Environment and Social Impact Assessment Report and Environment and Social Management Plan

Project Number: 44940 March 2012

IND: Nirvana Hills Slum Rehabilitation Project

Prepared by: Kumar Urban Development Limited

This report is made publicly available in accordance with ADB’s Public Communications Policy (2005). It does not necessarily reflect the views of ADB.

Environmental and Social

Impact Assessment for Project Nirvana: Pune,

Kumar Sinew Developers Private Final Report Limited March 2012

www.erm.com

Delivering sustainable solutions in a more competitive world FINAL REPORT

Kumar Sinew Developers Private Limited

Environmental and Social Impact Assessment for Project Nirvana: Pune, India

23 March 2012

Reference : I8390 / 0138632

Rutuja Tendolkar Prepared by: Consultant

Reviewed & Neena Singh Approved by: Partner

This report has been prepared by ERM India Private Limited, with all reasonable skill, care and diligence within the terms of the Contract with the client, incorporating our General Terms and Conditions of Business and taking account of the resources devoted to it by agreement with the client.

We disclaim any responsibility to the client and others in respect of any matters outside the scope of the above.

This report is confidential to the client and we accept no responsibility of whatsoever nature to third parties to whom this report, or any part thereof, is made known. Any such party relies on the report at their own risk.

EXECUTIVE SUMMARY

ERM India Private Limited has been engaged by M/s Kumar Sinew Urban Developers Limited (hereinafter referred to as ‘KUL’ or ‘the client’) on the behest of the Asian Development Bank (ADB), to update the Environmental Impact Assessment report of the “Nirvana Hills Phase II” Project (hereinafter referred to as ‘Project Nirvana’) located at Survey No. 44/1, , , in the state of in accordance to the ADB Safeguards Policy Requirements (2009). The ESIA also conforms to the requirements of the IFC Performance Standards, which was required by another group of Lenders lead by the Netherlands Development Finance Company (FMO).

This report is an addendum to the Environmental Impact Assessment (EIA) study (to be renamed as an Environmental and Social Impact Assessment or ESIA) which had been conducted by M/s Mahabal Enviro Engineers Pvt. Ltd. in February, 2009. The ESIA assesses the aforementioned project on the basis of ADB’s and IFC’s established environmental and social frameworks1 and safeguard policies and standards.

Project Nirvana, located in Survey no. 44/1, ward 57 Erandwane, in Haveli Taluka of Pune is an initiative on slum rehabilitation by KUL as a part of the SRA scheme. The project is spread over an area of approximately 79 acres (approximately 320,826 sq. m.) and incorporates six major slum zones (as identified by SRA) of Wadar Vasti, Kelewadi-Indira Park, Rajiv Gandhi Park, Vasant Nagar , Rautwadi and Hanuman Nagar. The client is implementing the second phase of the slum rehabilitation in the Kilewadi and Indira Park area. Demolition is currently underway in the Indira Park area and is being overlooked by the KUL personnel.

1.1 PROJECT DESCRIPTION

The site of Project Nirvana as per SRA demarcation is located at Survey no. 44/1, Erandwane, Haveli Taluka, in the city of Pune. Geographically, it is located at 18° 30’ 41.82”N and 73° 49’ 21.34”E and the entire site expanse is spread over a plot area of approximately 320,826 sq mts. The ongoing construction and development for Project Nirvana has been divided into three components. The first component is the Slum Rehabilitation and Redevelopment, the second is the Free Sale component utilised by KUL to construct its own commercial and residential properties and the third component pertains to provisions of infrastructure, utilities and amenities.

(1) The framework includes ADB’s 2009 Safeguards Policy Statement (SPS), the 1998 Gender and Development Policy, and 2001 Social Protection Strategy

ERM EXECUTIVE SUMMARY, KUMAR SINEW DEVELOPERS PROJECT # I8390/ 0138632 MARCH 2012

ES-I In all the five slum blocks together, there are about 4344 tenements. In all the above blocks, 21 rehabilitation buildings are proposed to be developed by the builder, each having 11 floors with 13 flats on each floor. The net carpet area provided for each of these apartments is equivalent to 25 sq.m. or 269 sq.ft. as per SRA guidelines. In lieu of the rehabilitation, KUL will obtain a Floor Space Index (FSI) of 2.5 which will be used for the construction of 18 sale buildings with residential and commercial units.

In addition to the above, KUL has also committed to provide the following additional amenities including:

 A temple;  Gym/playground;  Library;  Primary school and a secondary school;  A permanent crèche;  Community Hall; and  Aged People’s Space.

The client has obtained the Annexure II for Rajeev Gandhi Park which was published by the SRA on the 30th of May 2011 and thus efforts to facilitate eligibility of tenements and the appeal procedure are currently ongoing. KUL has established an office in this area and setup a Community Relations Team (CRT) (along with SRA personnel) consisting of around 10 personnel. These personnel are involved in facilitating slum demolition, land transfer or agreements between the client and the slum dwellers along with maintaining records on rent distribution, facilitating cheque transfers, biometric identification etc. They also address community issues, record grievances and oversee the entire public relation mechanism.

Labour camps have been set on site and about 100 labourers are currently being accommodated here. Inflows of about four hundred more labourers are expected during the construction. For the same, KUL is additionally developing a neighbouring site for building additional labour camps so as to accommodate the inflow.

Certain number of utilities is planned for the entire development in Project Nirvana. Some of the general multipurpose utilities include shopping malls, community centre, kids’ playgrounds, crèche, temples and green zones. The primary utilities required for day to day functioning of the buildings as assessed and studied in details are:  Parking Arrangements;  Water Supply and Storage system;  Sewage Disposal System,  Solid Waste Management;  Power Supply and Backup system;  Fire Fighting system; and  Rain Water Harvesting

ERM EXECUTIVE SUMMARY, KUMAR SINEW DEVELOPERS PROJECT # I8390/ 0138632 MARCH 2012

ES-II

1.2 ENVIRONMENTAL AND SOCIAL BASELINE

The site is situated at a prime commercial and residential area of central Pune and is primarily surrounded by commercial and residential structures. The site setting is such that it is surrounded by dense settlements and developed regions or regions falling into NDZ.

The environmental baseline is based on primary data collected by M/s Mahabal Enviro Engineers Pvt. Ltd. as a part of Environmental Impact Assessment (EIA) study. The data was collected for one season (November 2008 to February 2009). Available secondary data has been assessed covering an area of 10 km radius (referred to as the study area) from the Project Site.

Analysis of Primary Baseline Data

The Project Site is located at an elevation of approximately 590 m above mean sea level (amsl).

The northern portion of the Site is at higher elevation and the slope of the Site is from NW and NNW towards S and SSE. The difference in elevation at the Site is 30 m.

Following the slope, natural drainage of the region is from N and NNW towards South and SSE and SE. According to Seismic Zone Map of India, Project Site falls in Zone III; Zone III is defined as a zone having medium damage risk and vulnerable to earthquakes of intensity MSK VII or less (as defined by Building Materials and Technology Promotion Council). Thus, the Project accordingly is required to have provisions of earthquake resistant construction of Plant structure. Suitable seismic coefficients in horizontal and vertical directions respectively, have to be adopted while designing the structures.

The Project site falls in Moderate Damage Risk Zone B (Vb = 39 m/s) according to Wind and Cyclone Hazard Map of India. As per the information in Pune District Environmental Atlas, 2006, most of the Taluka in the Pune district are flood prone. River Indrayani, and river Pauna are the rivers which are likely to cause flooding in Haveli Taluka and river Mutha in Taluka . , , Chikali, Ashtapur and Sangaur Haveli are the villages in Haveli Taluka which are affected by flood (1 in 100 years).

As per the Natural Hazard Map of Pune District the area where Site is located has low flood frequency, with the last dam overflow having occurred more than 40 years ago.

The study area has Tropical Wet and Dry climate. The year may broadly be divided into four seasons.

ERM EXECUTIVE SUMMARY, KUMAR SINEW DEVELOPERS PROJECT # I8390/ 0138632 MARCH 2012

ES-III Winter season : December- February Summer season : March – mid June Monsoon season : Mid June – September Post Monsoon : October- November

The area receives major parts of its rainfall during monsoon season due to south west monsoon. Owing to the geographical conditions in the district the rainfall is unevenly distributed. The western part to the West coast is a hilly area having forest cover and receives more rainfall than the eastern parts.

In Haveli sub division, the climate is dry and healthy but varies much in different part of the subdivision, the rainfall increases so rapidly towards the west that in the border villages, rice and nagli take the place of jowar and bajra.

Humidity is considerably low during the summer months and diurnal variations in humidity during this period are high and day time temperatures are high.

Air Quality

Primary source of air pollution in the study area is vehicular traffic. The SPM concentration observed during the period ranged from 96.5 μg/m3 to 56.2 μg/m3. The SPM values (98 percentile) were observed to be within the NAAQ’s limits at all monitoring locations. The RSPM concentration observed during the period ranged from 14 .7μg/m3 to 38.9μg/m3. As per revised

NAAQS the prescribed limit of RSPM/PM10 for 24 hours monitoring is 3 100μg/m . The 98 percentile PM10 values were observed to be well within the revised NAAQS limit at all locations. The SO2 concentration observed during the period ranged from 0.00 μg/m3 to 16.8 μg/m3. As per the revised NAAQS 3 the prescribed limit of SO2 for 24 hours monitoring is 80μg/m . The 98 percentile SO2 values were observed to be within the NAAQS limit at all locations. The NOx concentration observed during the period ranged from 3 3 0.0μg/m to 21.5μg/m . As per revised NAAQS the prescribed limit of NOx 3 for 24 hours monitoring is 80μg/m . The 98 percentile NOx values were observed to be within the revised NAAQS limit at all locations. The CO concentration observed during the period ranged from 0.1 mg/m3 to 1.0 3 mg/m . As per revised NAAQS the prescribed limit of CO for 8 hours 3 monitoring is 2 mg/m . The 98 percentile CO values were observed to be within the revised NAAQS limit at all locations.

Surface & Groundwater Quality Monitoring

All the parameters were found to be well within the desirable limits. It is recommended that BOD and COD should be analysed to assess if there is any sewage contamination as ground water table is not deep in this area.

ERM EXECUTIVE SUMMARY, KUMAR SINEW DEVELOPERS PROJECT # I8390/ 0138632 MARCH 2012

ES-IV Soil Quality at Site

The top layer of the soil at the site is of hard strata and the texture is largely sandy loam with low to moderate erosion potential. The depth of this textured soil layer varies from 1.0m to 2.5m. The area is surrounded by plains containing murrum and soft rock. The observed values for metals namely Zinc and Copper much below the soil remediation intervention values specified in Soil Remediation Circular 2009.

Noise Level in the Study Area

The equivalent ambient noise level for day time (Leq day) and night time (Leq night) at proposed Project Site were observed to be below the prescribed corresponding limits for residential area.

For other sampling locations too the results of day time and night time noise levels are below the prescribed corresponding limits. Noise levels measured at Project site indicates that both day and night time ambient noise levels (ANL)are closer to residential ANL limits of 55 dB(A) and 45 dB(A) respectively. Major source of noise in the baseline environment are the following:

 Heavy traffic movement through road and Karve road opposite to Project site on its southern side; and  Dense residential and commercial zones abutting the project site on all three sides barring the northern side.

Ecology

The project site comprises of dense slum settlements covering almost the entire plot area with limited number of trees and other ecological features. As per EIA report 2009, the observations of field survey has concluded that the site is devoid of tree cover and the plant species observed in the area includes trees, shrubs, climbers and herbs that are common and found in other parts of Maharashtra as well. There are no endangered flora and fauna in the project region. The project proponent has obtained permission for cutting 24 number of trees from Horticulture Department of Municipal Corporation of Pune.

1.3 SOCIAL BASELINE

The population was mainly constituted by Hindus, with 3308 households reporting they followed Hinduism. It could be also gathered from the data that 42 households reported that they belong to the Muslim community. It should be noted that there are a few settlements, such as Rautwadi that have a dominance of certain communities (i.e. Marathi and Konkani) as well as Indira Park (predominantly scheduled caste communities of Mahar, Neo-buddha, Mang etc). Other communities also include Other Backward Caste (OBC) such

ERM EXECUTIVE SUMMARY, KUMAR SINEW DEVELOPERS PROJECT # I8390/ 0138632 MARCH 2012

ES-V as Mali and the Nomadic Tribe Community of Vadars, the traditional stone cutters.

The slums in the project area are densely clustered around approximately 70% of the site in largely flat structure with the usual built up being that of one- storied hutments. The average size of the structure is determined to be about 10*12 ft (i.e. 120 sq ft) in dimensions. The structure and layout of these tenements depict a typical slum scenario with narrow lanes and by-lanes, contiguous hutments with corrugated roofing, and inadequate public sanitation facilities.

The household size on site varies from 2 to 7 and is on an average approximately 4 members per household. The sex ratio for the area is determined to be 888. This is much lower compared to the sex ratio of Maharashtra state (922) and even Pune district (917). The working age group constitutes 70.4 percent which indicates a positively skewed dependency. The dependency ratio for the area is estimated to be 0.4 which is significantly lower compared to the national ratio of 0.6. The data indicates that about 15 percent of the households have at least one elderly family member. It is estimated that project site has about 524 senior citizens, 222 of whom being women in a total of 511 households.

From the primary data, the average duration of stay at the slum area is computed to be around 28 years. A majority (94.4 percent) of the population are native Marathi speakers. A minority of the population (about 88 households) are native Hindi speakers from the states of Uttar Pradesh and Madhya Pradesh. There are also few households who have their origins in Andhra Pradesh and Karnataka. However, it is imperative to note that only 719 households reported at the time of survey that they have a proof of residence and only about 816 households reported having election card.

It is of significance that only 34 % of the total site population reported having at least secondary education. 53 % of the total male population at the site reported having at least secondary education and 56 % in the case of total female population at the site. Only about 2 percent of those having educational qualifications higher than secondary education have reported having postgraduate degrees.

The common occupations that were cited by the slum residents include rickshaw driver, coolie, security guard and even services like plumbing, parlour work and salesmanship. Some of the respondents even reported their own businesses like repair shops, laundry, general stores etc. Another significant observation is that most of the women in the slum area were engaged as housemaids, while they also took up other occupations like tailoring, scrap business and selling of vegetable, fruits or flowers.

The average income of the household is coming to about INR 6400 per month wherein the range of income listed being as low as below INR 1000 to INR

ERM EXECUTIVE SUMMARY, KUMAR SINEW DEVELOPERS PROJECT # I8390/ 0138632 MARCH 2012

ES-VI 20000 a month .The average age of the earning member is estimated to be about 40 years.

279 households were headed by a male senior citizen and 42 households were headed by a female senior citizen. It is also imperative to note that on an aggregate level, 169 households were women headed households.

Infrastructure and amenities

1021 of the households reported that their hutments were made of load bearing structure, 906 reported shed as the type of structure and 328 reported RCC as the structure.

the entire slum has been electrified over the last ten years with specific settlements having electric meters through the Maharashtra State Electricity Board (MSEB). However over 90 percent of the connections are illegal with only very few households having meter facilities for electricity. The power supply in the area is also reported to be quite regular with only 3-4 hours cut on Thursdays. The most common cooking fuel reported was LPG with about 90 percent of the household relying on LPG for cooking.

Municipal water was reported as the main source of water by 99 percent of the households in the primary survey. The water supply of Pune Municipal Corporation was reported to be regular. In addition, most of the households (99%) reported using public toilets that had been set up by the Pune Municipal Corporation and are also in charge of its maintenance.

Education facilities are readily available in the area with a major municipal school (the school will need to be shifted due to the project) as well as two other private English and Marathi-medium schools. The primary data has also captured the existence of 3 aanganwadi centres. Availability of health infrastructure in the project area is limited to private clinics and hospitals such as the Jog Hospital with 150 beds and Krishna Hospital with about 70 beds.

About 72 percent of the households reported having a bank account.

1.4 STAKEHOLDER ENGAGEMENT, DISCLOSURE AND CONSULTATION

The stakeholders for the purpose of stakeholder analysis have been primarily classified as:  Internal Stakeholders:  External Stakeholders

A detailed stakeholder analysis presents the description of the stakeholder, key expectations, influence level on the project and the priority for KUL. Some of the high influencers to be prioritised by KUL include local residents, hawkers and vendors as well as lenders/international banks.

ERM EXECUTIVE SUMMARY, KUMAR SINEW DEVELOPERS PROJECT # I8390/ 0138632 MARCH 2012

ES-VII

KUL has been engaging with the slum community since 2005, but a more structured engagement has been started only recently. The engagement has been in the following formats:

 On going consultations and negotiations with individuals and cluster of households to get the community to agree to the SRA scheme;  Individual consultations and interviews during the socio-economic survey initiated at the behest of the Lenders through an ESAP. Currently, 3309 households of the 4038 households have been surveyed;  Frequent interactions for specific purposes, as and when required, primarily related to the scheme; and  KUL facilitating the formation of the Wada Basti Housing Society election in Phase I.

1.5 IMPACT ASSESSMENT

 The overall impact on land use will be beneficial in the medium context and minor intensity for a medium to long term duration.

 The maximum impact on solid waste generation would be in the construction and operations phase. It should be noted that during the operations phase, generation of solid waste (sludge) can be reused for landscaping.

 The maximum impact on AAQ levels will occur during construction phase of the project life cycle and is anticipated to be minor adverse. Else, during operational phase, depending upon the location of STPs and other such facilities and by maintaining green buffer zones, AAQ levels will not be impacted significantly by the project.

 The impact on soil and water environment will be minor adverse during operational phase considering the long term sustained impact. Else, during construction phase, insignificant adverse impact is anticipated.

 The impact on ANLs will be moderately adverse in the medium context both during construction and operation phases at moderate intensity. During operation phase, however, the impact will be longer during the entire operational phase and hence needs to be managed at receptor locations besides controlling the source. During decommissioning, impact on ANLs is expected to be minor adverse in the local context.

 The impact on ecological environment will be insignificant during construction phase and moderately beneficial during operational phase.

 In this context, the impact on cultural environment due to Project Nirvana is insignificant through the project life cycle.

ERM EXECUTIVE SUMMARY, KUMAR SINEW DEVELOPERS PROJECT # I8390/ 0138632 MARCH 2012

ES-VIII

 The impact on visual environment will be insignificant during construction phase and moderately beneficial during operational phase.

 The impact due to sustainable resource management initiatives integrated in the Project design will be significantly beneficial during project life cycle.

 The impact on traffic and transport infrastructure will be insignificant during construction phase and moderately beneficial during operational phase.

 The impact on H&S aspects will be minor adverse during both construction and operational phase.

 The impact due to natural disasters and emergency scenarios will be minor adverse during construction phase and insignificant during operational phase.

 Although physical displacement is likely to lead to other adverse impacts such as temporary disruption of livelihoods and loss of social networks, overall, the impact has been assessed to be moderate due to the existence of mechanisms by which negotiated settlements can be reached with slum dwellers.

 Project Nirvana will bring about an improvement in the quality of life and several other human development indicators by the rehabilitation of slum dwellers living in sub-standard conditions into organized housing with security of tenure.

 A subsequent exponential increase in population can lead to adverse impacts such as stress on local infrastructure but can also create significant economic benefits in the project area

ERM EXECUTIVE SUMMARY, KUMAR SINEW DEVELOPERS PROJECT # I8390/ 0138632 MARCH 2012

ES-IX

CONTENTS

1 INTRODUCTION 1

1.1 BACKGROUND 1 1.2 OBJECTIVE AND SCOPE OF WORK 2 1.3 APPROACH AND METHODOLOGY 3 1.4 LIMITATIONS 5 1.5 LAYOUT OF THE REPORT 6 1.6 ANNEXURE 6

2 PROJECT DESCRIPTION 8

2.1 INTRODUCTION 8 2.2 PROJECT SETTING 9 2.3 SITE HISTORY AND DETAILS ON LAND OWNERSHIP 12 2.4 PROJECT COMPONENTS 13 2.5 PROJECT INFRASTRUCTURE AND UTILITIES PLANNED 17 2.6 ANALYSIS OF ALTERNATIVES 22

3 ENVIRONMENTAL AND SOCIAL REFERENCE FRAMEWORK 31

3.1 INTRODUCTION 31 3.2 INSTITUTIONAL FRAMEWORK - ENFORCEMENT AGENCIES 31 3.3 ENVIRONMENTAL REGULATORY FRAMEWORK 35 3.4 APPLICABLE ENVIRONMENTAL STANDARDS 41 3.5 REGULATIONS RELATED TO SLUM AND BUILDINGS CONSTRUCTION 46 3.6 LABOUR RELATED REGULATIONS 51 3.7 ARCHAEOLOGY AND CULTURAL HERITAGE RELATED REGULATIONS 53 3.8 CONSULTATION AND DISCLOSURE RELATED LEGISLATIONS 54 3.9 IFC PERFORMANCE STANDARDS 55 3.10 ASIAN DEVELOPMENT BANK REQUIREMENTS 61

4 ENVIRONMENTAL AND SOCIAL BASELINE 67

4.1 ENVIRONMENTAL BASELINE 67 4.2 TOPOGRAPHY AND DRAINAGE 69 4.3 GEOLOGY AND HYDROGEOLOGY 72 4.4 LAND USE 74 4.5 NATURAL HAZARDS 76 4.6 METEOROLOGY 79 4.7 AIR QUALITY 85 4.8 WATER QUALITY 91 4.9 SOIL QUALITY 94 4.10 NOISE LEVEL 95 4.11 TRAFFIC DENSITY 97 4.12 ECOLOGY 99 4.13 SOCIAL BASELINE 99

5 STAKEHOLDER ENGAGEMENT, DISCLOSURE AND CONSULTATION 111

5.1 STAKEHOLDER CLASSIFICATION 111 5.2 STAKEHOLDER ENGAGEMENT AS PART OF THE PROJECT 120

6 IMPACT ASSESSMENT 124

6.2 SOCIAL AND ENVIRONMENTAL IMPACT EVALUATION CRITERIA 128 6.3 SOCIAL AND ENVIRONMENTAL IMPACT IDENTIFICATION 130 6.4 ASSESSMENT OF ENVIRONMENTAL IMPACTS 135 6.5 ASSESSMENT OF SOCIO-ECONOMIC IMPACTS 164

1 INTRODUCTION

ERM India Private Limited has been engaged by M/s Kumar Sinew Urban Developers Limited (hereinafter referred to as ‘KUL’ or ‘the client’) on the behest of the Asian Development Bank (ADB), to update the Environmental Impact Assessment report of the “Nirvana Hills Phase II” Project (hereinafter referred to as ‘Project Nirvana’) located at Survey No. 44/1, Erandwane, Haveli Taluka, Pune district in the state of Maharashtra in accordance to the ADB Safeguards Policy Requirements (2009). The ESIA also conforms to the requirements of the IFC Performance Standards, which was required by another group of Lenders lead by the Netherlands Development Finance Company (FMO).

This report is an addendum to the Environmental Impact Assessment (EIA) study (to be renamed as an Environmental and Social Impact Assessment or ESIA) which had been conducted by M/s Mahabal Enviro Engineers Pvt. Ltd. in February, 2009. The ESIA assesses the aforementioned project on the basis of ADB’s and IFC’s established environmental and social frameworks1 and safeguard policies and standards.

1.1 BACKGROUND

KUL is a leading real estate developer in the state of Maharashtra, India with commercial and residential developments in cities such as , Pune and . KUL is also an approved developer by the Slum Rehabilitation Authority (SRA) and has been involved in the implementation of the slum rehabilitation scheme (SRS) (2) of the Government of Maharashtra in Pune and Mumbai under the provisions of the Development Control Rules 33(10), also known as the in-situ rehabilitation scheme. The scheme primarily involves the builder developing the identified and demarcated slum pockets in the city of Pune to provide better accommodation and facilities to the slum dwellers in lieu of Floor Space Index (FSI) and Transferable Development Rights ( TDR) to develop their own property for sale and profit.

Project Nirvana, located in Survey no. 44/1, ward 57 Erandwane, in Haveli Taluka of Pune is one such initiative on slum rehabilitation as a part of the SRA scheme3. The project is spread over an area of approximately 79 acres (approximately 320,826 sq. m.) and incorporates six major slum zones (as identified by SRA) of Wadar Vasti, Kelewadi-Indira Park, Rajiv Gandhi Park,

(1) The framework includes ADB’s 2009 Safeguards Policy Statement (SPS), the 1998 Gender and Development Policy, and 2001 Social Protection Strategy

(2) The initiative involves redeveloping a portion of the identified slums to provide improved residential quarters for the eligible residents of the slum while opening up an opportunity for the developers to undertake commercial development of the remaining space. (3) The SRA scheme under consideration for this project is specific to Pune-- districts which is different from the SRA scheme of Mumbai ERM ESIA: KUMAR SINEW DEVELOPERS PROJECT # I8390/ 0138632 MARCH 2012 1 Vasant Nagar , Rautwadi and Hanuman Nagar. The demarcation of the slum began in 1982 and development of the site started around 1994. Under the first phase of development carried out in the Wadar Vasti area from 1996 to 2000, the erstwhile M/s Sinew Developers Limited had already shifted approximately 463 slum dwellers and 25 shops into eight rehabilitation towers. KUL took over this scheme from the former builder and have commenced activities after the incorporation of the SRA in Pune since 2005.

The client is implementing the second phase of the slum rehabilitation in the Kilewadi and Indira Park area. Demolition is currently underway in the Indira Park area and is being overlooked by the KUL personnel (last assessed demolition number stands at 439 tenements as reported by KUL). KUL has simultaneously commissioned the construction of two transit buildings of approximately 800 units which will be subsequently converted into rehabilitation buildings. Apart from the slum redevelopment, construction activities of the first of the four residential towers developed by KUL are also underway in the free sale land allocated in the Vasti area.

ERM understands that ADB is evaluating a potential investment opportunity in KUL through the modalities of project finance. As a part of its environmental and social commitment, ADB is required to assess Project Nirvana against their established safeguard framework which includes the Safeguards Policy Statement (SPS 2009) especially the Special Requirements under Different Financing Modalities, the Gender and Development Policy (1998), and the Social Protection Strategy (2001).

ERM also understands that prior to ADB, another group of Lenders, including FMO, have already invested in the project, with a requirement that the project should update the regulatory EIA into an Environmental and Social Impact Assessment (ESIA) to meet the IFC Performance Standards. This ESIA therefore, also meets the IFC Performance Standards as relevant to the project. A detailed reference to the ADB and IFC standards is found in Section 3 on the legal and policy framework for this ESIA.

1.2 OBJECTIVE AND SCOPE OF WORK

The objective of this assessment is to develop an addendum to the government approved EIA which will formulate an Environmental and Social Impact Assessment study to meet the requirements of the ADB and FMO. In addition, the addendum to the EIA will also include the development of Environmental and Social Management Plan (ESMP) to establish certain safeguards mechanisms to mitigate the adverse impacts identified and to enhance the beneficial impacts from Project Nirvana.

The Scope of Work for the addendum ESIA entailed:

 To undertake a detailed environmental and social assessment of the project as per the established ADB framework and IFC Performance Standards;

ERM ESIA: KUMAR SINEW DEVELOPERS PROJECT # I8390/ 0138632 MARCH 2012 2  Review of the already established government approved EIA and combining it with the current assessment to formulate one single ESIA document;  Addressing the environmental and social risks/gaps that were assessed by the due diligence assessment through additional social baseline study i.e. the socio- economic survey; and  Development of an Environmental and Social Management Plan (ESMP) in conformity to SPS appendix 1 and also address the FMO performance standard requirements as highlighted in the earlier constructed Environmental and Social Action Plan (ESAP).

1.3 APPROACH AND METHODOLOGY

ERM’s approach to develop a comprehensive Environmental and Social Impact Assessment (ESIA) for Project Nirvana was to build upon the existing social and environmental documentation and studies on the project such as:

 An independent environmental and social review that was commissioned by FMO and DEG (May 2010);  The EIA report prepared by M/s Mahabal Enviro Engineers Private Limited (consultants engaged by client) was submitted to Maharashtra State Level Expert Appraisal Committee (SEAC) in February 2009 for getting Environmental Clearance for the whole project. Earlier, the client made an application to SEAC for the entire project but since Letter of Intent (LOI) was obtained only for the part of the project State Environment Impact Assessment Authority (SEIAA) of Maharashtra granted Environmental Clearance (EC) for part of the project confining it to the area for which LOI was obtained (1) ; and  The Environmental and Social Safeguards Audit for ADB (July 2011).

ERM adopted the following methodology to develop the addendum to the EIA.

Ongoing Discussions with the Project Proponent

ERM undertook discussions with the project management of KUL that is in charge of developing Project Nirvana. The management included the Planning team, the Engineering and Construction Team, the Environment Health & Safety team as well as the Community Relations team. These discussions also included the key Engineering Procurement and Construction (EPC) contractors, i.e. M/s Man-Infra and M/s Karan Builders who are currently engaged in the construction of the sale component and rehabilitation buildings respectively.

Documentation Review and Onsite Monitoring

ERM undertook the review of updated project documentation, such as the household survey, labour welfare documents etc. as a part of the Environmental and Social Safeguards Audit for the ADB. This audit enabled ERM to develop a pragmatic approach towards the ESIA and the ESMP which

(1) Minutes of 31 meeting of the State Level Expert Appraisal Committee (SEAC) held on 28 July 2010 ERM ESIA: KUMAR SINEW DEVELOPERS PROJECT # I8390/ 0138632 MARCH 2012 3 was focused on enhancing existing capacities and systems that were being put in place by KUL.

Gap Assessment of the EIA

As per the Environmental Impact Assessment (EIA) notification S.O. 1533 dated 14 September, 2006 (amended in December, 2009 and April, 2011), any township and area development project which has area 50 Ha and or has built-up area 150,000 sq.mt. (Category 8(b) needs to carry out Environment Impact Assessment (EIA) study to obtain Environmental Clearance. KUL undertook the EIA study in February 2009 and the Environmental Clearance (EC) for part of the project development [KUL plans to apply for EC in different stages as and when they get Letter of Intent (LOI) from Slum Rehabilitation Authority (SRA) ] was issued in February, 2011. For the present study, EIA provided by KUL was reviewed and most of the current environmental assessment provided in the baseline chapter is based on it. No additional primary baseline monitoring or data collection was done by ERM. As per Indian governmental regulations, the baseline data is valid for a maximum period of three years. As the proposed project is a building construction project with limited impact on the surroundings, the data collected for the project site is considered to be sufficient to formulate the Environment Management Plan. Regular monitoring of environmental parameters has been recommended as part of ESMP.

Socio-Economic survey and Socioeconomic Baseline Data

A socio-economic survey was conducted by a local NGO M/s Vatsalya for the entire slum population on Survey No. 44/1 Erandwane, as a response to one of the key recommendation and action suggested by ERM as part of IFC Performance Standard Review done for FMO. The survey was started in late 2010 and was completed in May, 2011. Subsequently, the on field data was transferred into electronic form, segregated and processed by the client and presented to ERM for use and assessment for identifying key social indicators and parameters which have been used in the subsequent Socio-Economic baseline chapter in this report. Summary information on the socioeconomic survey done for the entire slum area further classified into phase wise information was an outcome of the analysis (refer section 6) ERM also undertook almost 10 focus-group discussions (FGDs) and community consultations with the slum dwellers to provide an independent assessment of the existing baseline conditions. The groups for stakeholder consultations and FGDs on the basis of the KUL feedback and independent professional judgement of ERM while assessing the various categories of impacted groups. The socio- economic data also helped in identifying the various groups to be engaged in consultations.

Stakeholder Consultations

ERM undertook consultations with the key stakeholders of this project including the SRA officials, the Municipal Corporator of the area, key informants (such as community-based organizations, government

ERM ESIA: KUMAR SINEW DEVELOPERS PROJECT # I8390/ 0138632 MARCH 2012 4 infrastructure of municipal schools etc.) as well as members of the NGO Vatsalya that undertook the household survey. The consultations provided insights into the entire SRA scheme, the knowledge, understanding and perceptions of the different factions of the project stakeholders to this project as well as allowed ERM to understand the key issues and impacts arising from this Slum Resettlement Scheme (SRS).

