of Impact assessed in RP) will be restored to pre-construction conditions and will be subject to compensation at contractor cost and through written agreement with the land owner, as applicable

(xvi) Ensure availability of budget for safeguards activities (xvii) Ensuring disclosure of EARF, IEEs and EMPs, and monitoring documents (xviii) Ensure that IEE studies and GOI EIA studies for a subproject is prepared

concurrently to avoid any inconsistencies and ensure robust environmental assessment is undertaken.

174. Project Implementation Unit Circle and Project Implementation Divisions (PIDs). The PMU will be supported by the Project Implementation Unit Circle (PIU) and a total of three (3) PIDs, established at Madurai, Salem and Villupuram for implementation of IRSHUPSP. The Superintending Engineering of the PIU Circle will be in charge of all PIDs in the Circle. Each of the PIDs will be headed by an Executive Engineer. The PIU Circle and PIDs will be responsible for the implementation, management and monitoring of the subprojects and supervision of contractors and all day-to-day activities in the field. The PID located in Madurai will be responsible for implementation, management and monitoring of the Kalanivasal Resettlement site. 175. To ensure effective implementation of environmental safeguards procedures, three (3) environmental specialists will be hired as independent consultants and assigned to the Environment Cell of each PID. The environmental specialist will be supported by one (1) Assistant / Junior Engineer that will be full time employee of the TNSCB. PID (Environment Cell) will be responsible for the following environmental safeguard activities.

(i) Identify/select subprojects in compliance with the key exclusion criteria and subproject selection guidelines stipulated in EARF

(ii) Conduct regular site visits for overseeing compliance with safeguards (iii) Prepare screening checklists and submit to PMU for categorization; update

checklist and category as and when required to reflect subproject changes, and report to PMU

(iv) Work closely with design teams to include environmental considerations in subproject location, design and technical specifications.

(v) Identify and obtain statutory environmental clearance/permissions/approvals required for subproject

(vi) Include standards/conditions, if any, stipulated in regulatory clearances, consents in the subproject detailed design

(vii) Conduct environmental baseline surveys (viii) Prepare subproject IEE studies and reports and EMPs and submit to PMU for

approval (ix) Update subproject IEE studies and reports and EMPs to reflect any changes in

subproject during detail design / implementation; IEE shall reflect the final subproject design; IEE shall also be updated in case of any unanticipated impacts

(x) Conduct adequate awareness campaigns are held with affected persons and within the host communities to minimize resistance and ensure hassle free transition for the affected persons / resettled households to new locations

148

(xi) Conduct meaningful consultation in compliance with the EARF; disclose relevant information on safeguards to stakeholders, affected people etc. reflect inputs from public consultation in subproject IEE studies and reports and EMPs

(xii) Integrate EMP into the bid and contract documents (xiii) Review and approval of contractor’s site specific EMP (e.g. C-EMP / D-EMP/ R-

EMP), individual sub-plans and SOMPs as indicated in Appendix 3 of EARF. (xiv) Ensure implementation of subproject C-EMP / D-EMP / R-EMP, individual sub-

plans and SOMPs as indicated in Appendix 3 of EARF by contractors (xv) Establish GRM at divisional level; coordinate grievance redress process,

registration, records, information dissemination, etc., and ensure timely actions by all parties; report to PMU

(xvi) Conduct training and capacity building activities (workshops, hands-on trainings, visits etc.) to contractors and field level staff as well as participating ULBs or PWDs (as necessary) in C-EMP/D-EMP/R-EMP, individual sub-plans and SOMPs implementation

(xvii) Undertake internal monitoring and supervision and record observations throughout the subproject implementation period

(xviii) Review and approval of contractor’s monthly report, consolidation into quarterly progress reports and submission to PMU

(xix) Submit periodic monitoring reports22 to the PMU, who will then submit these to the ADB.

176. Contractors. Contractors will appoint their own Contractor Environment, Health and Safety (C-EHS) and Contractor Grievance Redressal Mechanism (C-GRM) staff as well as Contractor Asbestos Containing Materials (C-ACM) staff for construction works at resettlement sites, demolition sites / removal of encroachments and regeneration works.23 All the contractors will be required to prepare a site-specific EMP (C-EMP / D-EMP /R-EMP) and Standard Operation and Maintenance Plans (SOMP) manuals. The contractors will bear the costs of preparing these site-specific plans included in the EMP. The contracts will not be awarded until the SEIAA has approved all environmental clearances, other relevant permits and clearances have been obtained, ADB has approved the subproject IEEs and EMPs and corresponding subproject EMPs are included in the bid and contract documents. The following are the key safeguards tasks for contractors:

(i) Submit site specific EMP for construction, demolition and regeneration works, individual sub-plans and SOMPs to PID

(ii) Attend training and capacity building sessions (iii) Conduct orientation and daily briefing sessions to workers on EHS (iv) Ensure that appropriate worker facilities (workers accommodation / camps) are

provided at the work sites in line with this EARF (v) Register and maintain records of all work-related accidents, and undertake

remedial actions to mitigate/minimize recurrence (vi) Implement EMP measures and report to PIDs if any new impacts are surfaced;

seek guidance from PID as required in EMP implementation (vii) Conduct environmental monitoring (air, noise, etc.) as per the monitoring plan (viii) Prepare monthly EMP monitoring reports and submit to PID

22 The monitoring report will focus on the progress of implementation of the safeguard, issues encountered and

measures adopted, follow-up actions required, if any, as well as the status of compliance with subprojects election criteria and relevant loan covenants.

23 C-ACM staff appointment will be for demolition / removal of encroachment works only.

149

(ix) Address any grievances effectively and in timely manner

177. The PMU and PIDs will ensure that the contractors are aware of their obligations including specific provisions requiring contractors to comply with: (i) all applicable labour laws and core labour standards on (a) prohibition of child labour as defined in national legislation for construction and maintenance activities; construction site should not hire any child below 18 years of age; (b) equal pay for equal work of equal value regardless of gender, ethnicity, or caste including no discrimination against pregnant women and (c) prohibition of forced labour; and with (ii) the requirement to disseminate information on health & safety risks due to transmittable diseases, including HIV/AIDS and COVID-19,24 to employees. 178. If the TNSCB PMU fails to comply with the loan and legal agreements on safeguards requirements, ADB will seek corrective measures and work with the TNSCB PMU to achieve compliance. If the TNSCB PMU fails to re- establish compliance, then ADB may exercise remedies, including suspension, cancellation or acceleration of maturity that are available under ADB legal agreements. Before resorting to such measures, ADB will use other available means to rectify the situation satisfactory to all parties to the legal agreements, including initiating dialogue with the parties concerned to achieve compliance with legal agreements. Further details on institutional roles and responsibilities for safeguards implementation are presented in Table 41.

Table 41: Institutional Roles and Responsibilities for Safeguards Implementation Project Stage Tasks

Responsible Agency

Implementation Supervision

Subproject identification and finalization

Preliminary design

• Ensuring that the key exclusion criteria and environmental guidelines for subproject selection are adhered to

• Prepare REA and No Mitigation (Scoping) checklists

• Categorize the subproject

PIDs (Environment Cell)

PMU (Environment Team)

• Identify GOI and GoTN regulatory requirements (clearances/approvals/ consents etc.)

• Check latest amendments to EIA

• Notification 2006 for environmental clearance requirement and subproject categorization (B1 / B2)

• Preparation of subproject IEE studies and reports and EMPs



• Delineating and mapping of catchment areas of encroached water bodies

PID (Environment Cell)


24 The Ministry of Health and Family Welfare, Government of India has released the Environmental and Social

Management Framework for India #COVID19 Emergency Response and Health Systems Preparedness Project; particularly Annex IV: India COVID-19 Project – Clauses for Inclusion in Civil Works Contracts; The document can be accessed here: https://www.mohfw.gov.in/pdf/EnvironmentalandSocialManagementFrameworkforindiaCOVID19EmergencyResponseandHealthSystemsPreparednessProjectP173836.pdf The Ministry of Law and Justice, Government of India has released the Occupational Safety, Health, Working Conditions Code, No. 37, 28th September 2020; the document can be accessed here: http://dgms.gov.in/writereaddata/UploadFile/Occupational Safety Health Code Act 2020 as assented by the President of India637370849494550871.pdf

https://www.mohfw.gov.in/pdf/EnvironmentalandSocialManagementFrameworkforindiaCOVID19EmergencyResponseandHealthSystemsPreparednessProjectP173836.pdf

https://www.mohfw.gov.in/pdf/EnvironmentalandSocialManagementFrameworkforindiaCOVID19EmergencyResponseandHealthSystemsPreparednessProjectP173836.pdf

http://dgms.gov.in/writereaddata/UploadFile/Occupational%20Safety%20Health%20Code%20Act%202020%20as%20assented%20by%20the%20President%20of%20India637370849494550871.pdf

http://dgms.gov.in/writereaddata/UploadFile/Occupational%20Safety%20Health%20Code%20Act%202020%20as%20assented%20by%20the%20President%20of%20India637370849494550871.pdf

