KATTUPALLI PORT CHENNAI's NEW GATEWAY Date: 19 Feb 2019

Home , Buckingham Canal, Ennore, Ennore Creek, Kalanji, Karungali, Kattupalli

Date: 19th Feb 2019

Ministry of Environment , Forest and Climate Change, IA Division, Indira Paryavaran Bhavan, Jor Bagh Road, Aliganj, New Delhi – 110 003

Kind Attn: Dr.Vinod K Singh, Scientist D

Sub : Revised Master Plan (RMP) Development of Kattupalli Port by Marine Infrastructure Developer Pvt Ltd (MIDPL) – Reply to the representation of CAG (Citizen consumer and civic action group) – Reg.

Ref : Additional details sought vide Final Minutes of 38th EAC Infra-2 meeting held on 6-8 Feb. 2019 Sir,

This has reference to the captioned subject and cited reference above; we hereby submit our response to the key representation of CAG (Citizen consumer and civic Action Group) for your kind consideration.

Sr. Key representation from MIDPL’s Response No CAG 1 No other Site selection  It is pertinent to mention that the proposed criterion has been project under discussion is Expansion of Existing considered for the project Kattupalli Port Only and not a new Port creation.  Kattupalli port has already been established and is operational, and current proposal is for expansion of the port.  Following (Environment & Social) considerations were taken for finalising the master plan. - Existing port is bifurcated from Shipyard and therefore there is scope for expansion in southern side. Port expansion is being done mostly towards North, North west & Westward side - As a part of our expansion plan, ~ 33% of the total area is being proposed under reclamation to avoid R&R and other related issues - Further government and private land, as proposed are free from human settlements.

Marine Infrastructure Developer Pvt Ltd Tel +91 44 2824 3062 (Kattupalli Port) Kattupalli Village, Ponneri Taluk, CIN: U74999TN2016PTC103769 Tirivalluvar District 600 120, Tamil Nadu, India

Registered Office: Ramcon Fortuna Towers, 4th floor No 1/2, Kodambakkam High RoadNungambakkam, Chennai 600034

KATTUPALLI PORT CHENNAI’s NEW GATEWAY

2 Ennore creek is already  Ennore creek is located on the southern side at a under severe distance of ~ 4.0 kms from proposed project. anthropogenic pressure  Port expansion is planed mostly towards North, due to existing industrial North west & Westward side of the existing port establishments area and will not have direct impact on Ennore creek.  Proposed expansion is planned with adequate Environmental management facilities such as - Part of the cargo transportation through rail and Pipelines - Covered Conveyor and Transfer Points - Dust Suppression System at stockyard, Transfer towers, at berth/Unloaders, at wagon (Un)loading, at Track Hoppers, at Truck loading Silos, Discharge and feeding points of Conveyors etc., - Use of specialised ship loaders/unloaders, wagon tippler, track Hopper, covered conveyors and rapid loading system through silos - Proper house keeping - Trucks before leaving the loading area shall be covered with tarpaulin and also the railway wagons - Greenbelt Development - STP of 240 KLD - ETP of 1.5 MLD - Storm Water Drainage System for Inside and some portion of outside port area - Proper Collection, handling and Transport System for Solid Waste Management  Additional measures if any will be provided based on the EIA Studies and suggestions of MoEF&CC/TNPCB/TNCZMA etc.,  However, as part of EIA, detailed studies will be carried out as per ToR with respect to impact of proposed activity on the 10 km radius of the project area and the proposed mitigation measures will be implemented as a part of Environment Management Plan. 3 Conversion of Ennore  Ennore creek is located on the southern side at a creek and its associated distance of ~ 4.0 kms from proposed project. wetlands into industrial real  No activities are proposed as part of Ennore estate. Activities like Creek. reclamation in prohibited  Port expansion is being done mostly towards

Marine Infrastructure Developer Pvt Ltd Tel +91 44 2824 3062 (Kattupalli Port) Kattupalli Village, Ponneri Taluk, CIN: U74999TN2016PTC103769 Tirivalluvar District 600 120, Tamil Nadu, India

Registered Office: Ramcon Fortuna Towers, 4th floor No 1/2, Kodambakkam High RoadNungambakkam, Chennai 600034

KATTUPALLI PORT CHENNAI’s NEW GATEWAY

activity in this areas North, North west & Westward side of the existing port area and will not have direct impact on Ennore creek.  As per the Coastal Zone Management plan, published by Dept. of Environment, Tamil Nadu, the area proposed under Revised Master Plan development falls under CRZ I(B), CRZ III, CRZ IV(A) & CRZ IV(B).  Proposal for Revised Master Plan is submitted to MoEF&CC for consideration of ToR. As a part of draft ToR Proposed by MIDPL, the impact due to proposed activities including the sea reclamation and raising of low lying area has been committed. Based on the approved ToR, Environment Impact Assessment will be carried out including hydro dynamic modelling studies for the study area and mitigation measures will be identified and implemented as part of EMP.  Land use proposed as a part of Revised Master plan is in-line to the permissible activities, as per CRZ notification 2011, amended till date.  However all activities will be carried out, only after obtaining required permission from the concerned authorities. 4 Ennore creek is a protected  Ennore creek is located on the southern side at a wetland under “Wetland distance of ~ 4.0 kms from proposed project. Conservation and Ennore creek is not listed under Management Rules, 2010 wetlands/Ramsar sites under Ramsar & reclamation, setting up of Convention of Wetlands. new industries or  No activities are proposed as part of Ennore expanding existing creek. The proposed project under discussion is industries on protected Expansion of Existing Kattupalli Port Only not a wetland is prohibited. new Port creation. Port expansion is being done mostly towards North, North west & Westward side of the existing port area and will not have direct impact on Ennore creek. 5 Increase in Vehicular  As a part of our proposed project, apart from movement will further road evacuations, it is also proposed to evacuate deteriorate the air quality in cargo through Railway which is proposed on this region. North and South side of the project, which will help reduce the impact on the surrounding region. However, proper traffic management plan will be prepared and covered as a part of EIA & EMP, which will be implemented during execution of the project.

Marine Infrastructure Developer Pvt Ltd Tel +91 44 2824 3062 (Kattupalli Port) Kattupalli Village, Ponneri Taluk, CIN: U74999TN2016PTC103769 Tirivalluvar District 600 120, Tamil Nadu, India

Registered Office: Ramcon Fortuna Towers, 4th floor No 1/2, Kodambakkam High RoadNungambakkam, Chennai 600034

KATTUPALLI PORT CHENNAI’s NEW GATEWAY

 Impacts on air environment during operation phase during Bulk cargo handling/storage and transportation, Cryogenic Gases (Upto -162 degree Celsius, Pressurized Gases) regasification process and emissions from ships etc. Build-up of pollutant levels due to these emissions will be arrived through modelling studies using Gaussian Dispersion Models (ISCST3/ AERMOD). Mitigation measures will be accordingly suggested and implemented. 6 Location of critical – high  The project is not located in any declared investment infrastructure critically polluted area. Present proposal is like ports in areas expansion of existing Kattupalli port facilities.Port degrade/damaged by infrastructure will be developed, with all safety climate change needs to be consideration, considering proneness to natural looked at critically hazards. Disaster Management Plan is available with respect to existing infrastructure and operations and same will be upgraded in line to the proposed Revised Master Plan and same will be submitted to District administration.  However, as part of EIA, detailed studies will be carried out as per ToR with respect to impact of proposed activity on the 10 km radius of the project area and the proposed mitigation measures will be implemented as a part of Environment Management Plan. 7 Villages like  As per the Status of Shoreline change maps, Goongankuppan, Vairavan published by Institute of Ocean Management Kuppam, Korai Kuppan, (IOM), Anna University, Chennai and Ministry of Lighthouse Nadu Kuppam, Environment Forest & Climate Change, New Kadal Kanniyur, Kattupalli, Delhi, the shoreline where the water front Kalanji, Karungali, development as a part of Kattupalli port Revised Arangankuppan and Master Plan is proposed, is subjected to Low Thirumalai Nagar are likely accretion to Stable Coast to Low erosion. to be displaced by erosion  In general, the net littoral drift in this region is and privatising for the port. noted towards north and hence erosion on north side and accretion on south side of proposed marine structures are envisaged. The extent erosion/ has to be studied and accordingly available proven measures such as sand trap/bypassing, shoreline protection by using geo membranes/rocks/groins, etc., shall need to carried out to protect the shoreline.  As part of EIA Study detailed shoreline assessment will be conducted considering

Marine Infrastructure Developer Pvt Ltd Tel +91 44 2824 3062 (Kattupalli Port) Kattupalli Village, Ponneri Taluk, CIN: U74999TN2016PTC103769 Tirivalluvar District 600 120, Tamil Nadu, India

Registered Office: Ramcon Fortuna Towers, 4th floor No 1/2, Kodambakkam High RoadNungambakkam, Chennai 600034

KATTUPALLI PORT CHENNAI’s NEW GATEWAY

Revised Master Plan Layout to understand the impact on shoreline within 10 Km radius from the Project boundary and necessary Shoreline Management Plan will be proposed as part of mitigation measures which will be also considered as part of Environment Management Plan for the project.  Under CSR and CER program, sustainable livelihood projects will also be carried out in consultation with local communities that exists within project impact area.