1.4 LIMITATIONS

ERM would like to highlight the following limitations to this addendum ESIA document:

 Environmental Baseline: ERM has not conducted any primary data collection and has relied on the environmental baseline data provided in the EIA report submitted to Maharashtra SEAC, supplemented by additional relevant information from secondary sources. The environmental baseline data was collected in the radius of 10 km study area. Hence, ERM cannot validate or prove the authenticity of the data used in the earlier EIA and takes no ownership or responsibility whatsoever;  Social Baseline: The socio-economic data presented in this document is based on the socio-economic survey carried out by a third party on contractual engagement with the client. Also, the data has been processed and presented to ERM by the client themselves. ERM cannot validate or prove the authenticity of this data nor take responsibility for errors made during the data collection and processing. In addition, at the time of writing of this report, the household survey was not completed and thus it does not include a 100% census of all the slum dwellers;  Management Plan: The key outcome of the addendum ESIA will be the Environmental and Social Management Plan document, which will ensure that adequate mechanisms are in place to manage/mitigate all the impacts that have been identified. The management plans have detailed out the necessary monitoring requirements in recognition of the existing gaps in site-specific baseline information.

Professional judgements expressed herein are based on facts and information provided. Wherever ERM has not been able to make a judgement or assess any process, it has highlighted that as an information gap and suggested a way forward.

1.4.1 Uses of the Report

ERM is not engaged in consulting or reporting for the purpose of advertising, sales promotion, or endorsement of any client interests, including raising investment capital, recommending investment decisions, or other publicity purposes. Client acknowledges this report has been prepared for their and their clients’ exclusive use and agrees that ERM reports or correspondence will not be used or reproduced in full or in part for such purposes, and may

ERM ESIA: KUMAR SINEW DEVELOPERS PROJECT # I8390/ 0138632 MARCH 2012 5 not be used or relied upon in any prospectus or offering circular. Client also agrees that none of its advertising, sales promotion, or other publicity matter containing information obtained from this assessment and report will mention or imply the name of ERM.

Nothing contained in this report shall be construed as a warranty or affirmation by ERM that the site and property described in the report are suitable collateral for any loan or that acquisition of such property by any lender through foreclosure proceedings or otherwise will not expose the lender to potential environmental or social liability.

1.5 LAYOUT OF THE REPORT

The layout of this report is as follows:

Section 1 (this section) provides an introduction, project background, objectives, scope of work, deliverables and methodology adopted along with limitations of the ESIA study;

Section 2 provides a description of Project Nirvana and its components as well as a discussion on the Analysis of Alternatives;

Section 3 discusses the applicable environmental and social regulatory framework and its relevance for Project Nirvana;

Section 4 describes the Environmental and Social baseline context of Project Nirvana;

Section 5 assesses the key stakeholders for Project Nirvana and their expectations as well as influence levels;

Section 6 presents our impact assessment methodology and identifies potential environmental and social impacts from the project;

Section 7 provides an Environmental and Social Management Plan for Project Nirvana; and

Section 8 concludes with overall observations and remarks on implementation of the ESMP

1.6 ANNEXURE

Annexure 1 Ownership related Details of the land

Annexure 2 Water Requirement of Different Building Types

ERM ESIA: KUMAR SINEW DEVELOPERS PROJECT # I8390/ 0138632 MARCH 2012 6 Annexure 3 Tree Cutting Permission

Annexure 4: Summary Table from socio Economic survey

Annexure 5: Rainwater Harvesting System

Annexure 6: Site Layout Plan

ERM ESIA: KUMAR SINEW DEVELOPERS PROJECT # I8390/ 0138632 MARCH 2012 7 2 PROJECT DESCRIPTION

2.1 INTRODUCTION

Project Nirvana (designated by KUL as “45 Nirvana Hills”) is a slum rehabilitation and commercial development project located in the central part of Pune district. As mentioned earlier, the land addressed as survey no. 44/1 Erandwane, municipal ward 57 was declared as a slum area by the SRA back in the year 1982. The demolition and clearing of structures from the slum area started around late 1994 by the erstwhile developers of the slum, M/s A.V.Bhat and Megapolis Developers (now incorporated into the client). During the initial phase of development, 8 multi-storeyed structures were constructed as per the then Phase I of the project in the Vasti area and around 463 eligible households and 25 shops were rehabilitated. The commencement certificate for this phase was obtained in 2000.

At present, the project is in its second phase of development (hence the name Nirvana Hills Phase II). As per KUL, under this second phase (and subsequent phases), development would take place in the remaining five blocks of the slum which are Kelewadi-Indira Park, Rajiv Gandhi Park, Rautwadi, Hanuman Nagar and Vasant Nagar. The following table indicates the approximate number of tenements that are being considered for rehabilitation.

Table 2.1 Slum Blocks and Number of Tenements

Name of the Block Number of Tenements Kilewadi and Indira Park 1145 Rajeev Gandhi Park 985 Rautwadi 498 Hanuman Nagar 1145 Vasant Nagar 571 Total 4344 Source: Phase II to Phase V data from KUL Socio-economic Survey, 2011

In all the above blocks, 21 rehabilitation buildings are proposed to be developed by the builder, each having 11 floors with 13 flats on each floor. The net carpet area provided for each of these apartments is equivalent to 25 sq.m. or 269 sq.ft. as per SRA guidelines. In lieu of the rehabilitation, KUL will obtain a Floor Space Index (FSI) of 2.5 which will be used for the construction of 18 sale buildings with residential and commercial units (this includes the ongoing construction of the sale components C1, C2, C4; C4 from the FSI made available through the Wadar Vasti redevelopment). In total, as per the EIA report, the entire development would take place over a plot area of approximately 3,20,826 sq.m. out of which super built up area would be approximately 3,37,170.24 sq.m.. In addition, KUL will also provide amenities as per the SRA guidelines in terms of community halls, recreation centres etc. In accordance to the EIA report (2009), a total of 66,460 sq.m. (20%of the total plot area) will need to be landscaped and is a part of the non-buildable area.

ERM ESIA: KUMAR SINEW DEVELOPERS PROJECT # I8390/ 0138632 MARCH 2012 8 The State Level Expert Appraisal Committee (Maharashtra) provided an Environmental Clearance (EC) to M/s Kumar Sinew Developers Private Limited on the 28th of February 2011 for construction of total built-up area of 1,43,734 sq.m which includes a free sale building of 54,493 sq.m. and rehabilitation buildings of 54,997 sq.m.. The Consent to Establish (CTE) by the Maharashtra Pollution Control Board has also been obtained for the same. This EC reportedly includes the present construction of 1600 tenements at Kilewadi. It should be noted that in accordance to local regulatory requirements, the EC and CTE will be applied for and made available in phases on the basis of the Commencement Certificate that is obtained from the municipal authorities as well as the SRA’s Letter of Intent which sanctions the number of tenements for rehabilitation.

2.2 PROJECT SETTING

2.2.1 Site Location

The site of Project Nirvana as per SRA demarcation is located at Survey no. 44/1, Erandwane, Haveli Taluka, in the city of Pune. Geographically, it is located at 18° 30’ 41.82”N and 73° 49’ 21.34”E. It is situated at a prime commercial and residential area of central Pune and is flanked by Karve1 road in the East South direction and the Paud road in the West South direction. Figure 2.1 provides a site location map and Figure 2.2 provides the regional setting of the Project.

Figure 2.1 Site Location Map

Source: EIA Report prepared by M/s Mahabal Enviro Engineers Pvt. Ltd., 2009

(1) Karve Road is a prominent road which connects the Deccan area near the Garware Flyover - Lakdi Bridge junction to the densely populated and Karve Nagar area in Pune, Maharashtra. ERM ESIA: KUMAR SINEW DEVELOPERS PROJECT # I8390/ 0138632 MARCH 2012 9

Figure 2.2 Context setting for the Project Site in Pune

ERM ESIA: KUMAR SINEW DEVELOPERS PROJECT # I8390/ 0138632 MARCH 2012 10

The site is primarily surrounded by commercial and residential structures. In the immediate vicinity, the site is surrounded by SNDT College in the east, Residential colony in the west, Automotive Research Association of India (ARAI) reservation area in the North and the Karve-Paud road in the south. The nearest railway station is the Pune railway station located at around 7 km aerial distance and the nearest interstate corridor that is the Mumbai-Pune expressway is located at an aerial distance of 4 km from the site.

2.2.2 Site Setting and Layout

As mentioned before, the entire site expanse is spread over a plot area of approximately 320,826 sq.mt. or 79 acres. Currently, the slums exist in about one third (1/3) of this area as the remaining area is a no-development zone which comprises of a land classification known as “hilltop-hill slope”. The total super built-up area used for the development would be approximately 337,170.24 sq.mt.An expanse of 66,460 sq.mt. of the total plot will need to be landscaped and will be part of the non-buildable area. The entire development will be having a total of 41 Structures out of which 21 are slum rehabilitation structures, 18 are commercial and residential towers and two are public places (1 community hall and 1 women association hall). The following figure provides a diagrammatic representation of the site layout:

Figure 2.3 Proposed Layout Plan for 45 Nirvana Hills

Non-buildable Area/No Development Zone

Sale Component of Commercial/ Residential Towers

Wadar Vasti Tenements in 8 rehabilitation buildings

Buildable Area Proposed for Slum Rehabilitation N

Source: Adapted from KUL

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2.3 SITE HISTORY AND DETAILS ON LAND OWNERSHIP

ERM understands that the land addressed as Survey no. 44/1 Erandwane, Municipal ward 57 has been leased out to M/s Sinew Developers Limited on a long-term lease basis. The land or property amounting to an area of approximately 79.75 acres is under the legal ownership of a public charitable trust by the name of Khwaja Peer Sayed Hisamuddin Kattal-E-Zanjani Chisti (trustees) as per the provisions of the Bombay Public Charitable Trust Act of 1950. The land was unanimously put up for development by the trust itself and was leased out in the year 1982. The Lease documents are attached as Annex 1.

Box 2.1 Brief History of Land lease and transfer

Initially in 1982, the land was leased out as per deed dated 13/5/1982 to M/s A.V. Bhat & Co., a registered partnership firm in the city of Pune for a period of 50 years (with an option of extending the lease by another 49 years at the end of the term). This lease was under the agreement that a certain rent payment had to be paid to the trustee by the lessees and the lessees were authorized to carry out development of the said property and were also further authorized to transfer or assign their leasehold rights and interests acquired by them to any sub-lessees of their choice.

On the 21st June1984, this land was declared as a “Slum Area” under section 13 of the Maharashtra Slum Areas (Improvement, Clearance and Redevelopment) Act, 1971 and was put for development under the SRA. The same engaged M/s A.V.Bhat for the work of clearance of the slum area by demolishing old structures standing thereon and rehabilitation of the slum dwellers.

After 10 years of declaration of the land as a slum, M/s A.V.Bhat & Co. under a Memorandum of Understanding (MoU) dated 30/07/1994 and after consent of the trustees, agreed to assign and entrust the rights and work of development along with the right to get assigned lease hold rights of the property in favour of Megapolis Developers Pvt. Ltd after obtaining the necessary permission from the Charity Commissioner, Pune. Furthermore, as per certificate dated 24th June, 2002 issued by the Registrar of Companies, Pune, Maharashtra, Megapolis Developers were granted permission to change their name to “Sinew Developers Limited”. Source: Legal Search Report, “Opinion on Title, SV Erande (Advocate), 4th January 2003”

This same Sinew Developers Limited or the erstwhile Megapolis Developer was merged with Kumar Urban Developers Limited as in 23 of March, 2009 under the name “Kumar Sinew Developers Limited”. Therefore, after the incorporation, the lease hold rights along with the development right automatically passed on to Kumar Sinew Developers Limited or the client. The client, as per the original deed dated 13/05/1982 is currently the lessee up till the year 2032 after which it has an option of an extension of 49 more years. Consultations with the municipal corporator indicate that there were concerns regarding the security of land lease and tenure and accordingly the Slum Rehabilitation Authority (SRA) Pune had asked KUL to get a legal opinion on the same. It is known to ERM that they are in the process of filling for an extension for an additional 999 years or an indefinite lease. The copy of the application for the 999 years was not made available to ERM.

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2.4 PROJECT COMPONENTS

The ongoing construction and development for Project Nirvana has been divided into two components. The first component is the Slum Rehabilitation and Redevelopment and the second is the Free Sale component utilised by KUL to construct its own commercial and residential properties.

Figure 2.4 Two Primary Components of Project Nirvana

Component II will be planned in this portion of land

Component I

N

Source: Adapted from KUL

The following sections details the various characteristics of these two components.

2.4.1 Component I- Slum Rehabilitation and Redevelopment

The slum rehabilitation and redevelopment for Project Nirvana has been planned by KUL to be carried out over five phases. Under first phase of development, the rehabilitation towers in Vasti zone have been constructed and 463 slum dwellers and 25 commercial establishments have already been rehabilitated in 8 multi storey buildings. The project is currently in its second phase of development in Kelewadi-Indira Nagar and Rajiv Gandhi Park. Subsequently, after the completion of this current phase, the project will move forward towards the next phases. The following table indicates the slum zone, the number of slum tenements on the basis of the socio-economic survey.

Table 2.2 Slum Zone and Number of Tenements

Name of the Zone Number of Tenements Phase of Development Vasti 488 Phase I (completed) Kilewadi and Indira Park 1145 Phase II

ERM ESIA: KUMAR SINEW DEVELOPERS PROJECT # I8390/ 0138632 MARCH 2012 13

Name of the Zone Number of Tenements Phase of Development Rajeev Gandhi Park 985 Phase II Rautwadi 498 Phase III Hanuman Nagar 1145 Phase IV and V Vasant Nagar 571 Phase V Total 4832 From Phase II to Completion *Source: Phase II to Phase V data from KUL Socio-economic Survey 2011

As mentioned before, 21 rehabilitation buildings are proposed to be developed by the developer, each having 11 floors with 13 flats on each floor. The net carpet area provided for each of these apartments is equivalent to 269 sq feet as per SRA guidelines. Also, two community halls will also be developed by KUL. Following is the artistic representation of the slum rehabilitation building as shared by the client with ERM.

Figure 2.5 Artistic representation of the Slum Rehabilitation Building (left) and existing slum rehabilitation towers in Wadar Vasti (right)

*Source: KUL and Photo-documentation

Figure 2.6 Sample Flat

*Source: KUL and Photo-documentation

Every rehabilitation unit has an independent toilet, bathroom, and specific provisions such as cooking platforms, sinks etc as per the provisions of the

ERM ESIA: KUMAR SINEW DEVELOPERS PROJECT # I8390/ 0138632 MARCH 2012 14

SRA norms. Fire fighting provisions will be in each building as discussed in Section 2.5.6. In addition to the above, KUL has also committed to provide the following additional amenities including:

 A temple;  Gym/playground;  Library;  Primary school and a secondary school;  A permanent crèche;  Community Hall; and  Aged People’s Space.

The client has obtained the Annexure II for Rajeev Gandhi Park which was published by the SRA on the 30th of May 2011 and thus efforts to facilitate eligibility of tenements and the appeal procedure are currently ongoing. In addition, KUL has obtained sanction or commencement certificate for 725 tenements for Rajeev Gandhi Park (KUL is yet to receive a sanction/commencement certificate for the 711 slum dwellers eligible for rehabilitation at Kilewadi and Indira Park). KUL has accordingly commissioned the construction of two transit buildings in this area of approximately 800 units which will be subsequently converted into rehabilitation buildings. These buildings along with two already established transit buildings will initially be used to accommodate displaced people as part of the demolition drive. They would be later converted into slum tenements once all the other towers are completed. KUL has hired a sub- contractor, M/s Karan Builders for the excavation and construction of the transit buildings up till the parking level. Currently the work is underway at full strength with about 40 builders at this site. These buildings are being built as per specifications of the SRA and will provide all amenities and utilities as specified in the scheme.

Box 2.2 Key Specifications for a slum rehabilitation building

The key specifications as per SRA which the developer is required to comply while constructing the rehabilitation towers are:  A Carpet area of 25 sq. m. or 269 sq. ft. including balcony, bath and water closet  A Carpet area of 25 sq m or 269 sq. ft. for displaced shops and commercial establishment  A multi purpose room with size up to 12.5 sq.m and with a minimum width of 2.4 m  The cooking space allowed with a minimum size of 2.4 sq.m with minimum width of 1.2 m  Width of pathway around the buildings to vary from 1.5m to 3m starting from a pathway length of 20m and incrementing by 0.5 for every increase of 10m  It is not essential to provide flushing cisterns and toilets without this provision can be supplied. The water closet seat shall be of minimum of 0.46 m (18 inches) in length  The minimum internal dimension for a water closet (if separately provided ) shall be 0.90m x 1.10m  The minimum internal size of ventilation shaft provided shall be 1.50m x 2.40m  A septic tank shall be provided with capacity of 141.6 liters (five cubic feet) per capita where the municipal services are likely to be available within four or five years or so. Pour flush water seal latrines (NEERI TYPE) shall be permitted where the municipal sewerage system is not available and the water table in the area is not high. Source: SRA Pune Website

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Simultaneous to the construction in Rajiv Gandhi Park, demolition is also underway in the Indira Park area and is being overlooked by the KUL Community Relations personnel. For precaution as well as procedures with respect to voluntary consent from the slum dweller, the KUL team is following a demolition policy which includes signing a consent agreement as well as a demolition checklist before carrying out any work.

Figure 2.7 Demolished Plot in Indira Park

*Source: ERM Photo Documentation

KUL has established an office in this area and setup a Community Relations Team (CRT) (along with SRA personnel) consisting of around 10 personnel. These personnel are involved in facilitating slum demolition, land transfer or agreements between the client and the slum dwellers along with maintaining records on rent distribution, facilitating cheque transfers, biometric identification etc. They also address community issues, record grievances and oversee the entire public relation mechanism.

2.4.2 Component II- Free Sale Component

KUL will utilize the FSI and TDR received from construction of component one to construct and develop commercial and residential spaces inside the project zone. Out of the 41 towers, KUL will establish 18 residential and commercial towers in the area allocated as per TDR and FSI by the SRA for their own sale. Commercial will be on ground floor of A 1 to A 8 residential structures; seven floors of A 9 residential structure and five floors of D 1 to D 4 structures. Currently, construction of C1 tower is underway in the commercial area allocated to KUL in the Wadar Vasti area for which the CTE from the MPCB has been received. KUL has contracted a sub-contractor, M/s Man- Infra for construction (up till the first floor), Fusion as a Project Management Consultant for management of all the ongoing activities and some of their own staff to oversee the entire process. Labour camps have been set on site and about 100 labourers are currently being accommodated here. Inflows of about four hundred more labourers are expected during the construction. For

ERM ESIA: KUMAR SINEW DEVELOPERS PROJECT # I8390/ 0138632 MARCH 2012 16

the same, KUL is additionally developing a neighbouring site for building additional labour camps so as to accommodate the inflow.

2.5 PROJECT INFRASTRUCTURE AND UTILITIES PLANNED

Certain number of utilities is planned for the entire development in Project Nirvana. Some of the general multipurpose utilities include shopping malls, community centre, kids’ playgrounds, crèche, temples and green zones. The primary utilities required for day to day functioning of the buildings as assessed and studied in details are:  Parking Arrangements;  Water Supply and Storage system;  Sewage Disposal System,  Solid Waste Management;  Power Supply and Backup system;  Fire Fighting system; and  Rain Water Harvesting

Following sections highlights each of these in detail:

2.5.1 Parking Arrangement

For all the 41 structures to be developed including residential, commercial and slum rehabilitation parts, the client in the development plan have allocated area for parking in each building. Parking Details for the project is as follows:

Table 2.3 Parking Details

Type of Vehicle Parking in Parking in Residential Area Commercial Area No. of vehicles No. of vehicles Cars 3739 720 Scooters 9811 963 Cycles 11,159 683 Total 24,709 2,366 *Source: EIA Report prepared by M/s Mahabal Enviro Engineers Pvt. Ltd., 2009

2.5.2 Water Supply and Storage System

The area receives water supply from the local municipal corporation PMC (Pune Municipal Corporation). As per the EIA report the total water requirement estimated for both component I and II approximately equals to 4069 m³ per day. Out of this, water consumption for component I is envisaged at 3884 m³ per day and for component II it is approximately 185 m³.

A detailed table representing water requirement of different building types is provided in the Annex 2

ERM ESIA: KUMAR SINEW DEVELOPERS PROJECT # I8390/ 0138632 MARCH 2012 17

2.5.3 Sewage Water Disposal System

Two sewage plants would be setup for treating sewage water discharged from the developed complexes. As per the EIA, the sewage expected to be generated is approximately 3.25 MLD (Mega Litres per Day). This value is approximately 80% of the water that would be consumed per day. The designed capacity of the sewage treatment plant is 3.30 MLD which is provided in the form of 2 STP s of capacity 1.20 MLD and 2.20 MLD. The treated water will be used for gardening, flushing and HVAC purpose.

Figure 2.8 Routing of Sewage and locations of the Sewage Treatment Plants (STP)

Locations of STPs

N

Source: Adapted from KUL

Following represents the key stage involved in processing the sewage.

Box 2.3 Key Stages Involved in processing the Sewage  Sewage water from Lavatories and that from bathing, cleaning and washing, to be separated at source from each other through separate drainage lines.  The raw sewage generated will be passed through the BAR SCREEN CHAMBER and the coarse solids will be trapped and removed manually.  This effluent is then collected in the equalization tank where the wastewater will be collected by gravity and pumped into downstream units.  It is then pumped into aeration tank wherein the attached, aerobic microbes will utilize the pollutant in presence of oxygen thereby reducing BOD/COD.  The biomass generated will be separated in the tube settling tank and clear supernatant will flow with gravity.  The treated wastewater will be dosed with liquid Chlorine and allowed to react in chlorine contact/treated waste water tank for disinfection purpose.  The treated wastewater will then be disposed off / reuse suitably.  Optionally, the treated wastewater will be pumped through pressure sand filter and activated carbon filter prior to reuse for gardening / toilet flush or other tertiary requirements. Source: EIA Report prepared by M/s Mahabal Enviro Engineers Pvt. Ltd., 2009

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2.5.4 Solid Waste Management

The waste generated from the construction and demolition (C&D) activities (primarily inert waste) are being used by the project proponent for backfilling purpose at the quarry site. Waste generated form construction and demolition waste would be stored at a designated place within the sight premises itself will be reused to the maximum extent possible before using it for backfilling purpose. Secondary information indicates that about 25 kg of waste is generated per sq ft area of buildings demolished. Assuming 25 kg of C&D waste generation per sqft of building under demolition, about 13200 tons of waste is expected for generation. It should be noted that the there can be potential asbestos containing material especially in roofing which is classified as hazardous waste. This issue is discussed in Section 6.4.2. It should be noted that hazardous wastes is minimal and could be less than 5%. However, any such waste should be disposed off in a secure landfill and should not be used for onsite backfilling.

During operational phase of the project, approximately 12.2 tonnes per day of domestic solid waste would be generated; which consists of biodegradable, non biodegradable and recyclable fraction. The domestic solid waste would be managed as per the provisions of Municipal Solid Waste (Management and Handling Rules), 2000.

 Storage and Collection: Source segregation of waste would be practised at household level by using double bin system, green bin for storage of biodegradable fraction and blue bin system for storing non biodegradable fraction of waste. All the waste generated at household level would be collected on daily basis. The waste from households will be transferred to bigger bins of suitable sizes which will be placed on each floor of the residential and commercial towers and at strategic places in the common areas. All the waste from these secondary bins would be transferred to the secondary collection chamber where waste would be further segregated into biodegradable, non biodegradable and recyclable fraction.

 Treatment and Disposal: Biodegradable waste would be treated through vermi-composting technology and the compost generated would be utilized as manure for the landscaping purpose. The site for this will be identified by KUL. Non biodegradable fraction will be collected by PMC (Pune Municipal Corporation) which will dispose off the waste at the landfill site. Recyclable fraction would be sold off to the local recyclers.

2.5.5 Power Supply and Backup system

As per the EIA, the net power supply required for the proposed buildings is estimated to be around 17.4 MW based on this assumption that approximately 4 watt of power will be required per sq ft. The power will be made available from the Maharashtra State Electricity Distribution Company Limited (MSEDCL). The client will put up appropriate transformers in the proposed sub station as required by electricity providers and provide meter rooms for

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all the residential flats and utility operations. As a power backup system, an alternative source of supply would be provided by the client from a separate sub station. Appropriate change over switch will be provided for provisions that include fire pumps, booster pumps, sprinkler & jockey pumps as well as the staircases/corridor lighting circuits.

2.5.6 Fire Fighting System

The client will provide fire fighting systems and mechanisms to the residential and commercial towers established in Project Nirvana as per the requirements of the National Building Code. The necessary systems and utilities to be provided are:  Automatic Sprinkler Systems  Underground tanks and reservoirs to provide supply to fire hydrants  Overhead Water Storage Tank to provide supply to wet risers via a booster pump  Portable Fire Extinguishers  Manual Fire Alarm Systems

Box 2.4 Key specifications and features of some of the above mentioned utilities and systems  The wet riser of each building will be connected to a fire pump at the ground floor level capable of giving pressure of not less than 3.2 kgs/cm2 at the topmost hydrant  A booster Pump having a capacity of 15 KW with pressure not less than 3.2 kg/cm2 at the topmost hydrant outlet at the wet riser will be provided at the terrace level of each building. Electric supply will be provided to these pumps on independent circuit. One backup pump will be diesel pump.  Stand by pump of equal capacity will be provided for each building.  Sprinkler pumps along with jockey pumps will be provided for automatic sprinkler systems.  Appropriate change over switches would be provided for fire pumps, booster pumps, sprinkler pumps and jockey pumps, staircases/corridor lighting circuit, fire lifts and manual fire alarm system. These will be housed in a separate cabin.  One dry chemical powder type fire extinguisher of 5 kgs capacity with wall mounting bracket having ISI certification mark and two buckets filled with dry, clean sand would be provided in the Electric Meter Room.  Dry chemical Powder type fire extinguishers of 5kgs capacity having ISI certification mark and four buckets of dry, clean sand will also be kept in the each car parking area.  Flat entrance and kitchen doors of each wing will be of solid core having fire resistance of not less than half an hour (solid wood of 45mm thickness).  Use of electric cable shaft for electric cable guide ways. Electric shafts will be sealed at each floor level with non combustible material such as Vermiculite concrete. Inspection door of the shaft will have two hours fire resistance.  Electric metering room will be located at the ground level. Adequate ventilation is to be provided. Source: KUL and EIA

2.5.7 Storm Water Drainage and Rain Water Harvesting System

KUL will construct proper storm water drains for collection and disposal of storm water from the entire plot area. RCC trench of 600 mm wide will be laid down covering all sides of the plot boundary. These drains will channel storm water and discharge the same into municipal storm water drains. All the surface drains will be covered with R.C.C gratings. Rain water pipes of 200

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mm will be laid to collect surface water. The water shall flowthrough the RCC NP2 which are connected to channel with slope of 1 in 200. These pipes will discharge the water into storm water drains of the municipal corporation. The storm water drains of the municipal corporation will eventually lead to nearby .

The client is in the process of setting up a rain water harvesting system for Project Nirvana. As Pune receives a considerable amount of rainfall every year from June to September, the water collected will minimize the net water consumption from the local municipality and will help saving the resource. It will also highlight the client’s commitment to environment friendly practice and will also assist them in their application for an “Eco Housing” certificates for the project.

Figure 2.9 Storm Water Drainage and Rain Water harvesting system

Storm Water Drainage Line

N

Source: EIA Report prepared by M/s Mahabal Enviro Engineers Pvt. Ltd., 2009

As per the EIA, the plot receives approximately13200 cum/hr of rainfall per year and the peak rain fall rate will be 55 mm/hr. The rain water would be collected via pits and discharged into collection chambers that are located in the planned utilities area towards the north west of the site. It could be further filtered for converting into potable water or used for maintenance of green zones.

2.5.8 Amenities and Public Spaces

A key feature of the slum rehabilitation project will be the amenities and public spaces provided to residents. It is reported that all such features are to be designed and built with attention to indoor air quality, ventilations etc. For instance, internal hallways are 1.8 mt and will be as per Appendix T of Development Control Rules under Town Planning Act. 1966Adequate access roads, recreation areas and green spaces are also to be provided as per the landscaping plan. Note that the commercial units in the rehabilitation components will be provided for commercial tenements existing in the erstwhile slums. Cleaning of public spaces will be undertaken by the Pune

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Municipal Corporation. INR 560 will be deposited as infrastructural Improvement charges in which 90% part will go to concerned Municipal and 10 % will go with SRA, for which required Service Charge will be paid to PMC through SRA. Building amenities such as elevators, lights, hallways and fire equipment will be maintained by the housing society by engaging housekeeping subcontractors.

2.6 ANALYSIS OF ALTERNATIVES

This section documents the alternative options that were considered during project conception and planning phase. KUL’s QE &OHS policy commits to sustainable development of all its building construction projects by striving to prevent environmental pollution and depletion of natural resources by using latest technology and training. In line with its policy statement, KUL has integrated practical and feasible sustainable options in the project planning and design. Though there are many sustainable options that were considered along with conventional/ traditional options for implementing Project Nirvana, the critical ones are highlighted here and discussed under following heads:  No project scenario  Project Location  Layout planning  Rehab flat design  Construction technology  Construction materials  Sustainable resource use options  Phasing Plan  Transit arrangements

2.6.1 No-Project Scenario

The slum colonies settled on the land parcel located on the rolling hill slope and foot hills at cadastral survey no. 44/1 in Erandwane comes under Municipal ward 57. The following slum colonies which settled at Erandwane since 1940s were recognised as slum areas and legally declared by SRA way back in the year 1982:  Vasti  Kelewadi  Indira Park  Rajiv Gandhi Park  Rautwadi  Hanuman Nagar and  Vasant Nagar.

Consultations with local community reveal that slums started sprouting at this location as stone quarry sites were operating then at the site. The remnants of the abandoned quarry site could be seen even now which now falls well within the project boundary. The workers who were employed in the stone

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quarry wanted to stay closer and hence put up slum colonies in the nearby vacant lands. In fact the name “Wadar vasti” – one of the slum colony located inside project site - has come to existence because “Wadar”refers to workers of quarry site and “vasti” refers to informally developed colony in the local language – Marathi. Hence, Wadar Vasti refers to informally developed colony comprising of stone worker families.

Project Nirvana – Failure is not an option

Today, the slum colonies that began as stone worker colonies have grown beyond its original purpose and has grown in size to become one of the major slum colonies in Pune City with about 4500 slum tenements. Significantly, almost all stakeholders who have direct stakes in the project such as KUL, slum community and regulators (PMC, SRA) want Project Nirvana to be successful as it can trigger more interest in similar slum rehabilitation projects promoted by SRA among private developers and other slum settlements in Pune City.

This huge expectation on Project Nirvana is not surprising considering the fact that nearly 32.5 per cent of the population of Pune lives in slums as per the 'Slum Atlas of Pune City’ prepared by NGO Mashal in 2008. The study found that there are 477 slum pockets in the city housing 1,150,000 people belonging to 211,423 slum families in the city. Today, the slum population estimates have gone up to 40-45% of City population occupying less than 6 percent of the city's area. This is paradoxical as 40-45% population use 6% of city area while the rest half of the population uses almost 80-90% of the geographical area. This is an unjust and in-equitable distribution of resources. In such a scenario the slum houses end up lacking the most basic facilities and inhabitants has to manage with a poor quality of life for many generations to come, till the time rehabilitation interventions such as the current project comes through.

It has been well documented through various NGO sponsored and government funded studies that slum rehabilitation projects that are executed in full compliance to government guidelines and NBC 2005 have improved the quality of life of many slum families across India, leave alone Pune city. Some basic testimonies gathered during survey such as this one coming from a mother of rehabilitated slum family saying that her daughters can get a better bridegroom because they are no longer living in the slums underline the importance of such slum rehabilitation projects.