150

Project Stage Tasks

Responsible Agency


and/or areas vulnerable to flooding hazards and mapping

• Delineating and mapping ROW for water canals / channels

Conduct survey and develop database for

information management for:

• Number of project beneficiaries

• full demographic and socio-economic profiles of project beneficiaries

• complete inventory of livelihood and asset losses due to physical and economic displacement of the project beneficiary

• information on environmental impacts of the subproject at the beneficiary-level

PID / PMU with support of other public / state agencies

PMU

Detailed design

• Mitigation measures specified in subproject IEE studies and reports incorporated in subproject detailed design

• Updating of subproject IEE studies and reports to integrate any changes in subproject after approval of studies and reports



• Conducting capacity development activities for staff, hired workers, contractors



• For subprojects involving facilities and/or business activities that already exist or are under construction, undertake an environment and/or social compliance audit, including on-site assessment, to identify past or present concerns related to impacts on the environment. Where non-compliance is identified, a Corrective Action Plan shall be prepared, and agreed on by ADB and the TNSCB PMU (Environment Team) and implemented, accordingly.



• Obtain all necessary environmental clearances, consents, and no objection certificates (NOCs) as per the national and state legal framework prior to bid invitation and/or award of contract25



• Meaningful consultations carried out in a manner commensurate with the impacts on affected stakeholders. The

PIDs (Environment Cell / Social Cell) /

PMU (Environment Team / Social

25 TNSCB will take into cognizance that it is a best practice to obtain all necessary environmental clearances, consents,

etc., prior to bid invitation; however, these must be clearly obtained prior to award of contract.

151

Project Stage Tasks

Responsible Agency


consultation process and its results to be documented and reflected in the subproject IEE reports.

Impact Assessment Team)

Information Disclosure: For Category B

• Disclosure on the TNSCB website of the draft subproject IEEs and EMPs; updated IEEs and EMPs including corrective action plans; environmental monitoring reports.

• Disclosure of draft IEE (and EMP) in a timely manner, in an accessible place and in a form and language understandable to affected people and other stakeholders. Any revised IEE (and EMP) should be disclosed to affected people and other stakeholders.




• Disclosure on ADB website of the final subproject IEE studies and reports and EMPs; updated subproject IEE studies and reports and EMPs and corrective action plans; environmental monitoring reports.

ADB ADB

• Incorporate final subproject EMP into bid/contract documents



Appraisal • EMP and other environmental covenants are incorporated into the sector loan agreement and project administration memorandum (PAM)

• Approval of subproject IEE studies and reports and EMPs prior to invitation of bids

• All clearances are in place prior to invitation of bid / award of contracts / start of work



• Effective GRM established prior to award of contracts



Approval ADB will be responsible for regular review and timely approval of subproject IEE

ADB -

152

Project Stage Tasks

Responsible Agency


studies and reports and EMPs (draft and final)

Bid Invitation and Award of Contracts

• Approval of subproject IEE studies and reports and EMPs a must prior to bid invitations

• Subproject EMPs to be incorporated into contracts.

• Ensure all statutory national and state clearances prior to award of contracts


PMU

Subproject Implementation

• Development and approval of site-specific Construction-EMP and Demolition-EMP by contractors and individual sub-plans

• Implementation of above EMP including monitoring and reporting plans by contractors and submission of monthly reports to PIDs (Environment Cell),

• Submission of Quarterly progress reports (Environment Cell) to PMU (Environment Team) including corrective action plan where a non-compliance is Identified

• Conduct public consultation and awareness programs as per EARF

• Overall compliance monitoring and submission of quarterly monitoring report during construction stage and annual reporting during operation stage by PMU (Environment Team) to ADB

• ADB will be responsible for reviewing regular monitoring reports

Contractors



PMU

179. Training Needs. The following Table 42 presents the outline of capacity building program to ensure EMP implementation. These capacity building and trainings will be conducted at the offices of PMU and PIDs by the environmental safeguards specialist of PID, which are part of project implementation set-up, and therefore no separate or additional costs are envisaged. Adequate costs are already considered in project’s capacity building program. The detailed program and specific modules will be customized for the available skill set after assessing the capabilities of the target participants and the requirements of the project by the PMU.

Table 42: Outline Capacity Building Program on EMP Implementation Sl.no Description Target Participants and

Venue Cost and Source of Funds

1 Introduction and Sensitization to Environmental Issues (1 day)

• ADB Safeguards Policy Statement

• Government of India and Tamil Nadu applicable safeguard laws, regulations and policies including but not limited to core labor standards, OH and S, etc.

All staff and consultants (if any) involved in the subproject PMU Office (combined program for all PIDs)

Included in the overall program cost

153

Sl.no Description Target Participants and Venue

Cost and Source of Funds

• Incorporation of EMP into the project design and contracts

• Monitoring, reporting and corrective action planning

2 EMP implementation (1/2 day)

• EMP mitigation and monitoring measures

• Roles and responsibilities

• Public relations, - Consultations

• Grievance redress

• Monitoring and corrective action planning

• Reporting and disclosure

• Construction site standard operating procedures (SOP)

• Chance find (archeological) protocol

• Work near ASI monuments

• AC pipe protocol

• Traffic management plan

• Waste management plan

• Site clean-up and restoration

All PID staff, contractor staff and consultants (if any) involved in the subproject PID Office

To be conducted by PID (Environmental Specialist) at the PID office; part of project implementation cost

3 Contractors Orientation to Workers (1/2 day)

• Environment, health and safety in project construction

• Once before start of work, and thereafter regular briefing every month once.

• Daily briefing on safety prior to start of work

• All workers (including unskilled laborers)

• Awareness & on-site training for workers and staff on sludge handling and disposal in existing STP repair work

Contractors’ EHS officer to conduct program, with guidance of PID

C. Monitoring and Reporting

180. The prepared IEE is based on the draft design for the resettlement site and likely construction activities in the demolishing sites and water body regeneration works. Hence upon finalising the detailed design for the resettlement site and preparation of the work plan for the demolishing sites and water body regeneration sites, this IEE has to be reviewed based on the updated information for the subproject. This includes, as soon as further information on the water supply works are made available (refer to para 169), this IEE needs to be updated and a separate EMP has to be prepared by the environment specialist PID, submitted to the environmental consultant PMU for review. Further consultations (that have been prevented due to COVID-19) at various places (including at encroachment sites and around the resettlement site) have to be conducted and the outcomes/ feedback and suggestions shared by the communities have to be incorporated in the project design, if not appropriate response have to be shared with the communities to their satisfaction. The revised draft IEE will then need to be submitted to ADB for concurrence. The EMP will need to be adopted by the water work construction contractor (appointed by TWAD) which has to be updated.

154

181. All subproject EMPs will have internal monitoring. The PIDs (Environment Cell) with support of the PMU (Environment Team) will conduct internal environmental monitoring for each subproject and provide the environment input based on site inspections, compliance checks and prepare the subproject Quarterly Progress Reports (QPRs) for submission to the PMU for final submission to ADB till the subproject completion report is issued. Monitoring will also encompass tracking progress on regeneration works undertaken by the PMU of previously encroached water bodies / channels and surrounding areas. 182. The environmental monitoring report26 for submission to ADB shall be on quarterly basis during construction and on an annual basis during operation (refer to Appendix 21 for subproject environmental monitoring report template). Environmental monitoring reports will be required to be submitted to ADB within 30 days from the end of the relevant period. The environmental monitoring reports will be publicly disclosed on ADB public website. Reporting to ADB will continue until a project completion report. is completed. 183. Types of subproject monitoring that may be conducted under subproject specific EMP will include:

(i) Project readiness monitoring. To be conducted by the PIDs (Environment Cell) (ii) Environmental monitoring. To be conducted by PIDs (Environment Cell) and

contractors across all stages of project implementation as described in the subproject specific EMP and assessing compliance with applicable GOI environmental quality standards and/or International standards and best practices

(iii) Compliance monitoring. To be conducted by the PMU / PIDs to verify EMP compliance across all stages of subproject implementation

(iv) Demolition works monitoring. To be conducted by the PMU (Environment Team) / PIDs (Environment Cell).

(v) Regeneration works monitoring. To be conducted by the PMU (Environment Team) / PIDs (Environment Cell).