Hope you find our above submissions are in order.

Thanking You

For Marine Infrastructure Developer Private Ltd

Authorized Signatory.

Marine Infrastructure Developer Pvt Ltd Tel +91 44 2824 3062 (Kattupalli Port) Kattupalli Village, Ponneri Taluk, CIN: U74999TN2016PTC103769 Tirivalluvar District 600 120, Tamil Nadu, India

Registered Office: Ramcon Fortuna Towers, 4th floor No 1/2, Kodambakkam High RoadNungambakkam, Chennai 600034

KATTUPALLI PORT CHENNAI’s NEW GATEWAY

Date: 19th Feb 2019 Ministry of Environment , Forest and Climate Change, IA Division, Indira Paryavaran Bhavan, Jor Bagh Road, Aliganj, New Delhi – 110 003

Kind Attn: Dr.Vinod K Singh, Scientist D

Sub : Revised Master Plan (RMP) for the Development of Kattupalli Port- Reply to the representation of Mr. Rahul Sridharan, Concerned Youth for People – Reg.

Ref : Additional details sought vide Final Minutes of 38th EAC Infra-2 meeting held on 6-8 Feb. 2019

Sir,

This has reference to the captioned subject above; we are submitting our pointwise response to the representation of Mr. Rahul Sridharan for your kind consideration.

Sl.No. Representation from Mr. Rahul MIDPL Reply Sridharan 1. The proposed expansion of the The land identified for the project Kattupalli Port by Adani and the abutting Kosasthaliyar river/ Buckingham proposed rail and road links from Canal including rail/ road corridor belongs Thatchur to Kattupalli, lay claim to to TIDCO and Department of Salt. almost all the commons – Including Transfer of lands in this region by the Salt the Kosasthalayar river – that have Department in favour of TIDCO was duly been used for centuries and continue considered and in progress. MIDPL is to be in use by the entire community already in touch with GoTN/ TIDCO for in Uranambedu. The same holds the use of the same land for Port true for the river commons and purpose. associated lands north of those tended to by the people of All the project activities will be carried out Uranambedu, where the customary only after obtaining required permissions rights of the communities from from the concerned authorities. Sengenimedu, Rajanthoppu, Ebrahampuram, Kaatupalli, Kalaanji, MIDPL is also committed to carry out Kaattur, Chindamanipuram and comprehensive CSR and CER programs Karungali to these landscapes are in the areas of Education, Community threatened by the proposed port Health, Sustainable Livelihood expansion. opportunities and Rural Infrastructure Development in the region. The aim is to walk with the communities, help people

Marine Infrastructure Developer Pvt Ltd Tel +91 44 2824 3062 (Kattupalli Port) Kattupalli Village, Ponneri Taluk, CIN: U74999TN2016PTC103769 Tirivalluvar District 600 120, Tamil Nadu, India

Registered Office: Ramcon Fortuna Towers, 4th floor No 1/2, Kodambakkam High RoadNungambakkam, Chennai 600034

KATTUPALLI PORT CHENNAI’s NEW GATEWAY

look ahead, make the right choices and secure a bright and beautiful future, together. Other than government land, there are private land which are forming a part of proposed port area as well as rail/road corridor. MIDPL is proposing the direct negotiated purchase of these areas from the land owners.

Proposed expansion will not hamper any customary rights of the concern Communities. 2. The construction of port facilities No activities are proposed in the Ennore including infrastructure for producing Creek area. power, desalination, storage of petrochemicals and ores, cryogenic Proposed project facilities doesn’t include facilities and warehousing in the any Ecological Sensitive Areas such as Ennore Creek and estuary of the Mud Flat/sand dunes/ mangroves as Kosathalayar river, its flood plains, defined in the Approved CZMP (attached mud flats, mangroves and salt pans as Annexure 1). It is pertinent to mention – all landscapes below sea level – that the mangroves are already excluded and in some 1800 acres reclaimed in the Master Plan during the planning from the Bay of Bangal – by dumping stage itself. earth dredged from the sea or carted in from further inland to protect the Proposal for Revised Master Plan is port facilities from the naturally flood submitted to MoEF&CC for consideration prone estuarine region – and by of ToR.. Based on the approved ToR, flattening the sand dunes in Environment Impact Assessment will be Kattupalli, will inevitably obstruct the carried out including hydro dynamic flood drainage of the lands to the modelling studies for the study area and west of the proposed port expansion mitigation measures will be identified and via the Kosasthalayar river and implemented as part of EMP. inundate thousands of acres of agricultural land and river commons In addition, Drainage study of the study besides several villages. area is also proposed as a part of draft ToR by MIDPL. Drainage pattern of the study area will be studied and adequate measures will be ensured to carry the runoff generated safely by deepening/widening and desilting if required based on the scientific study. Storm water drainage network will be designed considering the proposed level rising near these areas, the drain in and around project site area will be designed

Marine Infrastructure Developer Pvt Ltd Tel +91 44 2824 3062 (Kattupalli Port) Kattupalli Village, Ponneri Taluk, CIN: U74999TN2016PTC103769 Tirivalluvar District 600 120, Tamil Nadu, India

Registered Office: Ramcon Fortuna Towers, 4th floor No 1/2, Kodambakkam High RoadNungambakkam, Chennai 600034

KATTUPALLI PORT CHENNAI’s NEW GATEWAY

to safely carry the runoff generated due to rainfall. Outlets will be developed for the storm water towards natural sloping which can be used during monsoon and will be connected to existing drainage network if any. The details of the same shall be studied and covered as a part of EIA studies.

Land use proposed as a part of Revised Master plan is in line with the permissible activities, as per CRZ notification 2011, amended till date. 3. The exclusion of a narrow north- The drainage pattern of the study area is south channel from the proposed mainly governed by Araniyar, project boundary surrounding it, for Korattalayar, The drainage pattern, in the Kosasthalayar river and the general, is dendritic. All the rivers are Buckingham Canal to connect with seasonal and carry flood water during the Karungali estuary and the Pulicat monsoon period. The drainage pattern of lake, is nothing but a miserly and the region is given as Annexure 3. It is extremely short sighted ‘concession’ pertinent to mention that Korattaliar river to a major river draining the better empties into the Ennore creek which is part of thiruvallur District and known located 4.4 km South from the proposed to have carried over 100,000 cusecs expansion boundary. Aranai river empties of flood waters during the Chennai into the Pulicat lake which is located 7.2 Floods of 2015. km North from the proposed expansion boundary. The Kosasthaliyar stream and Buckinham Canal is connecting these Ennore Creek and Pulicat lake which is passing between the proposed expansion plan facilities.

Drainage study of the study area is also proposed as a part of draft ToR by MIDPL. Drainage pattern of the study area will be studied and adequate measures will be ensured to carry the runoff generated safely by deepening/widening and desilting if required based on the scientific study.

Land use proposed as a part of Revised Master plan is in line with the permissible activities, as per CRZ notification 2011, amended till date.