Slum situation is worsening

In the no-project scenario, the situation in the City is expected to get worse as it has been happening over the last two decades. According to Pune Municipal Corporation (PMC) estimates, some 88,000 people migrated to the city in 2006, of which 45,000 settled in the slums. Every year, the number of people migrating to the city continues to multiply due to economic and

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livelihood opportunities the City offers. Pune’s slum population has grown by 176 per cent since 1991 owing to constant migration.

Though the City has distinctions such as IT hub of the State and a centre of learning (Pune is called Oxford of the East), it is also fast gaining another epithet, that of a city of slums. The Town and Country Planning Organisation (TCPO), the technical arm of the ministry of urban development, , ranks Pune third in the cities with the largest number of slums in India. Mumbai stands first with 55 per cent of its total population in slums, followed by Meerut with a slum population of 44 per cent. Of the 244 sq km which come under the PMC limits, about 15 sq km, i.e. six per cent of the total land, is encroached upon by slums1.

2.6.2 Project Nirvana – in tune with Government Vision

In this context, rehabilitating 4500 slum families out of 211,423 slum families in the City under Project Nirvana constitutes rehabilitating only 2.1% of the slum population but is a critical step forward in making the City slum free by the year 2015 as enunciated by Chief Secretary in the Government of Maharashtra. In order to make the Pune city slum free in three years, Government of Maharashtra has outlined three avenues available for slum reconstruction which is listed below:  Under the provisions of the Basic Services for Urban Poor (BSUP) programme of the Jawaharlal Nehru National Urban Renewal Mission, (JNNURM) – a Government of India initiative, about INR 300 crore has been earmarked for relocating shanties.  The second avenue under JNNURM is what is called ‘in-situ' development where proper dwellings are constructed on the existing slum site using 10% contribution from slum dwellers and remaining shared between Municipal, State and Central Government funds.  The third option for slum reconstruction is under the Slum Rehabilitation Authority schemes established in 2003.

Project Nirvana being an SRA approved scheme falls under the third avenue outlined by Government of Maharashtra. In SRA, currently there are 132 slum rehabilitation proposals being examined and 32 schemes, covering 5,800 dwellings have been sanctioned. Nearly 42,000 dwellings will be built if all the proposals were to go through thus covering almost 20% of slum population in the City. It can be inferred that within SRA, Project Nirvana is one of the largest single site rehabilitation project and hence its successful execution is critical to the Government’s vision of making Pune a slum free city in the next three years.

An alternative without the project is obviously undesirable, as it would worsen the slum scenario in Pune City and would be a major constraint on the

(1) 1 Adapted from http://escapefromindia.wordpress.com/2007/12/19/55-mumbai-44-meerut-40-of-pune--top- list-on-slum-population/

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economic growth; moreover in the long run more public funds will be spent on providing basic amenities such as water supply, education and health of ever growing slum communities.

Project Location

The site of Project Nirvana as per SRA demarcation is located at survey no. 44/1, Erandwane, Haveli Taluka, in the city of Pune. As the project has been conceived as “in-situ” development project on a private owned land in lieu of the FSI incentives offered by SRA, there is no alternative option for the project to locate the slum rehabilitation buildings elsewhere in the City.

Slum communities, especially those that have resided in a particular location for many decades such as the current ones in Project Nirvana, refuse to accept alternate rehabilitation site due to various social and economic reasons. Slum redevelopment proposals at alternate locations from the original slum locations have always faced problems due to R&R aspect as there will be unanimous opposition from affected slum communities. Very few projects have been successful provided they are implemented by Government departments or authorities (e.g slum resettlement undertaken by World Bank funded Mumbai Urban Transport Project between 2001 and 2008). It will be difficult for a private developer to propose an alternate location for executing a slum redevelopment project in Indian conditions.

Hence, no alternative locations were analysed and the project utilised the in- situ slum redevelopment schemes available with SRA for moving forward.

Layout Planning

Considering the prevailing topography within the project site, the rehab building layout has been laid largely in north to south direction along the contour lines to the extent feasible. The current layout provides for ample ventilation and lighting as each of the rehabilitation flat will either face east or west direction.

Planning the layout along available hill slope contours reduces the significant amount of excavation work that would have been necessitated if the layout is perpendicular or angular to the contours. The amount of excavated debris is reduced significantly and also with it the associated problem of its disposal.

Rehab Flat Design

As per SRA rules, rehab tenements with a net carpet area of 25 sq.mt. or 269 sq.ft. is to be provided. Conventionally, the rehab flats were made with a 1 room, hall and kitchen (RHK) or simply a hall and kitchen with attached toilets and bathroom.

Exploring beyond the conventional design and SRA guideline requirements, KUL has proposed to build a 2 RHK i.e. two rooms, one hall, one kitchen with

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attached toilets and bathroom in the same carpet area by intelligently using the space and flat layout. KUL also proposes to provide empty space before the main door of each flat – a sort of individual portico – giving due consideration to slum community living habits especially the womenfolk who like to sit in front of their house to do their daily chores.

The model flat currently on display at Project Nirvana site is designed with this configuration along with arrangement of furniture’s to inform the slum community about its feasibility. KUL also wishes to provide the slum community with modular kitchen amenities and basic minimum furniture in each of the rehab flats and is currently exploring with low cost suppliers in India, China and South East Asia.

These initiatives are well above the SRA guidelines and regulatory requirements and a positive step forward to convince the slum communities to co-operate in successful execution of Project Nirvana. As per the consultations with slum community and project authorities, this 2 RHK flat configuration has been well received by slum community members and they have suggested some changes which has been readily accepted by KUL for incorporation in the actual flat.

Construction Technology

KUL has proposed to use aluminium form work technology over the conventional wooden scaffold and metal sheet/ply board form work technology in the construction of rehab tenements. Some of the basic benefits of aluminium form work technology as available in the secondary literature is listed below:

More seismic resistance: - The box type construction provides more seismic resistance to the structure.  Increased durability: - The durability of a complete concrete structure is more than conventional brick bat masonry.  Lesser number of joints thereby reducing the leakages and enhancing the durability.  Higher carpet area- Due to shear walls, the wall thickness is thin thus increasing the internal carpet area.  Integral and smooth finishing of wall and slab- Smooth finish of aluminium can be seen vividly on walls.  Uniform quality of construction – Uniform grade of concrete is used.  Negligible maintenance – Strong built up of concrete needs no maintenance.  Faster completion – Unsurpassed construction speed can be achieved due to light weight of aluminium forms.  Lesser manual labour- Less labour is required for carrying formworks.  Simplified foundation design due to consistent load distribution.  The natural density of concrete wall result in better sound transmission coefficient.

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The relative comparison of aluminium form work technology over conventional technology is listed at Table 2.4.

Table 2.4 Comparison of Form Work Construction Technologies

Factor of Comparison Conventional Aluminium Form Remarks Formwork Work Technology Technology Quality Normal Superior. In – Situ Superior quality in casting of whole “System housing” structure and transverse walls done in a continuous operation, using controlled concrete mixers obtained from central batching, mixing plants and mechanically placed through concrete buckets using crane and compacted in leak proof moulds using high frequency vibrators Speed of construction. The pace of In this system, the System construction is construction is slow walls and floors are much faster. due to step – by – step cast together in one completion of continuous operation different stages of in matter of few hours activity the masonry is and in built required to be laid accelerated curing brick by brick. overnight enable Erection of formwork, removal and re-use of concreting and forms on daily cycle deshuttering forms is basis. a two – week cycle. The plastering and other finishing activities can commence only thereafter. Aesthetics. In the case of RCC The Room – Sized wall - structural framework panels and the ceiling of column and beams elements cast against with partition brick steel plates have walls is used for smooth finishing and construction, the the interiors have neat columns and beams and clean lines show unsightly without unsightly projections in room projections in various interiors. corners. The walls and ceilings also have smooth even surfaces, which only need colour/white wash External finishes. Cement plastered Textured / pattern Permanent facia brickwork, painted coloured concrete finishes feasible with with cement – based facia can be provided. minor extra initial cost

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Factor of Comparison Conventional Aluminium Form Remarks Formwork Work Technology Technology paint. Finishing needs This will need no painting once in every frequent repainting. three years. Useful carpet area as Efficiency around Efficiency around More efficient % of plinth area. 83.5% 87.5% utilization of land for useful living space. Consumption of basic raw materials

Cement. Normal Consumption Although greater in somewhat more than consumption, the that used in strength and conventional durability is also more structures.

Reinforcing Steel Reinforcing steel It may, however will Steel requirement is required is less as be slightly more than more, as it is required compared to the in corresponding load – for the shear wall situ construction as bearing brick wall construction. But RCC framework uses construction for shear wall brick wall as which, requirements construction increases alternative of IS 456 have to be safety against followed for system earthquake. housing. Maintenance In maintenance cost, The walls and ceiling It can be concluded the major expenditure being smooth and that maintenance cost is involved due to: high quality concrete is negligible. - repairs and repairs for plastering maintenance of plaster and leakage’s are not of walls / ceiling etc. at all required - Painting of outer and frequently. inner walls. - Leakages due to plumbing and sanitation installation. Source: http://www.architectjaved.com/mivan- formwork/comparison_aluminum_formwork_vs_conventional_formwork.html

Sustainable resource use options

Project Nirvana has integrated sustainable resource use options over the conventional ones as highlighted under Section 7.4.6. Residential and commercial buildings consume significant amount of resources through their project life cycle. Conventionally designed buildings consume more resources than the modern buildings that incorporate latest sustainable technologies and concepts. Some of the sustainable resource initiatives proposed under the project include the following:  The total water demand of 4.1 Million Litres Daily (MLD) will be partially met through treated waste water recycle from in-house Sewerage Treatment Plant (STPs) in order to reduce the raw water consumption at site during the rest of project life cycle. Project proposes to recycle at least 50% of treated wastewater for gardening, flushing and heating,

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ventilation, and air conditioning (HVAC) purpose from in-house STPs having a total of 3.4 MLD capacity.  Storm water from the unpaved surface will be allowed to percolate in the ground.  Project Nirvana has formulated rainwater harvesting (RWH) scheme which will be constructed as part of other project proposals. Rain water is proposed to be injected into the fracture zones under the land. Project is proposing to construct recharge bores and soak pits to aid in recharging ground water resource. Excess water will be drained to Municipal drains. Two RWH tanks of capacity 250 cum and 570 cum each for rooftop rainwater storage has been proposed along with 51 recharge pits/ soak pits all through the plot area.  The 3.25 MLD sewage generated from proposed project will be treated in- house in about 2 STPs planned at various locations within project site. As highlighted earlier, almost 50% of wastewater received will be recycled back for gardening, flushing and landscape maintenance purposes after treatment and disinfection at STP and excess treated wastewater will be disposed off to PMC sewerage system.  The project proposes to have energy efficient building services, equipments, public area lighting and exterior lighting systems to reduce the energy demand.  Four (4) numbers of DG sets will be provided for power back-up for essential services such as fire fighting systems and lift systems.  Project has extensive plans to use solar energy for achieving energy conservation and the proposals include: o Solar hot water systems for sale buildings up to top 9 floors o Solar panel lights will be installed for common facilities o Solar street lights are proposed for common areas such as open spaces, pathways, reserved green (RG) etc.  About 12.2 tonnes per day of solid waste will be generated at the project site and this will be segregated in-house into wet and dry waste. The dry waste will be disposed off through an authorised contractor and wet waste will be treated by vermi-composting technology and the compost generated will be used as manure in the internal landscaped gardens. Sludge generated from STP too would be used as manure for gardening purpose. A demand-supply analysis of the manure and sludge from the STP has been provided under Section 6.4.2 on Solid Wastes (Box 6.1).  Some other sustainable measures proposed under the project include: o All rooms are designed with adequate opening to have proper natural light and ventilation. o All public areas will have CFC or solar lights for lighting. o External aluminium windows with glass which is reflective type to reduce heat gain. o All masonry work will be done with cement concrete block instead of burnt brick o All internal brick masonry walls will have gypsum plaster. o The project authorities have applied for Eco-Housing certification for sale building components of the project. The eco-housing

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certification program is operated by the Pune Municipal Corporation (PMC). Project hopes to attain four (4) star rating under the program where 5 star rating is the maximum.

Phasing Plan

As discussed under Section 2.4.1, the slum rehabilitation and redevelopment for Project Nirvana has been planned by KUL to be carried out over five phases over a five year period. This prudent phasing plan has been formulated to have least disturbance to existing slum community. The project is currently in its second phases of development in Kelewadi-Indira Nagar and Rajiv Gandhi Park. The slum population rehabilitation (in either transit tenements or in rented houses outside) and demolition of slum structures is currently limited to Kelewadi-Indira Nagar and Rajiv Gandhi Park areas only. The remaining areas which are proposed for redevelopment in successive phases will remain unaffected during the current phase of construction. Subsequently after the completion of this current phase, the project will move forward towards the next phases.

The phasing plan is prudent in the sense that the various project teams can focus on limited slum population and area during construction phase. As limited slum areas are opened up for construction, maintaining project schedule and management of manpower and material resources becomes easy.

Transit Arrangements

In the ongoing Phase 2 of Project Nirvana, KUL has offered two kinds of transit arrangements for slum families that are disturbed by second phase construction schedule. Slum families can either opt to stay in transit tenements available in-situ or take rental amounts from KUL to stay in rented houses outside the project site. The rented accommodation is identified and selected by slum families themselves and KUL reimburses the rental amount of INR 7000 per month/slum family, and a record pertaining to this maintained and updated on a regular basis.

In addition to the available transit tenement buildings, KUL plans to temporarily use the permanent rehab buildings currently under construction phase as transit tenements such that more slum families can be relocated in- situ and the project schedule can be maintained stringently. As highlighted elsewhere, executing the project in time as committed to slum community and SRA is critical to the success of the Project and hence the options worked out by KUL for providing transit accommodation is a positive step forward.

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3 ENVIRONMENTAL AND SOCIAL REFERENCE FRAMEWORK

3.1 INTRODUCTION

This section highlights environmental and social regulations applicable to Project Nirvana. All the laws and regulations derive their origin from the constitution of the country. The constitution broadly covers the intent on protecting the environment as mentioned in the Article 48-A of the Constitution which states that the State shall endeavour to protect and improve the environment and to safeguard the forest and wild life of the country. At the same time, it shall be the fundamental duty of every citizen of India under Article 51-A (g) of the Constitution of India, to protect and improve the natural environment including forests, lakes, rivers and wild life, and to have compassion for living creatures.

On the social front too the constitution broadly covers the protection of rights of individuals. The fundamental Right to Life is guaranteed under Article 21 that states “No person shall be deprived of his life or except according to the procedure established by law”. Article 21 has been used by the courts in a number of judgements, dealing with a range of social and environmental issues and has constantly progressed to include a number of rights, which interpret the “right to life”.

Apart from that there are other legislations which are specifically aimed at protection of environment and rights of the individuals. However, the regulatory framework analysis is limited to specific laws and regulations having implications for the project, which is primarily a housing project.

The section broadly focuses on:

Institutional Framework; Environmental Laws, Regulations and Policy; Social Laws, Regulations and Policy; Applicable Permits – Licences, approvals and consents; Applicable Standards.

3.2 INSTITUTIONAL FRAMEWORK - ENFORCEMENT AGENCIES

3.2.1 Ministry of Environment and Forests

The Ministry of Environment and Forests (MoEF), Government of India is responsible for the environment management at Union of India level. The specific functions of MoEF are as follows:

Environmental policy planning; Effective implementation of legislation;

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Monitoring and control of pollution; Environmental clearance for industrial and development projects; Promotion of environmental education, training and awareness; and Forest conservation, development, and wildlife protection.

The MoEF is responsible for the implementation and enforcement of the Environment Protection Act, 1986, and Rules issued under the Act, including the EIA notification, 2006. Under sections 3 and 5 of the EP Act, 1986, it retains enormous powers to issue directions in the interests of environment protection. MoEF is the responsible agency to issue Environmental Clearance (EC) as per the EIA Notification.

The environmental clearance process for new construction projects comprises of a maximum of 2 stages i.e. Screening and Appraisal.

Screening:

This stage will entail the scrutiny of an application seeking prior environmental clearance made in Form 1 and Form 1A by the concerned State level Expert Appraisal Committee (SEAC) for determining whether or not the project or activity requires further environmental studies for preparation of an EIA for its appraisal prior to the grant of environmental clearance depending up on the nature and location specificity of the project. The projects requiring an Environmental Impact Assessment report shall be termed Category ‘B1’ and remaining projects shall be termed Category ‘B2’ and will not require an Environment Impact Assessment report. For categorization of projects into B1 or B2 except item 8 (b), the Ministry of Environment and Forests issue appropriate guidelines from time to time. All projects and activities listed as Category ‘B’ in Item 8 of the Schedule (Construction/Township/Commercial Complexes /Housing) shall not require scoping and will be appraised on the basis of Form 1/ Form 1A and the conceptual plan.

Appraisal:

 Appraisal means the detailed scrutiny by the Expert Appraisal Committee or State Level Expert Appraisal Committee of the application and other documents like the Final EIA report, submitted by the applicant to the regulatory authority concerned for grant of environmental clearance. This appraisal shall be made by Expert Appraisal Committee or State Level Expert Appraisal Committee concerned in a transparent manner in a proceeding to which the applicant shall be invited for furnishing necessary clarifications in person or through an authorized representative. On conclusion of this proceeding, the Expert Appraisal Committee or State Level Expert Appraisal Committee concerned shall make categorical recommendations to the regulatory authority concerned either for grant of prior environmental clearance on stipulated terms and conditions, or rejection of the application for prior environmental clearance, together with reasons for the same.

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 The appraisal of all projects or activities which are not required to undergo public consultation shall be carried out on the basis of the prescribed application Form 1 and Form 1A as applicable, any other relevant validated information available and the site visit wherever the same is considered as necessary by the Expert Appraisal Committee or State Level Expert Appraisal Committee concerned.  The appraisal of an application be shall be completed by the Expert Appraisal Committee or State Level Expert Appraisal Committee concerned within sixty days of the receipt of the final Environment Impact Assessment report and other documents or the receipt of Form 1 and Form 1 A, where public consultation is not necessary and the recommendations of the Expert Appraisal Committee or State Level Expert Appraisal Committee shall be placed before the competent authority for a final decision within the next fifteen days.

3.2.2 Central Pollution Control Board

The Central Pollution Control Board (CPCB) has been created for the control of water, air and noise pollution, land degradation and hazardous substances and waste management.

The CPCB was established in September 1974, for the purpose of implementing provisions of the Water (Prevention and Control of Pollution) Act, 1974. The executive responsibilities for the industrial pollution prevention and control are primarily executed by the CPCB at the Central level, which is a statutory body, attached to the MoEF. The specific functions of CPCB are as follows:

 Prevent pollution of streams and wells;  Advise the Central Government on matters concerning prevention, control and abatement of water and air pollution;  Co-ordinate the activities of SPCB’s and provide them with technical and research assistance;  Establish and keep under review quality standards for surface and groundwater and for air quality;  Planning and execution of national programme for the prevention, control and abatement of pollution through the Water and Air Acts.

CPCB is primarily an advisory body to MoEF and provides technical support to evolve standards and oversee that these are enforced adequately by respective State Pollution Control Boards.

3.2.3 Maharashtra Pollution Control Board (MPCB)

Maharashtra Pollution Control Board (MPCB) is implementing various environmental legislations in the state of Maharashtra, mainly including

 Water (Prevention and Control of Pollution) Act, 1974,  Air (Prevention and Control of Pollution) Act, 1981,

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 Water (Cess) Act, 1977 and  some of the provisions under Environmental (Protection) Act, 1986 and the rules framed there under like, Biomedical Waste (M&H) Rules, 1998, Hazardous Waste (M&H) Rules, 2000, Municipal Solid Waste Rules, 2000 etc. MPCB is functioning under the administrative control of Environment Department of Government of Maharashtra. Some of the important functions of MPCB are:

 To plan comprehensive program for the prevention, control or abatement of pollution and secure executions thereof,  To collect and disseminate information relating to pollution and the prevention, control or abatement thereof,  To inspect sewage or trade effluent treatment and disposal facilities, and air pollution control systems and to review plans, specification or any other data relating to the treatment plants, disposal systems and air pollution control systems in connection with the consent granted  Supporting and encouraging the developments in the fields of pollution control, waste recycle reuse, eco-friendly practices etc.  To educate and guide the entrepreneurs in improving environment by suggesting appropriate pollution control technologies and techniques  Creation of public awareness about the clean and healthy environment and attending the public complaints regarding pollution.

MPCB is responsible for implementing the Central Acts and Rules for pollution control and to monitor KUL’s compliance with the same.

3.2.4 Maharashtra State Level Impact Assessment Authority

Government of Maharashtra on 16th July, 2008 declares Maharashtra Pollution Control Board as the agency to act as Secretariat for the State Level Environment Impact Assessment Authority (SEIAA), Maharashtra and the State Level Expert Appraisal Committee (SEAC), Maharashtra to provide all the required support. Thereafter, as per MoEF notification, 21st April 2008, Government of India in MoEF S.O. 898 (E) the Central Government, hereby, constitutes the SEAC, Maharashtra.

3.2.5 Maharashtra State Electricity Distribution Company Limited

Maharashtra State Electricity Board was looking after Generation, Transmission & Distribution of Electricity in the State of Maharashtra barring Mumbai. But with enactment of Electricity Act 2003, MSEB was unbundled in to 3 Companies viz. Maharashtra State Electricity Distribution Co. Ltd., Maharashtra State Power Generation Co. Ltd. and Maharashtra State Electricity Transmission Co. Ltd. on 6th June 2005. As per the EIA, the net power supply required for the proposed buildings is estimated to be around 17.4 MW based on this assumption that approximately 4 watt of power will be required per sq ft. The power will be made available from the Maharashtra State Electricity Distribution Company Limited (MSEDCL). The client will put

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up appropriate transformers in the proposed sub station as required by electricity providers and provide meter rooms for all the residential flats and utility operations.

3.2.6 Petroleum and Explosives Safety Organisation, (formerly Department of Explosives) Chief Controller of Explosives, Nagpur

Petroleum and Explosives Safety Organisation formerly known as Department of Explosives is under the Department of Industrial Policy & Promotion, Ministry of Commerce & Industry, and Government of India. The Chief Controller of Explosives, Nagpur heads the Petroleum and Explosives Safety Organisation and is responsible to deal with provisions of following rules:

 The Explosive Act 1884 and Rules, 1983,  The Petroleum Act 1934 and the Rules 2002,  Manufacture, Storage and Import of Hazardous Chemical Rules, 1989, as amended to date.

3.3 ENVIRONMENTAL REGULATORY FRAMEWORK

3.3.1 Environmental Laws and Regulations

In India, there are many laws and regulations directly and indirectly governing environment. However the most important direct legislations relevant to this project are listed in Table 3.1.

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Table 3.1 Applicable Environmental Laws and Regulations

S.No Issues Applicable Legislation Agency Responsible Applicable Permits and Status Requirement 1 Protection and Article 51-A Clause (g) of the Every Citizen of India Article 51-A of the Constitution of Followed improvement of & India states that it shall be the duty Natural Directive Principles of State of every citizen of India to protect Environmental Policy (Article 47) and improve the natural Resources environment including forests, lakes, rivers and wildlife and to have compassion for all living creatures. Article 47 of the Constitution of India requires not only a Protectionist stance by the state but also compels the state to seek the improvement of polluted environments 2 Prevention and The Water (Prevention and MPCB Consent for Establishment Obtained. As the project Control of Water Control of Pollution) Act, Consent to Operate progresses, the client Pollution 1974, amended in 1988 Compliance under the Act will apply for additional CTE from the appropriate regulatory agencies 3 Prevention and The Air (Prevention and MPCB Consent for Establishment Obtained. As the project Control of Air Control of Pollution) Act, Consent to Operate progresses, the client Pollution 1981, amended in 1987 and Compliance under the Act will apply for additional the Air (Prevention and CTE from the Control of Pollution) Rules appropriate regulatory 1982, as amended up to 18th agencies Feb 1992. 4 Water Cess Collection The Water (Prevention & MPCB Filing of monthly returns as per Yet to be obtained. (a tax on water use Control of Pollution) Cess prescribed format (Form I under and water pollution Act 1977, been implemented the Act- Form I duly completed caused) in the state of Maharashtra before 5th of next month showing with effect from 1st April water consumed in the previous 1983 and amended from 26th month) Jan 1992 and is further Compliance under the Act

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S.No Issues Applicable Legislation Agency Responsible Applicable Permits and Status Requirement amended w.e.f. 5/3/03. 5 Environmental The Environment MPCB Compliance under the rules to Protection (Protection) Act 1986, as maintain stipulated standards and amended in April 2003; environmental management through various supporting rules promulgated under the Act. EPA Rules 1986, as amended in 2002; Ministry of Environment and Forests

Central Pollution Control Board 6 Environmental a) Environmental Impact Ministry of Requirement of Environmental EC for the construction of Protection – EIA Assessment Notification 1994 Environment and Clearance first phase has been related (for project initiated prior to Forests through SEIAA, Environmental Impact Assessment obtained on 28th of 14 September 2006) Maharashtra for environmental appraisal of a February 2011 for project by SEIAA, Maharashtra construction of total built- b) Environmental Impact up area of 1,43,734 m2 and Assessment Notification, which includes a free sale September 2006 building of 54,493 m2 and rehabilitation buildings of 54,997 m2 . As the project progresses, the client will apply for additional EC in phases from the appropriate regulatory agencies. This is contingent to receipt of commencement certificate. 7. Felling of Trees Permission for felling of trees Revenue Department Number of Trees Felled to be Tree felling permit has (non forest land), Revenue enumerated under joint been obtained. Act verification 8 Public Consultation Environmental Impact MPCB Projects exempted from public Project undertook the Assessment Notification, consultation and the public Public Consultation September 2006 consultation procedure covered in process as suggested by EIA notification. MoEF.

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S.No Issues Applicable Legislation Agency Responsible Applicable Permits and Status Requirement All building/construction projects/area development projects and townships are exempt from public consultation and therefore the project would not require public consultation. 9 Noise Emissions The Noise (Regulation & MPCB Compliance under the rules to To be monitored. Control) Rules, 2000 as maintain stipulated standards amended in January 2010 10 Environmental EPA Rules 1992 and 1993 - MPCB Filing of annual environment To be monitored. statement Environmental Statement Statement under prescribed format under Rule 14 by 30 September of every year 11 Hazardous material Manufacture Storage and MPCB Central Identification of Major Accident Construction Chemical Storage Handling & Import of Hazardous Pollution Control Hazard under Rule 4 usage like solvents, paints, Transport Chemicals 1989 and Board Filing of Safety Report under Rule oil, etc should be recorded amendment Rules 2000 Ministry of 10 and the MSDS need to be under the Environment Environment and Preparation of Onsite and Offsite maintained. (Protection) Act, 1986, and Forests Emergency Control Plan under Rules framed there under Chief Inspector of Rules 13 & 14 Factories Collection, Development and District Collector, Dissemination of information Chief Controller of including Do’s and Don’ts and Explosives. labelling for hazardous substances handled onsite under Rule 17 Notification of accident to authorities under Schedule 5 and Rules 2b and 3. 12 Hazardous Wastes Hazardous Waste MPCB Authorisation for collection, Yet to be obtained. Management (Management, Handling and Central Pollution reception, storage, transportation Transboundary Movement) Control Board and disposal of hazardous wastes Rules, 2008 and as amended Filing of annual return under Form in October, 2010 4 to the rules Other compliance under the rules Authorisation by Central Pollution Control Boards to vendors accepting waste/used oil

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S.No Issues Applicable Legislation Agency Responsible Applicable Permits and Status Requirement Labelling of vehicles carrying hazardous substances (Transport Emergency - TREM card as per Form 11). Liability of the occupier, transporter and operator of a facility: The occupier, transporter and operator of a facility shall be liable for damages caused to the environment resulting due to improper handling and disposal of hazardous waste listed in schedule 1, 2 and 3 to the Rules; The occupier and operator of a facility shall also be liable to reinstate or restore damaged or destroyed elements of the environment; The occupier and operator of a facility shall be liable to pay a fine as levied by the State Pollution Control Board with the approval of the Central Pollution Control Board for any violation of the provisions under these rules. 13 Medical & infected The Bio-Medical Waste MPCB Authorisation as per form 1 under The first aid centre at the waste (Management and Handling) the Rule 8 for generation, construction site should Rules 1998, as amended in collection, reception, storage, maintain a waste September 2003; transportation, treatment and register-during disposal and any other form of construction phase. handling of bio-medical wastes Annual report as per Rule 10 Other compliance including reporting, labelling etc. 14 Regulation on Use of The Ozone Depleting Ministry of Regulation on consumption of Yet to be done during ODS Substances (Regulation) Environment and Ozone Depleting Substances on construction phase.

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S.No Issues Applicable Legislation Agency Responsible Applicable Permits and Status Requirement Rules 2000, as amended Forests end use basis (Year 2010 for Group through 26th September 2005; Director General of I, III, IV & V ODS; Year 2015 for Foreign Trade Group VII and Year 2040 for Other relevant agencies Group VI); like Small Industrial Annual reporting of ODS Development Regulation on import/export Organisation. /sale/purchase of ODS Regulation on manufacture, import and export and sale of compressors 15 Safety and Other The Gas Cylinders Rules Chief Inspector of Licence for possession of gas Yet to be done during related regulations 2004 Factories cylinders containing 100 kg of construction phase. Chief Controller of more of pressurised gas; Explosives Safe storage and Labelling of Gas cylinders Annual returns Compliance under the rules 16 Storage of Petroleum The Petroleum Act 1934, as Chief Controller of Licence for possession of Yet to be obtained. products amended in August 197 Explosives petroleum products (for Class A with flash point less than 23 ºC The Petroleum Rules 1976, as above 30 litres; Class B with flash amended in March 2002. point from 23 to 65ºC above 2500 litres; and Class C with flash point from 65 to 93ºC above 45000 litres) Provision of enclosure and safety measures for safe storage Labelling of vessels containing petroleum products; Compliance under the rules and as stipulated in the licence 17 Power Generation Electricity Act 2003, as State electricity A prior certificate of power Yet to be obtained. amended in May 2007 and department generation is required. Electricity Rules 2005

18 Slum Rehabilitation Under section 37 (1-B) of the Slum Rehabilitation To provide free houses to slum Ongoing Policy 1995 Maharashtra Regional And Authority-Maharashtra dwellers by using incentive Town Planning Act 1966 development rights.

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3.4 APPLICABLE ENVIRONMENTAL STANDARDS

The Central Pollution Control Board (CPCB) has also stipulated industry specific discharge of liquid effluents and general air emission standards. CPCB has also specified National Ambient Air Quality Standards (NAAQS) for residential, commercial, industrial and sensitive zones for the country as a whole. Standards for ambient noise quality are also to be followed up depending upon land use of the area.

The stipulated general wastewater discharge standards and general emission standards are to be followed together with specific requirements of MPCB. These standards limit the concentration and volumes of the effluents and emissions released to the atmosphere. These standards could be made more stringent by the MPCB based on the environmental sensitivity of a specific location.

The environmental standards relevant for proposed facility (in this case housing project) would be as per Environment Protection Rules, 1986 and amendments. The standards can be stricter as per notifications by State Pollution Control Boards depending upon location and other sensitivities in the area of industrial emissions.

3.4.1 Emission Standards

Different emission standards are notified from time to time for different set of industries. In case of non-specific standards, General Emissions Standards are as given in the Table 3.2 .

Table 3.2 General Emission Standards

S.N. Parameter Standard mg/Nm3 1 Particulate matter (PM) 150 2 Carbon monoxide 1% max. (v/v) Source: Schedule VI Environment (Protection) Rules, 1986 General Emission Standards Part D: Concentration based standards

3.4.2 Ambient Air Quality

The national ambient air quality standards, as notified under Environment Protection Rules, 1986 and revised through Environment (Protection) Seventh Amendment Rules, 2009 is presented in the Table 3.3.