184. ADB will oversee subproject compliance on the basis of quarterly (during construction) and annual (during operations) environmental monitoring reports provided by the PMU (Environment Team) and site visits (generally one to two times per year). For any non-compliance, ADB will make suitable recommendations for undertaking remedial measures for mid-term correction and improvement, if required. ADB’s monitoring and supervision activities are carried out on an on-going basis until a Project Completion Report is completed. 185. The contractor(s) will submit monthly progress reports to the PIDs (Environment Cell) on C-EMP/ D-EMP / R-EMP implementation, and SOMPs/ O&M EMP, which will inform the quarterly safeguards monitoring reports as part of the project QPR. The contractor monthly progress reports will include compilation of daily monitoring sheets that is duly signed by C-EHS. The template for daily monitoring sheet for contractors during construction stage is provided as Appendix 22. 186. During operations of the new housing development and regeneration works, the contractors will also submit monthly progress reports to PIDs (Environment Cell) on New Housing

26 The environmental reporting will cover EMP implementation, focusing on compliance and any needed corrective

actions.

155

Development SOMP/ O&M EMP and Regeneration Works for the first year of operation and quarterly progress reports thereafter. These will inform the annual safeguard monitoring reports. The contractor’s monthly (and quarterly) progress reports will include compilation of daily monitoring sheets corresponding to the operation of assets created. The subproject specific IEE will include a template for daily monitoring sheets during operation stage. D. EMP Implementation Cost

187. As part of good engineering practices in the project, there have been several measures such as safety, signage, dust suppression, procurement of personal protective equipment, provision of drains, etc. and the costs for which will be included in the design costs of specific subprojects. Therefore, these items of costs have not been included in the IEE budget. Only items not covered under budget for construction are considered in the IEE budget. 188. This is a large construction project and hence is expected to cause significant air, water and noise pollution. However, the implementation of the mitigation measures and required environmental reporting and monitoring in line with the environmental monitoring plan and included within the bidding and contract documents as separate line items will ensure that the environmental impacts will not be significant or irreversible. An appropriate Environmental Management Budget has been estimated to carry out the monitoring requirements.

189. The cost of water sprinkling for dust suppression and providing personal protective equipment to construction workers shall be borne by contractor as part of conditions of contract. In addition, the sources of funds for mitigation measures including monitoring during the construction stage are also to be borne by the contractor. These are deemed to be included as part of the contract price amount quoted by the contractor for the works. The costs of components for monitoring in operation stage and the capacity building costs are to be funded by the PMU. The EMP cost is given in the Table below.

Table 43: Indicative EMP Budget

Sl. No. Particulars Stages Unit Total

Number Rate (₹)

Cost (₹)

Source of fund

A. Monitoring Measures (Kalanivasal Resettlement Site)

1 Air quality

monitoring Pre-construction

Per sample

1 10,000 10,000 PID

2 Noise Levels Pre-construction

Per location

1 4,000 4,000 PID

3 Water Quality

Pre-construction

Per Sample

1 10,000 10,000 PID

4 Ambient Air Quality

Construction Per Sample

24 10,000 2,40,000 Contractor budget

5 Ambient Noise Quality


24 4,000 96,000 Contractor budget

6 Water Quality




Post Construction

Per Sample

20 10,000 2,00,000 Contractor budget (DLP)

156


Number Rate (₹)

Cost (₹)

Source of fund


Post Construction

Per Sample

20 4,000 80,000 Contractor budget (DLP)

9 Water Quality

Post Construction

Per Sample


10

Water Quality (TWAD water supply)

Post Construction

Per Sample

20 10,000 2,00,000 TWAD Budget

11 Water Quality (STP)

Post Construction

Per Sample

40 10,000 4,00,000

STP Service Provider Budget

Sub- Total (A)

15,60,000

B. Monitoring Measures (Demolishing Sites)

1 Air quality


Per sample

11 10,000 1,10,000 PID


Per location

11 4,000 44,000 PID

3 Water Quality

Pre-construction

Per Sample

11 10,000 1,10,000 PID







6 Water Quality




Post Construction

Per Sample



Post Construction

Per Sample


9 Water Quality

Post Construction

Per Sample


Sub- Total (B) 13,64,000

C. Monitoring Measures (Water Body Regeneration Works)

1 Air quality


Per sample

11 10,000 1,10,000 PID


Per location

11 4,000 44,000 PID

157


Number Rate (₹)

Cost (₹)

Source of fund

3 Water Quality

Pre-construction

Per Sample

11 10,000 1,10,000 PID







6 Water Quality




Post Construction

Per Sample



Post Construction

Per Sample


9 Water Quality

Post Construction

Per Sample


Sub- Total (C) 22,00,000

D.

Capacity Building – Training Cost (includes cost estimate for the subproject components (including resettlement site construction, demolishing works and water body regeneration

works), and not included in the package costs)

1 Sensitization Workshop

Pre-Construction

L.S 1,50,000 PMU

2 Training Session I

Construction L.S 1,00,000 PMU

3 Training Session II

Construction L.S 1,00,000 PMU

Sub -Total (D) 3,50,000

Total (A+B+C+D) ₹

54,74,000

158

X. CONCLUSION AND RECOMMENDATIONS

190. The proposed subproject is in line with the sub-project selection criteria for the program. The subproject conforms to all GoI and ADB regulations, policies, and standards including all necessary government permits and clearances. 191. During the subproject construction, there are possible negative environmental impacts envisaged. As per the Initial Environmental Examination (IEE), the specific management measures laid down in the EMPs will effectively address any likely environmental impacts due to the subproject. The effective implementation of the measures proposed will be ensured through building enhanced capacity through training on environmental management within the PIDs and PMU with overall supervision for environmental issues by the environmental consultant within the PMU. Further, the environmental monitoring plans provide adequate opportunity towards course correction to address any residual impacts during construction or operation stages. 192. The draft IEE carried out for the subproject shows that the proposed components/ interventions will result in net environmental benefits, and that any likely environmental impact can be addressed through proper location, planning and design of the proposed subproject; control of construction activity and mitigation measures. The EMPs provide for mitigation of all identified impacts and reflected within the contract clauses for the environmental provisions will be part of the civil works contracts. Further, consultation on the proposed designs have been undertaken with stakeholders and no significant issues requiring redress in terms of environmental safeguards are known to exist at present. However, this IEE has been prepared based on the preliminary information and hence upon finalising the detailed design, this IEE and EMPs (including the BoQ) have to be updated and relevant contractor clauses should be included in the EMPs. 193. The positive benefits of this project is to provide affordable housing for the people who are living in the encroached areas (encroached water bodies), which is prone for seasonal flooding. This project also benefits low-income families and female-headed households. Based on the climate risk assessment and heat modelling, the building plan has been developed to withstand the climate change including the high temperature. The proposed infrastructure including the provision of toilets, water supply, electric connection, community center and play areas shall provide an improved standard of living. 194. Based on the findings of the IEE, there are no significant impacts and the classification of the subproject as Category “B” is confirmed. No further special study or detailed environmental impact assessment (EIA) needs to be undertaken to comply with ADB SPS (2009).

Appendix 1 159

Confirmation letter from the Karakudi Commissioner for the Encroached Slums in the water bodies

160 Appendix 1

Appendix 2 161

Land use Classification and Enter Upon Permission Issued to TNSCB by the District

Collector, Sivaganga (Translated English Version)

162 Appendix 2

Appendix 2 163

164 Appendix 2

Appendix 2 165

166 Appendix 2

Appendix 2 167

168 Appendix 2

Appendix 3 169

Rapid Environmental Assessment (REA) Checklist

Instructions: (i) The project team completes this checklist to support the environmental classification of a project. It is to be attached to the environmental categorization form and submitted to the Environment and Safeguards Division (RSES) for endorsement by the Director, RSES and for approval by the Chief Compliance Officer. (ii) This checklist focuses on environmental issues and concerns. To ensure that social dimensions are adequately considered, refer also to ADB's (a) checklists on involuntary resettlement and Indigenous Peoples; (b) poverty reduction handbook; (c) staff guide to consultation and participation; and (d) gender checklists. (iii) Answer the questions assuming the “without mitigation” case. The purpose is to identify potential impacts. Use the “remarks” section to discuss any anticipated mitigation measures.

Country/Project Title:

Sector Division:

Screening Questions Yes No Remarks

A. Project Siting Is the project area…?

▪ Densely populated?

✓

The resettlement site at Kalanivasal is located in Sankarapuram Panchayat, on the outskirts of Karaikudi Municipality. It is having less population. But the 10 encroachment sites to be relocated are situated in Karaikudi Municipality, a densely populated area.