Marine Infrastructure Developer Pvt Ltd Tel +91 44 2824 3062 (Kattupalli Port) Kattupalli Village, Ponneri Taluk, CIN: U74999TN2016PTC103769 Tirivalluvar District 600 120, Tamil Nadu, India

Registered Office: Ramcon Fortuna Towers, 4th floor No 1/2, Kodambakkam High RoadNungambakkam, Chennai 600034

KATTUPALLI PORT CHENNAI’s NEW GATEWAY

All the activities will be carried out, only after obtaining required permission from the concerned authorities. 4. It will also destroy the region’s As per the Status of Shoreline change capacity to absorb storm surges from maps, published by Institute of Ocean the seaward side and expose the Management (IOM), Anna University, proposed facilities to extensive Chennai and Ministry of Environment damage from extreme climate Forest & Climate Change, New Delhi, the events. The proposed breakwater shoreline where the water front and land reclamation stretching from development as a part of Kattupalli port Kattupalli and Karungali, will push Revised Master Plan is proposed, is coastal erosion due to littoral drift subjected to Low accretion to Stable further north and risk the loss of Coast to Low erosion. Pulicat Lake and Sriharikota to the Sea. In addition, shoreline changes map prepared by IOM, AU for Andhra Pradesh based on LISS III 2010 imagery reveals that the shore line north of Pulicat lake mouth subjected to Low/Meduim/High Erosion and south of Pulicat lake mouth is subjected to Stable, Low/Medium/High accretion. It is observed that proposed Revised Master Plan Breakwater is located about 7.2 km south of Pulicat Lake and 11.0 km South from lake mouth opening to bay of Bengal. These maps are provided as Annexure 1.

Further, Revised Master Plan is submitted to MoEF&CC for consideration of ToR. As per the standard ToR, Environment Impact Assessment will cover various modelling studies, include shoreline assessment, to study the impact near the vicinity and the proposed mitigation measures as a part of Environment Management Plan.

Inline to the EIA notification 2006, amended till date, final EIA will be submitted to EAC for consideration for final Environment & CRZ Clearance. Only after obtaining final clearance from MoEF&CC, further development activities

Marine Infrastructure Developer Pvt Ltd Tel +91 44 2824 3062 (Kattupalli Port) Kattupalli Village, Ponneri Taluk, CIN: U74999TN2016PTC103769 Tirivalluvar District 600 120, Tamil Nadu, India

Registered Office: Ramcon Fortuna Towers, 4th floor No 1/2, Kodambakkam High RoadNungambakkam, Chennai 600034

KATTUPALLI PORT CHENNAI’s NEW GATEWAY

inline to Revised master plan will be carried out.

In general, the net littoral drift in this region is noted towards north and hence erosion on north side and accretion on south side of proposed marine structures are envisaged. The extent erosion/ has to be studied and accordingly available proven measures such as sand trap/bypassing, shoreline protection by using geo membranes/rocks/groins, etc., shall need to carried out to protect the shoreline. 5. The Proposed road and rail links Rail/Road corridor will be developed by from the west will cut through taking cognizance of the drainage pattern Maamuni eri while the elevated of the region. Water Body/ Drain crossing facilities referred to above will cut if any shall be duly considered in the through all the east flowing channels design and accordingly Culverts/ corridor from the tank into the river. The on stills will be provided as appropriate to obstruction to flood drainage will not ensure the drainage pattern of the region only inundate the lands to the west is undisturbed. during the monsoons and spells of heavy rain but prevent the Drainage pattern of the study area will be continuous recharge of ground water studied and adequate measures will be at a scale that will invite the salt ensured to carry the runoff generated water from the sea to take over the safely by deepening/widening and aquifer already threatened by desilting if required based on the scientific salinity, along the coast from North study. All measures will be taken The Chennai up to Pulicat lake. details of the same shall be studied and covered as a part of EIA studies

Proposal for Revised Master Plan is submitted to MoEF&CC for consideration of ToR. Based on ToR, Environment Impact Assessment will be carried out including hydro dynamic modelling studies & flood discharge scenarios inline to the proposed development and the mitigation measures will be identified suggested and implemented as part of EMP. All the activities will be carried out, only after obtaining required permission from the concerned authorities.

Marine Infrastructure Developer Pvt Ltd Tel +91 44 2824 3062 (Kattupalli Port) Kattupalli Village, Ponneri Taluk, CIN: U74999TN2016PTC103769 Tirivalluvar District 600 120, Tamil Nadu, India

Registered Office: Ramcon Fortuna Towers, 4th floor No 1/2, Kodambakkam High RoadNungambakkam, Chennai 600034

KATTUPALLI PORT CHENNAI’s NEW GATEWAY

6. The experience of the coastal and Proposed expansion is planned with inland fishing communities in the adequate Environmental management Ennore Creek and those from facilities such as Kattupalli, Sepakkam, Uranambedu  Part of the cargo transportation and Senganimedu point to the through rail and Pipelines distinct possibility that the  Covered Conveyor and Transfer construction and operation of mega- Points facilities like those proposed in the  Dust Suppression System at Revised Master Plan for the tenfold stockyard, Transfer towers, at expansion of the Kattupalli port, will berth/Unloaders, at wagon result in the endemic contamination (Un)loading, at Track Hoppers, at of air, water and soil to the degree Truck loading Silos, Discharge and that it will make it impossible for feeding points of Conveyors etc., thousands of families in the  Use of specialised ship surrounding villages to continue to loaders/unloaders, wagon tippler, live and work here. track Hopper, covered conveyors and rapid loading system through silos  Proper house keeping  Trucks before leaving the loading area shall be covered with tarpaulin and also the railway wagons  Trucks Tyres and areas susceptible for coal dust before leaving premises shall be cleansed washed to remove coal particles.  Use of -low sulphur diesel fuel is proposed.  Greenbelt Development  Use of Eco friendly regasification technology such as Seawater based/ Ambient Air Based for LNG Regasification.  STP of 240 KLD  ETP of 1.5 MLD  Settling Pond  Storm Water Drainage System for Inside and some portion of outside port area  Proper Collection, handling and Transport System for Solid Waste Management Additional measures if any will be provided based on the EIA Studies and suggestions of MoEF&CC/TNPCB/TNCZMA etc.,

Marine Infrastructure Developer Pvt Ltd Tel +91 44 2824 3062 (Kattupalli Port) Kattupalli Village, Ponneri Taluk, CIN: U74999TN2016PTC103769 Tirivalluvar District 600 120, Tamil Nadu, India

Registered Office: Ramcon Fortuna Towers, 4th floor No 1/2, Kodambakkam High RoadNungambakkam, Chennai 600034

KATTUPALLI PORT CHENNAI’s NEW GATEWAY

As a part of proposed expansion, all the required studies based on Terms of Reference granted by MoEF & CC will be carried out as part of EIA and mitigation plan will be proposed and implemented accordingly. 7. Whatever the merits of the proposed Nearest declared Ecological sensitive port expansion project, it is clear that area is Pulicat Sanctuary which is located in appropriating and privatizing at about 14.5 NW of proposed port thousands of acres of ecologically expansion boundary. The proposed fragile wetlands and estuarine – expansion site is superimposed on the coastal commons, it will snatch away approved CZMP which reveals that the the very basis for the sustenance of proposed expansion area is not a part of all those engaged in sea and inland any CRZ I A (i.e. Ecologically Sensitive fishing, farming, animal husbandry Areas) and forestry in the Ennore Creek and Kosasthalayar estuarine region and Only few patches of mangroves are related coastal environments, observed in and around the vicinity which destabilize beyond repair the are already excluded with sufficient buffer precarious hydrological balance by as per CRZ notification 2011. creating and promoting conditions for extreme flood, drought and salt As part of proposed project detailed study water intrusion, drive to extinction will be carried out with respect Changes several endemic species of flora and in Hydrodynamics fauna – many yet to be identified – Impacts on Marine water quality, and right the death kneel for Shoreline/Coastline, Marine ecology, thousands of people representing Pulicat Lake, fishing communities and several village communities in the animal husbandry etc. vicinity while irreversibly compromising the potential of the Under CSR and CER program, commons enclosed to support future sustainable livelihood projects will also be generations either directly or carried out in consultation with local indirectly. communities that exists within project impact area.