Table 3.3 National Ambient Air Quality Standards

Pollutant Time Weighted Concentration in Ambient Air Avg Industrial, Ecologically Residential, Sensitive Areas Rural & Other (notified by Central Areas Government) Sulphur dioxide (g/m3) Annual 50 20 Average* 24 Hours** 80 80

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Pollutant Time Weighted Concentration in Ambient Air Avg Industrial, Ecologically Residential, Sensitive Areas Rural & Other (notified by Central Areas Government) Oxides of Nitrogen (g/m3) Annual 40 30 Average* 24 Hours** 80 80

Particulate matter (PM10) (g/m3) Annual 60 60 Average* 24 Hours** 100 100

Particulate matter (PM2.5) (μg/m3) Annual 40 40 Average* 24 Hours** 60 60 Lead (Pb) (g/m3) Annual 0.5 0.5 Average* 24 Hours** 1.0 1.0 Ammonia (g/m3) Annual 100 100 Average* 24 Hours** 400 400 Carbon monoxide (CO) (g/m3) 8 Hours 2000 2000 1 Hour** 4000 4000 Arsenic ((ng/m3) Annual 6 6 Average* Nickel (ng/m3) Annual 20 20 Average* Benzene (g/m3) Annual 5 5 Average* Benzo--pyrene particulate phase Annual 1 1 (ng/m3) Average* NOTE * Annual arithmetic mean of minimum 104 measurements in a year taken twice a week 24 hourly at uniform interval. ** 24 hourly/8 hourly values should be met 98% of the time in a year. However 2% of the time, it may exceed but not on two consecutive days.

As per the EHS guidelines of IFC of April 30, 2007, “the ambient air quality standards are ambient air quality levels established and published through National legislative and regulatory processes and ambient quality guidelines refer to ambient quality levels primarily developed through clinical, toxicological, and epidemiological evidence (such as those published by the World Health Organization)”. A reference to the ambient air quality guidelines of World Health Organization (WHO) is included in the following Table 3.4

Table 3.4 World Heath Organization - Ambient Air Quality Guidelines Parameter Averaging Period* Guideline Value (in μg/m3)

Sulfur Dioxide (SO2)  24 hr.  20  10 minute  500

Nitrogen Dioxide (NO2)  1 year  40  1 hour  200

Particulate Matter (PM10 )  1 year  20  24 hour  50

Particulate Matter (PM 2.5 )  1 year  10  24 hour  25 Ozone 8- our daily maximum  100 * World Health Organization (WHO), Global Update, 2005. PM-24 hour value is the 99th Percentile. Source: IFC EHS Guidelines.

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3.4.3 Ambient Noise Standards

As this is a residential project, the applicable noise standards to the project are 55 dBA and 45 dBA during day and night time respectively. Ambient noise standards are to be maintained as land use of an area as specified in Table 3.5.

Table 3.5 Ambient Noise Standards

Area Code Category of Area Limits in dB(A) Leq Day time* Night Time A Industrial Area 75 70 B Commercial Area 65 55 C Residential Area 55 45 D Silence Zone** 50 40 Note:*Day time is from 6 am to 10 pm, Night time is10.00 pm to 6.00 am;**Silence zone is defined as area up to 100 meters around premises of hospitals, educational institutions and courts. Use of vehicle horns, loud speakers and bursting of crackers are banned in these zones.

As per the IFC’s EHS guidelines( April 30, 2007), noise impacts should not exceed the levels presented in Table 3.6 below, or result in a maximum increase in background levels of 3 dB at the nearest receptor location off-site

Table 3.6 Noise Level Guidelines for Ambient Noise

One hour Leq (dBA)* Receptor Day time (07:00 to 22:00) Night time (22:00 to 07:00) Residential, Institutional, educational 55 45 *Guideline values are for noise levels measured out of doors. Source: Guidelines for Community Noise, World Health Organization (WHO), 1999

3.4.4 Noise Standards for Occupational Exposure

The proposed project will take utmost care in minimising noise. Where unavoidable, occupational noise exposure as stipulated in the Factory Rules, for workers within the project site will have to be ensured as per the Table 3.7

Table 3.7 Standards for Occupational Noise Exposure

Total Time of Exposure per Day in Hours Sound Pressure Level in dB(A) (Continuous or Short term Exposure) 8 85 6 92 4 95 3 97 2 100 3/2 102 1 105 ¾ 107 ½ 110 ¼ 115 Never >115 Note:  No exposure in excess of 115 dB A) is to be permitted.  For any period of exposure falling in between any figure and the next higher or lower figure as indicated in column (1), the permissible level is to be determined by extrapolation on a proportionate scale.  The above standards are as per Factories Act, 1948

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As per the IFC EHS Guidelines, no employee should be exposed to a noise level greater than 85 dB(A) for a duration of more than 8 hours per day without hearing protection. In addition, no unprotected ear should be exposed to a peak sound pressure level (instantaneous) of more than 140 dB(C). For every 3 dB(A) increase in sound levels, the ‘allowed’ exposure period or duration should be reduced by 50 percent (1) .

3.4.5 General Standards for Discharge of Effluents

The general standards for discharge are as prescribed under the Environment Protection Rules, 1986 and amendments. The project intends to treat the domestic waste water in STP and re-use the treated wastewater for gardening, flushing and HVAC purposes and thus, aims at Zero wastewater discharge from the project site, therefore the incremental pollution load will be minimum due to waste water.

Table 3.8 General Standards for Discharge of Environmental Pollutants

S N Parameter Standards Inland surface Public sewers Land for water Irrigation 1. Colour and odour Refer to Note 1 - Refer to Note 1 2 Suspended solids mg/l, max. 100 600 200 3 Particle size of suspended solids Shall 850 micron - - IS sieve 4 pH 5.5 to 9.0 5.5 to 9.0 5.5 to 9.0 5 Temperature Shall not exceed - - 50 C above the receiving water temperature 6 Oil and grease, mg/l max, 10 20 10 7 Total residual chlorine, mg/l 1.0 - - max 8 Ammoniacal nitrogen (as N), 50 50 - mg/l max. 9 Total Kjeldahl nitrogen (as N); 100 - - mg/l max 10 Free ammonia (as NH3), mg/l 5.0 - - max 11 Biochemical oxygen demand (3 30 350 100 days at 270 C), mg/l max 12 Chemical oxygen demand, mg/l 250 - - max 13 Arsenic (as As) mg/l, max 0.2 0.2 0.2 14 Mercury (As Hg) mg/l max. 0.01 0.01 - 15 Lead (as Pb) mg/l, max 0.1 1.0 - 16 Cadmium (as Cd) mg/l, max 2.0 1.0 - 17 Hexavalent chromium (as Cr +6) 0.1 2.0 - mg/1 max 18 Total chromium (as Cr) mg/1 2.0 2.0 - max 19 Copper (as Cu) mg/1, max 3.0 3.0 -

(1) The American Conference of Governmental Industrial Hygienists (ACGIH), 2006

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S N Parameter Standards Inland surface Public sewers Land for water Irrigation 20 Zinc (as Zn) 5.0 15 - 21 Selenium (as Se) 0.05 0.05 - 22 Nickel (as Ni) mg/1,max 3.0 3.0 - 23 Cyanide (as CN) mg/1,max 0.2 2.0 0.2 24 Fluoride (as F) mg/1,max 2.0 15 - 25 Dissolved phosphates (as P) 5.0 - - mg/1,max 26 Sulphide (as S) mg/1,max 2.0 - - 27 Phenolic compounds (as 1.0 5.0 -

C6H5OH) mg/1,max 28 Radioactive materials: (a) Alpha 10-7 10-7 10-8 emitters micro curie mg/1,max (b) Beta emitters micro curie mg/1 10-6 10-6 10--7 29 Bio-assay test 90% survival of 90% survival of 90% survival of fish after 96 fish after 96 fish after 96 hours in 100% hours in 100% hours in 100% effluent effluent effluent 30 Manganese 2 mg/1 2 mg/1 - 31 Iron (as Fe) 3mg/1 3mg/1 - 32 Vanadium (as V) 0.2 mg/1 0.2 mg/1 - 33 Nitrate Nitrogen 10 mg/1 - - Note: * as per annexure 6 of the General Standards

3.4.6 Hazardous Waste Management

The Hazardous Wastes (Management, Handling and Transboundary Movement) Rules, 2008 are promulgated under Environment (Protection) Act 1986, which was further amended in July 2009, September 2009, March 2010 and August 2010. The rules define hazardous wastes to be any waste which by reason of any of its physical, chemical, reactive, toxic, flammable, explosive or corrosive characteristics causes danger or is likely to cause danger to health or environment, whether alone or when in contact with other wastes or substances, and will include any of hazardous processes generating wastes (as listed in Schedules 1) or concentration of hazardous contents in such wastes (as listed in Schedule 2) or import or export of hazardous wastes (as listed in Schedule 3). Import and export norms for the hazardous wastes have been provided in conformance with the Basel Convention, to which India is a signatory.

With the recent amendment, these rules have become quite comprehensive. The rules define responsibility of hazardous wastes generators, require safe handling practices and maintenance of manifest system during transport of hazardous waste and also describe technological aspects to be followed up by re-refiners and recyclers of hazardous wastes. The rules also cover liabilities of occupier, transporter and operator of a facility for any damages caused due to improper handling and disposal of hazardous wastes by reinstating or restoring environmental damages caused.

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The categories of wastes as applicable to proposed project operation and as covered under Schedule 1 to the Rules include Used Oil and construction wastes required during building construction.

3.5 REGULATIONS RELATED TO SLUM AND BUILDINGS CONSTRUCTION

A Policy, Legal and Administrative Framework including the definition of eligibility from the standpoint of SRA; and the company project level entitlement policy (e.g. going beyond 1995 cut-off)

The regulatory review for the project is being done on the premise that the land for the SRA site was always in the ownership of the project proponent by virtue of lease and was a private land (Please refer to project description section for detailed ownership of the land). However, it was brought under SRA, under the SRS of PCMC. Hence the applicability of the various regulations for the project needs to consider the premise of ownership for the project. Also, it is important to assess the understanding of the slums in the country. The definition of the slums as per Census of India and National Sample survey organisation is being detailed below:

Census of India

The Census of India, has adopted the definition of slums specified/declared “slums” through State/UT or local government under any act. In additions it also consider the following area as slum : “A compact area of at least 300 population or about 60-70 households of poorly built congested tenements, in unhygienic environment usually with inadequate infrastructure and lacking in proper sanitary and drinking water facilities”.

National Sample Survey Organization (58th Round)

“A compact settlement with a collection of poorly built tenements, mostly of temporary nature, crowded together usually with inadequate sanitary and drinking water facilities in unhygienic conditions. Such an area, for the purpose of this survey, was considered as “non-notified slum” if at least 20 households lived in that area. Areas notified as slums by the respective municipalities, corporations, local bodies or development authorities are treated as “notified slums”.

Possible land tenure system in Indian Slums fall in the categories mentioned in Table 3.9

Table 3.9 Form of Tenure in Slums

Sl.No Forms of tenure Characteristics 1 Freehold (Individual) Ownership in Perpetuity 2 Delayed Freehold Conditional Ownership. Title is granted on completion (Individual) of payments or when developments have been completed.

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Sl.No Forms of tenure Characteristics 3 Registered Leasehold The right to hold or use property for a fixed period at a (individual or community given price, without transfer of ownership, on the basis based) of a lease contract. Leasehold is a fixed asset. The Ownership for specified period. 4 Co-operative ownership Ownership is vested in the co-operative or group of which residents are co-owner 5 Public Rental Rental Occupation of publicly owned land or house 6 Private Rental Rental of privately owned land or property 7 Shared equity Combination of delayed freehold and rental in which residents purchase a stake in their property (often 50%) and pay rent on the remainder to the other stakeholder 8 Community based tenure This can take several forms for eg. Rental by a community of generally private land for an agreed period. At the end of the period, the community an extension may be agreed of the community is given notice to leave within a agreed period. Other options include Community Area Permits, Community Lease, or community ownership. 9 Religious Tenure Systems (e.g. 4main categories within Islamic Societies “Waqf”, ‘ Islamic) Mulk’, ‘Min’ ‘ Tassuruf’ or usufruct rights, is increasingly common whilst “musha/mushtarak”, is collective/tribal ownership 10 Encroachments on public Squatting on public land, prone to eviction as there is no land security of tenure but government may relocate. 11 Encroachment on private Squatting on private land, prone to forced eviction, the land land-owner reserves the land rights. 12 Pavement Dwellers Temporary Encroachment, government/private agencies keep removing them time to time Source: Risbud N (2010), Typology of Slums and Land Tenure in Indian Cities, Presentation made at National Workshop on Land Tenure Issues in Slum Free Planning, Centre of Urban Equity, CEPT University, Ahmadabad, India.

The laws and regulations relating to housing sector in India have not seen phenomenal changes over the years. More so with the rise of the slums in the cities some of the states have made acts to deal with the issue of slums in the cities. Maharashtra is one of the states, which on account of having limited avenues for expansion at the core, has seen proliferation of slums inside the city, also because the city grew over a period of time taking these slums in its fold, in some cases presently termed as prime areas of the city. With the requirement for affordable housing for the people living in slums and the opportunity cost for area covered by these horizontal slums led to evolution of schemes like SRS.

The section tries to capture the laws the regulations which will be applicable for slums and in particular to SRS in Pune in Maharashtra.

3.5.1 MRTP Act, 1966: for preparation of Development Plans to designate land for public purposes

(As Modified up to the 31st December 2005): While this Act does not explicitly mention the urban poor / slum dwellers, it deals with a number of planning issues related to the allocation and use of land for development that could affect them. Some key provisions under the Act are as follows:

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 Town Planning Schemes are covered under Chapter 5(a): Making of Town Planning Schemes.  The Sections 59 – 71 of the Act deal with (among other aspects) the preparation and contents of town planning scheme, the power of the planning authority, and the role of the state government in sanctioning the scheme.  Section 59(1) (a) states that “Subject to the provisions of this act or any other law for the time being in force, a Model Inclusive Zoning & planning authority may for the purpose of implementing the proposals in the final development plan, prepare one or more town planning schemes for the area within its jurisdiction, or any part thereof.”  Section 125 of this Act states that: “Any land required, reserved or designated in a Regional Plan, a Development or any other plan or town planning scheme, for a public purpose or purposes including plans for any area of comprehensive development or for any new town shall be deemed to be land needed for a public purpose within the meaning of the Land Acquisition Act 1894.”

3.5.2 Maharashtra Slum Areas (Improvement, Clearance & Redevelopment) Act, 1971

The main tenets of the act are:  The District Collector is a competent authority to declare an area as a slum.  Slum definitions are ambiguous & are subject to interpretation. Slums are declared & notified by the Housing Department, Government of Maharashtra based on the approval & report containing surveyed data of respective cities received from Additional Collector. The SRA is primarily an offshoot of this act and draws primarily from this act.

Defining Slum The act as per Section 26 (1) describes the process of identifying areas for slum improvement. The aforementioned action states that “26. (1) Where the Board upon report of any of its officers or other information is satisfied that any area is or may be a source of danger to the health, safety or convenience of the public of that area or of its neighbourhood by reason of the area having inadequate or no basic amenities, or being insanitary squalid, overcrowded or otherwise, it shall cause such area to be defined in a map and then it shall by an order published in the Official Gazette declare such area to be a slum improvement area.

However, the powers of declaring slums over the years have been vested with the local administration, i.e SRA or other such body at the local level.

Establishment of Panchayats for slum Improvement The act keeps the provision of establishment of Panchayats in slum improvement areas.

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Under SRA schemes, this has been taken forward with the formation of the cooperatives to be registered under the Maharashtra Cooperative Societies Act, 1960.

3.5.3 Development Control (DC) Rules for Pimpri-Chingchwad Municipal Corporation, Pimpri 1985

Development Control Rules for Pimpri-Chingchwad Municipal Corporation, Pimpri 1985, details out the requirement for building activity and development work in the Pimpri-Chinchwad Municipal Corporation area.

These rules supersede all Development Control Rules and bye-laws framed and Sanctioned under the Maharashtra Regional and Town Planning Act, 1966 the Bombay Provincial Municipal Corporation Act 1949. However, these rules are not applicable to the lands acquired for Pimpri-Chinchwad New Town Development Authority. The DC regulation for PCMC gives the details on the following aspects:

 Applicability of the Development Control Rules  Building Permission/Commencement Certificate Required  Procedure for obtaining Building Permission/Commencement Certificate  Procedure during construction  General building requirement  Structural safety and services

In case anything related to the building construction or slum redevelopment is not properly addressed or any other matter not detailed in Special regulations for Pune and Pimpri Chinchwad Slum rehabilitation authority, Pune, Development Control (DC) Rules for Pimpri-Chingchwad Municipal Corporation, shall be applicable along with the subsequent modifications.

3.5.4 The Maharashtra Cooperative Societies Act, 1960

The Act provides for the orderly development of the co-operative movement in the State of Maharashtra in accordance with the relevant directive principles of State policy enunciated in the Constitution of India. All the cooperative societies related to housing, agriculture, dairying etc. are registered under this act. This act lays down the requirement for the registration of societies in the state of Maharashtra. The main tenets covered under the act are as follows:  Requirements for registration of societies  Members and their rights and liabilities  Incorporation duties and privileges of societies  State aid to societies  Property and funds of societies  Management of societies including power and functions

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The society of the hutment dwellers to be formed for implementation of SRS needs to be registered under this act and will abide by this act and the modifications.

3.5.5 Special Regulations for Pune and Pimpri Chinchwad, Slum Rehabilitation Authority

SRS in all the cities of Maharashtra is guided by the SRA act. However the SRS schemes of the various cities have maintained their own regulations, as per the needs of the various cities. SRS regulations for Mumbai continue to dominate the scene with early beginning and the immenseness of the issues that it had to address due to specificity of the slums in various parts of Mumbai.

The SRA regulations for Mumbai were further followed by important notifications and guidelines especially in relation to Dharavi and other slums which hovered around the Mumbai coast, especially because of the implications of the Coastal Zone regulations.

The SRS Pune regulation was also based on SRS Mumbai, however it was separate. The notification is likely to undergo changes with local administration bringing out a draft and requesting comments and suggestions on the same. However, the same has not been implemented till date.

Box 3.1 Main features of the Pune SRS Scheme.

 Every slum structure existing prior to 01/01/1995 is treated as protected structure.  Every slum dweller whose name appears in the electoral rolls as on 01/01/1995 and who continues to stay in the slum is eligible for rehabilitation.  Every eligible residential slum structure is provided with an alternative tenement admeasuring 25.00 sq. mt. preferably at the same site, irrespective of the area of slum structure.  Every eligible slum structure that is being used for commercial purposes is granted an alternative tenement having area equal to the structure subject to an upper limit of 25.00 sq. mt.  A minimum of 70% of eligible slum dwellers in a slum pocket come together to form a co- operative housing society for implementation of Slum Rehabilitation Scheme. (SRS)  The slum dwellers appoint a developer for execution of SRS.  The developer puts in resources in the form of money, men and material for construction of free houses for the slum dwellers.  The developer is compensated for his efforts in the form of free sale component.  The developers are allowed to construct tenements for sale in the open market. The area allowed for sale in the open market is equal to the area of tenements constructed for Rehabilitation of slum dwellers.  Floor Space Index (known as FAR elsewhere) upto 2.5 is allowed for SRS.  The developer is required to construct the rehabilitation tenements on the plot itself. The balance FSI left is allowed for construction of free sale tenements.  The spill over entitlement to the developer is permissible for sale in the form of transferable development right in the open market. These transferable rights can be utilised on other non slum pockets subject to the provisions of DC. Regulations.  Slum Rehabilitation Authority is designated as a local planning authority to provide all the requisite approvals for SRS under one roof. The authority is mandated to act as a facilitating agency for implementation of SRS.  Along with the free rehabilitation tenements the developers also have to provide space for amenities like a creche (Balwadi), society office, welfare centre

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3.6 LABOUR RELATED REGULATIONS

The project will involve a main PMC contractor and its sub contractors. Typically the contractors employ the labour for the project and are responsible to ensure they are meeting the labour regulations. However, as the principal; employer, KUL is liable for any non-conformances or compliance. There are several laws and rules that govern labour issues in India. The issues covered include:

3.6.1 Child Labour

The Constitution of India (Part III, Article 24 - Fundamental Rights) describes that no child below the age of fourteen years shall be employed to work in any factory or engaged in any other hazardous employment

3.6.2 The Child Labour (Prohibition and Regulation) Act, 1986

As per the Child Labour (Prohibition and Regulation) Act, 1986, a child is defined as a person who has not completed 14years of age. The Act prohibits employment of children in certain occupation and processes (part II, Section 3). The Act also specifies conditions of work for children, if permitted to work. These include a working day of maximum of 6 hours a day (including rest), no work period exceeding 3 hours at a stretch, and no overtime (Section 7). The Act requires maintenance of a register for employed children (Section 11).

3.6.3 Forced Labour

Constitution of India (Part III, Fundamental Rights No 23): Right against Exploitation

The Bonded Labour (Abolition) Act 1976: States that all forms of bonded labour stands abolished and every bonded labourer stands freed and discharged from any obligations to render any bonded labour (Ch II, Section 4)

3.6.4 Freedom of Association

The Trade Union Act, 1926: Provides procedures for formation and registration of Trade Unions and lists their rights and liabilities. It encompasses any combination, permanent or temporary, that gets formed to regulate relationship between workmen and their employers.

3.6.5 Wages

Minimum Wages Act, 1948 requires the Government to fix minimum rates of wages and reviews this at an interval of not more than 5 years. The Payment of Wages Act, 1936, amended in 2005. Every employer shall be responsible for

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the payment to persons employed by him of all wages required to be paid under this Act.

As per the Equal Remuneration Act 1976, it is the duty of an employer to pay equal remuneration to men and women workers for same work or work of a similar nature.

3.6.6 Compensation

Workmen's Compensation Act, 1923 requires if personal injury is caused to a workman by accident arising out of and in the course of his employment, his employer shall be liable to pay compensation in accordance with the provisions of this Act.

3.6.7 Welfare and working conditions

As per the Maternity Benefit Act, 1961 no employer shall knowingly employ a woman in any establishment during the six weeks immediately following the day of her delivery or her miscarriage. No pregnant woman shall, on a request being made by her in this behalf, be required by her employer to do during the period any work which is of an arduous nature or which involves long hours of standing, or which in any way is likely to interfere with her pregnancy or the normal development of the foetus, or is likely to cause her miscarriage or otherwise to adversely affect her health.

3.6.8 The Contract Labour (Regulation & Abolition) Act, 1970 and Rules

As per the contract labour (Regulation & Abolition) Act, 1970 and Rules, every principle employer is required to get the establishment registered before employing any contract labour. The contractors are also required to provide at minimum amenities like canteen, urinals, restrooms or alternate accommodation (if night halting labour), first aid, safe drinking water, etc. in case of contractor’s failure to provide these amenities, the principle employer is liable to provide such amenities at its cost.

The key one is building and other construction workers legislation. It sets the standards for construction workers and labour camps.

3.6.9 Other Legislations

Other labour related legislations applicable for the Project include the following:  The E.P.F. and Miscellaneous Provisions act, 1952  Payment of Bonus Act, 1965 and Amendment Act No.43 of 1977 and No.48 of 1978 and amendments  Payment of Gratuity Act, 1972  Public Provident Fund Act, 1968  ESI Act , 1948 (Employees State Insurance Act, 1948)  Employer's Liability Act, 1938 (as amended).  The Industrial Employment (Standing Orders) Act, 1946 (as amended).

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 The Industrial Disputes Act, 1947 (as amended).  The Personal Injuries (Compensation Insurance) Act, 1963 (as amended).  Factories Act 1948.  Shops and Establishment Act  Interstate Migrant Workers Act 1979  Building and Other Construction Workers Act 1996

Rules include:  Industrial Disputes (Central) Rules, 1957  Minimum Wages (Central) Rules, 1950  Payment of Bonus Rules, 1975  The Personal Injuries (Compensation Insurance) Rules  Standing Orders Rules 1946.

3.7 ARCHAEOLOGY AND CULTURAL HERITAGE RELATED REGULATIONS

These regulations are important not only from the perspective of saving ancient archaeological findings, but also from the perspective of social, religious or sentimental value it may possess for the various communities. It is important, that in case such findings are reported, identified, and conserved not only for academic purposes but also for the importance they may have for certain communities.

3.7.1 Indian Treasure Trove Act, 1878 (as modified upto September 1949)

The act defines ‘treasure’ as anything of any value, hidden in soil or anything affixed to soil and treasure handing over procedure. As per section 4 of the said act, whenever any treasure exceeding in amount or value ten rupees is found, the finder shall, as soon as practicable, give to the Collector notice in writing— (a) Of the nature and amount or approximate value of such treasure; (b) Of the place in which it was found; (c) Of the date of the finding:

and either deposit the treasure in the nearest Government Treasury, or give the Collector such security as the Collector thinks fit, to produce the treasure at such time and place as be may from time to time require

3.7.2 The Antiquities and Art Treasures Act, 1972

This is an act which regulates trade in ‘antiquities’ and ‘art treasures’, and provides for prevention of smuggling and fraudulent dealing in antiquities and art treasures.

Both of above regulations will be applicable to KUL, in case it undertakes the construction of the project and comes across any artefact of archaeological importance during any excavation or earth work.

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3.8 CONSULTATION AND DISCLOSURE RELATED LEGISLATIONS

Right to Information Act, 2005

The Right to Information1 Act applies to the whole of India (except the State of Jammu and ). The Act includes the right to:  Inspects works, documents, records;  Take notes, extracts or certified copies of documents or records;  Take certified samples of materials; and  Obtain information in the form of printouts, diskettes, floppies, tapes, video cassettes or in any other electronic mode.

The Act does not include information including commercial confidence, trade secrets or intellectual property, the disclosure of which would harm the competitive position of a third party, unless the competent authority is satisfied that larger public interest warrants the disclosure of such information.

RTI act covers only govt institutions and departments. A company, shop or establishment is not obliged to give out information under this regulation However, there is an indirect implication in case a citizen wants to get information about any aspect of the project, s/he may approach the relevant govt official through a process outlined in the above regulation. The govt official/department may then seek the same information from company, shop or establishment if required.

As a good practice, KUL should pre-empt such scenarios and be as transparent as possible and engage with the local community through appropriate and timely disclosure of relevant information, having procedures in place to receive and respond to community interest, information request, grievances and concerns and through CSR or other activities.

The SRA disclosure process

Stakeholder engagement and regular public consultations are also in-built into the SRA Guidelines. These responsibilities are shared by the Builder and the SRA as follows:  Disclosure requirements of (a) Letter of Intent with the Builder and Society Members; Intimation and Notice of the SRA Annexure II Survey; and Results of the SRA Annexure II Survey;  Compulsory Consent of at least 70% of the tenement owners/occupiers to the builder’s development proposal;  Verification of the cooperative housing society by the SRA through a public meeting and subsequently a public hearing for general community grievances; and

(1) 1 ‘Information’ means any material in any form including records, documents, memos, e-mails, opinions, advice, press releases, circulars, orders, logbooks, contracts, reports and papers, samples, models, data material held in any electronic form and information relating to any private body which can be accessed by public authority under any other law for the time being in force but does not include ‘file notings’.

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 The SRA expects the builder to keep the community informed at intervals as desired by the society on the project details, schedules etc.

The EIA public Consultation and Disclosure process

As per the EIA Notification, 2006 “Public Consultation” refers to the process by which the concerns of local affected persons and others who have plausible stake in the environmental impacts of the project or activity are ascertained with a view to taking into account all the material concerns in the project or activity design as appropriate. The categories of projects requiring public consultation is given in the EIA notification.

The Public Consultation consists of carrying out a public hearing at the site or in its close proximity (district wise) for ascertaining concerns of local affected persons in a manner as prescribed in the notification and to obtain responses in writing from other concerned persons having a plausible stake in the environmental aspects of the project or activity.

The public hearing is required to be conducted by the State Pollution Control Board (SPCB) or the Union territory Pollution Control Committee (UTPCC) concerned in the specified manner and the proceedings are required to be forwarded to the regulatory authority concerned (MoEF/SEIAA).

For obtaining responses in writing from other concerned persons having a plausible stake in the environmental aspects of the project or activity, the concerned regulatory authority and the State Pollution Control Board (SPCB) or the Union territory Pollution Control Committee (UTPCC) invites responses from such concerned persons by placing on their website the summary EIA report prepared by the applicant.

3.9 IFC PERFORMANCE STANDARDS

The Performance Standards (PS) established by IFC stipulates that the project shall meet certain requirements throughout the life cycle of an investment by IFC or other relevant financial institution, who are signatory to the Equator Principles, 2006.

3.9.1 Brief on IFC Performance Standards

A brief description of the Performance standards is provided in Table 3.10

Table 3.10 IFC Performance Standards

Performance Standards Specific Areas Performance Standard 1: Social and Environmental Assessment and Management System Performance Standard 2 Labour and Working Conditions Performance Standard 3 Pollution Prevention and Abatement Performance Standard 4 Community Health, Safety and Security Performance Standard 5 Land Acquisition and Involuntary Resettlement

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Performance Standards Specific Areas Performance Standard 6 Biodiversity Conservation and Sustainable Natural Resource Management Performance Standard 7 Indigenous Peoples Performance Standard 8 Cultural Heritage

The PS 1 establishes the importance of:  Integrated assessment to identify the social and environmental impacts, risks, and opportunities of a project;  Effective community engagement through disclosure of project-related information and consultation with local communities on matters that directly affect them ; and  The project proponents’ management of social and environmental performance throughout the life of the Project.

The potential social and environmental impacts that require particular attentions with the relevant social and environment risks and impacts assessed are described throughout PS 2 through 8. They establish requirements to avoid, reduce, mitigate or compensate for impacts on people and the environment, and to improve conditions where appropriate.

These performance standards and guidelines provide ways and means to identify impacts and affected stakeholders and lay down processes for management and mitigation of adverse impacts. A brief on the requirements as laid down in the performance standards is described in the following subsections. More detail on the applicability of the Performance Standards is discussed in Environmental and Social Management Plan (ESMP) in Section 8 of this ESIA report.

3.9.2 Major Tenets of IFC Performance Standards

This sub section tries to provide the requirements of the specific PS, so as to set up the context for matching the requirements of these PS during the various stages of the life cycle of the housing project.

PS 1: Social and Environmental Management Principles

The PS-1 requires Social and Environmental Assessment and Management Systems for managing social and environmental performance throughout the life cycle of this Project and runs through all subsequent PSs. The main elements of PS - 1 include:

 A Social and Environmental Assessment to understand the social and environmental impacts and risks;  A Management Program for mitigating the impacts and minimizing the risks identified in the assessment;  Establishing and ensuring organizational capacity and requisite trainings to the staff to implement the Management Programme;  Engagement with the community to ensure free prior informed consultation (FPIC), community grievance redress constructive relationship all through the project life cycle; and

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 Adequate monitoring and reporting systems to measure and report the effectiveness of the Management Programs.

The social and environmental performance is a continuous process to be initiated by the management and would involve communication between organisation, its workers and local communities directly affected by the Project. The PS requires that Project proponent initiate regular assessment of the potential social and environmental risks and impacts and consistently tries to mitigate and manage strategy on an ongoing basis.

PS 2: Labour and Working Conditions

The economic growth through employment creation and income generation is recognised and balanced protecting the basic rights of workers. The PS 2 is guided by the various conventions of International Labour Organization (ILO) and outlines the minimum requirements of working conditions, protection to the workforce (including issues of child and forced labour) and ensuring occupational health and safety of both its ‘employees’ as well as ‘non employees’ working through contractors. The PS requires:

 Establishment of a sound worker-management relationship;  Encouraging equal opportunity and fair treatment of workers;  Promoting compliance with national labour and employment laws; and  Promoting healthy and safe working conditions for workers.

PS 2 requires KUL to conduct its activities in a manner consistent with the four core labour standards (child labour, forced labour, non discrimination, and freedom of association and collective bargaining). In addition, PS 2 also addresses other areas such as working conditions and terms of employment, retrenchment, and occupational health and safety issues.

Some of these requirements refer to the applicable national law. Whereas national law establishes standards that are less stringent than those in PS 2, or are silent, KUL is expected to meet the requirements of PS 2.