▪ Heavy with development activities?

✓

No, the resettlement site is classified as government waste land with no developmental activities. But the 10 encroachment sites to be relocated are situated in Karaikudi Municipality, heavy with development activities

▪ Adjacent to or within any environmentally sensitive areas?

• Cultural heritage site

✓

The resettlement site at Kalanivasal is not adjacent to any environmentally sensitive areas. But the 10 encroachment sites to be relocated are situated in Karaikudi Municipality, which is declared as a heritage town by the Government of Tamil Nadu. But there are no protected monuments within the town and the structures to be demolished within the encroachment sites have no heritage value since they are maximum 45 years old only.

• Protected Area

• Wetland

• Mangrove

• Estuarine

• Buffer zone of protected area

• Special area for protecting biodiversity

• Bay

B. Potential Environmental Impacts Will the Project cause…

▪ impacts on the sustainability of associated sanitation and solid waste ü

Yes, the proposed resettlement project shall have an impact on the existing sanitation and solid waste disposal systems due to the addition of

IND: Proposed Inclusive, Resilient and Sustainable Housing for the Urban Poor

Project in Tamil Nadu – Kalanivasal, Sivaganga

Urban Development and Water Division

170 Appendix 3


disposal systems and their interactions with other urban services.

huge population who will be relocated from other localities to Kalanivasal. However, sustainability of the associated sanitation and solid waste disposal system will be managed by the local Panchayat.

▪ deterioration of surrounding environmental conditions due to rapid urban population growth, commercial and industrial activity, and increased waste generation to the point that both manmade and natural systems are overloaded and the capacities to manage these systems are overwhelmed?

✓

No, the proposed resettlement site will have a moderate impact on the surrounding environment due to the commercial activities (small shops, stores, restaurants etc) and an increase in waste generation. However, it shall be managed. The generated municipal solid waste will be collected and disposed by Sankarapuram Panchayat and the generated sewage will be treated and disposed as per the discharge standard and hence the deterioration to the surroundings shall be mitigated to acceptable levels.

▪ degradation of land and ecosystems (e.g. loss of wetlands and wild lands, coastal zones, watersheds and forests)?

✓

There are no wetlands, wild lands, coastal zones, watersheds and forests at or nearby the resettlement site or the encroachment sites to be relocated.

▪ dislocation or involuntary resettlement of people?

✓

Yes, the proposed subproject will involve the dislocation of the flood affected and socially vulnerable people who are living near the water bodies. A Resettlement Framework and related Resettlement Plan have been prepared.

▪ disproportionate impacts on the poor, women and children, Indigenous Peoples or other vulnerable group?

✓

Yes, the proposed subproject does target those who are socially vulnerable living close to water bodies. However, this impact is expected to be positive as the subproject will help improve access to improved livelihoods and also save them from flood hazards.

▪ degradation of cultural property, and loss of cultural heritage and tourism revenues?

✓ Not envisaged

▪ occupation of low-lying lands, floodplains and steep hillsides by squatters and low-income groups, and their exposure to increased health hazards and risks due to pollutive industries?

✓

Not envisaged. There are no low-lying lands, floodplains, steep hillsides or pollutive industries near the resettlement site. The waterbodies to be regenerated after the relocation of encroachment located around them will be protected by fencing to prevent further encroachment.

▪ water resource problems (e.g., depletion/degradation of available water supply, deterioration for surface and ground water quality, and pollution of receiving waters?

✓

Yes, the proposed resettlement site in Kalanivasal shall have an impact on the ground water resources of the area. Water supply to the resettlement site will be provided by TWAD Board, which depends on borewells for water supply in this area due to the non-availability of surface water. During project construction, significant quantity of groundwater shall be used for construction purposes with necessary approvals. During operation, groundwater shall be used for drinking and other domestic purposes. Due to this, considerable quantity of

Appendix 3 171


ground water shall be extracted, which may lead to depletion of ground water. The sewage generated has to be treated and disposed properly to avoid negative impacts including deterioration of surface and ground water quality. The sub-project includes grey water recycling which will reduce the use of water for flushing purposes and a water source sustainability study will be completed to ensure rainwater harvesting structures will recharge the groundwater aquifer through which the groundwater table can be sustained.

▪ air pollution due to urban emissions?

✓

Yes, there may be increased urban emissions due to travel as people may still need to access previous livelihoods or services. However, resettled location has been chosen to be close to economic opportunities and infrastructure, including existing transport routes so this should be minimised.

▪ risks and vulnerabilities related to occupational health and safety due to physical, chemical and biological hazards during project construction and operation?

✓

Yes, generation of Asbestos materials/ sheets, which are used as roofing/ celling purposes from the 10 encroachment sites will have hazardous risks, hence it should be disposed as per the hazardous waste management rules 2016 with assistance from Asbestos expert, who will assess the site and will guide in handling the asbestos. For fire accidents, fire extinguisher has been proposed on each floor. Other OHS related impacts are also anticipated, however, they shall be mitigated through provision of appropriate PPEs to the labours and hence the risks and vulnerability shall be very much reduced.

▪ road blocking and temporary flooding due to land excavation during rainy season?

✓

Not envisaged since the resettlement site is located out of the municipal area and it does not have roads with heavy traffic to become blocked during the project construction. Construction activities shall be put on hold during the rainy seasons to avoid flooding or any other issues

▪ noise and dust from construction activities?

✓

Yes, noise and air quality impacts are anticipated due to the movement of vehicles carrying construction materials and the noise and vibration generated from the construction machineries.

▪ traffic disturbances due to construction material transport and wastes?

✓

The resettlement site is on the outskirts of Karaikudi Municipality, with very little traffic and hence the proposed construction activities (transportation of construction materials) will not have any major impacts. However, the transportation of waste generated from the demolition sites (encroachment sites) within the Municipality may create traffic disturbances. Hence a Traffic Management Plan will be prepared by the contractor.

172 Appendix 3


▪ temporary silt runoff due to construction?

✓

No, construction activities shall be put on hold during the rainy seasons. However, appropriate mitigation measures including silt fencing shall be provided for controlling silt runoff from the site.

▪ hazards to public health due to ambient, household and occupational pollution, thermal inversion, and smog formation?

✓ Not envisaged

▪ water depletion and/or degradation?

✓

Yes, during the project construction and operation, there is a moderate negative impact anticipated on the water resource. However, providing rain water harvesting structures within the project area will help to recharge the groundwater system. A water source sustainability study is being conducted for the resettlement site, the findings/ observations and suggestions from the study shall be implemented to maintain groundwater sustainability in the project area

▪ overpaying of ground water, leading to land subsidence, lowered ground water table, and salinization?

✓

There will be a moderate negative impact anticipated in the groundwater resource during the project construction and operation. However, rainwater harvesting structures are proposed at each block which shall act to improve the depleted groundwater table. The suggestion/ management measures from the water source sustainability will be implemented to main groundwater sustainability in the project area

▪ contamination of surface and ground waters due to improper waste disposal?

✓

There is an irrigation tank located near the resettlement site. Solid and liquid wastes generated from the construction camp during construction stage and from the residential units during operation stage may pollute the water body if wastes are not collected, treated and disposed appropriately. The sub-project design incorporates sufficient solid waste collection points and is located away from sensitive receptors.

▪ pollution of receiving waters resulting in amenity losses, fisheries and marine resource depletion, and health problems?

✓

No, The irrigation tank located near the resettlement site is seasonal and not used for fisheries or other amenities. It is suggested to discharge the excess treated sewage in the nearest UGD located at a distance of 450m from the resettlement site. Accordingly NoC from the local Panchayat has been obtained.

▪ large population influx during project construction and operation that causes increased burden on social infrastructure and services (such as water supply and sanitation systems)?

✓

Yes, During the construction activity, there will be influx of people from local areas and other states and will include those who would be migrating as labours. However, it will be temporary which will last up to the completion of the project. To avoid increased burden on social infrastructure and services such as water supply and sanitation systems, the Contractor shall

Appendix 3 173


provide them labour camps with all required amenities.

▪ social conflicts if workers from other regions or countries are hired?

✓

Yes, social conflicts mays arise with respect to competition for jobs, dispute with wages, attitude issues etc. Hence, the contractor has to adopt a Code of Conduct for the migrant labours to sort out any issues with the locals. However, preference shall be given to the local labour.

▪ risks to community health and safety due to the transport, storage, and use and/or disposal of materials such as explosives, fuel and other chemicals during operation and construction?