Proposal for Revised Master Plan is submitted to MoEF&CC for consideration of ToR. Based on ToR, Environment Impact Assessment will be carried out using appropriate available models for dredge spoil disposal, various discharges, shoreline changes, hydro dynamic modelling studies and flood discharge scenarios for the study area and mitigation measures will be identified and implemented as part of EMP.

Marine Infrastructure Developer Pvt Ltd Tel +91 44 2824 3062 (Kattupalli Port) Kattupalli Village, Ponneri Taluk, CIN: U74999TN2016PTC103769 Tirivalluvar District 600 120, Tamil Nadu, India

Registered Office: Ramcon Fortuna Towers, 4th floor No 1/2, Kodambakkam High RoadNungambakkam, Chennai 600034

KATTUPALLI PORT CHENNAI’s NEW GATEWAY

All the activities will be carried out, after obtaining required permission from the concerned authorities.

Hope you find our above submissions are in order.

Thanking You

For Marine Infrastructure Developer Private Ltd

Authorized Signatory.

Marine Infrastructure Developer Pvt Ltd Tel +91 44 2824 3062 (Kattupalli Port) Kattupalli Village, Ponneri Taluk, CIN: U74999TN2016PTC103769 Tirivalluvar District 600 120, Tamil Nadu, India

Registered Office: Ramcon Fortuna Towers, 4th floor No 1/2, Kodambakkam High RoadNungambakkam, Chennai 600034

KATTUPALLI PORT CHENNAI’s NEW GATEWAY

Date: 19th Feb 2019 Ministry of Environment , Forest and Climate Change, IA Division, Indira Paryavaran Bhavan, Jor Bagh Road, Aliganj, New Delhi – 110 003

Kind Attn: Dr.Vinod K Singh, Scientist D

Sub : Revised Master Plan (RMP) Development of Kattupalli Port by Marine Infrastructure Developer Pvt Ltd (MIDPL)– Reply to the representation of Fishermen Panchayat Sabha, Kattupallikupan, Ponneri Taluk, Thiruvallur District, Tamil Nadu – Reg.

Ref: Additional details sought vide Final Minutes of 38th EAC Infra-2 meeting held on 6-8 Feb. 2019

Sir,

This has reference to the captioned subject and cited reference above; we are submitting our response to the representation of Fishermen Panchayat Sabha, Kattupallikupan for your kind consideration.

Sl.No. Representation from Fishermen MIDPL Reply Panchayat Sabha, Kattupallikupan 1 It has come to our notice that It is pertinent to mention that the ministry is in receipt of revised proposed project under discussion is Master plan (RMP) for development Expansion of Existing Kattupalli Port of Katuapalli port by Adani / Marine and not a new Port creation. Infrastructure Development Private limited for Tor in Ponneri taluka, Kamarajar Port is operating since 2001 thiruvallur district, Tamilnadu. We and LTSB started its operation after would like to bring to your notice that obtaining required approvals, from Jan this port is being proposed just north 2013. Bifurcation of EC and CRZ of the existing Kamarajar Port and Clearance between MIDPL & LTSB L&T shipbuilding yard. Already, due obtained from MoEf & CC on 9th to these two operation ports, the February 2018. coastline on the northern parts towards pulicat has been subject to As per the Status of Shoreline change direct to wide spread beach erosion, maps, published by Institute of Ocean greatly affecting our fish livelihood. Management (IOM), Anna University, Now another mega project in the Chennai and Ministry of Environment area will prove disastrous as the rate Forest & Climate Change, New Delhi, of erosion toward pulicat lake will the shoreline where the water front increase significantly. There is a risk development as a part of Kattupalli port

Marine Infrastructure Developer Pvt Ltd Tel +91 44 2824 3062 (Kattupalli Port) Kattupalli Village, Ponneri Taluk, CIN: U74999TN2016PTC103769 Tirivalluvar District 600 120, Tamil Nadu, India

Registered Office: Ramcon Fortuna Towers, 4th floor No 1/2, Kodambakkam High RoadNungambakkam, Chennai 600034

KATTUPALLI PORT CHENNAI’s NEW GATEWAY

of the sand bar separating Pulicat Revised Master Plan is proposed, is lake and bay of Bengal eroding, subjected to Low accretion to Stable resulting in massive sea level raise Coast to Low erosion. that will swallow the islands of pulicat lake where many habitants are In addition, shoreline changes map situated. prepared by IOM, AU for Andhra Pradesh based on LISS III 2010 It is not only habitations in Pulicat imagery reveals that the shore line north that will be affected. Allowing the sea of Pulicat lake mouth subjected to to move inland into the Pulicat lake Low/Meduim/High Erosion and south of will greatly affect inland fresh water Pulicat lake mouth is subjected to aquifiers that will lead to collapse of Stable, Low/Medium/High accretion. It is fresh water resources in the district. observed that proposed Revised Master Plan Breakwater is located about 7.2 km south of Pulicat Lake and 11.0 km South from lake mouth opening to bay of Bengal. These maps are provided as Annexure 1.

Marine Infrastructure Developer Pvt Ltd Tel +91 44 2824 3062 (Kattupalli Port) Kattupalli Village, Ponneri Taluk, CIN: U74999TN2016PTC103769 Tirivalluvar District 600 120, Tamil Nadu, India

Registered Office: Ramcon Fortuna Towers, 4th floor No 1/2, Kodambakkam High RoadNungambakkam, Chennai 600034

KATTUPALLI PORT CHENNAI’s NEW GATEWAY

shoreline protection by using geo membranes/rocks/groins, etc., will be implemented.

It is to be noted that Pulicat lake is a brackish water system which is being fed by two rain fed rivers namely Kalangi and Arani. The salinity levels lowers during Monsoon season and will be carrying from brackish to Saline for the remaining period.

During the execution of the proposed project all the required support will be given to Government Authorities as part of CER for their efforts on protection and conservation of Pulicat lake. 2 The plan also propose to take over Proposed master plan will not be Karungali Estuary that will lead to obstructing Karungali Estuary. obstructing drainage - causing floods not only in these areas but also upstream areas 3 We are at the point, where many As per the Coastal Zone Management report and scientific studies, have plan, published by Dept. of proven variety of risk, due to climate Environment, Tamil Nadu, the area change induces sea level rise. The proposed under Revised Master Plan sand dune in Katupalli and Kalanji development does not contain any sand village act as buffer, protecting, the dunes. The approved CZMP is attached area and groundwater inland. Now, as Annexure 2. the port proposes to flatten many areas of sand dunes, exposing the Land use proposed as a part of Revised habitants here to the extreme effects Master plan is in line to the permissible of natural weather events like activities, as per CRZ notification 2011, cyclones, tsunami, etc. Blocking of amended till date. drainage and extreme land use Various studies will be carried out to changes in the backwater will result understand the impact of the proposed in the effect of these disaster being project in the vicinity areas. felt by areas even inland. However all the activities will be carried out only, after obtaining required permission from the concerned authorities. 4 The project envisages massive take As per the Coastal Zone Management over of backwater and river flood plan, published by Dept. of plains that will affect the livelihood of Environment, Tamil Nadu, the area thousands of people making a living proposed under Revised Master Plan

Marine Infrastructure Developer Pvt Ltd Tel +91 44 2824 3062 (Kattupalli Port) Kattupalli Village, Ponneri Taluk, CIN: U74999TN2016PTC103769 Tirivalluvar District 600 120, Tamil Nadu, India

Registered Office: Ramcon Fortuna Towers, 4th floor No 1/2, Kodambakkam High RoadNungambakkam, Chennai 600034

KATTUPALLI PORT CHENNAI’s NEW GATEWAY

by fishing and allied activities, salt development falls under CRZ IB, farming, fish farming, hand picking of CRZIII, CRZ IVA & CRZ IVB shells, grazing livestock and agriculture. Land use proposed as a part of Revised Master plan is in line to the permissible activities, as per CRZ notification 2011, amended till date.

No such activities like fishing, salt farming, fish farming, hand picking of the shells has been observed in the proposed project areas.

Proposal for Revised Master Plan is submitted to MoEF&CC for consideration of ToR. As per the standard ToR, Environment Impact Assessment will be prepared.