PS 3: Pollution Prevention and Abatement

The PS 3 outlines approach to pollution prevention and abatement in line with internationally disseminated technologies and practices with objectives to a) avoid or minimize adverse impacts on human health and the environment by avoiding or minimizing pollution from activities; and b) promote the reduction of emissions that contribute to climate change. The PS 3 requires a project to avoid, minimize, or reduce adverse impacts on human health and environment by adopting pollution preventive and control technologies throughout the Project life cycle.

PS 3 outlines a project approach to Pollution Prevention and Abatement (PPA) in line with internationally disseminated technologies and practices. It describes the measures to take into account the potential impact of emissions on the ambient conditions (such as ambient air quality) and seek to avoid or

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minimise these impacts within the context of the nature and significance of pollutants emitted.

PS 4: Community, Health, Safety and Security

The PS 4 concentrates on the responsibility that must be undertaken by the client to avoid or minimize the risks and impacts to the community’s health, safety and security that may arise from project activities. The PS 4 requires a project to evaluate risks and impacts to the health and safety of the affected community during the Project life cycle and establish measures to avoid minimize and reduce risks and impacts from the Project.

PS 4 recognises that project activities, equipment, and infrastructure often bring benefits to communities including employment, services, and opportunities for economic development. However, projects can also increase the potential for community exposure to risks and impacts arising from equipment accidents, structural failures, and releases of hazardous materials. The performance standard details out KUL’s responsibility to avoid or minimise the possible risks and impacts to community health, safety and security that may arise from project activities.

PS 5: Land Acquisition and Involuntary Resettlement

The objectives of this PS are to:

 Avoid or at least minimize the involuntary resettlement wherever feasible by exploring alternative project designs;  Mitigate adverse social and economic impacts from land acquisition or restrictions on affected persons’ use of land by:  Providing compensation for loss of assets at replacement cost; and  Ensuring that resettlement activities are implemented with appropriate disclosure of information, consultation, and the informed participation of those affected.  Improve or at least restore the livelihoods and standards of living of displaced persons;  Improve living conditions among displaced persons through provision of adequate housing with security of tenure at resettlement sites.

The PS 5 requires a project to consider various processes and systems to avoid /minimise social and economic impacts related to land acquisition and resettlement.

This PS applies to physical or economic displacement resulting from the following types of land transactions:

 Type I: Land rights for a private sector project acquired through expropriation or other compulsory procedures.  Type II: Land rights for a private sector project acquired through negotiated settlements with property owners or those with legal rights to land, including customary or traditional rights recognised or recognisable under the laws of the

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country, if expropriation or other compulsory process would have resulted upon the failure of negotiation.  This PS does not apply to resettlement resulting from voluntary land transactions (i.e., market transactions in which the seller is not obliged to sell and the buyer cannot resort to expropriation or other compulsory procedures if negotiations fail). The impacts arising from such transactions shall be dealt with as under PS1, though sometimes, when risks are identified, the project proponent may decide to adhere to PS 5 requirements even in willing buyer-seller cases.

PS 6: Biodiversity Conservation & Sustainable Natural Resource Management

The PS 6 aims at protecting and conserving biodiversity, the variety of life in all its forms, including genetic, species and ecosystem diversity and its ability to change and evolve, is fundamental to sustainable development. The components of biodiversity, as defined in the Convention on Biological Diversity, include ecosystems and habitats, species and communities, and genes and genomes, all of which have social, economic, cultural and scientific importance. This PS addresses how clients can avoid or mitigate threats to biodiversity arising from their operations as well as incorporate sustainable management of renewable natural resources.

PS 6 recognises that protecting and conserving biodiversity—the variety of life in all its forms, including genetic, species and ecosystem diversity—and its ability to change and evolve, is fundamental to sustainable development. It reflects the objectives of the Convention on Biological Diversity to conserve biological diversity and promote use of renewable natural resources in a sustainable manner.

PS 7: Indigenous Peoples

The PS 7 acknowledges the possibility of vulnerability of indigenous people owing to their culture, beliefs, institutions and living standards, and that it may further get compromised by one or other project activity throughout the life cycle of the project. The PS underlines the requirement of avoiding / minimizing adverse impacts on indigenous people in the project area, respecting the local culture and customs, fostering good relationship and ensuring that development benefits are provided to improve their standard of living and livelihoods.

PS 7 recognises that Indigenous Peoples, as social groups with identities that are distinct from dominant groups in national societies, are often among the most marginalised and vulnerable segments of the population. The term “indigenous people” is more clearly defined in the IFC Guidance Note for PS 7.

Objectives of PS 7 underscore the need to avoid adverse project impacts on Indigenous Peoples’ communities living in the project’s area of influence, or where avoidance is not feasible, to minimise, mitigate or compensate for such impacts through mechanisms that are tailored to their specific cultural

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characteristics and expressed needs of the Indigenous Peoples, in a manner commensurate with the scale of project risks and impacts.

PS 8: Cultural Heritage

The PS 8 aims to protect the irreplaceable cultural heritage and to guide clients on protecting cultural heritage in the course of their business operations. In addition, the requirements of this Performance Standard on a project’s use of cultural heritage are based in part on standards set by the Convention on Biological Diversity.

PS 8 recognises the importance of cultural heritage with an objective to:  Protect cultural heritage from the adverse impacts of project activities;  Support its preservation; and  Promote the equitable sharing of benefits from the use of cultural heritage in business activities.

The PS requires the KUL to comply with relevant national law on the protection of cultural heritage, including national law implementing the host country’s obligations under the Convention Concerning the Protection of the World Cultural and Natural Heritage and other relevant international law.

Note: PS 6, 7, and 8 are not envisaged primarily due to the location and the social profile of the people living in the proposed project area.

3.9.3 Categorization of Projects

As part of its review of a project’s expected social and environmental impacts, IFC uses a system of social and environmental categorisation. This categorisation is used to reflect the size of impacts understood as a result of the client’s social and environmental assessment and to specify IFC’s institutional requirements. The categories used by the IFC are:

 Category A Projects: Projects with potential significant adverse social or environmental impacts that are diverse, irreversible or unprecedented;  Category B Projects: Projects with potential limited adverse social or environmental impacts that are few in number, generally site-specific, largely reversible and readily addressed through mitigation measures;  Category C Projects: Projects with minimal or no adverse social or environmental impacts, including certain financial intermediary (FI) projects with minimal or no adverse risks;  Category FI Projects: All FI projects excluding those that are Category C projects.

IFC therefore categorises project primarily according to the significance and nature of impacts. IFC defines the project's area of influence as the primary project site(s) and related facilities that the client (including its contractors) develops or controls; associated facilities that are not funded as part of the project (funding may be provided separately by a client or a third party including the government), and whose viability and existence depend exclusively on the project and whose goods or services are essential for the

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successful operation of the project; areas potentially impacted by cumulative impacts from further planned development of the project; and areas potentially affected by impacts from unplanned but predictable developments caused by the project that may occur later or at a different location. The area of influence does not include potential impacts that would occur without the project or independently of the project

An independent review of the Nirvana project assessed that the project fell under Category B.

3.9.4 IFC EHS Guidelines

The ADB SPS policy Statement 2009 (SPS) states, "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." For this purpose IFC EHS guidelines are recommended.

The Environmental, Health, and Safety (EHS) General Guidelines (refer to: http://www.ifc.org/ifcext/sustainability.nsf/AttachmentsByTitle/gui_EHSG uidelines2007_GeneralEHS/$FILE/Final+-+General+EHS+Guidelines.pdf will be applicable for this Project.

3.10 ASIAN DEVELOPMENT BANK REQUIREMENTS

The Asian Development Bank is a regional multilateral financial institution established in 1966. Currently it has 66 member countries, 48 of which are Developing Member Countries (DMCs) and 18 non-regional donor countries. The Bank provides loans and grants through its two mechanisms:  low interest money from Asian Development Fund (ADF), and  high interest money through the Ordinary Capital Resources (OCR).

3.10.1 ADB’s Safeguard Policy Statement (SPS)

In July 2009, ADB's Board of Directors approved the new Safeguard Policy Statement (SPS) governing the environmental and social safeguards of ADB's operations. The SPS builds upon ADB's previous safeguard policies on the environment, involuntary resettlement, and Indigenous Peoples, and brings them into one consolidated policy framework with enhanced consistency and coherence, and that more comprehensively addresses environmental and social impacts and risks. The SPS also provides a platform for participation by affected people and other stakeholders in project design and implementation.

The SPS applies to all ADB-financed and/or ADB-administered projects and their components, regardless of the source of financing, including investment

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projects funded by a loan; and/or a grant; and/or other means, such as equity and/or guarantees. ADB works with borrowers/clients to put into practice the requirements of SPS.

The SPS supersedes ADB's Involuntary Resettlement Policy (1995), Policy on Indigenous Peoples (1998), and Environment Policy (2002). In accordance with the SPS, these previous policies apply to all projects and tranches of multitranche financing facility projects that were reviewed by ADB’s management before 20 January 2010.

The objectives of ADB’s safeguards are to:  avoid adverse impacts of projects on the environment and affected people, where possible;  minimize, mitigate, and/or compensate for adverse project impacts on the environment and affected people when avoidance is not possible; and  help borrowers/clients to strengthen their safeguard systems and develop the capacity to manage environmental and social risks.

ADB’s SPS sets out the policy objectives, scope and triggers, and principles for three key safeguard areas:  environmental safeguards,  involuntary resettlement safeguards, and  Indigenous Peoples safeguards.

To help borrowers/clients and their projects achieve the desired outcomes, ADB adopts a set of specific safeguard requirements that borrowers/clients are required to meet in addressing environmental and social impacts and risks. These safeguard requirements are as follows:  Safeguard Requirements 1: Environment (Appendix 1 of SPS),  Safeguard Requirements 2: Involuntary Resettlement (Appendix 2 of SPS),  Safeguard Requirements 3: Indigenous Peoples (Appendix 3 of SPS), and  Safeguard Requirements 4: Special Requirements for Different Finance Modalities (Appendix 4 of SPS).

In addition, ADB does not finance activities on the prohibited investment activities list (Appendix 5).

Also ADB does not finance projects that do not comply with its safeguard policy statement, nor does it finance projects that do not comply with the host country’s social and environmental laws and regulations, including those laws implementing host country obligations under international law.

3.10.2 ADB Social Protection Strategy (2001)

Social protection strategy is primarily targeted at reducing poverty through key interventions in specific areas, the details of which have been mentioned below:

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 labor market policies and programs designed to generate employment, improve working conditions and promote the efficient operations;  social insurance programs to cushion the risks associated with unemployment, ill health, disability, work-related injury and old age;  social assistance and welfare service programs for the vulnerable groups with inadequate means of support, including single mothers, the homeless, or physically or mentally challenged people;  micro and area-based schemes to address vulnerability at the community level, including microinsurance, agricultural insurance, social funds and programs to manage natural disasters; and  child protection to ensure the healthy and productive development of children.

The work on these indicators has already started and is a core component of all the projects it supports in various countries.

3.10.3 Revised ADB's Public Communications Policy (2011)

The revised ADB Public Communications Policy will take effect from 2nd April 2012 and describes the approaches ADB will adopt to make its external relations more proactive and to improve access to information about ADB operations. The policy describes information outreach, information sharing, and feedback from stakeholders; the key audiences ADB is aiming to reach; translation; and the roles of those responsible for implementing the Policy. In the context to the project, it describes requirements on project information that needs to be disclosed and what can be justifiably redacted.

The ADB communication policy, 2011 has the following top priorities:

 strengthening of in-country communications to give the public more information about projects and other ADB activities that could affect their lives;  translation of summary project information into relevant national languages;  creation of an independent appeals panel with three international experts to review information requests denied by ADB;  sharing and exchange of development knowledge and lessons learned, so as to provide fresh and innovative perspectives on development issues;  greater two-way flow of information between ADB and its stakeholders, including project affected people, in order to promote participatory development; and  transparency and accountability of ADB operations.

ADB envisages the implementation of the communications policy in a manner which ensures that the priorities mentioned above are taken care of.

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3.10.4 Operation Manual (OM) – as published in March, 2010 on EIA Requirements

This Operations Manual (OM) section outlines the procedural requirements through which the Asian Development Bank (ADB) ensures the social and environmental sustainability of the projects it supports. The Operations Manual is applicable to the ADB Safeguards Policy as a whole. The classification of the projects tentatively happens at the project identification stage, when it is classified during the initial screening of anticipated impacts. However, classification is an ongoing process, and the classification can be changed at any time with the concurrence of the CCO as more detailed information becomes available and project processing proceeds.

Environment

A project’s environment category is determined by the category of its most environmentally sensitive component, including direct, indirect, induced, and cumulative impacts. Each proposed project is scrutinized as to its type, location, scale, sensitivity and the magnitude of its potential environmental impacts. The level of detail and comprehensiveness of the EIA or IEE are commensurate with the significance of the potential impacts and risks. A proposed project is assigned to one of the following categories depending on the significance of the potential environmental impacts and risks:  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), including an environmental management plan (EMP), is required.  Category B. A proposed project is classified as category B if its potential adverse environmental impacts are less adverse than those of category A projects. These impacts are site-specific, few if any 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), including an EMP, is required.  Category C. A proposed project is classified as category C if it is likely to have minimal or no adverse environmental impacts. An EIA or IEE is not required, although environmental implications need to be reviewed.  Category FI. A proposed project is classified as category FI if it involves the investment of ADB funds to, or through, a financial intermediary (paras. 53–58).

Involuntary Resettlement

A project’s involuntary resettlement category is determined by the category of its most sensitive component in terms of involuntary resettlement impacts. The involuntary resettlement impacts of an ADB-supported project are considered significant if 200 or more persons will experience major impacts, which are defined as (i) being physically displaced from housing, or (ii) losing 10% or more of their productive assets (income generating). The level of detail

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and comprehensiveness of the resettlement plan are commensurate with the significance of the potential impacts and risks. A proposed project is assigned to one of the following categories depending on the significance of the probable involuntary resettlement impacts:  Category A: A proposed project is classified as category A if it is likely to have significant involuntary resettlement impacts. A resettlement plan, including assessment of social impacts, is required.  Category B: A proposed project is classified as category B if it includes involuntary resettlement impacts that are not deemed significant. A resettlement plan, including assessment of social impacts, is required.  Category C: A proposed project is classified as category C if it has no involuntary resettlement impacts. No further action is required.  Category FI: A proposed project is classified as category FI if it involves the investment of ADB funds to, or through, a financial intermediary (paras. 53–58).

The project is also classified on the basis of the impact on the indigenous people, which however is not applicable for this project, and hence not being discussed.

Further during the Project Design and Preparation, the need for Environmental impact assessment (EIA) is assessed and reviewed. The project category can change after the EIA study too.

ADB has categorised the project as Category “B” project for Environment and as Category “A” for involuntary resettlement.

ADB’s Disclosure Policy

ADB’s safeguard policy imply the need for prior and informed consultation with affected persons and communities in the context of safeguard planning and for continued consultation during project implementation to identify and help address safeguard issues that may arise. ADB requires the borrower/client to carry out meaningful consultation with affected persons and communities in the implementation of safeguard policies. For ADB “meaningful consultation” for policy application refers to a process that :  begins early in the project preparation stage and  is carried out on an ongoing basis throughout the project cycle;  provides timely disclosure of relevant and adequate information that is understandable and readily accessible to affected people;  is undertaken in an atmosphere free of intimidation or coercion;  is gender inclusive and responsive, and tailored to the needs of disadvantaged and vulnerable groups; and  enables the incorporation of all relevant views of affected people and other stakeholders into decision making, such as project design, mitigation measures, the sharing of development benefits and opportunities, and implementation issues.

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In line with ADB’s Public Communications Policy, ADB is committed to working with the borrower/client to ensure that relevant information (whether positive or negative) about social and environmental safeguard issues is made available in a timely manner, in an accessible place, and in a form and language(s) understandable to affected people and to other stakeholders, including the general public, so they can provide meaningful inputs into project design and implementation. ADB will post the following safeguard documents on its website:  for environment category A projects, draft environmental impact assessment reports at least 120 days before Board consideration;  draft environmental assessment and review framework, draft resettlement frameworks and/or plans, and draft Indigenous Peoples planning frameworks and/or plans before project appraisal;  final or updated environmental impact assessments and/or initial environmental examinations, resettlement plans, and Indigenous Peoples plans upon receipt;  environmental, involuntary resettlement and indigenous Peoples monitoring reports submitted by borrowers/clients during project implementation upon receipt.

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4 ENVIRONMENTAL AND SOCIAL BASELINE

This section describes the environmental and socio economic baseline status of Project Nirvana and the study area (defined as an area of 10 km radius from the Project Site).

Establishing environmental and social baseline is an integral part of ESIA process as it helps in understanding the prevailing environmental and socio economic status of the study area and prediction of the future environmental and social characteristics of the area based on the construction and operation of any new project. It also helps in environmental and social management, planning and strategising to minimise any potential adverse impacts.

4.1 ENVIRONMENTAL BASELINE

4.1.1 Site Setting and its Surroundings

The Project Site is located at Survey No. 44/1, Erandwane, Haveli Taluka, Pune District, in the state of Maharashtra. Site coordinates noted approximately at middle of the Project Site are 18° 30’ 41.82”N and 73° 49’ 21.34”E.

It is located at heart of Pune City between densely developed regions such as Kothrud (on the west), Deccan Gymkana (on the north east), Sadashiv Peth and SNDT College (on the east), Erandwane (on the south east) and (on the south). On its north and north-west, a large institutional campus belonging to Automotive Research Association of India (ARAI) is located along with hill top–hill slope regions which are prohibited for development and declared as No-Development zones (NDZ) as per local development rules. It is accessible by the busy 26 m wide Karve (1)road in South.

It is situated at a prime commercial and residential area of central Pune and The site is primarily surrounded by commercial and residential structures

The site setting is such that it is surrounded by dense settlements and developed regions or regions falling into NDZ.

The nearest railway station is Pune railway station located at around 7 km aerial distance and the nearest interstate corridor that is the Mumbai-Pune expressway is located at an aerial distance of 4kms from the Site.

Pashan lake is situated at a distance of approximately 4.6 km from the middle of the Project Site in WNW direction. Mutha River is flowing at a distance of 1.75 km in east direction and in SE direction Mutha River is at a distance of 2.8

(1) Karve Road is a prominent road which connects the Deccan area near the Garware Flyover - Lakdi Bridge junction to the densely populated Kothrud and Karve Nagar area in Pune, Maharashtra ERM ESIA: KUMAR SINEW DEVELOPERS PROJECT # I8390/ 0138632 MARCH 2012 67

km. The slope indicates that the storm water might eventually join river Mutha in SE direction. The confluence of river Mula and river Mutha is at a distance of approximately 5 kms in ENE direction from the middle of the project Site.

4.1.2 Methodology

The environmental baseline is based on primary data collected by M/s Mahabal Enviro Engineers Pvt. Ltd. as a part of Environmental Impact Assessment (EIA) study. The data was collected for one season (November 2008 to February 2009). Available secondary data has been assessed covering an area of 10 km radius (referred to as the study area) from the Project Site.

4.1.3 Analysis of Primary Baseline Data

As per the available information M/s Mahabal Enviro Engineers Pvt. Ltd. had engaged a laboratory (Name of the laboratory engaged is not disclosed in the report) for collection of baseline information on micrometeorology, ambient air quality, water quality (groundwater quality), soil quality, ambient noise quality and traffic volume counts. Ecological survey was not undertaken in the study area (10 km radius).

The details of aspects for which primary baseline data was collected are detailed out in Table 4.1. The inputs are based on the EIA Report submitted by M/s Mahabal Enviro Engineers Pvt. Ltd

Table 4.1 Primary Baseline Data

S. N Environmental Attribute No. of Frequency Remarks Locations 1. Meteorology 1 Hourly for 3 Site specific Wind Speed months Meteorological data Wind Direction (November was collected by Temperature 2008 to installing continuous Humidity January 2009) meteorological station. Rainfall 2. Ambient Air Quality 5 24 hourly, Ambient Air Quality Suspended Particulate Matter twice a week (AAQ) monitoring was Respirable Suspended for 12 weeks carried out at Site and Particulate Matter for 5 locations in the Oxides of Nitrogen (NOx) study area.

Sulphur dioxide (SO2) Carbon monoxide (CO) 3. Groundwater Quality: 1 Once during 1 Ground water sample Physical parameters: pH, the study was collected from the temperature, colour, odour, period Project Site turbidity. Chemical parameters: Alkalinity, total dissolved solids, total suspended solids, oil and grease, chlorides, sulphates, nitrate, fluorides, Total Ammoniacal nitrogen, Free Ammonia, Boron, iron, copper, zinc, lead,

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S. N Environmental Attribute No. of Frequency Remarks Locations cadmium, Total chromium, Hexavalent Chromium, Phenolic compounds. Biological parameters: Total coliform and faecal coliform. 4. Soil Quality: 1 Once during Soil sample was Parameters: Particle size the study collected from Project distribution, pH, moisture, period Site. organic carbon, available nitrogen as N, available

phosphorous as P2O5, available sulphur, Copper, Zinc.

5. Ambient Noise Quality 5 Once during Noise levels were the study monitored on hourly period basis for 24 hours. 6. Traffic Count 3 Once during Traffic movement was the study monitored on hourly period basis for 24 hours (to and from directions). Source: EIA Report prepared by M/s Mahabal Enviro Engineers Pvt. Ltd., 2009

4.1.4 Secondary Baseline Data Collection

Secondary baseline data collection involved identification and collection of data from existing published materials and documents. Secondary data was collected for following attributes:

Table 4.2 Secondary Baseline Data

S. No Environmental Attribute Source of Data Collection 1. Long term meteorological data India Meteorological Department 2. Geology, geomorphology and Geological Survey of India, Central Ground Water hydrogeology Board, District Environmental Atlas of Pune, Maharashtra prepared by Maharashtra Pollution Control Board (M PCB), 2006. District Resource Map of Pune District 3. Land use National Atlas and Thematic Mapping Organization

4. Forest area Pune District Gazetteer 5. Natural Hazards Building Materials and Technology Promotion Council of India Meteorological Department Vulnerability Atlas District Environmental Atlas of Pune, Maharashtra prepared by Maharashtra Pollution Control Board (M PCB), 2006 6. Socio-economic Socio Economic Survey report of NGO Vatsalya

4.2 TOPOGRAPHY AND DRAINAGE

The Project Site is located at an elevation of approximately 590 m above mean sea level (amsl).

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The northern portion of the Site is at higher elevation and the slope of the Site is from NW and NNW towards S and SSE. The difference in elevation at the Site is 30 m.

Following the slope, natural drainage of the region is from N and NNW towards South and SSE and SE.

On the north and north-west, a large institutional campus belonging to Automotive Research Association of India (ARAI) is located along with hill top – hill slope regions which are prohibited for development and declared as No-Development zones (NDZ) as per local development rules.

Site coordinates noted approximately at middle of the Project Site are 18° 30’ 41.82”N and 73° 49’ 21.34”E.

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Figure 4.1 Satellite Imagery showing Site and its Immediate Surroundings

N

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4.3 GEOLOGY AND HYDROGEOLOGY

4.3.1 Pune District Geology

Pune district area is covered by thick pile of Basaltic lava flow of Deccan Trap of Uppercretacious to "Palaeohoe" age. The basaltic flows are of two type viz. compound "pahoehoe" and "aa" flows. The pahoehoe flows contain several units which vary in thickness from less than a metre to several metres. The compound pahoehoe flows generally underlie or overlie a thick succession of aa flows, thereby constituting a regional marker for correlation. The thick lava succession has been grouped into seven formations. The oldest Lower Ratangarh Formation, consisting only of compound pahoehoe flows is restricted to the north-western parts of Ghod valley and in the central part of Bhima valley. A megacryst flow, M3 marks the top of his Formation. Overlying this formation is the Indrayani Formation comprising a thick succession of "aa" flows. This is succeeded by a sequence of "pahoehoe" flows grouped under Karla Formation. These Formations are confined to the north western, central and eastern parts. Further east, the thickness decreases and the flows pinch out. Overlying this is a sequence of sampled and "aa" flows forming the Diveghat Formation which cover the southern part and a part of eastern margin. These flows show characteristics of both "aa" and "pahoehoe" types. The overlying Purandargarh and Mahabaleshwar Formations comprise flows of essentially "aa" types and their occurrence is mainly restricted to the south-western, north-western and central parts. These two Formations are separated by a megacryst basalt floe M4 which forms the top of the Pundagarh Formation. The basalts are essentially tholeiites without any marked variation trending NNE-SSW. The dykes are cut by joints parallel to the walls and at right angles to the walls besides horizontal joints. The dyke rocks are fine to medium grained and shoe spares phenocrysts. (Source: District Resource Map, Pune District, Maharashtra).

Geology and Geomorphology of the Project Site is depicted in Figure 4.2 and Figure 4.3

4.3.2 Site Geology

Study area lies on high plateau. On the northern and north western side, there are low hills.

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Figure 4.2 Map showing Geology

Project Site

Source: Developed from Geological Map of India, published by Geological Survey of India

Figure 4.3 Geomorphology of the Study Area

Project Site

Source: Developed from Geological and Mineral Map of Pune district, published by Geological Survey of India

4.3.3 Hydrogeology

Hydrogeology of the city (located on the Deccan Plateau) indicates that basaltic hard rock is the primary geological formation over the entire district. Depending upon the local weathering, fracturing and jointing in the basaltic rock formations, the potential aquifers could be in the shallow range (depth of

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20- 22 m bgl) to deep confined aquifers (occurring below the depth of 40 m bgl).

4.4 LAND USE

4.4.1 Pune District Land Use

The landuse distribution of the Pune District according to Maharashtra Remote Sensing Applications Centre (MRSAC, Nagpur) is shown below in Table 4.3 and its percentage in below Figure 4.5

Table 4.3 Land Use Distribution of Pune District

S. No. Landuse Pattern Total Area (in sq.km.) 1. Built-Up Land 401.63 2. Closed Forest 1054.69 3. Degraded forest 2095.77 4. Open Forest 497.53 5. Double crop 1422.57 6. Agricultural Plantation 264.59 7. Single Crop 3092.20 8. Scrub/ Waste land 5995.39 9. Water bodies/ Tanks/ River 815.63 Total 15640 Source: Landuse Map, MRSAC, Nagpur. Based on satellite imagery (2001-2002)

Satellite Imagery of the study area (10 km radius) is provided in Figure 4.4 and graphical representation of the land use is presented in Figure 4.5.

Total area of 1597.94 sq. km. falls under reserved forests in Pune district, out of which 80 sq. km. (5%) of reserved forest falls under Haveli Taluka (Source: District Environment Atlas).

4.4.2 Project Specific Land Use

The Site is located amidst densely developed regions in directions other than north and northwest direction. It is located centrally in Pune City between densely developed regions such as Kothrud (on the west), Deccan Gymkana (on the north east), Sadashiv Peth (on the east), Erandwane (on the south east) and Dattawadi (on the south). On its north and north-west, a large institutional campus belonging to Automotive Research Association of India (ARAI) is located along with hill top – hill slope regions which are prohibited for development and declared as No-Development zones (NDZ) as per local development rules. The site setting indicates that due to project development through its life cycle both at regional level and in the immediate vicinity is not possible due to densely developed surrounding regions or regions falling into NDZ. The entire site is spread over a plot area of approximately 320,826 m2 and the slums are currently occupying about 1/3rd of this area (i.e. roughly 120,000 m2).

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Figure 4.4 Satellite Imagery of Study Area

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Figure 4.5 Land use of Pune District

Source: Pune District Environment Atlas, 2006.Land Use Map- MSRAC, Nagpur (based on satellite imagery 2001-02)

4.5 NATURAL HAZARDS

4.5.1 Earthquake Hazard

Based on the tectonic features and records of earthquake, a Seismic Zoning map has been developed for the country by Bureau of Indian Standard (BIS). According to Seismic Zone Map of India, Project Site falls in Zone III as presented in Figure 4.6. Zone III is defined as a zone having medium damage risk and vulnerable to earthquakes of intensity MSK VII or less (as defined by Building Materials and Technology Promotion Council). Thus, the Project accordingly is required to have provisions of earthquake resistant construction of Plant structure. Suitable seismic coefficients in horizontal and vertical directions respectively, have to be adopted while designing the structures. Seismic Zoning Map of India is presented in Figure 4.6.

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Figure 4.6 Seismic Zoning Map of India as per IS 1893(Part -1), 2002, IM4

Project Site

Source: India Meteorological Department

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4.5.2 Winds and Cyclone

The Project site falls in Moderate Damage Risk Zone B (Vb = 39 m/s) according to Wind and Cyclone Hazard Map of India as presented in Figure 4.7.

Figure 4.7 Wind and Cyclone Hazard Map

Project Site

Source: Building Materials and Technology Promotion Council, Vulnerability Atlas

4.5.3 Flood Risk

As per the information in Pune District Environmental Atlas, 2006, most of the Taluka in the Pune district are flood prone. River Indrayani, and river Pauna are the rivers which are likely to cause flooding in Haveli Taluka and river Mutha in Taluka Mulshi. Loni Kalbhor, Pimpari, Chikali, Ashtapur and Sangaur Haveli are the villages in Haveli Taluka which are affected by flood (1 in 100 years).

As per the Natural Hazard Map of Pune District the area where Site is located has low flood frequency, with the last dam overflow having occurred more than 40 years ago.

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4.6 METEOROLOGY

The study area has Tropical Wet and Dry climate. The year may broadly be divided into four seasons.

Winter season : December- February Summer season : March – mid June Monsoon season : Mid June – September Post Monsoon : October- November

The area receives major parts of its rainfall during monsoon season due to south west monsoon. Owing to the geographical conditions in the district the rainfall is unevenly distributed. The western part to the West coast is a hilly area having forest cover and receives more rainfall than the eastern parts. (Source: District Environmental Atlas)

In Haveli sub division, the climate is dry and healthy but varies much in different part of the subdivision, the rainfall increases so rapidly towards the west that in the border villages, rice and nagli take the place of jowar and bajra. (Source: Poona District Gazetteer, 1885).

Humidity is considerably low during the summer months and diurnal variations in humidity during this period are high and day time temperatures are high.

4.6.1 Meteorology at Site

A micro-meteorological station was installed at the Project Site for continuous recording of data at one-hour interval for 24 -hour period or a period of three months (12 weeks). This station measured hourly data on wind speed, wind direction, temperature, relative humidity, and rainfall.

From the EIA report, the detailed data on the microclimate of the site was collected for a period of three months (November 2008 to January 2009), representing the winter season. Parameters monitored at hourly intervals were Temperature; humidity; wind speed; wind direction and rainfall were the parameters monitored at hourly intervals. The prime requirement of this data will be for dispersion modelling to predict incremental increase in ground level concentrations in the study area. The summary of meteorological data is presented in Table 4.4.

Table 4.4 Meteorological Monitoring Data Summary during Study Period of three months

Monitored Parameter Unit Values Average Wind Speed m/s 1.49 m/s Predominant wind direction From WNW to ESE with Calm winds 65.9% Rainfall mm Nil 0C Minimum is 13.5oC; Temperature Maximum is 31oC

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Minimum – 42.6% Relative Humidity Minimum – 78.8% Source: Source: EIA Report prepared by M/s Mahabal Enviro Engineers Pvt. Ltd., 2009.. Weather monitoring station at Project Site, November 2008 – January 2009

During the study period of three months (November 2008- January 2009), the temperature varied from minimum of 13.5°C to a maximum of 31ºC. Relative humidity during the monitoring period varied from a minimum of 42.6% to a maximum of 78.8%. During monitoring period average wind speed recorded was 1.7 m/s or 1.49 m/s, two different values have been mentioned at two places. No rainfall was recorded during the monitoring period. However, hourly average meteorological data has not been presented in EIA report.

In consonance with IMD data predominant wind direction during the monitoring period was from west and northwest. Approximately 65.9% of the winds were recorded to be calm thereby reducing the impact on the Site. 24 hour wind rose diagram is presented in Figures 4.8 below.