✓

Yes, though the stored construction materials are not toxic or hazardous in nature and hence explosion, fires are not anticipated. However, the removal of asbestos from the demolition sites during construction and disposal of STP sludge during operation are considered to be hazardous. With the help/ assistance from the asbestos expert, the asbestos waste shall be handled and disposed as per hazardous waste management rules 2016. The sludge from the STP will be treated prior to disposal. The prepared CEMP shall have mitigation measure for managing the same.

▪ community safety risks due to both accidental and natural hazards, especially where the structural elements or components of the project are accessible to members of the affected community or where their failure could result in injury to the community throughout project construction, operation and decommissioning?

✓

There may be a minimal risk during demolition at the encroachment sites, however this area will be fenced and access will be restricted. So no risks are envisaged.

174 Appendix 3

A Checklist for Preliminary Climate Risk Screening

Country/Project Title : IND: Proposed Inclusive, Resilient and Sustainable Housing for the

Urban Poor Project in Tamil Nadu – Kalanivasal, Sivaganga

Sector : Urban Development and Water

Subsector :

Division/ Department:

Screening Questions Score Remarks27

Location and Design of project

Is siting and/or routing of the project (or its components) likely to be affected by climate conditions including extreme weather-related events such as floods, droughts, storms, landslides?

1 The resettlement site have not experienced flooding or worst climate impacts however the encroachment areas have witnessed seasonal flooding.

Would the project design (e.g. the clearance for bridges) need to consider any hydro-meteorological parameters (e.g., sea-level, peak river flow, reliable water level, peak wind speed etc)?

1 The Kalanivasal resettlement site is not located in a flood-prone area. It has a gentle slope which will help drainage. However, the project design will consider appropriate drainage of the site to prevent storm surges.

Materials and Maintenance

Would weather, current and likely future climate conditions (e.g. prevailing humidity level, temperature contrast between hot summer days and cold winter days, exposure to wind and humidity hydro-meteorological parameters likely affect the selection of project inputs over the life of project outputs (e.g. construction material)?

1 The apartment blocks have been designed considering the hot climate of the area to reduce temperature. Weather proof construction materials are proposed to withstand extreme heat and humid weather conditions.

Would weather, current and likely future climate conditions, and related extreme events likely affect the maintenance (scheduling and cost) of project output(s) ?

1 Likely the maintenance of housing will depend on how degraded it becomes due to weather and extreme events. The site has been chosen to ensure it is not in a hazard zone.

Performance of project outputs

Would weather/climate conditions, and related extreme events likely affect the performance (e.g. annual power production) of project output(s) (e.g. hydro-power generation facilities) throughout their design life time?

0 Weather/climate conditions and related extreme events are not likely to affect the residential units since they have been designed to withstand them.

Options for answers and corresponding score are provided below:

Response Score

Not Likely 0

Likely 1

27 If possible, provide details on the sensitivity of project components to climate conditions, such as how climate

parameters are considered in design standards for infrastructure components, how changes in key climate parameters and sea level might affect the siting/routing of project, the selection of construction material and/or scheduling, performances and/or the maintenance cost/scheduling of project outputs.

Appendix 3 175

Very Likely 2

Responses when added that provide a score of 0 will be considered low risk project. If adding all responses

will result to a score of 1 - 4 and that no score of 2 was given to any single response, the project will be

assigned a medium risk category. A total score of 5 or more (which include providing a score of 1 in all

responses) or a 2 in any single response, will be categorized as high-risk project.

Result of Initial Screening (Low, Medium, High): Medium

Other Comments: The proposed Resettlement Project site in Kalanivasal will not have significant

environmental / climate change impacts. The proposed rainwater harvesting, harnessing solar energy and

landscaping shall have a positive impact on the environment and the climate change. The clearing of the

encroachments will improve the water capacity of the surrounding areas. It is also proposed to use

environmentally friendly construction materials as to safeguard the surrounding environment.

Prepared by: Tamil Nadu Slum Clearance Board, Chennai

176 Appendix 4

Environmental Clearance from SEIAA

Appendix 4 177

178 Appendix 4

Appendix 4 179

180 Appendix 4

Appendix 4 181

182 Appendix 4

Appendix 4 183

184 Appendix 4

Appendix 4 185

186 Appendix 4

Appendix 4 187

188 Appendix 4

Appendix 4 189

190 Appendix 4

Appendix 4 191

192 Appendix 4

Appendix 4 193

194 Appendix 4

Appendix 4 195

196 Appendix 4

Appendix 4 197

198 Appendix 5

Salient Features of Major Labor Laws Applicable to Establishments Engaged in Construction of Civil Works

(i) Workmen Compensation Act, 1923 - The Act provides for compensation in case of injury by

accident arising out of and during the course of employment.

(ii) Payment of Gratuity Act, 1972 - Gratuity is payable to an employee under the Act on

satisfaction of certain conditions on separation if an employee has completed 5 years’ service or

more or on death at the rate of 15 days wages for every completed year of service. The Act is

applicable to all establishments employing 10 or more employees.

(iii) Employees’ PF and Miscellaneous Provisions Act, 1952 - The Act provides for monthly

contributions by the employer plus workers @10 % or 8.33 %. The benefits payable under the

Act are: (a) Pension or family pension on retirement or death as the case may be; (b) deposit

linked insurance on the death in harness of the worker; (c) payment of PF accumulation on

retirement/death etc.

(iv) Maternity Benefit (Amendment) Act 2017- The Act provides for leave and some other

benefits to women employees in case of confinement or miscarriage etc.

(v) Contract Labour (Regulation and Abolition) Act, 1970 - The Act provides for certain welfare

measures to be provided by the Contractor to contract labor and in case the Contractor fails to

provide, the same are required to be provided by the Principal Employer by Law. The principal

employer is required to take Certificate of Registration and the Contractor is required to take a

License from the designated Officer. The Act is applicable to the establishments or Contractor of

principal employer if they employ 20 or more contract labor.

(vi) Minimum Wages Act, 1948 - The employer is supposed to pay not less than the Minimum

Wages fixed by appropriate Government as per provisions of the Act if the employment is a

scheduled employment. Construction of Buildings, Roads, Runways are scheduled employment.

(vii) Payment of Wages Act, 1936 - It lays down as to by what date the wages are to be paid,

when it will be paid and what deductions can be made from the wages of the workers.

(viii) Equal Remuneration Act, 1979 - The Act provides for payment of equal wages for work of

equal nature to Male and Female workers and not for making discrimination against Female

employees in the matters of transfers, training and promotions etc.

(ix) Payment of Bonus Act, 1965 - The Act is applicable to all establishments employing 20 or

more workmen. The Act provides for payments of annual bonus subject to a minimum of 8.33 %

of wages and maximum of 20 % of wages to employees drawing ₹3,500/- per month or less. The

bonus to be paid to employees getting ₹2,500/- per month or above up to ₹3,500/- per month

shall be worked out by taking wages as ₹2,500/- per month only. The Act does not apply to certain

establishments. The newly set up establishments are exempted for five years in certain

circumstances. Some of the State Governments have reduced the employment size from 20 to

10 for the purpose of applicability of the Act.

(x) Industrial Disputes Act, 1947 - The Act lays down the machinery and procedure for

resolution of industrial disputes, in what situations a strike or lock-out becomes illegal and what

Appendix 5 199

are the requirements for laying off or retrenching the employees or closing down the

establishment.

(xi) Industrial Employment (Standing Orders) Act, 1946 - It is applicable to all establishments

employing 100 or more workmen (employment size reduced by some of the States and Central

Government to 50). The Act provides for laying down rules governing the conditions of

employment by the employer on matters provided in the Act and get the same certified by the

designated Authority.

(xii) Trade Unions Act, 1926 - The Act lays down the procedure for registration of trade unions

of workmen and employees. The trade unions registered under the Act have been given certain

immunities from civil and criminal liabilities.

(xiii) Child Labor (Prohibition and Regulation) Act, 1986 - The Act prohibits employment of

children below 14 years of age in certain occupations and processes and provides for regulation

of employment of children in all other occupations and processes. Employment of child labor is

prohibited in Building and Construction Industry.

(xiv) Inter-State Migrant Workmen's (Regulation of Employment and Conditions of Service) Act,

1979 - The Act is applicable to an establishment which employs 5 or more inter-state migrant

workmen through an intermediary (who has recruited workmen in one state for employment in the

establishment situated in another state). The inter-state migrant workmen, in an establishment to

which this Act becomes applicable, are required to be provided certain facilities such as housing,

medical aid, traveling expenses from home up to the establishment and back, etc

(xv) The Building and Other Construction Workers (Regulation of Employment and Conditions

of Service) Act, 1996 and the Cess Act of 1996 - All the establishments who carry on any building

or other construction work and employ 10 or more workers are covered under this Act. All such

establishments are required to pay Cess at rate not exceeding 2% of the cost of construction as

may be notified by the Government. The employer of the establishment is required to provide

safety measures at the building or construction work and other welfare measures, such as

canteens, first-aid facilities, ambulance, housing accommodation for workers near the workplace

etc. The employer to whom the Act applies has to obtain a registration certificate from the

Registering Officer appointed by the Government.