Further, Social Impact assessment will be carried out as a part EIA studies to identify the impact on locals and CSR plan will be developed accordingly.

Hope you find our above submissions are in order.

Thanking You

For Marine Infrastructure Developer Private Ltd

Authorized Signatory.

Marine Infrastructure Developer Pvt Ltd Tel +91 44 2824 3062 (Kattupalli Port) Kattupalli Village, Ponneri Taluk, CIN: U74999TN2016PTC103769 Tirivalluvar District 600 120, Tamil Nadu, India

Registered Office: Ramcon Fortuna Towers, 4th floor No 1/2, Kodambakkam High RoadNungambakkam, Chennai 600034

KATTUPALLI PORT CHENNAI’s NEW GATEWAY

Date: 19th Feb 2019 Ministry of Environment , Forest and Climate Change, IA Division, Indira Paryavaran Bhavan, Jor Bagh Road, Aliganj, New Delhi – 110 003

Kind Attn: Dr.Vinod K Singh, Scientist D

Sub : Revised Master Plan (RMP) for the Development of Kattupalli Port – Agenda Item No. 38.3.2 EAC (Infra 2) – Kattupalli Port, MIDPL – Thiruvallur District, Tamil Nadu - Reply to the representation of Mr. Nityanand Jeyaraman – Reg.

Ref : Additional details sought vide Final Minutes of 38th EAC Infra-2 meeting held on 6-8 Feb. 2019

Sir,

This has reference to the captioned subject above; we are submitting our pointwise response to the representation of Mr. Nityanand Jeyaraman for your kind consideration.

Sl.No. Representation from Mr. MIDPL Reply Nityanand Jeyaraman 8. The Port is set to come up into  It is pertinent to mention that the erosion – prone zone, in close proposed project under discussion is proximity to the Kamarajar Port Ltd., Expansion of Existing Kattupalli Port which has already triggered harmful  As per the Status of Shoreline shoreline dynamics. change maps, published by Institute of Ocean Management, Anna University, Chennai and Ministry of Environment Forest & Climate Change, New Delhi, the shoreline where the water front development as a part of Kattupalli port Revised Master Plan is proposed, is subjected to Low accretion to Stable Coast to Low erosion.  In general, the net littoral drift in this region is noted towards north and hence erosion on north side and accretion on south side of proposed marine structures are envisaged. The extent erosion will be studied as a part of EIA and accordingly available

Marine Infrastructure Developer Pvt Ltd Tel +91 44 2824 3062 (Kattupalli Port) Kattupalli Village, Ponneri Taluk, CIN: U74999TN2016PTC103769 Tirivalluvar District 600 120, Tamil Nadu, India

Registered Office: Ramcon Fortuna Towers, 4th floor No 1/2, Kodambakkam High RoadNungambakkam, Chennai 600034

KATTUPALLI PORT CHENNAI’s NEW GATEWAY

proven measures such as sand trap/bypassing, shoreline protection by using geo membranes/rocks/groins, etc., will be implemented to protect the shoreline.  As per CRZ Notification 2011 and subsequent amendments, ports are permissible activity in such classified area for which Comprehensive EIA is to be done.  MIDPL will comply with all the requirements as per the EIA notifications 2006 as well as CRZ notifications 2011 and subsequent amendments till date.  As part of EIA Study detailed shoreline assessment will be conducted considering Revised Master Plan Layout to understand the impact on shoreline within 10 Km radius from the Project boundary and necessary Shoreline Management Plan will be proposed as part of mitigation measures which will be also considered as part of Environment Management Plan for the project. 9. Erosion triggered by the Port can  The habitation of Koraikuppam harm fisher villages like village is located at 1.5 km north of Koraikuppam to the North. proposed Northern boundary of the Revised Master Plan.  As per the Status of Shoreline change maps, published by Institute of Ocean Management (IOM), Anna University, Chennai and Ministry of Environment Forest & Climate Change, New Delhi, the existing status of shoreline near Koriakuppam is under low erosion under natural phenomenon.  As part of EIA Study detailed shoreline assessment will be conducted considering Revised Master Plan Layout to understand the impact on shoreline within 10 Km

Marine Infrastructure Developer Pvt Ltd Tel +91 44 2824 3062 (Kattupalli Port) Kattupalli Village, Ponneri Taluk, CIN: U74999TN2016PTC103769 Tirivalluvar District 600 120, Tamil Nadu, India

Registered Office: Ramcon Fortuna Towers, 4th floor No 1/2, Kodambakkam High RoadNungambakkam, Chennai 600034

KATTUPALLI PORT CHENNAI’s NEW GATEWAY

radius from the Project boundary and necessary Shoreline Management Plan will be proposed as part of mitigation measures to prevent erosion along the coast of fishing villages  Under CSR and CER program, sustainable livelihood projects will also be carried out in consultation with local communities that exists within project impact area. 10. Erosion triggered by the Port can  It is to be noted that Pulicat lake is a breach the narrow strip of sand brackish water system which is being separating the Bay of Bengal from fed by two rain fed rivers namely the Lake Pulicat irreversibly altering Kalangi and Arani. The salinity levels the brackish water system and lowers during Monsoon season and causing salinity intrusion deep will be carrying from brackish to inland. Saline for the remaining period.  As per shoreline changes map prepared by IOM, AU for Andhra Pradesh based on LISS III 2010 imagery reveals that the shore line north of Pulicat lake mouth subjected to Low/Meduim/High Erosion and south of Pulicat lake mouth is subjected to Stable, Low/Medium/High accretion. It is observed that proposed Revised Master Plan Breakwater is located about 7.2 km south of Pulicat Lake and 11.0 km South from lake mouth opening to bay of Bengal. These maps are provided as Annexure 1.  As a part of EIA Study detailed shoreline assessment will be conducted considering Revised Master Plan Layout to understand the impact on shoreline within 10 Km radius from the Project boundary and necessary Shoreline Management Plan will be proposed as part of mitigation measures which will be also considered as part of Environment Management Plan for the project.

Marine Infrastructure Developer Pvt Ltd Tel +91 44 2824 3062 (Kattupalli Port) Kattupalli Village, Ponneri Taluk, CIN: U74999TN2016PTC103769 Tirivalluvar District 600 120, Tamil Nadu, India

Registered Office: Ramcon Fortuna Towers, 4th floor No 1/2, Kodambakkam High RoadNungambakkam, Chennai 600034

KATTUPALLI PORT CHENNAI’s NEW GATEWAY

 All the developments will be carried out only after obtaining required permissions from the Concerned Authorities.  During the execution of the proposed project all the required support will be given to Government Authorities as part of CER for their efforts on protection and conservation of Pulicat lake. 11. The approach channel to the  Ennore Shoals are tentatively located proposed port will disturb the Ennore towards eastern side of the North Shoals which are the sole reason break waters of Kamarajar Port and why the eroding effects of the south break waters of Kattupalli Port Kamarajar Port are not as  As per the data available, Ennore pronounced as otherwise. shoals are located about 5 km North- Northeast direction of the Ennore creek.  The stated Ennore shoals are located south of existing Kattupalli port approach channel.  As a part of Revised Master Plan, existing navigation channel will be used with some widening and deepening of the channel without changing the orientation of the channel which is located perpendicular to coast i.e., eastern side.  Further, As per the standard ToR, Environment Impact Assessment will be carried out, covering various modelling studies, including shoreline assessment, to study the impact near the vicinity and the proposed mitigation measures as a part of Environment Management Plan. 12. The harbor within the breakwaters  It is pertinent to mention that the encloses the richest fishing grounds, proposed project under discussion is characterized by a muddy seabed Expansion of Existing Kattupalli Port ideal as a prawn habitat. Only and not a new Port creation.  No such activities like fishing, salt farming, fish farming, hand picking of the shells has been observed in the proposed project areas.