Figure 4.8 Site Specific 24 Hours Windrose

Source: EIA Report prepared by M/s Mahabal Enviro Engineers Pvt. Ltd., 2009. It was developed based on site specific meteorological data collected during November 2008 – February 2009

Major sources of air pollution near the site vicinity include the following:

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 Heavy traffic movement through Paud road and Karve road opposite to Project site on its southern side; and  Dense residential and commercial zones abutting the project site on all three sides barring the northern side.

Besides, the future development proposal of a DP road and HCMTR passing through the Project site bifurcating it into eastern and western halves will add to the ambient air quality load.

4.6.2 Regional Meteorology

The brief meteorology (from 1951-1980) based on data recorded at the nearest India Meteorological Department (IMD) observatory station at Pune (18032’N and 73051’E) is given in Table 4.5.

Table 4.5 Climatological Data, Pune

Months Temperature (°C) % Relative Rainfall (mm) Mean Humidity Wind Speed kmph Highest Max Min Low- 830 1730 Monthly Max (24 Mean Mean Mean est hrs hrs Total hourly) Jan 32.6 30.3 11.4 7.1 74 31 0.0 22.3 2.5 Feb 35.9 32.8 12.7 8.2 61 23 0.5 16.3 3.4 Mar 38.9 36.0 16.5 11.7 50 21 5.3 35.1 4.4 Apr 41.1 38.1 20.7 16.3 48 26 16.6 51.1 5.7 May 40.8 37.2 22.5 18.9 58 38 40.6 82.5 8.6 Jun 36.9 32.1 22.9 20.8 75 62 116.1 131.9 10.2 Jul 31.8 28.3 22.0 20.7 84 76 187.2 130.4 9.7 Aug 30.2 27.5 21.4 19.8 86 78 122.3 108.7 8.7 Sep 32.8 29.3 20.7 18.2 83 71 120.0 132.3 5.9 Oct 34.1 31.8 18.8 13.8 76 51 77.9 149.1 3.4 Nov 32.8 30.5 14.7 10.0 72 42 30.2 96.8 2.6 Dec 31.9 29.6 12.0 8.0 74 37 4.8 42.4 2.3 Annual 32.0 18.0 70 18.7 - 5.6 Average Total - - - - 721.7 -

Source: Climatological data 1951-80, India Meteorological Department

Predominant wind direction based on long term meteorological data is presented in Table 4.6.

Table 4.6 Wind Pattern

Month Morning Time Predominant Winds Evening Time Predominant Winds (from) (from) I II III I II III January CALM W NW/SW/SE/E CALM W E February CALM W NW/SW/SE/E NW N W March CALM W E W NW CALM April CALM W NW W NW CALM May W CALM NW W NW SW June W SW CALM W CALM SW July W SW CALM W SW CALM

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August W SW CALM W CALM SW September CALM W SW W NW SW October CALM W E CALM W E November CALM E NE CALM E NE December CALM E N/NE/SE/S CALM E W Source: Climatological data 1951-80, India Meteorological Department.

IMD Data Observations

Rainfall

As per the India Meteorological Department data (1951-1980), Pune receives total annual rainfall of 721.7 mm. The maximum monthly rainfall is in July which is 187.2 mm and minimum monthly rainfall recorded is 0.0 mm in January. Maximum 24 hourly rainfall recorded is 130.4mm in June. The area receives 75% of its rainfall during the months of June, July, August and September.

Temperature

The minimum mean temperature varies from 11.4º C to 22.90C and the mean maximum fluctuates from 27.5ºC to 38.1ºC. The highest temperature was recorded at 41.100C in the month of April and lowest minimum temperature was recorded at 7.10C in the month of January.

Relative Humidity

During morning hours at 0830 hrs, relative humidity is recorded to be highest at 86% in the month of August and lowest at 48% in the month of June. During evening hours at 1730 hrs, relative humidity is recorded to be highest at 78% in the month of March and lowest at 21% in the month of March.

Wind Speed

Mean wind speed in the region varies from 2.3 km/hr to 10.2 km/hr. Highest wind speed of 10.2 km/hr. is observed to be during the month of June and lowest wind speed of 2.3 km/hr is observed in the month of December.

Wind Pattern

During morning hours, predominant wind direction is calm during the months of September to April while during monsoon season (May to August) predominant wind direction is west.

During evening hours, predominant wind directions is Calm during the months of October to January; while from March to September it is predominantly towards the West.

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Similar wind pattern was observed for year 1981-1994, as is evident from the Figure 4.9 and Figure 4.10.

Figure 4.9 Wind Rose for 0830 hrs (1981-1994)

Source: Dy. Director- General. Regional Metrological Department, Pune

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Figure 4.10 Wind Rose for 1730 hrs

Source: Dy. Director- General. Regional Metrological Department, Pune (2001)

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4.7 AIR QUALITY

As per the data presented in EIA Report the ambient air quality of the study area was monitored at five locations during the study period. The monitoring parameters included Suspended Particulate Matter (SPM), Respiratory

Particulate Matter or (size less than 10 micron (PM10), Sulphur Dioxide (SO2),

Oxides of Nitrogen (NOx) and Carbon Monoxide (CO). SPM, RSPM, NOx, SO2 were monitored on 24-hourly basis while CO was monitored on eight hourly basis monitored twice a week for a period of 12 weeks during November 2008 to January 2009.

Selection of sampling locations

The baseline status of the ambient air quality was established through ambient air quality monitoring network and is based on the following considerations: Meteorological conditions of the area based on IMD data; Topography of the study area; Location of sensitive receptors i.e. major settlements;

Primary source of air pollution in the study area is vehicular traffic.

The monitoring locations within the study area are presented in Table 4.8 and represented in the Figure 4.11. Figure 4.11 also illustrates noise, groundwater and soil monitoring locations.

The sampling and analysis of ambient air quality parameters was carried out as per the procedures detailed in relevant Parts of IS-5182 (Indian Standards for Ambient Air Quality Parameters). The applied testing procedures are given in brief in Table 4.7.

Table 4.7 Methodology for Analysis of Ambient Air Quality

S.N. Parameter Instrument Equipment/ Method & Protocol Followed Instruments for Analysis 1. SPM High Volume Balance, Oven Gravimetric Method, IS 5182 (Part IV); Sampler and Dessicators 2. RSPM/ Respirable Dust Balance Gravimetric Method, IS:5182 (Part-IV);

PM10 Sampler with Cyclone Separator

3. SO2 High Volume Colorimeter IS:5182 (Part-V), Colorimetric; Sampler

4. NOx High Volume Colorimeter IS:5182 (Part-V), Colorimetric; Sampler Source: EIA Report prepared by M/s Mahabal Enviro Engineers Pvt. Ltd., 2009

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Table 4.8 Details of Ambient Air Monitoring Stations

S. No. Sampling Code Distance and Justification for Selection of Location and Location Direction from its setting centre of Project Site 1 Project AQ-1 0 km As per IMD data for 30 years (1951- Site 1980), the stations AAQ data captures the baseline for the Project Site. 2 AQ-2 3.2 km, NE As per IMD data for 30 years (1951- Nagar 1980), this station is upwind of the Project Site in winter season and downwind of the Project Site in monsoon season (June-August).

Further, this station’s AAQ data captures the baseline for residential location located in the study area. 3 AQ-3 5.6 km, NW As per IMD data for 30 years (1951- 1980), this station is upwind of the Project Site in all seasons.

Further, this station’s AAQ data captures the baseline for residential location located in the study area. 4 AQ-4 5.0 km, WNW As per IMD data for 30 years (1951- 1980), this station is upwind of the Project Site in all seasons.

Further, this station’s AAQ data captures the baseline for residential location located in the study area. 5 Khondwa AQ-5 7.7 km, SE As per IMD data for 30 years (1951- 1980), this station is upwind of the Project Site in all months except in the months of March, April and June.

Further, this station’s AAQ data captures the baseline for residential area which is a significant habitation within the study area. Source: EIA Report prepared by M/s Mahabal Enviro Engineers Pvt. Ltd., 2009

Map showing location of ambient air quality monitoring stations is presented in Figure 4.11.

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Figure 4.11 Sampling Locations Map for Air, Noise, Soil and Ground Water Monitoring Stations in Study Area

N33 Pashan N2 AQ3 AQ2 N4 AQ4 AQ S1 N1 GW

N5 LEGEN AQ5 Groundwater Monitoring Location Soil Sampling

Ambient Air Quality Monitoring Location Ambient Noise Monitoring

Source: Google image, 2010. Accessed on August 30th 2011 Note: One sample for Air, water, noise and soil monitoring location was collected from Site itself. Additionally, as per the data available in the EIA report for groundwater and soil only one sample was collected in the study area (i.e. Project Site).

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AAQ results as monitored at various locations are presented in Table 4.9.

Table 4.9 Ambient Air Quality in the Study Area

Parameters Unit Observed AQ1 AQ2 AQ3 AQ4 AQ5 Project Shivaji Pashan Bavdhan Khondwa Site Nagar SPM* μg/m3 NAAQS 200 200 200 200 200 24 Hourly Maximum 82.6 96.5 79.8 98.8 78.8 Minimum 56.2 68.7 67.2 80.4 69.8 Average 70.7 82.5 73.8 89.7 74.2 98 percentile 82.5 94.9 79.1 98.1 78.7 RSPM μg/m3 NAAQS 100 100 100 100 100 24 Hourly Maximum 30.2 21.4 22.8 38.9 27.5 Minimum 14.7 17.6 16.3 21.8 19.8 Average 22.0 22.7 19.2 31.3 22.4 98 percentile 30.0 27.6 22.5 38.8 27.0

SO2 μg/m3 NAAQS 80 80 80 80 80 24 Hourly Maximum 3.6 4.00 10.5 16.8 10.4 Minimum 0.0 1.90 1.4 2.6 3.2 Average 2.1 3.20 4.7 5.8 5.1 98 percentile 3.6 4.00 9.8 14.0 10.1

NOx: μg/m3 NAAQS 80 80 80 80 80 24 Hourly Maximum 8.1 8.2 14.7 21.5 14.5 Minimum 0.0 3.5 4.3 5.0 5.8 Average 4.7 6.0 8.7 11.5 9.7 98 percentile 7.8 7.8 14.6 19.6 13.6 CO: mg/m3 NAAQS 2.0 2.0 2.0 2.0 2.0 8 hourly Maximum 1.00 0.05 0.26 0.26 0.24 Minimum 0.20 0.12 0.10 0.09 0.09 Average 0.60 0.04 0.20 0.20 0.18 98 percentile 0.94 0.20 0.30 0.30 0.20 NAAQS = Revised National Ambient Air Quality Standard have been adopted for RSPM/PM10, SOx, NOx, CO as notified on 16 November 2009;. *However, since no standards exist for SPM now, the standard prevailing prior to 16 November was adopted. Landuse of AQ 1 to AQ 5 is residential. Source: EIA Report prepared by M/s Mahabal Enviro Engineers Pvt. Ltd., 2009

Suspended Particulate Matter (SPM)

3 The SPM concentration observed during the period ranged from 96.5 μg/m to 56.2 μg/m3. AQ-2 (Shivaji Nagar) recorded the maximum concentration of 96.5 μg/m3 while AQ-1 (Site) recorded the minimum concentration of 56.2 μg/m3. Average concentration values ranged from 70.7 μg/m3 to 89.7 μg/m3 while 98 percentile values ranged from 78.7 μg/m3 to 94.9 μg/m3

The SPM values (98 percentile) were observed to be within the NAAQ’s limits

at all monitoring locations. Slightly high SPM values were observed well within the prescribed limits for all areas. The graphical representation of SPM concentration in the study area is shown in Figure 4.12.

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Figure 4.12 SPM Concentrations in Study Area

250.00

200.00

150.00

100.00

50.00 Concnetration (μg/m3) Concnetration 0.00 AQ1 AQ2 AQ3 AQ4 AQ5

Monitoring Locations (SPM) Max. Min. Ave. 98 percentile NAAQS Source: EIA Report prepared by M/s Mahabal Enviro Engineers Pvt. Ltd., 2009

Respirable Suspended Particulate Matter (RSPM)

The RSPM concentration observed during the period ranged from 14 .7μg/m3 to 38.9μg/m3. AQ-2 (Shivaji Nagar) recorded the maximum concentration of 38.9 μg/m3 while AQ-1 (Site) recorded the minimum concentration of 14.7 μg/m3. Average concentration values ranged from 19.2 μg/m3 to 31.3 μg/m3 while 98 percentile values ranged from 22.5 μg/m3 to 30 μg/m3

As per revised NAAQS the prescribed limit of RSPM/PM10 for 24 hours 3 monitoring is 100μg/m . The 98 percentile PM10 values were observed to be well within the revised NAAQS limit at all locations. The graphical

representation of RSPM concentration in the study area is shown in Figure 4.13.

Figure 4.13 RSPM or PM10 Concentrations in Study Area

120.00

100.00 80.00

60.00 40.00

20.00 Concentration ((μg/m3) Concentration 0.00 AQ1 AQ2 AQ3 AQ4 AQ5 Monitoring Locations (RSPM) Max. Min. Ave. 98 percentile NAAQs

Source: EIA Report prepared by M/s Mahabal Enviro Engineers Pvt. Ltd., 2009

Sulphur dioxide (SO2)

3 The SO2 concentration observed during the period ranged from 0.00 μg/m to 16.8 μg/m3. AQ-4 (Bavdhan) recorded the maximum concentration of 16.8 μg/m3 while AQ-1 (Site) recorded the minimum concentration of 0 μg/m3. Average concentration values ranged from 2.1 μg/m3 to 5.8 μg/m3 while 98 percentile values ranged from 3.6 μg/m3 to 14 μg/m3 ERM ESIA: KUMAR SINEW DEVELOPERS PROJECT # I8390/ 0138632 MARCH 2012 89

As per the revised NAAQS the prescribed limit of SO2 for 24 hours monitoring 3 is 80μg/m . The 98 percentile SO2 values were observed to be within the

NAAQS limit at all locations. The graphical representation of SO2 concentration in the study area is shown in Figure 4.14.

Figure 4.14 SO2 Concentrations in Study Area

90.00 80.00 70.00 60.00 50.00 40.00 30.00 20.00 Concentration (μg/m3) 10.00 0.00 AQ1 AQ2 AQ3 AQ4 AQ5

Monitoring Locations (SO2) Max. Min. Ave. 98 percentile NAAQS

Source: EIA Report prepared by M/s Mahabal Enviro Engineers Pvt. Ltd., 2009

Oxides of Nitrogen (NOx)

3 The NOx concentration observed during the period ranged from 0.0μg/m to 21.5μg/m3. AQ-1 (Site) recorded the maximum concentration of 25.1μg/m3 while AQ-1 (Site) recorded the minimum concentration of 21.5 μg/m3. Average concentration values ranged from 4.7 μg/m3 to 11.5μg/m3 while 98 percentile values ranged from 7.8 μg/m3 to 19.6μg/m3. As per revised 3 NAAQS the prescribed limit of NOx for 24 hours monitoring is 80μg/m . The 98 percentile NOx values were observed to be within the revised NAAQS limit at all locations. The graphical representation of NOx concentration in the study area is shown in Figure 4.15.

Figure 4.15 Oxides of Nitrogen Concentrations in Study Area

90.0 80.0 70.0 60.0 50.0 40.0 30.0 20.0

Concentration (μg/m3) 10.0 0.0 AQ1 AQ2 AQ3 AQ4 AQ5

Monitoring Locations (NOx)

Max. Min. Ave. 98 percentile NAAQS

Source: EIA Report prepared by M/s Mahabal Enviro Engineers Pvt. Ltd., 2009

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Carbon Monoxide (CO)

3 The CO concentration observed during the period ranged from 0.1 mg/m to 1.0 mg/m3. AQ-1 (Site) recorded the maximum concentration of 1.0 mg/m3 while AQ-3 (Pashan) recorded the minimum concentration of 0.1 mg/m3. Average concentration values ranged from 0.04 mg/m3 to 0.6 mg/m3 while 98 percentile values ranged from 0.2 mg/m3 to 0.94 mg/m3

As per revised NAAQS the prescribed limit of CO for 8 hours monitoring is 2 mg/m3. The 98 percentile CO values were observed to be within the revised NAAQS limit at all locations. The graphical representation of CO concentration in the study area is shown in Figure 4.16.

Figure 4.16 Carbon Monoxide Concentrations in the Study Area

2.50 ) 3 2.00

1.50

1.00

0.50 Concentration (mg/m

0.00 AQ1 AQ2 AQ3 AQ4 AQ5

Monitoring Locations (CO) Max. Min. Ave. 98 percentile NAAQS

Source: EIA Report prepared by M/s Mahabal Enviro Engineers Pvt. Ltd., 2009

4.8 WATER QUALITY

Water environment consists of water resources such as river, ponds, streams, etc. The water quality forms the essential component of EIA that helps to identify and evaluate critical impacts / issues with a view to suggest appropriate mitigation measures for implementation.

4.8.1 Groundwater Quantity

Table 4.10 Ground Water table details in Pune District

Zone Area Location of the District GW Potential sq. km. Less than 5 m below High 3638.66 Scattered in all taluka of the ground level district. Covers major area of Northern, Central, Eastern and South eastern side of the district. It shows major portion in Taluka , Pune city, Haveli, , and Baramati. Small portion scattered in Taluka Purandhar, Shirur, and . Small narrow steps are scattered in Taluka Maval, Khed, Mulshi and

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Zone Area Location of the District and small-patched portion in Velhe. 5-15m below Medium 2964.33 Small patches are scattered in all ground level Taluka of the district. Shows major portion of Taluka Shirur, Indapur. More than 15m Low 8381.11 Major portion of the district is below ground level covered by this area. This portion is scattered in all taluka, shows the Major portion of Western seven taluka, Northeastern and Southeastern area of the district Source: District Environment Atlas, 2006

Figure 4.17 Groundwater Potential (%) in Pune District

High Ground water Potential 24%

Low Ground Water Potential Medium Ground 56% water Potential 20%

Source: Pune District Environmental Atlas

4.8.2 Surface & Groundwater Quality Monitoring

The water quality assessment was done to understand the baseline ground water quality of the study area. The groundwater sample was collected from the Project Site, geographically located at 18° 30' 39.5" N and 73° 49' 19.8”E. Details of water sampling location are presented in Table 4.11 and the location from where the sample was collected is described in Figure 4.11.

As per the EIA Report, 2009, water quality of one ground water sample has been sampled. The project will use Pune Municipal Corporation (PMC) supply during construction phase and operational phase. PMC is the main source of drinking water (sensitive use) in the study area.

Table 4.11 Details of Ground Water Sampling Locations

S.N. Sampling Location Distance and Justification for Location of Sample Direction from Project Site

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S.N. Sampling Location Distance and Justification for Location of Sample Direction from Project Site 1 Project site At project site Representing groundwater quality at the N 18° 30' 39.5" Project Site. E 73° 49' 19.8”

Source: EIA Report prepared by M/s Mahabal Enviro Engineers Pvt. Ltd., 2009

4.8.3 Groundwater Quality Results

All the parameters were found to be well within the desirable limits. Water quality sampling results are given in Table 4.12.

Table 4.12 Ground Water Quality in Study Area

S.N. Parameters Project Site IS: 10500 IS: 10500 Limits, Unit Limits, Desirable Permissible 1 Colour Visual Colorless 5 25 2 pH 7.72 6.5 - 8.5 No Relaxation 3 Odour - Odorless 4 Turbidity NTU Nil 5 10 5 Total Suspended Solids mg/l Nil 6 Total Dissolved Solids mg/l 90 500 2000 7 Oil & Grease mg/l Nil -- -- 8 Phenol mg/l Nil 0.001 0.002 9 Total Alkalinity mg/l 60 200 600 10 Total Hardness mg/l Nil 300 600 11 Chlorides mg/l 28.36 250 1000 12 Sulphates mg/l 2 200 400 13 Nitrate mg/l Nil 45 100 14 Fluoride mg/l Nil 1 1.5 15 Sodium (as Na) mg/l Nil - - 16 Potassium (as K) mg/l Nil - - 17 Iron (as Fe) mg/l Nil 0.3 1 18 Copper (as Cu) mg/l Nil 0.05 1.5 19 Lead (as Pb) mg/l Nil 0.05 No Relaxation 20 Zinc (as Zn) mg/l Nil 5 15 21 Cadmium mg/l Nil 0.01 No Relaxation 22 Total Chromium mg/l Nil 0.05 No Relaxation 23 Hexavalent Chromium mg/l Nil 0.05 No Relaxation 24 Calcium mg/l Nil 75 200 25 Magnesium mg/l Nil 30 100 26 Total Nitrogen mg/l Nil 27 Free Ammonia mg/l Nil 28 Boron mg/l Not 1 5 detectable 29 Total Coliforms, Nos./100ml Nil < 2 30 Faecal Coliforms Nos./100ml Absent Absent Source: EIA Report prepared by M/s Mahabal Enviro Engineers Pvt. Ltd., 2009

It is recommended that BOD and COD should be analysed to assess if there is any sewage contamination as ground water table is not deep in this area.

Surface Water Quality

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Water samples were not collected from tap water to assess the quality of drinking water in the study area. Further actions on this have been recommended in the ESMP.

4.9 SOIL QUALITY

4.9.1 Regional Soil Characteristics

On the basis of soil depth, drain, soil characteristics, slope etc. following soil types are identified in the district. Table 4.13 shows the soil types and its location in the district.

Table 4.13 Soil Types and its Location in the District

S. N. Soil Type Locations in The District 1 Deep, Moderately Well Narrow stretches are spread in Taluka Ambegaon, drained, strongly calcareous, Khed, Maval, Mulshi, Velhe, Haveli, Bhor, Purandhar, fine soils on gently sloping Baramati and Indapur along the river banks. plains and valleys with moderate erosion. 2 Slightly deep, well drained, Except Maval and remaining all Taluka fine, calcareous soils on very have this soil coverage. Which include major portion of gently sloping lands with Taluka Indapur, Baramati, Purandhar, Pune-City, measas and buttes with Haveli, Daund and Shirur. A narrow stretch on the moderate erosion eastern side are spread in Taluka Junnar, Khed, Ambegaon and Velhe. 3 Very deep, well drained, Patches are spread in Taluka Mulshi, Bhor and Velhe loamy soils on gently sloping narrow valleys with moderate erosion 4 Shallow well drained, clayey Major portion of the district is covered by this type of soils on gently sloping lands soil. This include major portion of Taluka Maval, Khed, with mesas and buttes with Mulshi, Velhe, Bhor, Purandhar Haveli and Daund. moderate erosion and slight Small stretchs are spread in Taluka Pune-City, stoniness Indapur, Baramati, Ambegaon, Shirur and Junnar. 5 Shallow, well drained, clayey Stretches are spread in Taluka Junnar, Maval, Shirur, soils on gently sloping land Haveli, Baramati, Daund, Khed and Indapur. with moderate erosion. Ambegaon, Purandhar, Source: Pune District Environment Atlas, 2006

4.9.2 Soil Quality at Site

The top layer of the soil at the site is of hard strata and the texture is largely sandy loam with low to moderate erosion potential. The depth of this textured soil layer varies from 1.0m to 2.5m. The area is surrounded by plains containing murrum and soft rock.

As per the EIA report, the soil quality was assessed based on primary soil sample collection from Project Site and results are produced in Table 4.14.

Table 4.14 Soil Sampling Location

SI.No. Parameters Unit Project Site

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SI.No. Parameters Unit Project Site 1 pH 8.11 2 Organic Carbon % 0.29 3 Available Nitrogen as N kg/ha 135

4 Available Phosphorous as P205 kg/ha 31.9 5 Available Sulfur as S kg.ha 0.22 6 Copper mg/kg 01.8 7 Zinc mg/kg 2.11 Source: EIA Report prepared by M/s Mahabal Enviro Engineers Pvt. Ltd., 2009

Table 4.15 Soil Remediation Intervention Values as per Dutch Standards

Parameter Intervention Values (mg/kg dry matter) Zinc 720 Arsenic 76 Lead 530 Cadmium 13 Copper 190 Mercury Mercury (inorganic) 36 Mercury (organic) 4 Source: Soil Remediation Circular 2009, Minister of Housing, Spatial Planning and Environment, Netherlands. Note: Concentrations are shown for standard soil (10% organic matter and 25% clay)

India does not have any specific concentration based soil contamination standards. In absence of any existing standards, Dutch standards have been considered for the purpose of analysis. The observed values for metals namely Zinc and Copper much below the soil remediation intervention values specified in Soil Remediation Circular 2009.

4.10 NOISE LEVEL

Details of noise measurement locations in the study area are given in Table 4.16.

Table 4.16 Description of Noise Sampling Locations

S. No. Sampling Code Distance and Justification for Selection of Location Direction from Location and its setting Project Site 1 Project Site N-1 0 km Represents Project site.

2 Shivaji Nagar N-2 3.2 km, NE Represents residential area near the study area. 3 Pashan N-3 5.6 km, NW Represents residential area in north- western part of the study area and is to the Project Site. 4 Bavdhan N-4 5.0 km, WNW Represents residential area in the study area 5 Khondwa N-5 7.7 km, SE Represents residential area in the study area Source: EIA Report prepared by M/s Mahabal Enviro Engineers Pvt. Ltd., 2009

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The recorded noise levels in the study area are summarised in Table 4.17.

Table 4.17 Noise Level in the Study Area

Day Time Noise Night Time S.No Location Levels Noise Levels

Leq day Limit (dBA) Leq night Limit (dBA) 1. N-1 54 55 41 45 2. N-2 51 55 34 45 3. N-3 47 55 39 45 4. N-4 53 55 42 45 5. N-5 49 55 37 45 Note: Day time is considered from 6 am to 10 pm and night time is considered from 10 pm to 6am. CPCB limits for residential area during daytime and night time are 55dB (A) and 45 dB (A) respectively, commercial area during daytime and night time are 65dB (A) and 55 dB (A) respectively and industrial area during daytime and night time are 75dB (A) and 70 dB (A) respectively Source: EIA Report prepared by M/s Mahabal Enviro Engineers Pvt. Ltd., 2009

The equivalent ambient noise level for day time (Leq day) and night time (Leq night) at proposed Project Site were observed to be below the prescribed corresponding limits for residential area.

For other sampling locations too the results of day time and night time noise levels are below the prescribed corresponding limits.

Noise levels measured at Project site indicates that both day and night time ambient noise levels (ANL)are closer to residential ANL limits of 55 dB(A) and 45 dB(A) respectively. Major source of noise in the baseline environment are the following:

 Heavy traffic movement through Paud road and Karve road opposite to Project site on its southern side; and  Dense residential and commercial zones abutting the project site on all three sides barring the northern side.

Besides, the future development proposal of a DP road and HCMTR passing through the Project site bifurcating it into eastern and western halves will further increase the ambient noise levels in the region.

Daytime and nightime noise levels recorded at various sampling locations are also presented in Figures 4.18 & 4.19

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Figure 4.18 Day Time Noise Levels

56 54 52 50 48 46 44 Noise Level indB(A) 42 N1 N2 N3 N4 N5

Monitoring Locations

Leq Day Permissible Limits, Day time- Residential Area

Note: The applicable noise standards: Leq Day of 55 dB (A) for location N 1 to N5 (Residential Area)

Figure 4.19 Night Time Noise Levels

50

40

30

20

10

Noise Levels in dB(A) Levels Noise 0 N1 N2 N3 N4 N5 Monitoring Locations

Leq Night Permissible Limits, Night Time- Residential Area

Note: The applicable noise standards: Leq Night of 45 dB (A) N1 to N5 (Residential Area). These standards must be adhered to as has been stipulated by CPCB for effective implementation by the Project Site and also by the surrounding areas.

4.11 TRAFFIC DENSITY

As per the inputs from EIA Report prepared by M/s Mahabal Enviro Engineers (2009) primary traffic survey was done at 3 locations. The major road in the vicinity of the Project Site is Paud Road. Hence, the traffic survey to ascertain the traffic density in the study area was conducted for a day on this road during the study period.

Traffic flow towards following directions was surveyed on the National Highway near the Project Site.

 Traffic flow from towards Paud Road (Project Site)  Traffic Flow from Paud Road towards Deccan Gymkhana  Traffic flow from S.N.D.T. College towards Law College Road

The traffic survey was carried out at these points in to and fro directions. The hourly counts were carried out for the different type/category of vehicles. The

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variations in the traffic flow at all the places along with the number of vehicles are presented in Table 4.18.

Table 4.18 Percentage Composition of Vehicles in Study Area

Type of Vehicles and its Traffic Count Cars Two Cycles Three LMV HMV Wheeler Wheeler

From Deccan Gymkhana 2245 4172 606 1346 583 296 towards Paud Road (Project Site) From Paud Road towards 1866 1092 331 1076 502 266 Deccan Gymkhana (Project Site) From SNDT college toward 1742 1020 355 1065 506 267 Law College Road Source: EIA Report prepared by M/s Mahabal Enviro Engineers Pvt. Ltd., 2009

Observations:

Observations on the traffic flow and its density are given below.

Deccan Gymkhana towards Paud Road (Project Site)

The total vehicle count at this point was observed to be 9248 during the survey of 13 hours (0700 hrs to 2000hrs). The two wheelers were observed to be plying at maximum with 4172 numbers followed by cars and three wheelers with 2245 and 1346 in numbers respectively. The light motor vehicles were also observed in significant number with total count of 583. The peak hour traffic flow in the morning was observed between 10-11 hrs with 1076 vehicles on the road and in the evening the peak hour observed was between 17-18 hrs with count of 1128 vehicles.

Paud Road (Project Site) towards Deccan Gymkhana

The total count of vehicles was observed to be 5140 during 13 hours of survey. The cars were plying in maximum with 1866 in number. It was followed by two wheelers and three wheelers whose count was 1092 and 1076 respectively. The light motor vehicles were also observed in significant number with total count of 502. The peak hour traffic flow in the morning was observed between 9-10 hrs with 502 vehicles plying on the road. The peak hour traffic flow in the evening was observed between 18-19 hrs with 434 vehicles plying on the road.

S.N.D.T. College towards Law College Road

The total count of vehicles was observed to be 4958 during 13 hours of survey. The cars were plying in maximum with 1742 in number. It was followed by three wheelers and two wheelers whose count was 1065 and 1020 respectively. The light motor vehicles were also observed in significant number with total count of 506. The peak hour traffic flow in the morning was observed between

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8-9 hrs with 445 vehicles plying on the road. The peak hour traffic flow in the evening was observed between 18-19 hrs with 670 vehicles plying on the road.

The survey was conducted for 13 hours only and is more than a year old data. During the Operational phase the project it is expected that the traffic flow will increase further. To assess the carrying capacity of the nearby roads, a fresh survey is required.

4.12 ECOLOGY

The project site comprises of dense slum settlements covering almost the entire plot area with limited number of trees and other ecological features. As per EIA report 2009, the observations of field survey has concluded that the site is devoid of tree cover and the plant species observed in the area includes trees, shrubs, climbers and herbs that are common and found in other parts of Maharashtra as well. There are no endangered flora and fauna in the project region.

The project proponent has obtained permission for cutting 24 number of trees from Horticulture Department of Municipal Corporation of Pune. Tree cutting permission is attached as Annex 3.

4.13 SOCIAL BASELINE

4.13.1 Context to the Social Baseline

The proliferation of slums in the Kilewadi area of Pune has seen accelerated growth since the last two decades, coinciding with the rapid urbanization of the city. A study undertaken by a Pune-based NGO Mashal indicates that up to March 2011, there were 2.04 Lakh tenements in 477 slum pockets (Mashal, 2011) and that the total number of slum dwellers accounts for nearly 29% of the population of the city. With a boom in the construction industry around prime locations such as Erandwane, the establishment of the Slum Rehabilitation Authority in Pune around 2005 has been channelizing the phase wise redevelopment of over 52,50,197 sq m of land that is currently under slums. It is understood that, the slum erstwhile redevelopment of Wadarwasti and the ongoing redevelopment in Kilewadi is a flagship project of the SRA and represents one of the biggest urban development in the city of Pune.