200 Appendix 7

Certification for the Resettlement Site (Encumbrance Free Site)

Appendix 6 201

Confirmation letter from the Tamil Nadu Electricity Board (TNEB)

202 Appendix 7

Confirmation letter from Taluk office on the flood situation in the slum sites

Appendix 8 203

Land Transfer certificate

204 Appendix 9

Certificate indicating Kalanivasal site is not vulnerable for flooding

Appendix 10 205

Acceptance letter for collection of Municipal Solid Waste

206 Appendix 11

Permission letter for discharge of Treated Sewage

Appendix 13 207

Tamilnadu Water Supply and Drainage Board (TWAD) acceptance/ acknowledge for the supply of water to Kalanivasal resettlement site

208 Appendix 13

Appendix 13 209

Confirmation Letter for Collection and disposal of Sludge generated from STP installed at Kalanivasal Resettlement site

210 Appendix 15

Compliance Matrix for the EC Conditions

Appendix 15 211

212 Appendix 15

Appendix 15 213

214 Appendix 15

Appendix 15 215

216 Appendix 15

Appendix 15 217

218 Appendix 15

Appendix 15 219

220 Appendix 15

Appendix 15 221

222 Appendix 15

Appendix 15 223

224 Appendix 15

Appendix 15 225

226 Appendix 15

Appendix 15 227

228 Appendix 15

Appendix 15 229

Groundwater Quality Test Results at Kalanivasal Resettlement Site

230 Appendix 17

IBAT Study for the subproject area

Appendix 17 231

232 Appendix 17

Appendix 17 233

234 Appendix 17

Appendix 17 235

236 Appendix 17

Appendix 17 237

238 Appendix 17

Appendix 18 239

Health and Safety Plan/ Response and Measures for COVID 19

‘To Do’ List / Protocol

Daily Drill:

• All workers to report some time earlier before the start of the shift. An attendance register is to be maintained for each shift. Masks are mandatory and social distancing28 of at least 1m to be followed in the holding area. The focal point to provide information update.

• The workers need to wash their hands thoroughly (for at least 20-30 seconds) with soap or use sanitizers just before reporting screening. Adequate provision for hand washing, soaps, sanitizers needs to be made at the reporting location. Hand gloves mandatory for teams who are screening workmen, conducting medical check-up, disinfection

• Health screening to be done for all workers in the shift - including temperature monitoring using a non-contact thermometer. Any worker reporting with temperature higher than 37.3oC shall be sent to the isolation quarters and periodic observation be made.

o In case the worker shows symptoms of the pandemic (including COVID-19), the procedures as laid down by the national and state laws need to be followed for testing, quarantine of at least 14 days or hospitalization, depending upon individual case.

o All the co-workers in the shift, and other persons with known contact history in the construction site should be quarantined for a period of at least 14 days, followed by regular check-ups/ observation/ examinations as laid down by the national and state laws.

• The workers found fit need to proceed to work with all required personal protective equipment, e.g., masks, gloves, goggles, boots, helmets, harness, etc.

• The workers be encouraged to avoid contact with co-workers as far as possible and wash their hands at regular intervals.

• Lunch/meal break be staggered into two so that workers proceed for lunch/meal at different times.

• There needs to be a provision of separate drinking bottles/cups for each worker, and these need to be cleaned thoroughly after meals.

• Proper hand washing arrangement (water/soaps/sanitizers) needs to be ensured at eating locations. Hand washing facilities are ideally to be located within 5m of toilets and at close range of eating space.

• The workers returning to the shift after lunch/meal break need to thoroughly wash their hands and follow the same procedure as that followed at the start of the shift.

• At the close of shift, the workers need to thoroughly wash their hands with soap/sanitizers etc.

• The PPE should be thoroughly washed/cleaned/sanitized (depending upon the type of PPE) after the shift ends.

• The meal timings should be phased in each shift. There should be a difference of about 1 hour between two shifts and the sensitive areas of the workplace should be cleaned / sanitized as far as possible.

28 https://www.mohfw.gov.in/pdf/SocialDistancingAdvisorybyMOHFW.pdf

240 Appendix 18

• The time between two shifts should be used for cleaning and sanitizing machines, hand tools and areas of regular contact – grab handles, control levers, steering wheels, control panels, etc. shall be regularly cleaned, and at the end of shifts used across shifts (or continuous operations) where operators/helpers change.

General Guidance for Contractors:

• Site specific risk assessment needs to be undertaken and emergency preparedness plan be prepared for all sites, including camp sites and construction sites.

• Protocols for medical treatment, etc. should be prepared/followed, including for reporting, referral, treatment and discharge as per national and state laws and other guidelines.

• A health and safety officer/environment to be deployed as the focal point at all project sites, and wherever, the same is not in place, urgent action needs to be taken by the contractor to recruit someone.

• Register for all the workers needs to be maintained, along with their health records. Prepare a profile of the workforce considering the following: i) Total number of workers who live in the labor camps; ii) Total number of workers who commute from their houses; iii) Number of male and female workers.

• Limit the number of workers on site at any one time to minimize contact, including exploring operations for multi-shift working rotation.

• Entry/exit to the site should be documented. Transport vehicles used during construction activities to carry construction materials should be sanitized on regular basis (at least once a day).

• Hygienic living conditions need to be ensured in the camp sites with regular/daily cleaning, adequate hand washing facilities. Adequate provision for solid waste management needs to be provided.

• Provide health and safety training/orientation on COVID19, or any other pandemic, to all workers and staff. Some initiatives could be like training family members of construction workers to stitch masks and gloves to augment PPE.

• Ensure adequacy of necessary supplies of energy, water, food, medical supplies, cleaning equipment, PPE (both for regular use and those for medical exigencies) etc.

• Quarantine and isolation facilities should be established in the camps (WHO Guidelines). The isolation facilities should have separate and dedicated toilets with proper arrangement for cleaning and removal of faeces.

• Any medical waste produced during the care of ill workers should be disposed as per the national and state laws or relevant guidelines (e.g. WHO guidelines from time to time). PPE used for medical treatment/care purposes should be stored securely and kept separate from other waste. Current WHO recommendations are to clean utility gloves or heavy duty, reusable plastic aprons with soap and water and then decontaminate them with 0.5% sodium hypochlorite solution after each use. Single-use gloves (nitrile or latex) and gowns should be discarded after each use and not reused;

• Incentivize workers lodging in the local community to move to site accommodation.

• The community should be made aware, through posters etc., of procedures put in place at site to address issues related to COVID-19. This should include all measures being implemented to limit or prohibit contact between workers and the community.

Appendix 18 241

Additional guidance for good practice for Contractors:

o Follow national orders/circulars/guidelines issued from time to time

o Apply the guidelines/guidance notes referred in the document

o Practice the Daily Drill and General Guidance above.

o Camp sites and construction sites may require different approaches to avoid spread of COVID-19. Special care to be taken for supply chain related vehicles, personnel and material.

o Provide Contactless attendance system

The various guidelines / interim notes for construction sites have been prepared by several

institutions and organizations, some of which are listed below:

a. The Ministry of Home Affairs and Ministry of Health and Family Welfare, Government of India

issued several Orders/Circulars/Guidelines from time to time to be followed by the State

governments, sectors and individuals :- (https://www.mha.gov.in/notifications/circulars-covid-

19,

https://www.mha.gov.in/sites/default/files/PR_ConsolidatedGuidelinesofMHA_28032020_0.p

df , https://www.mohfw.gov.in/. Further, amendments to these orders are updated from time

to time on https://www.mha.gov.in/media/whats-new,

b. ILO’s Guidance: Considerations for employment intensive works in response to COVID 19

(April 12, 2020): https://www.ilo.org/wcmsp5/groups/public/---

ed_emp/documents/publication/wcms_741669.pdf

c. WB’s ESF/Safeguards interim note: COVID-19 considerations in construction/civil works

projects (April 7, 2020)

d. WHO’s guidelines: Getting your workplace ready for COVID-19 (March 03, 2020)

https://www.who.int/docs/default-source/coronaviruse/getting-workplace-ready-for-covid-

19.pdf; Water, sanitation, hygiene, and waste management for the COVID-19 virus (March