Marine Infrastructure Developer Pvt Ltd Tel +91 44 2824 3062 (Kattupalli Port) Kattupalli Village, Ponneri Taluk, CIN: U74999TN2016PTC103769 Tirivalluvar District 600 120, Tamil Nadu, India

Registered Office: Ramcon Fortuna Towers, 4th floor No 1/2, Kodambakkam High RoadNungambakkam, Chennai 600034

KATTUPALLI PORT CHENNAI’s NEW GATEWAY

 The fish landing centres in the study area are Ennore 3.15 km S and Pulicat 7.2 km N.  As part of proposed project detailed study will be carried out with respect to Shoreline/Coastline, Marine ecology, Pulicat Lake, fishing grounds/prawn habitats/fishing communities and animal husbandry etc.  Under CSR and CER program, fishermen livelihood projects will also be carried out in consultation with Fishermen group that exists within project impact area.  All the activities will be carried out, after obtaining required permission from the concerned authorities. 13. The economic necessity of a third  The state of Tamil Nadu contributes mega port within the same city of 17% of the total number of factories Chennai is not made out. and 11% to the industrial output of the country which requires infrastructure for speedy cargo evacuation for trade.  The expansion proposal is important because it can serve several purposes like alternative gateway for Chennai and Kamarajar Ports, potential for container traffic due to vicinity of Chennai and Ennore SEZ, the cargo potential exists due to the presence of number of industries including Power plants and refineries. 14. The port’s land-side facilities will  It is pertinent to mention that the necessitate the conversion of more proposed project under discussion is than 2000 acres of wetlands, and the Expansion of Existing Kattupalli Port takeover of Ennore Creek. This will Only and not a new Port creation. have the following effects;  Ennore creek is located on the  Salinity intrusion southern side at a distance of ~ 4.0  Impact on biodiversity due to km from proposed project. land-use change  Port expansion is being done mostly  Increased risk of flooding in towards North, North west & Araniyar and Kosasthalaiyar Westward side that has no direct basins. More than 10 Lakh impact on Ennore creek. people will be at increased risk of  As per the Coastal Zone

Marine Infrastructure Developer Pvt Ltd Tel +91 44 2824 3062 (Kattupalli Port) Kattupalli Village, Ponneri Taluk, CIN: U74999TN2016PTC103769 Tirivalluvar District 600 120, Tamil Nadu, India

Registered Office: Ramcon Fortuna Towers, 4th floor No 1/2, Kodambakkam High RoadNungambakkam, Chennai 600034

KATTUPALLI PORT CHENNAI’s NEW GATEWAY

disastrous flooding if the Creek is Management plan, published by encroached upon. Dept. of Environment, Tamil Nadu,  Impact on fishing, agriculture and the area proposed under Revised the cattle economy Master Plan development falls under  Impact due to land-use changes CRZ IB, CRZIII, CRZ IVA & CRZ IVB. caused by roads and other  It is to be noted that Pulicat lake and infrastructure associated with Ennore creek are brackish water ports. systems which are being fed by rain fed rivers namely Nagari, Araniar, Korathalayar. The salinity levels lower during Monsoon season and will be carrying from brackish to Saline for the remaining period.  There are no declared areas protected under international conventions, national or local legislation for their ecological, landscape, cultural or other related value.  In addition, Drainage study of the study area is also proposed as a part of draft ToR by MIDPL. Drainage pattern of the study area will be studied and adequate measures will be ensured to carry the runoff generated safely by deepening/widening and desilting if required based on the scientific study. Storm water drainage network will be designed considering the proposed level rising near these areas, the drain in and around project site area will be designed to safely carry the runoff generated due to rainfall. Outlets will be developed for the storm water towards natural sloping which can be used during monsoon and will be connected to existing drainage network if any. The details of the same shall be studied and covered as a part of EIA studies.  Activities like fishing, salt farming, fish farming, hand picking of the shells has not been observed in the proposed project areas.

Marine Infrastructure Developer Pvt Ltd Tel +91 44 2824 3062 (Kattupalli Port) Kattupalli Village, Ponneri Taluk, CIN: U74999TN2016PTC103769 Tirivalluvar District 600 120, Tamil Nadu, India

Registered Office: Ramcon Fortuna Towers, 4th floor No 1/2, Kodambakkam High RoadNungambakkam, Chennai 600034

KATTUPALLI PORT CHENNAI’s NEW GATEWAY

 Land use proposed as a part of Revised Master plan is inline to the permissible activities, as per CRZ notification 2011, amended till date.  However, as part of EIA, detailed studies will be carried out as per ToR with respect to impact of proposed activity on the 10 km radius of the project area and the proposed mitigation measures will be implemented as a part of Environment Management Plan. 15. The Ennore region is already well  The expansion proposal is for port past its environmental carrying and related infrastructure facilities. capacity with two ports, a coal yard,  As a part of our proposed project, more than 3000 MW of coal fired apart from road evacuations, it is also power plants, coal ash ponds spread proposed to evacuate cargo through over 1700 acres, the Manali Railway which is proposed on North Petrochemical region and high traffic and South side of the project, which of heavy vehicles. will help reduce the impact on the surrounding region. However, proper traffic management plan will be prepared and covered as a part of EIA & EMP, which will be implemented during execution of the project.  However, as part of EIA, detailed studies will be carried out as per ToR with respect to impact of proposed activity in the 10 km radius of the project area and the proposed mitigation measures will be implemented as a part of Environment Management Plan.  All the developments will be carried out only after obtaining required permissions from the Concerned Authorities. 16. The Ennore Creek and the air shed  Ennore creek is located on the in the vicinity are heavily polluted, southern side at a distance of ~ 4.0 and further intensification of polluting km from the project. activities in the region is not justified.  Port expansion is being done mostly towards North, North west & Westward side that has no direct impact on Ennore creek.

Marine Infrastructure Developer Pvt Ltd Tel +91 44 2824 3062 (Kattupalli Port) Kattupalli Village, Ponneri Taluk, CIN: U74999TN2016PTC103769 Tirivalluvar District 600 120, Tamil Nadu, India

Registered Office: Ramcon Fortuna Towers, 4th floor No 1/2, Kodambakkam High RoadNungambakkam, Chennai 600034

KATTUPALLI PORT CHENNAI’s NEW GATEWAY

 Impacts on air environment during operation phase during Bulk cargo handling/storage and transportation, Cryogenic Gases (Upto -162 degree Celsius, Pressurized Gases) regasification process and emissions from ships etc. Build-up of pollutant levels due to these emissions will be arrived through modelling studies using Gaussian Dispersion Models (ISCST3/ AERMOD). Mitigation measures will be accordingly suggested and implemented.  However, as part of EIA, detailed studies will be carried out as per ToR with respect to impact of proposed activity on the 10 km radius of the project area and the proposed mitigation measures will be implemented as a part of Environment Management Plan. 17. The proposed site was the landfall  Port infrastructure will be developed, point for Cyclone Vardah and is with all safety consideration, disaster prone. The flattening of considering proneness to natural coastal sand dunes for the purposes hazards. Disaster Management Plan of constructing the port will further is available with respect to existing expose the inland areas to the wrath infrastructure and operations and of the sea. same will be upgraded in line to the proposed Revised Master Plan and same will be submitted to District administration.  As per the Coastal Zone Management plan, published by Dept. of Environment, Tamilnadu, the area proposed under Revised Master Plan development does not contain any sand dunes.  Land use proposed as a part of Revised Master plan is in line to the permissible activities, as per CRZ notification, 2011 amended till date.  However all activities will be carried out, after obtaining required permission from the concerned authorities.

Marine Infrastructure Developer Pvt Ltd Tel +91 44 2824 3062 (Kattupalli Port) Kattupalli Village, Ponneri Taluk, CIN: U74999TN2016PTC103769 Tirivalluvar District 600 120, Tamil Nadu, India

Registered Office: Ramcon Fortuna Towers, 4th floor No 1/2, Kodambakkam High RoadNungambakkam, Chennai 600034

KATTUPALLI PORT CHENNAI’s NEW GATEWAY

18. The proposed developments are set  As per the Coastal Zone to come up within the Hazard Line Management plan, published by demarcated by Survey of India for Dept. of Environment, Tamil Nadu, this region. the area proposed under Revised Master Plan development falls under CRZ IB, CRZIII, CRZ IVA & CRZ IVB which is a permissible activity as per CRZ Notification, 2019.  Proposal for Revised Master Plan is submitted to MoEF&CC for consideration of ToR. Based on ToR, Environment Impact Assessment will be carried out and DMP will be prepared and implemented. All the activities will be carried out, only after obtaining required permission from the concerned authorities. 19. The proposed developments,  Ennore creek is located on the particularly those encroaching upon southern side at a distance of ~ 4.0 the Creek, are likely to be kms from Proposed project. submerged due to sea level rise, if  Port expansion is being done mostly modelling studies, including by the towards North, North west & Space Application Centre, ISRO, are Westward side that has no direct to be believed. impact on Ennore creek  Further, Revised Master Plan is submitted to MoEF&CC for consideration of ToR. As per the standard ToR, Environment Impact Assessment will cover various modelling studies, include shoreline assessment, to study the impact near the vicinity and the proposed mitigation measures as a part of Environment Management Plan.