Table 4.19 Affected Population

Total Affected as Total Affected as Total Affected Phase (I-V) % of total HH of Yr 1995 of Yr 2000 after Yr 2000 Phase II (Kelewadi/IndraPark) 72.03% 3.24% 24.73% Phase III (R.G.P/VasantNagar) 40.42% 7.39% 52.19% Phase IV (HanumanNagar) 61.70% 7.60% 30.70% Phase V (Rautwadi) 49.66% 7.46% 42.88% Source: Socio Economic Survey, Vatsalya, 2010

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The socio-economic baseline that is depicted subsequently needs to be seen in the context of the following:

 Slum redevelopment in Pune is largely replicating the model that is being followed in Mumbai along with specific by-laws developed by the SRA Pune and the Jawaharlal Nehru National Urban Renewal Mission;  The site location (i.e. Survey Number 44/1 Erandwane, Municipal Ward 57) has already seen an initial phase of redevelopment (before the formation of SRA, Pune) which involved the rehabilitation of 463 families;  A key reason for the development of slums in the project area is attributed to its central location amid prime land and lack of control/supervision by the owners of the Chisti Charitable Trust which allowed its proliferation; and  Typically, a slum community depicts a heterogeneous mix of community groups which have migrated into an urban area. However, the Wadarvasti and Kilewadi settlement, centrally located in Pune, depicts a more homogeneous characteristic and is dominated by Maharashtrian communities.

The slum rehabilitation is proposed to be done in phases and accordingly the site has been divided into five phases namely: (a) Phase I: Wadar Wasti; (b) Phase II: Kilewadi; (c) Phase III: Rajeev Gandhi Nagar; (d) Phase IV: Hanuman Nagar; and (e) Phase V: Raut Wadi. The subsequent table depicts the current status for the phase-wise development.

Table 4.20 Project Affected Families for 45 Nirvana Hills

Location Number of Eligible Status Tenements for Rehabilitation Wadarwasti 463 out of 550 The number of tenements that were (rehabilitation declared eligible was as per a previous building was provision of 1st January 1985 which has completed in 2003 as been revised to 1/1/1995. SRA verification part of Phase I) procedure for the same is not yet completed. Kilewadi and Indira 711 tenements out of 1092 Annexure II procedure has been completed Park total tenements and the appeal procedure for eligibility is currently ongoing Rajeev Gandhi Park 446 eligible tenements out Annexure II was published on the 30th of of 973 total tenements May 2011 by SRA Pune *Source: KUL

This socio-economic baseline survey has been developed on the basis of information obtained through stakeholder consultations as well as through a household survey that was conducted by an NGO based in Pune on behalf of KUL. The data presented in the subsequent sections needs to be assessed in the context of the following limitations:

 The household data has been collected and organized for the entire settlement at Survey Number 44/1 however it does not bifurcate

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households according to the specific phase of development, i.e. Phases I to V;  The survey for the settlement of Wadarvasti (Phase I) is currently ongoing and hence this analysis does not include approximately 463 households;  Though the actual survey was conducted for all the households in the four concerned phases of the project area, the data represented below takes into account the responses from the valid schedules only. The survey was conducted in a total of 4324 households at the site, but the data has been generated only from the valid responses gathered from 3445 households. However this sample size is adequate to provide data at 95% confidence.

4.13.2 Demographic Indicators

As on March 2011, there were approximately 10 lakh slum dwellers in the city of Pune with an average density of 290 tenements/hectare (Mashal, 2011). At Kilewadi, the total population on site is enumerated to be 13506 people with a much lower habitation density of 55 tenements/hectare. In terms of social classification, consultations indicated that a majority of the households have migrated from different parts of Maharashtra and belong to the general/traditional castes.

Table4.21 Dialects phase wise

Phase II Phase III Phase IV Phase V Dialect/Language (kelewadi/IndraP (R.G.P/VasantNag (HanumanNa (Rautwadi) ark) ar) gar) Marathi 27.07% 30.36% 27.88% 14.69% Hindi 18.39% 24.13% 36.80% 20.68% Others 27.28% 18.22% 36.28% 18.22% non participation 31.27% 47.83% 11.42% 9.48% Source: Socio Economic Survey, Vatsalya, 2010

The population was mainly constituted by Hindus, with 3308 households reporting they followed Hinduism. It could be also gathered from the data that 42 households reported that they belong to the Muslim community. Among the 3315 households that responded to the question on social category, the percentage distribution of households’ caste wise have been depicted below. It should be noted that there are a few settlements, such as Rautwadi that have a dominance of certain communities (i.e. Marathi and Konkani) as well as Indira Park (predominantly scheduled caste communities of Mahar, Neo-buddha, Mang etc). Other communities also include Other Backward Caste (OBC) such as Mali and the Nomadic Tribe Community of Vadars, the traditional stone cutters.

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Figure 4.20 Social Category

24%

4% 7% 65%

General Category SC ST OBC

Source: Socio Economic Survey, Vatsalya, 2010

It should be noted that the Vadar community (nomadic tribe) depicted as approximately 7% of the total population were one of the earliest settlers in this area and worked in stone cutting and petty quarrying in the area that is currently being backfilled by KUL to accommodate labour camps.

Table4.22 Phase wise distribution of castes

Phase II Phase III Phase IV Phase V Caste (kelewadi/IndraPark) (R.G.P/VasantNagar) (HanumanNagar) (Rautwadi) Scheduled 21.49% 45.87% 19.01% 13.64% Caste Scheduled 8.80% 44.00% 33.60% 13.60% Tribe OBC 18.62% 21.89% 33.58% 25.91% GEN 31.88% 29.90% 27.63% 10.60% Others 20.00% 30.00% 12.50% 37.50% non 30.56% 49.01% 11.01% 9.42% participation Source: Socio Economic Survey, Vatsalya, 2010

Settlement Pattern

The slums in the project area are densely clustered around approximately 70% of the site in largely flat structure with the usual built up being that of one- storied hutments. It is understood that the area within the site which was classified by the Town Planning Authority as “hill-top hill-slope” or a no- development zone has been monitored over the ages and there is no encroachment on this land. The slum has been divided by the most recent slum census into several blocks that are further grouped under the settlements of wasti; Kilewadi; Rajeev Gandhi Nagar; Hanuman Nagar; and Raut Wadi. Each of these settlements is largely homogenous and is not stratified on the basis of caste or communal lines.

The average size of the structure is determined to be about 10*12 ft (i.e. 120 sq ft) in dimensions. The structure and layout of these tenements depict a typical slum scenario with narrow lanes and by-lanes, contiguous hutments with

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corrugated roofing, and inadequate public sanitation facilities. The availability of infrastructure and other amenities is discussed subsequently in this chapter.

Household Size

The household size on site varies from 2 to 7 and is on an average approximately 4 members per household. It was observed that there is a trend towards nuclear/smaller families in the site which is indicated by the number of one-storey expansions above the existing hutment that are occupied by a newly married son/brother within a family.

Sex ratio

The sex ratio for the area is determined to be 888. This is much lower compared to the sex ratio of Maharashtra state (922) and even Pune district (917). Maharashtra has been witnessing a sharp decline in sex ratio in the decades since 1991. The project area is also seen to reflect the state trend when it comes to gender selection. Typically, consultations with women groups in the area indicate the availability of adequate health infrastructure in tune with gender sensitivity as one of the main constraints.

Dependency Ratio

To obtain an insight onto the dependency ratio prevailing on site, the population was divided into major age groups as provided in Table 4.2. It can be gathered from the data that majority of the site population belong to the working age group of 15-64. The working age group constitutes 70.4 percent which indicates a positively skewed dependency. This is typical of a slum demographic scenario as most of the population would be migrants in their youth relocated from their native place to find gainful employment.

Table4.23 Age groups

Age Group Male Female 0 - 4 4.7 4.6 5-9 6.7 6.7 10-14 9.8 10.0 15- 19 10.5 11.4 20 - 24 10.9 10.2 45 - 64 15.6 15.8 65 - 79 3.4 2.9 80+ 0.4 0.3 No responses 7.3 2.5 Source: Socio Economic Survey, Vatsalya, 2010

For any family the number of dependents is a crucial factor to understand their economic vulnerability. For the purpose of the study, dependents are being defined as senior citizens above 65 years of age and children below 15 years of age. The dependency ratio for the area is estimated to be 0.4 which is significantly lower compared to the national ratio of 0.6. The data indicates that about 15 percent of the households have at least one elderly family member. It is estimated that project site has about 524 senior citizens, 222 of

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whom being women in a total of 511 households. No separate estimate is available on the number of women-headed households.

Duration of Stay

From the primary data, the average duration of stay at the slum area is computed to be around 28 years. A majority (94.4 percent) of the population are native Marathi speakers. A minority of the population (about 88 households) are native Hindi speakers from the states of Uttar Pradesh and Madhya Pradesh. There are also few households who have their origins in Andhra Pradesh and Karnataka. However, it is imperative to note that only 719 households reported at the time of survey that they have a proof of residence and only about 816 households reported having election card.

Literacy

Literacy levels on site are reflective of the urban setting of the slum area as well as the availability of municipal as well as private schools. It is of significance that only 34 % of the total site population reported having at least secondary education. 53 % of the total male population at the site reported having at least secondary education and 56 % in the case of total female population at the site. The gender-wise break-up of the highest education received has been presented in the graph below.

Figure 4.21 Literacy Levels

Literacy levels

55.6 60.0 52.6 50.0

40.0

30.0 25.9 25.4 17.6 20.0 15.4

10.0 1.9 2.3 2.0 1.3 0.0 Postgrad Grad Secondary Higher secondary Vocational

Male Female

Source: Socio Economic Survey, Vatsalya, 2010

It could be observed that most respondents have secondary education as their highest educational qualification. Only about 2 percent of those having educational qualifications higher than secondary education have reported having postgraduate degrees. From the above graph it can be ascertained that, there is a significant potential for providing vocational training to the people at the project site. Only a minority (1.7 percent) of the population has received any vocational training even though it is apparent that there is a large percentage of population at the site who are below par with respect to educational adequacy.

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The table below gives the phase wise details for the highest level of education with respect to gender.

Table.4.24 Gender and Education

Phase II (kelewadi/ Phase III (R.G.P/ Phase IV (Hanuman Education Phase V (Rautwadi) Total IndraPark) VasantNagar) Nagar) Level

Male Female Male Female Male Female Male Female Male Female S.S.C 471 302 532 353 567 348 274 170 1844 1173 H.S.C 232 126 220 117 245 151 127 106 824 500 Graduatio 146 81 133 72 207 105 115 52 601 310 n Post Graduatio 12 10 12 9 22 16 11 80 57 115 n Vocationa 10 5 12 9 27 8 9 4 58 26 l Total 871 524 909 560 1068 628 536 412 3384 2124 Source: Socio Economic Survey, Vatsalya, 2010

Another important observation is the presence of two schools in the project site. But, clearly, the two schools alone cannot meet the educational requirements of the 2800 children within the project site. It is also observed that people with advanced qualifications like postgraduates are employed in service jobs like teaching or government offices.

4.13.3 Occupational Profile

Consultations with communities in Indira Park, Wadarvasti and Kilewadi indicate that there is diversity in terms of occupational profile within the slum communities. The common occupations that were cited by the slum residents include rickshaw driver, coolie, security guard and even services like plumbing, parlour work and salesmanship. Some of the respondents even reported their own businesses like repair shops, laundry, general stores etc. Another significant observation is that most of the women in the slum area were engaged as housemaids, while they also took up other occupations like tailoring, scrap business and selling of vegetable, fruits or flowers.

Over the years, with a gradual increase in education levels as well as opportunities in the surrounding areas – especially in sectors such as construction, information technology etc, employment levels in the organized and government sector (such as factories, clerks etc) is increasing. This is also indicated by the worker participation ratio which is observed to be quite high in the area with high proportion of youth in the working age category.

Table. 4.25 Phase wise income range

Phase II Phase III Phase IV Phase V Income (kelewadi/Ind (R.G.P/Vasant (HanumanNaga Total (Rautwadi) Range raPark) Nagar) r) % % % % No. of HH 5,000 & 24.84% 33.21% 25.29% 16.66% 1518

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Phase II Phase III Phase IV Phase V Income (kelewadi/Ind (R.G.P/Vasant (HanumanNaga Total (Rautwadi) Range raPark) Nagar) r) % % % % No. of HH Below 5,001 – 26.49% 31.25% 28.47% 13.79% 1261 10,000 10,001 – 29.06% 23.43% 35.63% 11.88% 320 15,000 15,001 – 24.70% 20.00% 37.64% 17.66% 85 20,000 20,000 & 20.37% 20.37% 50.01% 9.25% 54 Above Source: Socio Economic Survey, Vatsalya, 2010

It is also observed that both genders are engaged in economically productive work. It is observed that nearly all the households have reported a source of employment. The average income of the household is coming to about INR 6400 per month wherein the range of income listed being as low as below INR 1000 to INR 20000 a month .The average age of the earning member is estimated to be about 40 years. This indicates that there may still be a significant proportion of people that are employed in the unorganized sector as well as those that are engaged in wage labour. Most of the occupations listed are observed are not seasonal in nature and therefore it is apparent that the population have some source of income flow throughout the year. Moreover, all the households had sought gainful employment within the nearby area with the average distance to work place being only about 6.8 kms.

Box 4.1 Entrepreneurial Ventures in the Slum Area

A general visit/reconnaissance of the slum area indicates that there are several entrepreneurial ventures, such as flour mills (aata chakkis), community-based organizations and societies, as well as training centres on beauty, basic information technology and other such initiatives. For women, the Lijjat Enterprise has employed over 400 “sakhis (sisters)” in the slum in an initiative wherein dough to prepare an Indian snack is provided and each member obtains approximately INR 25/kg of snacks (papad in local parlance) that is sold to vending points of the enterprise.

Another indication of diversity of livelihood options in the area is the number of commercial tenements, from provision stores to medical shops etc. For instance, the completed rehabilitation in Wadarvasti has seen over 20 shops that have been moved into the ground floor of the redeveloped building. However, it should be noted that there have been certain conflicts owing to the size of the commercial units prior to rehabilitation and after the same. For instance, a garage mechanic, who is currently set shop near the existing labour camp, does not want to be rehabilitated into Wadarvasti because the commercial space is too small for his enterprise. Source: Primary Consultations

Consultations also indicated that there are approximately 250-300 self-help groups (SHGs) comprising of mostly women that work as savings units to deal with emergencies or urgent requirement for money. Women in the area are looking forward to training on enterprise development and are in the need for “gruh udyog” (household enterprise).

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4.13.4 Social Vulnerability

Vulnerability refers to the susceptibility of a person, group, society or system to physical or emotional injury attack and social vulnerability is one dimension of vulnerability to multiple stressors and shocks, including abuse, social exclusion and natural hazards. In the context of the current project, vulnerability can be assessed as arising from (a) demographic factors; (b) economic factors; and (c) physical vulnerability. The table below presents the numbers of vulnerable persons in each phase owing to factors like physical disability or illness.

Table.4.26 Types of vulnerability

Type of Vulnerability Total Phase II Phase III Phase IV Phase V Disability 14 21 19 8 62 Illness 50 39 43 19 151 Old age 105 60 63 26 254 Addiction 131 154 42 36 363 Total 300 274 167 89 830 Source: Socio Economic Survey, Vatsalya, 2010

Physical illness or disability and substance abuse are two established causes of vulnerability pertaining to which enquires were made in the socio-economic survey conducted in the project area. 61 households were found to have members with some level of disability, while 363 households reported addiction and 152 households reported having a person suffering from a long term illness. An important aspect of vulnerability is that the existing socio- economic dynamic within the slum relies on cohesiveness amongst communities and families and thus increasing the ability to adapt and cope from common problems.

It is usually the women headed households and those headed by the elderly that takes the maximum brunt in case of any possible hazard or social disturbances. Discussions with women in Indira Park indicates that are several instances wherein husbands have taken more than one wife and are living within the same community on rent in another hutment. In this case, it is reportedly the first wife who would be eligible for rehabilitation and constitutes the maximum cases of women headed households. In the proposed project area about 10 percent (321 households in absolute figures) were found to be headed by an elderly member. 279 households were headed by a male senior citizen and 42 households were headed by a female senior citizen. It is also imperative to note that on an aggregate level, 169 households were women headed households.

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Figure 4.22 Social Vulnerability

12.0 10.5 10.0 9.3

8.0

6.0 4.9 4.4 4.0 1.8 2.0

0.0 Senior citizen Women headed HH HH with disability HH with illness HH with addiction headed HH

Source: Socio Economic Survey, Vatsalya, 2010

Consultations with community-based organizations in the area indicated that roughly 10% of the households have been classified as below the poverty line, whereas estimates of women headed households as well as those with handicapped members coincides with the data obtained through the household survey. As pointed out above, the average income for a household of four people is Rs.6400. It is also apparent that the slum dwellers in the project premises have found gainful employment in the local area. Therefore any shift in their place of residence would undoubtedly and significantly affect their means of livelihood.

4.13.5 Infrastructure and Amenities

Structure of hutments

The survey also attempted to capture the type of house structure. 1021 of the households reported that their hutments were made of load bearing structure, 906 reported shed as the type of structure and 328 reported RCC as the structure. 127 respondents did not give any response to the question on the type of structure. In terms of salvageable material, the sites of specific hutments which had been demolished indicates that many households had refurbished their interiors with tiles, a sink, granite structures etc. and reportedly, such refurbishments constitute an important aspects of financial compensation expectations.

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Figure 4.23 Type of structure

Type of Structure

28%

59% 10% 3%

Loadbearing Loadbearing RCC Shed

Source: Socio Economic Survey, Vatsalya, 2010

The phase wise details of slum structures have been presented in the table below:

Table 4.27 Type of structures phase wise

Type of Phase II Phase III Phase IV Phase V Structure (kelewadi/IndraPark) (R.G.P/VasantNagar) (HanumanNagar) (Rautwadi) RCC 7.3% 41.8% 28.8% 22.1% Load bearing 30.5% 25.4% 30.8% 13.3% slab Shed 26.5% 35.2% 21.7% 16.6% Others 30.0% 48.8% 12.2% 9.0% Source: Socio Economic Survey, Vatsalya, 2010

Physical Infrastructure

It was reported that the slums had RCC pavements across the area. In addition, the entire slum has been electrified over the last ten years with specific settlements having electric meters through the Maharashtra State Electricity Board (MSEB). However over 90 percent of the connections are illegal with only very few households having meter facilities for electricity. The power supply in the area is also reported to be quite regular with only 3-4 hours cut on Thursdays. It is significant to note that 1010 households (about one-third) reported that they have inadequate ventilation and about the same proportion (1037 houses) reported that they have inadequate sunlight. The most common cooking fuel reported was LPG with about 90 percent of the household relying on LPG for cooking. About 5 percent reported using ‘chulhas’ or earthen stoves’.

Sanitation and Drainage

Municipal water was reported as the main source of water by 99 percent of the households in the primary survey. The water supply of Pune Municipal Corporation was reported to be regular by the client. Apparently, the area also has a storage tank for water in Vasant Nagar phase, with a capacity adequate ERM ESIA: KUMAR SINEW DEVELOPERS PROJECT # I8390/ 0138632 MARCH 2012 109

for the entire population in the project site. A sewerage system to cover the entire slum area has been installed by the local Municipal Corporator. It was reported by the client that the drainage structures were mostly closed units. In addition, most of the households (99%) reported using public toilets that had been set up by the Pune Municipal Corporation and are also in charge of its maintenance. This figure is however contradictory to the feedback that open defecation is commonly practiced here.

Education

Education facilities are readily available in the area with a major municipal school (the school will need to be shifted due to the project) as well as two other private English and Marathi-medium schools. The primary data has also captured the existence of 3 aanganwadi centres. The number of children that are enrolling into higher education, college and vocational courses are gradually increasing with an increase in disposable income and the proximity to institutes such as Bhartiya Vidyapeeth and other colleges in Pune.

Health Infrastructure

Availability of health infrastructure in the project area is limited to private clinics and hospitals such as the Jog Hospital with 150 beds and Krishna Hospital with about 70 beds. Results of the survey and discussions with Community Building Organisations (CBOs) in the area indicate low awareness levels on health-related issues. Women in the slum are specifically vulnerable to health issues due to their addiction to “misri” (a local type of tobacco), low education levels, exposure to unsanitary conditions through working as maids or rag pickers as well as unstable marital status. As a result, women generally do not tend to access/frequent hospitals.

Community Based Organizations

As mentioned earlier, there were savings schemes organised by women operating in the slum areas, know as ‘bachat gat’ and it was reported to be quite prevalent among the women population. However, these groups were largely known to operate underground with no significant overt identities. About 72 percent of the households reported having a bank account. A significant presence of ‘mandals’ were also reported in this area. These Mandals are apparently active with respect to religious activities and also to some extent for cultural events. A common activity of these mandals is to celebrate festivals such as Ganesh Chaturthi, Dassehra, Mahashivratri etc.

The Pune Municipal Corporation is also known to engage non-governmental organizations (NGOs) to initiate and carry out social development in education, health etc. Some of the prominent NGOs that have been active in the project area in the past include Mashaal and Vatsalya.

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5 STAKEHOLDER ENGAGEMENT, DISCLOSURE AND CONSULTATION

Stakeholder identification and mapping is the first and foremost element of any form of stakeholder analysis of a project. Stakeholder mapping and analysis is one of the biggest challenges faced by any project, and all the more when they have an influence over a large group of entities. Often regarded as one of the most crucial and critical steps of any project’s modus operandi, it is the process of establishing an understanding of the key associates other than the project proponent and the internal stakeholders having any association or bearing on the success or failure of the project. Once these stakeholders are established, their roles and levels of impact on the project can be envisaged.

Failure to understand or neglect important stakeholder is likely to result in risk for the project ranging from negative publicity for both the project as well as the proponent to the very existence of the project. In the present context, this identification and analysis of the stakeholders become all the more important as the project involves temporary displacement and rehabilitation of community because of which a large no. of interrelated groups will have some form of direct or indirect stake in this project. These direct and indirect stakeholders can range from the slum dwellers themselves, to the governmental agencies, hired sub-contractors and labourers, local Corporator to NGO/CBO’s and media depending on the degree of interest, influence and control over the project.

The next sub section is aimed at identification and preliminary classification of the stakeholders, followed by a brief analysis of these identified stakeholder groups, their perception of the project, and the priority for KUL while dealing with these stakeholder groups. It also describes the systems and process through which ESIA proposes to or will handle these stakeholder groups.

5.1 STAKEHOLDER CLASSIFICATION

The stakeholders for the purpose of stakeholder analysis have been primarily classified as:  Internal Stakeholders:  External Stakeholders

5.1.1 Internal Stakeholders

The internal stakeholders for the project include:

Project Management  Kumar Sinew Developers Limited and the holding company Kumar Urban Developers Private Limited  Project specific teams such as EHS cell of KUL, CRT  Employees

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Contractors and Sub-Contractors  Present and future contractors and sub-contractors (Man-Infra and Karan Builders presently)  Labour and other construction workforce engaged by the contractors

5.1.2 External Stakeholder

Lenders, Investors, Financiers and Development Agencies  Development Institutions (ADB and FMO)  Investment Banks and Lead arrangers (Deutsche Bank)

Slum Dwellers or the Local Community  Slum Residents including Owners, Tenants and Squatters. This includes both Eligible as well as Non-Eligible for the rehabilitation as per the SRA  Commercial establishments and small business ventures inside the project area  Slum Lords (large, medium, marginal and small) with multiple slum holdings  Key local decision makers in the Slums or informal representatives  Women  Vulnerable population including Old aged, widows and minors  Aanganwadi group workers and School Teachers  Hospitals, medical centres working inside slum area and deployed personnel  People with linkages to political parties, self proclaimed leaders, extortionist groups local level  Communities encompassing the site or are located in the immediate vicinity

Regulatory Authorities  SRA Pune, Government of Maharashtra  Maharashtra Housing and Area Development Authority, Government of Maharashtra  Ministry of Environment and Forest as State level Environmental Impact Assessment Authority (SEIAA) and State level Expert Appraisal Committee (SEAC)  Maharashtra Pollution Control Board (MPCB)  District Collector/Magistrate  Pune Municipal Corporation (PMC)  Public Works Department (PWD), Government of Maharashtra

Civil Society  NGOs  Religious and other associations  Media  Local MLA, Corporator and other politicians

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Table 5.1 Stakeholder Analysis

Stakeholder Brief description Expectations/Key Concerns/Interests Overall Influence on Priority for KUL Category the Project CATEGORIZATION OF INTERNAL STAKEHOLDERS Project Management Kumar Sinew A major real estate  Completion of the project in a timely manner with continued High High developers and developer in Pune, they funding from ADB; holding company are the project promoter  Minimal social and environmental foot print of the project; Kumar Urban and primary developers  Proper addressing of the social and environmental issues as per IFC Developers Private of Project Nirvana. and ADB standards; Limited  Acting in compliance to the host country acts, rules and regulations; A registered developer  Managing the contractors and sub contractors and ensuring with the SRA Pune with compliances as per the local laws, IFC and ADB SPS standards; and buildings rights over  Minimising impact on the hutment dwellers and providing unlimited floor space. optimum rehabilitation package as per the requirements of SRA, ADB and IFC.

KUL Employees Employees of project  Concern over proper understanding and clarity over the IFC and Medium Medium developer especially ADB requirements with respect to project implementation and those representing the delivery; EHS cell, the technical  Appreciation for their work involving engagement with largely wing and the hostile community also triggering personal safety issues; Community Relations  Ensuring compliance to the local laws and regulations during the Team (CRT) currently complete project cycle including: deployed at Project  Working conditions Nirvana site.  Community engagement, especially the hutment dwellers  Managing sub contractor and their regulatory as well as ADB and IFC compliance;  Ensuring the project completion with minimal social and environmental impact Adequate working conditions; and  Consultation, disclosure and reporting requirements;

Contractors And Sub-Contractors Man-Infra Sub Contractor hired by  Ensuring completion of the project as per the envisaged timeline; Low Medium Construction KUL to undertake  Concern over the fact that the earlier budget was prepared keeping

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Stakeholder Brief description Expectations/Key Concerns/Interests Overall Influence on Priority for KUL Category the Project Limited construction of the local context and requirements in consideration; while presently commercial structure work is expected to be done as per IFC/ADB standards with likely C1 at Wadar Vasti free cost and time escalation not previously anticipated in the tender; sale land (Component  Additional understanding of the IFC/ ADB requirements on what II) upto first level. needs to be done to abide by the standards; Karan Builders Sub Contractor hired by  Working in accordance with the local laws and regulations Low Medium KUL to undertake applicable for local contractors, especially dealing with labourers; excavation and  Ensuring compliance to the special requirements on social and construction of two environmental issues as per ADB and IFC guidelines; Rehabilitation  Reporting and process requirements of KUL technical team, Buildings in Rajiv community relations team and grievance redressal team (especially Gandhi Park for the labourers); (Component I) till the  Provision of labour amenities including safe and hygienic water completion of the supply and sanitation, housing, adequate labour camp facilities etc.; parking level.  Ensuring regular payment of wages including PF, medical, health care insurance, and following zero tolerance for child labour, forced Fusion India Project Management labour and wage discrimination; Low Medium Management Contractors hired by  Liaison with government authorities for labour and other Private Limited KUL for managing the compliances; and construction of  Maintaining of records related to labour management, payment, Component II. health and safety and regular inspections etc. CATEGORIZATION OF EXTERNAL STAKEHOLDERS Project Financiers Banks and Local Lead arranger and  Ensure timely commitments by KUL to delivery of the project; High High Financing Agencies transaction agency like  Ensure compliance of the project to the local applicable rules and Deutsche Bank. regulations;  To ensure compliance to its existing environmental and social Lenders, Investors, Lenders and safeguard policies; High High Financiers and development  Minimum project risk in the short and long term especially from Development institutions like ADB social and environmental perspective; Agencies and FMO who are  Reporting from KUL on various identified parameters; funding Project  Identification of the E&S impacts followed by commitment and Nirvana at the suitable actions on part of the project proponent; and corporate level.  Regular updates from KUL on E&S impacts and progress on addressing these impacts.

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Stakeholder Brief description Expectations/Key Concerns/Interests Overall Influence on Priority for KUL Category the Project  Existing Slum Dwellers/Residents And Local Community Residents including This includes both  Proper enumeration and benefit to maximum hutment dwellers; High High Owners, Tenants Eligible as well as Non-  Concerns over eligibility and ineligibility due to the cut-off date of and Squatters. Eligible for the 1995 which makes slum dwellers residing after that date ineligible rehabilitation as per the for rehabilitation; SRA and SRS scheme.  Concerns over quality houses and facilities to be provided in the rehabilitation housing;  Discussion on entitlement and other benefits to be decided through proper consultation followed by disclosure;  Compensation for temporary displacement in as a form of physical accommodation or rent;  Completion of the housing scheme as soon as possible;  Compensation for all the structures, likely to be impacted however not classified for entitlement under SRS;  Access to grievance redressal authority in case of issues related to SRS implementation or entitlement;

Other issues related to public amenities:  Concern over displacement of schools established inside the slum area;  Displacement of hospitals and medical centres currently functional; and  Concern over proper reestablishment of these important public amenities back to their original status quo.

Hawkers and other Business ventures and  Concern over plot for plot re establishment after rehabilitation, High High commercial entities small commercial because as per SRA, commercial establishment are eligible for same establishment inside the entitlement as are the residential slum dwellers; project area (eligible  Concern over entitlement for workers and employees of these and ineligible). establishments who come from outside the slums to work here;  Change in location after rehabilitation which might lead to negative impact on business and revenue; and  Lack of access to entitlement for hawkers and others who temporarily use the area as a market for selling their goods.

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Stakeholder Brief description Expectations/Key Concerns/Interests Overall Influence on Priority for KUL Category the Project

Slum Lords (large, Slum dwellers having  Expecting additional benefits outside the purview of SRS, from the Low to Medium Medium medium, marginal stake in form of legal or project proponents; and small) with illegal ownership in  Multiple allotment under SRS; multiple slum multiple slum hutments  Usurping the rights of the slum dwellers living as tenants much holdings which they have given before the cut off date; and for rent and commercial  Getting the names of the people in the survey list through corrupt purposes with the practices in lieu of monetary benefits returns from them being a livelihood source. Local concerned Local informal groups  Proper implementation of the SRS scheme by both the parties, KUL Low to Medium Medium slum existing in the various as well as the SRA; representatives slum zones which are  Representation in the decision making on entitlements; (in good faith) self proclaimed local  Payment of proper dues and remunerations by the developer in Including the local grievance addressing form of rent, one time compensation after signing of individual youth groups agencies and a source agreement between the slum dwellers and the developer; of voice to the slum  Quick disposal of the grievances of the hutment dwellers; dwellers.  Clarity, transparency and accountability in the whole process;  Mandate for construction of community buildings, temples etc in These are also the proposed SRS scheme; represented by groups  Due recognition from KUL and from the community; like Ganesh Mandals  Some of them could be seeking personal gains; and (Religious groups),  Eligibility period to extend beyond 1995 dates. youth wings, political party units etc.

Anti-social elements Groups that lack  Additional benefits in form of gratification, outside the purview of Medium Medium and people with genuine base in the SRS, from KUL; extortionist community; however  Improper claims in the SRS housing; approach command respect due  Fear of loosing control over the others due to transparent to fear and control over engagement process and regular flow of information from KUL; anti social elements,  Lack of scope for negotiation over and above the SRA requirements; and their possible and linkages in petty crimes  Developing mistrust and detestation in the slum dwellers for the

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Stakeholder Brief description Expectations/Key Concerns/Interests Overall Influence on Priority for KUL Category the Project etc. developers by spreading rumours, misnomers regarding the project.