19, 2020) https://www.who.int/publications-detail/water-sanitation-hygiene-and-waste-

management-for-covid-19; Rational use of personal protective equipment (PPE) for

coronavirus disease (March 19, 2020):

https://apps.who.int/iris/bitstream/handle/10665/331695/WHO-2019-nCov-IPC_PPE_use-

2020.3-eng.pdf .

e. IASC Interim Guidance: Scaling-Up Covid-19 Outbreak Readiness and Response Operations

in Humanitarian Situations, Including Camps and Camp-Like Settings (March 17, 2020)

https://interagencystandingcommittee.org/other/interim-guidance-scaling-covid-19-outbreak-

readiness-and-response-operations-camps-and-camp

f. IDB’s Guidance for infrastructure projects on COVID-19

https://www.idbinvest.org/en/download/9625

g. IFC Guidance: Workers’ accommodation: processes and standards (2009)

http://documents.worldbank.org/curated/en/604561468170043490/pdf/602530WP0worke10B

ox358316B01PUBLIC1.pdf

https://www.mha.gov.in/notifications/circulars-covid-19

https://www.mha.gov.in/notifications/circulars-covid-19

https://www.mha.gov.in/sites/default/files/PR_ConsolidatedGuidelinesofMHA_28032020_0.pdf

https://www.mha.gov.in/sites/default/files/PR_ConsolidatedGuidelinesofMHA_28032020_0.pdf

https://www.mohfw.gov.in/

https://www.mha.gov.in/media/whats-new

https://www.ilo.org/wcmsp5/groups/public/---ed_emp/documents/publication/wcms_741669.pdf

https://www.ilo.org/wcmsp5/groups/public/---ed_emp/documents/publication/wcms_741669.pdf

https://www.who.int/docs/default-source/coronaviruse/getting-workplace-ready-for-covid-19.pdf

https://www.who.int/docs/default-source/coronaviruse/getting-workplace-ready-for-covid-19.pdf

https://www.who.int/publications-detail/water-sanitation-hygiene-and-waste-management-for-covid-19

https://www.who.int/publications-detail/water-sanitation-hygiene-and-waste-management-for-covid-19

https://apps.who.int/iris/bitstream/handle/10665/331695/WHO-2019-nCov-IPC_PPE_use-2020.3-eng.pdf

https://apps.who.int/iris/bitstream/handle/10665/331695/WHO-2019-nCov-IPC_PPE_use-2020.3-eng.pdf

https://interagencystandingcommittee.org/other/interim-guidance-scaling-covid-19-outbreak-readiness-and-response-operations-camps-and-camp

https://interagencystandingcommittee.org/other/interim-guidance-scaling-covid-19-outbreak-readiness-and-response-operations-camps-and-camp

https://www.idbinvest.org/en/download/9625

http://documents.worldbank.org/curated/en/604561468170043490/pdf/602530WP0worke10Box358316B01PUBLIC1.pdf

http://documents.worldbank.org/curated/en/604561468170043490/pdf/602530WP0worke10Box358316B01PUBLIC1.pdf

242 Appendix 18

Date Place of Registration

Contact Information/Personal Details Name: Gender: Male Female Age: Home Address Village/Town District Phone no. E-mail Complaint/Suggestion/Comment/Question Please provide the details (who, what, where and how) of your Grievance below: If included as an attachment/note/letter, please mention here:

How do you want us to reach you for feedback on your comment/grievance?

Registered by: (Name of Official registering grievance)

Verified through:

Note/Letter

E-mail

Verbal/Telephonic Reviewed by: (Names/Position of Official(s)reviewing grievance)

Action Taken:

Whether Action Taken Disclosed:

Yes

No Means of Disclosure:

Sample Grievance Form

(To be made available in Tamil)

The Proposed Inclusive, Resilient and Sustainable Housing for the Urban Poor Project welcomes

complaints, suggestions, queries, and comments regarding program implementation. We

encourage persons with a grievance to provide their name and contact information to enable us

to get in touch with you for clarification and feedback.

In case you want to include your personal details but want information to remain confidential,

please type CONFIDENTIAL above your name.

FOR OFFICIAL USE ONLY

Appendix 19 243

Sample Environmental Site Inspection Report

Project Name Contract Number

NAME: _____________________________________ DATE: __________________________ TITLE: _______________________________________ DMA: ___________________________ LOCATION: __________________________________ GROUP: ________________________ WEATHER CONDITION:______________________________________________________________________ INITIAL SITE CONDITION:___________________________________________________________ CONCLUDING SITE CONDITION: Satisfactory ______Unsatisfactory ______Incident ______Resolved _______ Unresolved ______ INCIDENT: Nature of incident:__________________________________________________________________ Intervention Steps:__________________________________________________________________ Incident Issues

Project Activity Stage

Survey

Design

Implementation

Pre-Commissioning

Guarantee Period

Inspection

Emissions Waste Minimization

Air Quality Reuse and Recycling

Noise pollution Dust and Litter Control

Hazardous Substances Trees and Vegetation

Site Restored to Original Condition Yes No Signature _______________________________________ Sign off Name Position

Name Position

Resolution

244 Appendix 21

Quarterly Environmental Monitoring Report Template

Introduction

• Overall project description and objectives

• Environmental categorization of each subproject as per ADB Safeguard Policy Statement (SPS 2009)

Project Safeguards Team

• Identify the role/s of Safeguards Team including schedule of on-site verification of reports submitted by consultants and contractors.

Name Designation/Office Email Address Contact Number Roles

1. PMU

2. PIDs

3. Consultants

Overall Project and Subproject/Package Progress and Status

• Description of Sub-projects and Indicate

o Status of design – preliminary design or final design, o Status of implementation - under bidding, contract awarded but no works yet,

contract awarded with works (on-going construction), civil works completed, and/or Operation & Maintenance (O&M)

Package Number

Subproject Name / List of Works

Type of Contract (specify if DBO, DB

or civil works)

Status of Design

(specify if Preliminary

Design, Final Detailed Design

Contract Status

(specify if under

bidding or contract

awarded)

Status of Implementation

(specify if Contract awarded with works (On-

going Construction),

Completed Works, or O&M

phase)29

If On-going Construction

%Physical Progress

Expected Completion

Date

o For package with “Contract Awarded”, provide name/s and contact details of

contractor/s’ nodal person/s for environmental safeguards.

29 If on-going construction, include %physical progress and expected date of completion

Appendix 21 245

Package-wise Contractor/s’ Nodal Persons for Environmental Safeguards

Package Name

IEE Cleared by ADB (provide

date)

Contractor EHS Nodal Person

Email Address

Contact Number

Status of IEE per Subproject/Package

• Provide status of updated/final IEE30 per package.

Package-wise Implementation Status

Package Number

Final IEE based on Detailed Design Site-specific EMP or

Construction (C-EMP) approved

by Chief Engineer?31

(Yes/No)

Remarks

Not yet due

(detailed design not

yet completed)

Submitted to ADB (provide date of

submission)

Disclosed on

project website (provide

link)

Final IEE provided to Contractor/s

(Yes/No)

Compliance Status with National/State/Local Statutory Environmental Requirements32

Package Number

Statutory Environmental Requirements33

Status of Compliance (Specify if obtained,

submitted and awaiting approval, application not yet

submitted )

Validity Date(s)

(if already

obtained)

Action Required

Specific Conditions that will require environmental

monitoring as per environmental

clearance, consent / permit to establish34

Compliance Status with Environmental Loan Covenants

Schedule No. and Item Covenant Status of Compliance Action Required

30 IEE prepared based on preliminary design and cleared by ADB with condition that updated/Final IEE based on

detailed design will be submitted. 31 Works will not be allowed until C-EMP is approved by the PMU and/or PID. 32 All statutory clearance/s, no-objection certificates, permit/s, etc. should be obtained prior to award of contract/s.

Attach as Appendix all clearances obtained during the reporting period. If already reported, specify in the “remarks” column.

33 Specify statutory requirements: environmental clearance? Permit/consent to establish? Forest clearance? Workers/Labor permit, etc.

34 Example: Environmental Clearance requires ambient air quality monitoring, Forest Clearance/Tree-cutting Permit requires 2 trees for every tree, etc.

246 Appendix 21

(see Project Loan Agreement and list

provisions / paragraph relevant to environmental

safeguards, core labor standards, occupational

EHS, community health and safety)

Compliance Status with the Environmental Management Plan (refer to EMP tables in

approved IEE/s)

• Confirm in IEE/s if contractors are required to submit construction EMPs (C-EMP). If not, describe the methodology of monitoring each package under implementation.