Hope you find our above submissions are in order.

Thanking You

For Marine Infrastructure Developer Private Ltd

Authorized Signatory.

Marine Infrastructure Developer Pvt Ltd Tel +91 44 2824 3062 (Kattupalli Port) Kattupalli Village, Ponneri Taluk, CIN: U74999TN2016PTC103769 Tirivalluvar District 600 120, Tamil Nadu, India

Registered Office: Ramcon Fortuna Towers, 4th floor No 1/2, Kodambakkam High RoadNungambakkam, Chennai 600034

KATTUPALLI PORT CHENNAI’s NEW GATEWAY

Date: 19th Feb 2019 Ministry of Environment , Forest and Climate Change, IA Division, Indira Paryavaran Bhavan, Jor Bagh Road, Aliganj, New Delhi – 110 003

Kind Attn: Dr.Vinod K Singh, Scientist D

Sub : Consideration of Revised Master Plan (RMP) Development of Kattupalli Port by Marine Infrastructure Developer Pvt Ltd (MIDPL)– Reply to the representation of Thirumalai Nagar Fishermen Panchayat Sabha, Palaverkadu, Ponneri Taluk, Thiruvallur District, Tamil Nadu – Reg.

Ref: Additional details sought vide Final Minutes of 38th EAC Infra-2 meeting held on 6-8 Feb. 2019

Sir,

This has reference to the captioned subject and cited reference above; we are submitting our response to the representation of Thirumalai Nagar Fishermen Panchayat Sabha, Palaverkadu for your kind consideration.

Sl.No. Representation from Thirumalai MIDPL Reply Nagar Fishermen Panchayat Sabha, Palaverkadu 1 It has come to our notice that It is pertinent to mention that the ministry is in receipt of revised proposed project under discussion is Master plan (RMP) for development Expansion of Existing Kattupalli Port and of Katuapalli port by Adani / Marine not a new Port creation. Infrastructure Development Private limited for Tor in Ponneri taluka, Kamarajar Port is operating since 2001 thiruvallur district, Tamilnadu. We and LTSB started its operation after would like to bring to your notice that obtaining required approvals, from Jan this port is being proposed just north 2013. Bifurcation of EC and CRZ of the existing Kamarajar Port and Clearance between MIDPL & LTSB L&T shipbuilding yard. Already, due obtained from MoEf & CC on 9th February to these two operation ports, the 2018. coastline on the northern parts towards pulicat has been subject to As per the Status of Shoreline change direct to wide spread beach erosion, maps, published by Institute of Ocean greatly affecting our fish livelihood. Management (IOM), Anna University, Now another mega project in the Chennai and Ministry of Environment area will prove disastrous as the rate Forest & Climate Change, New Delhi, the of erosion toward pulicat lake will shoreline where the water front

Marine Infrastructure Developer Pvt Ltd Tel +91 44 2824 3062 (Kattupalli Port) Kattupalli Village, Ponneri Taluk, CIN: U74999TN2016PTC103769 Tirivalluvar District 600 120, Tamil Nadu, India

Registered Office: Ramcon Fortuna Towers, 4th floor No 1/2, Kodambakkam High RoadNungambakkam, Chennai 600034

KATTUPALLI PORT CHENNAI’s NEW GATEWAY

increase significantly. There is a risk development as a part of Kattupalli port of the sand bar separating Pulicat Revised Master Plan is proposed, is lake and bay of Bengal eroding, subjected to Low accretion to Stable resulting in massive sea level raise Coast to Low erosion. that will swallow the islands of pulicat lake where many habitants are In addition, shoreline changes map situated. prepared by IOM, AU for Andhra Pradesh based on LISS III 2010 imagery reveals It is not only habitations in Pulicat that the shore line north of Pulicat lake that will be affected. Allowing the sea mouth subjected to Low/Meduim/High to move inland into the Pulicat lake Erosion and south of Pulicat lake mouth will greatly affect inland fresh water is subjected to Stable, Low/Medium/High aquifiers that will lead to collapse of accretion. It is observed that proposed fresh water resources in the district. Revised Master Plan Breakwater is located about 7.2 km south of Pulicat Lake and 11.0 km South from lake mouth opening to bay of Bengal. These maps are provided as Annexure 1.

Marine Infrastructure Developer Pvt Ltd Tel +91 44 2824 3062 (Kattupalli Port) Kattupalli Village, Ponneri Taluk, CIN: U74999TN2016PTC103769 Tirivalluvar District 600 120, Tamil Nadu, India

Registered Office: Ramcon Fortuna Towers, 4th floor No 1/2, Kodambakkam High RoadNungambakkam, Chennai 600034

KATTUPALLI PORT CHENNAI’s NEW GATEWAY

using geo membranes/rocks/groins, etc., will be implemented.

It is to be noted that Pulicat lake is a brackish water system which is being fed by two rain fed rivers namely Kalngi and Arani. The salinity levels lowers during Monsoon season and will be carrying from brackish to Saline for the remaining period.

During the execution of the proposed project all the required support will be given to Government Authorities as part of CER for their efforts on protection and conservation of Pulicat lake. 2 The plan also propose to take over Proposed master plan will not be Karungali Estuary that will lead to obstructing Karungali Estuary. obstructing drainage - causing floods not only in these areas but also upstream areas 3 We are at the point, where many As per the Coastal Zone Management report and scientific studies, have plan, published by Dept. of Environment, proven variety of risk, due to climate Tamil Nadu, the area proposed under change induces sea level rise. The Revised Master Plan development does sand dune in Katupalli and Kalanji not contain any sand dunes. The village act as buffer, protecting, the approved CZMP is attached as area and groundwater inland. Now, Annexure 2. the port proposes to flatten many areas of sand dunes, exposing the Land use proposed as a part of Revised habitants here to the extreme effects Master plan is inline to the permissible of natural weather events like activities, as per CRZ notification 2011, cyclones, tsunami, etc. Blocking of amended till date. drainage and extreme land use Various studies will be carried out to changes in the backwater will result understand the impact of the proposed in the effect of these disaster being project in the vicinity areas. felt by areas even inland. However all the activities will be carried out only, after obtaining required permission from the concerned authorities. 4 The project envisages massive take As per the Coastal Zone Management over of backwater and river flood plan, published by Dept. of Environment, plains that will affect the livelihood of Tamilnadu, the area proposed under thousands of people making a living Revised Master Plan development falls by fishing and allied activities, salt under CRZ IB, CRZIII, CRZ IVA & CRZ

Marine Infrastructure Developer Pvt Ltd Tel +91 44 2824 3062 (Kattupalli Port) Kattupalli Village, Ponneri Taluk, CIN: U74999TN2016PTC103769 Tirivalluvar District 600 120, Tamil Nadu, India

Registered Office: Ramcon Fortuna Towers, 4th floor No 1/2, Kodambakkam High RoadNungambakkam, Chennai 600034

KATTUPALLI PORT CHENNAI’s NEW GATEWAY

farming, fish farming, hand picking of IVB shells, grazing livestock and agriculture. Land use proposed as a part of Revised Master plan is inline to the permissible activities, as per CRZ notification 2011, amended till date.

No such activities like fishing, salt farming, fish farming, hand picking of the shells has been observed in the proposed project areas.

Proposal for Revised Master Plan is submitted to MoEF&CC for consideration of ToR. As per the standard ToR, Environment Impact Assessment will be prepared.

Further, Social Impact assessment will be carried out as a part EIA studies to identify the impact on locals and CSR plan will be developed accordingly.

Hope you find our above submissions are in order.

Thanking You

For Marine Infrastructure Developer Private Ltd

Authorized Signatory.

Marine Infrastructure Developer Pvt Ltd Tel +91 44 2824 3062 (Kattupalli Port) Kattupalli Village, Ponneri Taluk, CIN: U74999TN2016PTC103769 Tirivalluvar District 600 120, Tamil Nadu, India

Registered Office: Ramcon Fortuna Towers, 4th floor No 1/2, Kodambakkam High RoadNungambakkam, Chennai 600034

KATTUPALLI PORT CHENNAI’s NEW GATEWAY

Date: 19th Feb 2019 Ministry of Environment , Forest and Climate Change, IA Division, Indira Paryavaran Bhavan, Jor Bagh Road, Aliganj, New Delhi – 110 003

Kind Attn: Dr.Vinod K Singh, Scientist D

Sub : Consideration of Revised Master Plan (RMP) Development of Kattupalli Port by Marine Infrastructure Developer Pvt Ltd (MIDPL)– Reply to the representation of Vairavankuppam Fishermen Panchayat Sabha, Ponneri Taluk, Thiruvallur District, Tamil Nadu – Reg.

Ref: Additional details sought vide Final Minutes of 38th EAC Infra-2 meeting held on 6-8 Feb. 2019

Sir,

This has reference to the captioned subject and cited reference above; we are submitting our response to the representation of Vairavankuppam Fishermen Panchayat Sabha for your kind consideration.

Sl.No. Representation from MIDPL Reply Vairavankuppam Fishermen Panchayat Sabha 1 It has come to our notice that It is pertinent to mention that the ministry is in receipt of revised proposed project under discussion is Master plan (RMP) for development Expansion of Existing Kattupalli Port and of Katuapalli port by Adani / Marine not a new Port creation. Infrastructure Development Private limited for Tor in Ponneri taluka, Kamarajar Port is operating since 2001 thiruvallur district, Tamilnadu. We and LTSB started its operation after would like to bring to your notice that obtaining required approvals, from Jan this port is being proposed just north 2013. Bifurcation of EC and CRZ of the existing Kamarajar Port and Clearance between MIDPL & LTSB L&T shipbuilding yard. Already, due obtained from MoEf & CC on 9th February to these two operation ports, the 2018. coastline on the northern parts towards pulicat has been subject to As per the Status of Shoreline change direct to wide spread beach erosion, maps, published by Institute of Ocean greatly affecting our fish livelihood. Management (IOM), Anna University, Now another mega project in the Chennai and Ministry of Environment area will prove disastrous as the rate Forest & Climate Change, New Delhi, the of erosion toward pulicat lake will shoreline where the water front

Marine Infrastructure Developer Pvt Ltd Tel +91 44 2824 3062 (Kattupalli Port) Kattupalli Village, Ponneri Taluk, CIN: U74999TN2016PTC103769 Tirivalluvar District 600 120, Tamil Nadu, India

Registered Office: Ramcon Fortuna Towers, 4th floor No 1/2, Kodambakkam High RoadNungambakkam, Chennai 600034

KATTUPALLI PORT CHENNAI’s NEW GATEWAY

increase significantly. There is a risk development as a part of Kattupalli port of the sand bar separating Pulicat Revised Master Plan is proposed, is lake and bay of Bengal eroding, subjected to Low accretion to Stable resulting in massive sea level raise Coast to Low erosion. that will swallow the islands of pulicat lake where many habitants are In addition, shoreline changes map situated. prepared by IOM, AU for Andhra Pradesh based on LISS III 2010 imagery reveals It is not only habitations in Pulicat that the shore line north of Pulicat lake that will be affected. Allowing the sea mouth subjected to Low/Medium/High to move inland into the Pulicat lake Erosion and south of Pulicat lake mouth will greatly affect inland fresh water is subjected to Stable, Low/Medium/High aquifiers that will lead to collapse of accretion. It is observed that proposed fresh water resources in the district. Revised Master Plan Breakwater is located about 7.2 km south of Pulicat Lake and 11.0 km South from lake mouth opening to bay of Bengal. These maps are provided as Annexure 1.

Marine Infrastructure Developer Pvt Ltd Tel +91 44 2824 3062 (Kattupalli Port) Kattupalli Village, Ponneri Taluk, CIN: U74999TN2016PTC103769 Tirivalluvar District 600 120, Tamil Nadu, India

Registered Office: Ramcon Fortuna Towers, 4th floor No 1/2, Kodambakkam High RoadNungambakkam, Chennai 600034

KATTUPALLI PORT CHENNAI’s NEW GATEWAY

using geo membranes/rocks/groins, etc., will be implemented.

During the execution of the proposed project all the required support will be given to Government Authorities as part of CER for their efforts on protection and conservation of Pulicat lake. 2 The plan also propose to take over Proposed master plan will not be Karungali Estuary that will lead to obstructing Karungali Estuary. obstructing drainage - causing floods not only in these areas but also upstream areas 3 We are at the point, where many As per the Coastal Zone Management report and scientific studies, have plan, published by Dept. of Environment, proven variety of risk, due to climate Tamil Nadu, the area proposed under change induces sea level rise. The Revised Master Plan development does sand dune in Katupalli and Kalanji not contain any sand dunes. The village act as buffer, protecting, the approved CZMP is attached as area and groundwater inland. Now, Annexure 2. the port proposes to flatten many areas of sand dunes, exposing the Land use proposed as a part of Revised habitants here to the extreme effects Master plan is inline to the permissible of natural weather events like activities, as per CRZ notification 2011, cyclones, tsunami, etc. Blocking of amended till date. drainage and extreme land use Various studies will be carried out to changes in the backwater will result understand the impact of the proposed in the effect of these disaster being project in the vicinity areas. felt by areas even inland. However all the activities will be carried out only, after obtaining required permission from the concerned authorities. 4 The project envisages massive take As per the Coastal Zone Management over of backwater and river flood plan, published by Dept. of Environment, plains that will affect the livelihood of Tamilnadu, the area proposed under thousands of people making a living Revised Master Plan development falls by fishing and allied activities, salt under CRZ IB, CRZIII, CRZ IVA & CRZ

Marine Infrastructure Developer Pvt Ltd Tel +91 44 2824 3062 (Kattupalli Port) Kattupalli Village, Ponneri Taluk, CIN: U74999TN2016PTC103769 Tirivalluvar District 600 120, Tamil Nadu, India

Registered Office: Ramcon Fortuna Towers, 4th floor No 1/2, Kodambakkam High RoadNungambakkam, Chennai 600034

KATTUPALLI PORT CHENNAI’s NEW GATEWAY

No such activities like fishing, salt farming, fish farming, hand picking of the shells has been observed in the proposed project areas.

Proposal for Revised Master Plan is submitted to MoEF&CC for consideration of ToR. As per the standard ToR, Environment Impact Assessment will be prepared.

Further, Social Impact assessment will be carried out as a part EIA studies to identify the impact on locals and CSR plan will be developed accordingly.

Hope you find our above submissions are in order.

Thanking You

For Marine Infrastructure Developer Private Ltd

Authorized Signatory.

Marine Infrastructure Developer Pvt Ltd Tel +91 44 2824 3062 (Kattupalli Port) Kattupalli Village, Ponneri Taluk, CIN: U74999TN2016PTC103769 Tirivalluvar District 600 120, Tamil Nadu, India

Registered Office: Ramcon Fortuna Towers, 4th floor No 1/2, Kodambakkam High RoadNungambakkam, Chennai 600034

ANNEXURE 1

ANNEXURE 2

WILL BE CONNECTED TO GOVT. PROPOSED NORTHERN RAIL LINK

ACCESS ROAD ACCESS

NORTH PORT NORTH PROPOSED ROB PROPOSED Existing 580Ø TURNING CIRCLE DREDGED TO (-)14.0 M DREDGED TO (-)20.5 M Proposed 650m Ø TURNING CIRCLE 700m Ø -20.5 m CD Turning Circle DREDGED TO (-)25.0 M Proposed 700m Ø TURNING CIRCLE

ANNEXURE 3