• Provide over-all compliance of the contractors with C-EMP. This should be supported by contractors’ monthly monitoring reports to PID(s) and/or verification reports of PID(s) or project consultants. Include as an Appendix supporting documents such as signed monthly environmental site inspection reports prepared by consultants and/or contractors.

Overall Compliance with C-EMP

Package Number

Status of C-EMP Implementation (Excellent/ Satisfactory/ Partially Satisfactory/

Below Satisfactory)

Action Proposed and Additional Measures Required

• Provide description based on site observations and records: o Confirm if any dust was noted to escape the site boundaries and identify dust

suppression techniques followed for site/s. o Identify muddy water was escaping site boundaries or muddy tracks were seen on

adjacent roads. o Identify type of erosion and sediment control measures installed on site/s, condition of

erosion and sediment control measures including if these were intact following heavy rain.

o Identify designated areas for concrete works, chemical storage, construction materials, and re-fuelling. Attach photographs of each area.

o Confirm spill kits on site and site procedure for handling emergencies. o Identify any chemical stored on site and provide information on storage condition.

Attach photograph. o Describe management of stockpiles in each work site (construction materials,

excavated soils, spoils, etc.). Provide photographs. o Describe management of solid and liquid wastes on-site (quantity generated,

transport, storage and disposal). Provide photographs. o Provide information on barricades, signages, and on-site boards. Provide

photographs. o Provide information on construction / workers camp(s). Provide photographs.

Appendix 21 247

o Provide information on work-related accidents and incidents. Describe actions implemented.

o Provide information on if there are any activities being under taken out of working hours and how that is being managed.

• Provide list of trainings on environmental safeguards, core labor standards, and Occupational environment, health and safety conducted during the reporting period. Include ADB-organized workshop, trainings, seminars, etc)

Trainings, Workshops and Seminars Conducted

Date Topic Conducted by

No. of Participants

(Total)

No. of Participants

(Female)

Remarks

• Provide the monitoring results as per the parameters outlined in the approved EMP (or C-EMP when applicable).

Summary of Environmental Monitoring Activities (for the Reporting Period)35

Impacts (List

from C-EMP)

Mitigation Measures (List from C-EMP)

Parameters Monitored

(As identified in

the C-EMP)

Method of Monitoring

(Visual, Actual

Sampling, etc.)

Location of Monitoring

(Provide GPS Coordinates)36

Date of Monitoring Conducted

Person Who

Conducted the

Monitoring

Design Phase

Pre-Construction Phase

Construction Phase

Operational Phase

Monitoring of Environmental Impacts on Project Surroundings

• Confirm records of pre-work condition of roads, agricultural land or other infrastructure prior to starting to transport materials and construction.

Package Number. Status of Pre-Work Conditions

Baseline Environmental Conditions (air,

Action Proposed and Additional Measures

Required

35 Attach Laboratory Results and Sampling Map/Locations 36 If GPS coordinate is not available, provide landmark(s) and/or chainage.

248 Appendix 21

(Recorded / Not Recorded)

water, noise) Documented

(Yes / No)

• Provide information on monitoring activities conducted during reporting period. If not conducted, provide justification. Compare results with baseline and internationally recognized standards.37

Air Quality Monitoring Results

Site No. Date of Testing Site Location (Provide GPS Coordinates)38

Parameters (as required by statutory

clearances or as mentioned in the IEE)

Remarks

PM10 µg/m3

SO2 µg/m3

NO2 µg/m3

Water Quality Monitoring Results

Site No.

Date of Sampling

Site Location

Parameters (as required by statutory clearances or as mentioned in the IEE)

Remarks

pH Conductivity µS/cm

BOD mg/L

TSS mg/L

TN mg/L

TP mg/L

Noise Quality Monitoring Results

Site No. Date of Testing

Site Location

LAeq (dBA) (as required by statutory clearances or as mentioned in the IEE)

Remarks

Day Time Night Time

Information Disclosure, Participation and Consultations

37 ADB Safeguard Policy Statement (SPS) Appendix 1, para 33: During the design, construction, and operation of the

project the borrower/client will apply pollution prevention and control technologies and practices consistent with international good practice, as reflected in internationally recognized standards such as the World Bank Group’s Environment, Health and Safety Guidelines. These standards contain performance levels and measures that are normally acceptable and applicable to projects. When host country regulations differ from these levels and measures, the borrower/client will achieve whichever is more stringent. If less stringent levels or measures are appropriate in view of specific project circumstances, the borrower/client will provide full and detailed justification for any proposed alternatives that are consistent with the requirements presented in the SPS.

38 If GPS coordinate is not available, provide landmark(s) and/or chainage.

Appendix 21 249

• Confirm PMU/PID/contractors provide project-related information to stakeholders, communities and/or affected people before and during construction works.39

• Provide information on consultations conducted during reporting period such dates, topics discussed, type of consultation, issues/concerns raised, safeguards team member present. Attach minutes of meetings (ensure English translation is provided), attendance sheet, and photos.

Date of Consultation

Location Number of Participants (specify total, male and

female)

Issues/Concerns Raised

Response to issues/concerns

Grievance Redress Mechanism

• Grievance Redress Mechanism. Provide information on establishment of grievance redress mechanism and capacity of grievance redress committee to address project-related issues/complaints. Include as an Appendix Notification of the GRM (package-wise if applicable).

• Complaints Received during the Reporting Period. Provide information on number, nature, and resolution of complaints received during reporting period. Attach records as per GRM in the approved IEE. Identify safeguards team member/s involved in the GRM process. Attach minutes of meetings (ensure English translation is provided).

Summary of Key issues/concerns identified during the Reporting Period and Remedial

Actions

• Provide corrective action plan which should include all issues/concerns, actions required to be implemented, responsible entities, and target dates.

Status of Corrective Actions from Previous Monitoring Report(S)

• Provide information on corrective actions to be implemented as reported in the previous Monitoring Report(s). Include status of implementation of feedbacks/comments/suggestions as provided by ADB, if any.

Corrective Action Plan Status

Issues/Concerns Corrective Action Status Remarks

Appendices

• Photos

• Records of consultations

• Copies of environmental clearances and permits (if not provided in the previous Monitoring Reports)

• Environmental site inspection report (if not provided in the previous Monitoring Reports)

• Other

39 Check EMP requirement on information disclosure. At a minimum, PID through the contractor should notify

communities/affected persons/sensitive receptors 7 days and again 1 day before start of works.

250 Appendix 22

Outline of Daily Monitoring Sheet for Contractors

Contractor Monitoring Sheet Name of Subproject:

Location of Subproject: Supervising PID: Contractor: Contractor EHS Supervisor (or equivalent): Date of monitoring:

Summary of Findings Monitoring Item Status Remarks

1. Compliance with Local Permit (Secured / Application

Requirements Submitted / Not Applicable)

Location/zoning permits

Permit to construct

Building permit

Transport / hauling permits

2. Compliance with IEE Requirements (Approved / Under

Preparation / Submitted to PID for Approval)

Construction EMP (C-EMP)

Corrective Action Plan, if any

3. Compliance with C-EMP

Construction Site (Satisfactory / Needs

Improvement / Not Implemented)

- Conduct of toolbox talk

- Use of PPE

- Rest areas for male and female workers

- Toilets for male and female workers

- Medical kits

- Drinking water supply

- Dust control

- Noise control

- Solid waste management

- Wastewater management

- Chemicals storage (fuel, oil, etc.)

- Siltation or erosion control

- Heavy equipment staging / parking area

- Barricades around excavation sites

- Access to residential

houses/shops/businesses

- Traffic routing signages

- Lightings at night

- Trench shoring / landslide protection

Construction Workers’ Camp Site (Available / Needs

Appendix 22 251

Monitoring Item Status Remarks

Improvement / Not

Available)

Quarters for male and female workers

Monitoring Item Status Remarks

- Sleeping utilities (e.g. beds, pillows, blankets, mosquito nets, etc.)

- Power/Electricity supply

- Drinking water supply

- Toilets for male and female workers

- General purpose water supply (cooking, washing, bathing)

- Cooking facilities and areas

- Solid waste management

- Wastewater management

- Pest control

4. Implementation of GRM (Yes / No or None / Under

Resolution)

Complaints

Complaints resolution

5. Environmental Quality Measurement (Passed / Failed / Not

Applicable)

Ambient air quality sampling

Noise level measurement

Receiving water quality sampling

Other Issues:

Attachments:

1. Copies of permits secured, if any. 2. Photos taken at worksites, if any.

(Photos attached in previous monitoring sheets should not be used again). 3. Laboratory results of environmental quality measurements, if any.

Prepared by:

Name, Designation and Signature