Women Women groups in the  Ownership of the new housing in the name of both male and female Low to medium Medium community mostly heads of the household; work as domestic help  Perceived impact on the pre SRS livelihood sue to paucity of space or get engaged in small for economic activities; livelihood opportunity.  Loss of livelihood in the transition period; Rest of them mostly  Concern over participation of women in bringing their own lead the life of grievances into the developers attention; and housewife. These also  Water supply, sanitation, safety and privacy issues during transition include the women period. SHG groups. Vulnerable groups Old aged, Widows,  Concern over separate entitlement for housing under SRS; Low Low Disabled and Minors  Location and accessibility issues in the new housing proposed under SRS;  Special needs of the vulnerable people including the old aged, widows, disabled, children in the housing scheme;  Transition period issues and the special needs of the vulnerable people;  Livelihood issues and social security getting affected both during the transition period and due to proposed housing scheme; and  Special preference and provisions to old aged and disabled while allocating accommodation in transit building or while allocating flats in the rehabilitation building like allocating the ground floor to these groups.

Nearby community Communities  Disturbance in form of noise, waste loitering, dust from the ongoing Low Low encompassing the site construction activities. or located in the immediate vicinity.

Regulatory Authorities And Local Administration SRA Pune The SRA is the nodal  Successful roll out of the SRS, as per the SRA guidelines; High Medium authority classified as  Verification of the eligible and ineligible hutment dwellers and “planning Authority” finalizing the Annexure II list as per SRA;

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Stakeholder Brief description Expectations/Key Concerns/Interests Overall Influence on Priority for KUL Category the Project for demarcation and  Overseeing the activities of the developers during the transition declaration of the slum period, and till the completion of the housing scheme; area and for the  Construction of the flats and other public utilities by KUL as per the implementation of the guidelines under SRA; SRS in the city of Pune  Undertaking the ownership of the slum rehabilitation buildings and PCMC from the developer, once the construction is complete and possession is given to the hutment dwellers; and  Supporting the slum dwellers in formation of the housing societies till its formal registration under the Registration of Societies Act.

Ministry of Nodal authority at  Proper EIA and addressing of impacts identified in EIA. Medium Medium Environment and central and state level Forest and State for ensuring level Environmental compliances aimed Impact Assessment environmental Authority (SEIAA) protection and and State level management. Expert Appraisal Committee (SEAC) Sanctioning of Environmental and other related Technical clearances as per local acts, rules and regulations. Maharashtra Responsible for  KUL should work as per the CTE, and CTO; and High High Pollution Control sanctioning the Consent  Regular submissions on compliances Board (MPCB) to Establish (CTE) and Consent to Operate (CTO) to the project.

Establish guidelines for environmental protection during construction and operation activities.

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Stakeholder Brief description Expectations/Key Concerns/Interests Overall Influence on Priority for KUL Category the Project

Pune Municipal Primary role in  Compliances of the local municipal regulations especially relation Medium Low Corporation (PMC) establishing or municipal solid waste rules etc, and other local regulations or restoring important requirements as applicable. public utilities like water supply, electricity, drainage etc one the project is in its operational phase

Public Works Primary role in  Proper displacement and re setup of public roads and utilities that Low Low Department (PWD), development of public might interfere in ongoing construction activities; and Government of infrastructure like  Participation only once the complete project has been established Maharashtra roads, governmental with regards to development of public buildings and infrastructure buildings, drainage that might be established later on. lines etc.

Political And Local Groups Local Corporator Highly influential in the  Completion of SRS scheme; High Medium and Other Political project area and is the  Continuous commitment from the developer to the project; Groups elected representative  Increase in the entitlement and eligibility date of the slum dwellers; of that area.  Addressal of key issues of the hutment dwellers by the developer;  Possibility of undue benefits from the project proponent; Responsible for  Concern over rival political groups becoming more influential; propagating PMC  Gaining Political mileage from project commissioning; and activities inside the  Garnering compassion from the community. slum area, including providing proper roads, sanitation facilities and waste disposal

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5.2 STAKEHOLDER ENGAGEMENT AS PART OF THE PROJECT

KUL has been engaging with the slum community since 2005, but a more structured engagement has been started only recently. The engagement has been in the following formats:

 On going consultations and negotiations with individuals and cluster of households to get the community to agree to the SRA scheme;  Individual consultations and interviews during the socio-economic survey initiated at the behest of the Lenders through an ESAP. Currently, 3309 households of the 4038 households have been surveyed;  Frequent interactions for specific purposes, as and when required, primarily related to the scheme; and  KUL facilitating the formation of the Wada Basti Housing Society election in Phase I.

In addition, during the ESIA process, ERM held some consultations and focus group discussions with a range of stakeholders which has been detailed later in this section.

The following Table 5.2presents the key consultations held under the SRS.

Table 5.1 Stakeholder Analysis

Meeting Agenda Location of No. of Key issues Final meeting/ people Discussed Outcome consultation attended 1 Public Address by Kelewadi on 600 to 700 Introduction The Chairman and dated 7th Feb People of SRA community Stakeholders to explain 2004 Scheme and started giving the SRA scheme along Start of work consent with Local Politicians 2 Inauguration of Sample Kelewadi 1500 people Advantages Start of the flat to explain the 2Sept 2010 visited of transit advantages after rehabilitation process rehabilitation and seeking participation with slum feedback on dwellers the sample flat 3 Discussion with SRA/ Kelewadi 150 People To know the Two transit Corporater /KUL 2Sept 2010 reaction of building Chairman with public public on construction sample flat started and discussed further plan to start the Transit Building 4 A meeting to discuss the Kelewadi 15 People Progress of progress of Transit Construction Building SRA and Site In of Transit charge 5 Chairman and Kelewadi 30-50 Develop Corporator meeting with Model for

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Meeting Agenda Location of No. of Key issues Final meeting/ people Discussed Outcome consultation attended working women betterment of regarding their work and their business betterment of business 7 Participation and in Kothrud 31 250 hh of Election of Society General Body election of July 2011 Phase 1 executive started Wadar Samaj Co Opp body of function and Housing Society Phase 1 society approval is yet to come from Registrar Co Opp Housing Society 8 Local Corporator Kelewadi 100 People Local PMC Constructed meeting with dwellers works RCC road in for their grievances slum 9 SRA addressing Rajeev All slum Eligibility Annexure II document, the list of Gandhi Park declaration declared eligibility annexure II of Rajeev Gandhi Park 10 Public Address by Kelewadi on 600 to 700 Introduction The Chairman and dated 7th Feb People of SRA community Stakeholders to explain 2004 Scheme and started giving the SRA scheme along Start of work consent with Local Politicians Source: KUL documentation

As mentioned above a structured consultation process has begun only recently and there was a gap in systematic consultation process in between owing to the fact the SRA Pune was being rolled out in the meantime and there was no clarity on the provisions of Pune SRA scheme. However, the community relations team had continuous but largely informal interaction with the slum community throughout the period till 2009.

It is suggested that based on the issues raised through the grievance redressal mechanism or through informal networks like informal meetings in groups or individuals, should be identified, categorised and taken up during the various consultation process that KUL plans to organise/ hold in future as a part of the stakeholder engagement strategy.

5.2.1 Consultations conducted during the ESIA process

For the purpose of undertaking this assessment, a range of stakeholder consultations were done. These issues from these consultations have informed the impact assessment for the project and the mitigation strategies suggested under ESMP. . Following are some of the Focused Group Discussions and consultations that were carried out during ERM’s visit:  Community consultations at different zones of the slum area: ERM conducted separate community consultations with people located at different slum zones at Survey No.44/1 including those from Kilewadi, Rajiv Gandhi Park, Vasant Nagar and Indira Park

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 Consultations with women: ERM conducted Focused Group Discussions with women groups living in the slum area. Specifically, ERM spoke to women who were slum owners, entrepreneurs (carrying out small business out of their residents) and old aged slum residents.  Consultations with temporary tenements at Transit Camp located at Rajiv Gandhi Park: ERM had consultations with the people who had been temporarily shifted at the transit camps located behind the community relations office of KUL at Rajiv Gandhi Park  Consultation with the subcontractors responsible for construction at both component I as well at component II construction zone: ERM held discussions with the subcontractor teams responsible for work activities at both the construction site and tried to get an insight on the construction activities, the key risks and concerns with regards to Environmental Impacts and Health and Safety as well as their ongoing relationship status with the immediate slum community.  Consultations with surrounding communities: ERM held consultations with communities that reside in the vicinity of the project, on the opposite side of the ARAI road that passes around the site. In addition, discussions were also held with representatives of the municipal hospital and school as well as commercial establishments along the approach road to the site;  Consultation with the laborers at both the construction zones: A consultation was carried out with the laborers of both the components sites and detailed discussions where done to understand key issues, challenges faced by the laborers with respect to housing, food, sanitation, wages etc.  Consultations with the Community Relations Team: ERM met the CRT both at the project site as well as later at the client’s office. A detailed discussions, documentation and procedural review and technique assessment was carried out by ERM along with a discussion on the key challenges that were being continuously faced by them on a day to day basis;  Consultation with the SRA representative and the Additional Chief Executive Officer at SRA office Pune and with the local corporator or the local administrative representative  Consultations with the local NGO: ERM held a detailed discussion with the NGO Vatsalya that carried out the entire socio-economic survey in the slum area. During this discussion ERM tried to assess the method employed for the socio-economic survey, key challenges and opposition faced during the survey as well as the responses and reactions received from the community.

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Figure 1.1 Stakeholder consultations with the community

Source: Stakeholder consultation in the community

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6 IMPACT ASSESSMENT

This section discusses the range of potential environmental and social impacts, their extent and severity that are likely to result from different project activities across the lifecycle of Project Nirvana. Potential impacts have been identified based on site walk through surveys, onsite primary monitoring data generated (from an earlier EIA Study done in February 2009), secondary data and literature review pertaining to Project Nirvana area, review of international best practice guidelines and wide-ranging stakeholder consultation. Discussions with Project developers (KUL), Slum Rehabilitation Authority, regulators, urban municipal administration officials, slum representatives, elected local government representative (ward councillor) and other community stakeholders were undertaken along the study area.

A mix of quantitative and qualitative methods i.e. sampling, monitoring, interviews, unstructured interviews, oral histories, and indirect and unstructured observations have been used to derive these impacts. Potential impacts have also been predicted based on the understanding of the site and the processes involved in planning, construction and operation of a typical urban slum rehabilitation project.

6.1.1 Summary of Project Activities

As highlighted previously, the development of Nirvana Hills Phase II (Project Nirvana) consists of the slum rehabilitation component, the free sale component and the associated infrastructure and ancillary facilities to support the project:

 Under Component I which pertains to slum rehabilitation and redevelopment, the project is planned to be implemented over five phases. As mentioned before, 21 rehabilitation buildings are proposed to be developed by the developer, each having 11 floors with 13 flats on each floor. The net carpet area provided for each of these apartments is equivalent to 269 sq. ft. as per SRA guidelines;  Under Component II pertaining to free sale component, KUL will utilize the FSI and TDR received from construction of component one to construct and develop commercial and residential spaces inside the project site. Out of the 41 towers, KUL will establish 18 residential and commercial towers in the area allocated as per TDR and FSI by the SRA for sale in the private market at rates determined by KUL  Besides the two components, KUL has planned for common infrastructure and utilities for the entire Project Nirvana. Some of the general multipurpose utilities include shopping malls, community centre, kids’ playgrounds, crèche, temples and green zones. As per the previous EIA study report, the primary utilities required for day to day functioning of the housing society as assessed and studied in details are o Parking Arrangements,

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o Water Supply and Storage system, o Sewage Disposal System, o Solid Waste Management, o Power Supply and Backup system o Fire Fighting system and o Rain Water Harvesting

Discussions with various KUL teams responsible for developing Project Nirvana indicates that a typical slum rehabilitation project under a government approved SRA scheme consists of the following key activities that are summarized from an impact identification perspective under three distinguishable phases:

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Table 6.1 Summary of Key Project Activities

Planning Phase Construction Phase Operations Phase  Community consent for SRA scheme  Pre construction and mobilisation phase activities  Residential Society formation and  Regulatory authority approval of SRA scheme  Setting up site office training  Initiate Civil engineering surveys:  Setting up labour camps  Registration of Residential Society  Topographical surveys  Setting up onsite concrete batching plant  Allocation of Flats  Cadastral surveys  Setting up of model rehab flat  Handing over physical assets and  Geotechnical investigations  Setting up material storage and scrap yards and society accounts to legally approved  Environmental quality monitoring transport of materials/scraps Residential Society  Social surveys and consultations  Setting up of onsite material testing laboratory  Defect liability period O&M activities  Project planning phase activities  Construction of transit tenements in vacant/ SRA and responsibilities of KUL:  Master plan preparation covering building layout of both allotted space o Building repair and maintenance rehab and saleable buildings  Shifting of select slum communities to transit o Plumbing repairs o  Infrastructure planning and design (such as drinking water tenements Housekeeping o storage, treatment and supply systems; wastewater  Operation and maintenance of transit tenements Electrical repairs o conveyance, treatment and reuse systems; storm water through project construction phase Lift O&M o drainage systems (SWD); rainwater harvesting (RWH)  Utility relocation Carpentry related repairs o systems; Waste management systems; Transport network;  Demolition of cleared slum areas Associated infrastructure Street lights; and other facilities)  Construction of rehabilitation buildings utility/facility O&M o  Architectural planning and design of both rehab and  Clearing and scrubbing Community infrastructure saleable buildings  utility/facility O&M Foundation excavation and construction o  Structural planning and design of both rehab and saleable  Superstructure construction Address grievances of rehab buildings  Electrical works community regularly and systematically  Mechanical and electrical utilities planning and design  Plumbing works o Maintenance of security and order  Social infrastructure planning and design (such as  Carpentry works playground; Children and elders (Nana Nani park) park;  Tiling works community halls; Anganwadi/Balwadis; Crèche; Samajik  Painting works mandir/religious places; gymnasium; Schools; Hospital;  Shifting of slum communities from transit tenements other SRA mandated facilities; and project commitments to to permanent rehab buildings slum community)  Provision of one time settlement to those wanting to  Preparation of detailed project report (DPR) with other SRA self relocated scheme details along ready for construction drawings;  Payment of transition allowance  Building plan approvals and other developmental proposal  Construction of associated infrastructural facilities approvals from various line departments including local and utilities: municipal corporation (such as Fire NOC; Municipal Utilities o Drinking water supply; capacity and availability related approvals; approvals from lift o Waste water conveyance, treatment

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Planning Phase Construction Phase Operations Phase inspectorate etc.) (Sewage treatment plant), reuse and  Preparation of the EIA report disposal systems;  Environmental Clearance (EC) from State Environmental Impact o Storm water drainage systems; Assessment Authority (SEIAA) of Maharashtra and Consent to o Rainwater harvesting systems; Establish (CTE) from Maharashtra State Pollution Control Board o Solid waste collection, storage, (MPCB) treatment and disposal systems;  Compliance to permit conditions. o Landscaping and garden facilities; o Roads and related road furnitures;  Construction of Community and Social infrastructure facilities:  Schools;  Hospitals;  Playgrounds;  Gymnasium;  Children and elders (Nana Nani park) park;  Community halls;  Anganwadi/Balwadis;  Samajik mandir/religious places;  Other SRA mandated facilities;  Other Project commitments to slum community

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Understanding these key activities is critical in identifying and assessing E&S impacts through the project life cycle. Based on this understanding, a Leopold type Impact identification matrix has been formulated and presented in Table 6.3.

6.2 SOCIAL AND ENVIRONMENTAL IMPACT EVALUATION CRITERIA

In general, the ESIA of Project Nirvana assesses impacts of a slum rehabilitation project in the context of a dynamic urban environment and wherein a rapid increase in the density of population is likely to occur over approximately 79 acres of area. As a result, types of impacts can be classified as (a) adverse – which can negatively affect the baseline; and (b) beneficial – which can enhance and improve the existing baseline. Further, the criterions that have been used to evaluate impacts on the environmental and social baseline are as follows:

Context

The context refers to the spatial and/or geographical extent of impact due to Project Nirvana. For this study, contextual impacts can either be:

 Local (low spread): When an impact is site-specific and is restricted within 1 km of the project/project component site;  Medium: When an impact is spread around 3 km of the project site; and  Regional: When an impact is not restricted to the site and its immediate vicinity but influences an area beyond 3 km.

Duration

For the proposed project, impacts were classified based on their existence in temporal scale as follows:

 Short-term (low duration): when impacting for a duration of six months; this will result in the recovery of the effected environmental/social component (other than for ecology) within a year;  Medium-term (medium duration): when impacting between six months and three years; this will result in the recovery of the effected environmental component (other than for ecology) within 1 to 3 years;  Long-term (prolonged duration): when impacting beyond 3 years; and will result in recovery of prevailing conditions beyond 3 years.

Intensity

Indicators of intensity of impact, i.e. whether it is insignificant, minor, moderate or major is based on the following criterion:

 Insignificant intensity: Insignificant intensity when resulting in changes in the environmental baseline of less than 20% in regional context or 20 to

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30% in medium context or up to 30% in local context but for short duration;  Minor intensity when resulting in changes in the baseline up to 20% in regional context or up to 30% in medium context or more than 30% in local context or for ecology minimal changes in the existing ecology in terms of reproductive capacity, survival or habitat suitability;  Moderate intensity when resulting in changes in the baseline for up to 30% in regional context or more than 30% in medium context or for ecology changes are expected to be recoverable in terms of medium duration; and  Major intensity when resulting change in the baseline beyond 30% in regional context or for ecology changes serious impairment to species, productivity or their habitat.

Table 6.2 illustrates the significance assessment matrix to evaluate impacts in accordance to the criterion discussed in this section. It should be noted that the significance of impacts is pre-mitigation and that they can potentially change over the project lifecycle on the basis of mitigation measures.

Table 6.6.2 Evaluation of Impact Significance

Significance of Types of Impacts Impact Evaluation Criterion Adverse Impacts Beneficial Context Duration Intensity Impacts Insignificant Insignificant Local Short Low Minor Minor Local Short Moderate Local Medium Low Local Medium Moderate Medium Short Low Local Long Low Moderate Moderate Local Short High Local Long Moderate Medium Short Moderate Medium Medium Low Medium Medium Moderate Medium Long Low Medium Long Moderate Regional Short Low Regional Medium Moderate Regional Medium Low Major Major Local Medium High Local Long High Medium Short High Medium Medium High Medium Long High Regional Short High Regional Medium High Regional Long Low Regional Long Moderate Regional Long High

The subsequent section discusses the impacts identified in the following manner:

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 For environmental impacts, significance for baseline parameters is discussed over the project lifecycle;  For social impacts; the discussion is based on issues for Project Nirvana as a whole over its entire lifecycle.

6.3 SOCIAL AND ENVIRONMENTAL IMPACT IDENTIFICATION

The assessment process is based on available information, including the project description (as provided by KUL), proposed activities, and social and environmental baseline data. The assessment considers all relevant social and environmental impact/risks, including issues identified in IFC Performance Standards 2 through 8, the ADB SPS and the concerns expressed by those who will be affected by such risks and impacts. The potential environmental and social impacts that are anticipated during various phases of the project life cycle are listed at Table 6.3 using the Leopold Matrix approach

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Ambient Sustainable Social and Environmental Soil and Ambient Socio- Road Health and Natural Land use Air Ecology Resource Cultural Visual aspects/Project Activities Water Noise levels Economic network Safety disasters Quality Use Planning Phase Community consent for SRA ------ - - - scheme Regulatory authority ------ - - - approval of SRA scheme Initiate Civil engineering surveys: Topographical surveys ------Cadastral surveys ------Geotechnical investigations ------Environmental quality ------monitoring Social surveys and ------ - - - consultations Project planning phase activities Master plan preparation covering building layout of  - - -       -  both rehab and saleable buildings Infrastructure planning and -   -   -   - -  design Architectural planning and design of both rehab and   - -      -   saleable buildings Structural planning and design of both rehab and - - - - -  - -  - -  saleable buildings Mechanical and electrical - -  - -  - -  -   utilities planning and design Social infrastructure planning - - - -      - - - and design

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Ambient Sustainable Social and Environmental Soil and Ambient Socio- Road Health and Natural Land use Air Ecology Resource Cultural Visual aspects/Project Activities Water Noise levels Economic network Safety disasters Quality Use Preparation of detailed project report (DPR) with other SRA scheme details - - - - -  ------along with ready for construction drawings; Building plan approvals and other developmental  - - - -  ------proposal approvals Compliance to Permit             Conditions Environmental Clearance (EC) and Consent to Establish  - - - -  ------(CTE) Construction Phase Pre construction and mobilisation phase activities Setting up site office  -  - -  - - - - -  Setting up labour camps    -     - -   Setting up onsite concrete       -  -    batching plant Setting up of model flat  ------ - - - Setting up and transport of material storage and scrap      - - - - -  - yards Setting up of onsite material  -  -  - -  - -  - testing laboratory Construction of transit tenements in vacant/ SRA       -      allotted space Shifting of select slum communities to transit ------ - - - tenements Provision of One-Time Settlement to those wanting  ------ -  - self-relocation

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Ambient Sustainable Social and Environmental Soil and Ambient Socio- Road Health and Natural Land use Air Ecology Resource Cultural Visual aspects/Project Activities Water Noise levels Economic network Safety disasters Quality Use Payment of Transition ------ - - - Allowance Operation and maintenance of transit tenements through  -  - -  -   -   project construction phase Utility relocation and demolition of cleared slum            - areas Construction of rehabilitation            - buildings Clearing and scrubbing -  -   -   -   - Foundation excavation and -    - - -  -   - construction Superstructure construction -    - - -  - -  - Electrical works - -  - -  - - - -  - Plumbing works - -  - -  - - - -  - Carpentry works - -  ------ - Tiling works - -  ------ - Painting works - -  ------ - Shifting of slum communities from transit tenements to  ------ - - - permanent rehab buildings Construction of associated infrastructural facilities and utilities Drinking water supply       -     - Waste water conveyance, treatment (Sewage treatment       -     - plant), reuse and disposal systems Storm water drainage       -     - systems Rainwater harvesting       -     - systems Solid waste collection, storage, treatment and       -     - disposal systems

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Ambient Sustainable Social and Environmental Soil and Ambient Socio- Road Health and Natural Land use Air Ecology Resource Cultural Visual aspects/Project Activities Water Noise levels Economic network Safety disasters Quality Use Landscaping and garden       -     - facilities Roads and related road       -     - furnitures Construction of Community and Social infrastructure            - facilities Operation and Maintenance Residential Society formation - - - - -  - -  - - - and training Registration of Residential ------ - - - Society Handing over physical assets and society accounts to ------ - - - legally approved Residential Society Defect liability period O&M activities and responsibilities Building repair and  -  - -  -   -   maintenance Housekeeping  -  - -  -   -   Plumbing repairs - - - - -  - -  - - - Electrical repairs - - - - -  - -  -  - Lift O&M - - - - -  - -  -  - Carpentry related repairs ------Associated infrastructure -   -   -   -  - utility/facility O&M Community infrastructure - - - -   - -  - - - utility/facility O&M Address all grievances of ------ - - - rehab community Maintenance of Security and ------ -  - Order

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6.4 ASSESSMENT OF ENVIRONMENTAL IMPACTS

6.4.1 Land use

Impacts

Project Nirvana is centrally located in Pune City between densely developed regions such as Kothrud (on the west), Deccan Gymkana (on the north east), Sadashiv Peth (on the east), Erandwane (on the south east) and Dattawadi (on the south). On its north and north-west, a large institutional campus belonging to Automotive Research Association of India (ARAI) is located along with hill top – hill slope regions which are prohibited for development and declared as No-Development zones (NDZ) as per local development rules. The site setting indicates that for Project Nirvana a major land use change due to project development through its life cycle both at regional level and in the immediate vicinity is not possible due to densely developed surrounding regions or regions falling into NDZ.

Major change in land use is expected only within the site premises. From a many decades old slum land use area, the project will convert it into a formally developed residential area with positive impact on land values in and around the site. As highlighted earlier, the entire site is spread over a plot area of approximately 320,826 m2 and the slums are currently occupying about 1/3rd of this area (i.e. roughly 120,000 m2). The FSI use statement issued by Project Architects clearly indicates that the following land use features will be kept intact during commercial project development out of the total plot area as shown in Figure 6.1:

Figure .6.1 Proposed Land Use in the Plot Area

Proposed Mandatory Development Proposed Open Space Road and Residential 9% Mass Rapid and Transport Commercial Route Development 12% 33%

Park Reservation Area 16% Hill top - hill Existing ARAI slope zone road 28% 2% *Source: FSI Statement of Project Architects

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Thus within an equivalent area currently occupied by slum settlements, Project Nirvana will develop all amenities and infrastructure facilities to improve the quality of life along with residential buildings.

The project development will also mainstream existing slum settlements into Pune City integrating them with all other development proposals of Pune City which otherwise eluded them for many decades.

In this context, during planning phase of the project, following keys impacts are anticipated:

 Major positive change in land use from a dense slum cluster to formally developed high value land;  Rise in land values induces change in land use pattern in the neighbourhood. As the nearby areas are already well developed, induced impact is less likely to happen;  State of the art architectural planning (both exterior and interior of rehab/sale buildings) and design adds to positive increase in land values within project site and immediate neighbourhood; and  Obtaining regulatory approvals and clearances in time reinforces the impacts cited above.

The key impact anticipated on land use aspect both within project premises and in the surrounding regions is the positive appreciation of land values due to positive change in land use, as well as improved environmental hygiene in the area. This key positive impact that sets in during the planning phase of the Project is expected to sustain through the project life cycle, i.e. rehabilitation of slum dwellers into organized housing.

During construction phase of the project, typical impacts associated with building construction projects include the following:

 Abandoned sites and facilities that are created during construction phase (such as site office, labour camps, onsite concrete batching plant, model rehab flat, material storage and scrap yards, onsite material testing laboratory, transit tenements etc.) could lead to misuse and encroachment;  Ancillary sites and facilities that inadvertently develop around construction sites and facilities stays put during post construction phase leading to an adverse impact on land use.  Good upkeep and maintenance of transit tenements through the construction phase of the slum rehabilitation project reinforces the positive impacts highlighted in the planning phase;  Possible re-encroachment of vacated slum areas leading to adverse impact on the project and land use aspect;  Vacated slum dwellers setting up slums elsewhere in City;  Timely shifting of slum communities from transit tenements to permanent rehab buildings and construction of associated infrastructural facilities and utilities along with Community and Social infrastructure facilities will

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reinforce the positive change in land values and use highlighted during planning phase of the project.

However, considering the project setting and construction phase proposals, none of the adverse impacts listed above is anticipated. All the sites and facilities that are created during construction phase (such as site office, labour camps, onsite concrete batching plant, model rehab flat, material storage and scrap yards, onsite material testing laboratory, transit tenements etc.) will be located within the proposed development area and hence will be demolished for constructing rehab and saleable buildings or other associated infrastructure facilities and amenities in the later course of project construction phase.

Possible re-encroachment of vacated slum areas is not anticipated as only limited space required for constructing buildings in a phased manner is vacated and demolished. Vacated slum dwellers setting up slums elsewhere in City is not anticipated as the Project complying with SRA regulations have made available transit tenements and rental provisions till the permanent rehab buildings are ready. Stakeholder consultations also concur with this opinion.

During project operational phase, the level of repair and maintenance sustained through project life cycle will determine the sustenance of positive change in land use and land value. Key impacts are summarised subsequently.

Table .6.3 Summary of Anticipated Impacts on Land Use

Impacts to consider during Impacts during Construction Impacts Operational Phase Planning Phase Phase Positive change in land use Good upkeep and Level of repair and pattern from slum cluster to maintenance of transit maintenance sustained formally developed residential tenements reinforces the through project life cycle will cum commercial zone positive impacts highlighted determine the sustenance of in the planning phase; positive change in land use and land value Positive rise in land value that Timely execution of project - will remain sustained through milestones reinforces the project life cycle provided positive impacts highlighted Project meets its goals in planning phase. Good architectural planning Timely completion of - and design adds to positive construction of associated increase in land values within infrastructural facilities and project site and immediate utilities will reinforce the neighbourhood. positive change in land values and use Timely regulatory approvals - - and clearances reinforces the impacts cited above

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Significance of Impact

The overall impact on land use will be beneficial in the medium context and minor intensity for a medium to long term duration. The impact significance assessed is summarised largely as beneficial:

Factors Significance – Planning Significance – Significance – Phase Construction Phase Operational Phase Context Local Local Medium Duration Short Medium Long Intensity Insignificant Insignificant Minor Overall Insignificant beneficial Minor beneficial Moderately beneficial

6.4.2 Solid Waste

Significant amount of solid waste will be generated both during the construction and operation phase of the project.

Type of waste generated from the construction and demolition activities would be primarily inert and non - biodegradable in nature (construction debris- soil, sand, gravel, concrete, masonry, rubble, metal, pipes, wood scrap etc.); and small quantities of waste oil and rags; and domestic solid waste. Secondary information indicates that about 25 kg of waste is generated per sq ft area of building demolished. Assuming 25 kg of construction and demolition waste generation per sq ft of building under demolition, about 13200 tons of waste is expected for generation.

During construction phase of the project, typical impacts/problems related with the solid waste management during building construction projects include the following:

 Stacking or storage of bulky construction waste outside the construction site which can lead to traffic congestion and disruption, choking of drains etc;  Improper disposal of domestic solid waste generated by labourers engaged in construction leads to unhygienic conditions;  Soil contamination due to any oil spill, chemical etc.

It is noted that during demolition as well as construction, some amounts of hazardous waste which have asbestos containing material will also be generated. It should be noted that approximately 2200 roofing sheets were quantified as having asbestos. The range of asbestos varies from 8 to 20% in such sheets. Such material will fall under Schedule I and II of the Hazardous Waste Act and Rules, 2008 and the Environmental and Social Management Plan provides measures for disposal of the same. It should be noticed that all hazardous waste containing material will need to be disposed off in a secure landfill site. However, hazardous waste is assessed to be minimal due to the residential nature of the site and is likely to be less than 5%.

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However, the impact caused during the construction phase would be mitigated by adopting good housekeeping and waste management practices. All construction/demolition waste would be stored within the site itself in an earmarked area. Proper screen would be provided so that the waste does not get scattered and does not become an eyesore which will confine the impact to the project area and reducing any impacts on surroundings. Additionally as the project is planned in phases the quantity of construction waste generated would not be too significant. In current situation, construction and demolition waste generated by the ongoing project activities is being used by the Client for the filling of the quarry site where eventually Component II of the project will be developed (residential and commercial towers).

Metals, pipes, conduits etc. will be recycled either within site or outside with help of the local authority. The measures like reusing materials on-site and /or donating /selling salvaged items reduces waste, virgin material use and disposal cost.

Siting or disposal of construction waste which is likely to entail unaesthetic view, unhygienic condition, choking of near by drains, etc. are short term impacts. By adopting proper management of construction material and mitigation measures such impacts will be marginalized. All the hazardous chemicals and materials would be stored on site with proper secondary containment facility to prevent any potential soil contamination. Domestic solid waste generated from the labour camps and site offices will be stored in secondary collection bins which will be placed at strategic locations at the construction site and near labour camps. The domestic solid waste would be transported and disposed off by PMC.

During operational phase, about 12.2 Tonnes per day of domestic solid waste will be generated. Box 6.1 provides a brief demand and supply assessment of STP manure and sludge and indicates that based on the proposed landscaping plan, the manure generated may be inadequate during the operations phase.

Box 6.1 Demand Supply Analysis of STP Manure and Sludge

About 1.5kg/day of manure will be required for every 100 sq ft gardens/landscape area (assuming 1 inch thick manure is applied on the surface every 90 days). 715370 sq ft (66460 sq m) of gardening is proposed as part of the project. Hence, about 10.8 tonnes of compost manure will be required per day.

A sludge digestor is proposed for reducing sludge disposal from Sewage Treatment Plants. The digested sludge is planned for disposal only once in a year. Hence, the digested sludge quantity available as manure will be nominal for meeting day to day manure requirements at the Project site. The project has proposed to install composting plant within the site and use the generated compost for internal landscaping purposes. On an average, rate of compost generation from pre-sorted MSW is about 15%. Hence from 12.2 tonnes of total MSW, about 1.83 tons/day of compost can be generated.

Overall, both the digested sludge and compost from solid waste generated at Project site during operational phase will not be sufficient to meet the manure demand of about 10 tons per day and may require external sourcing of manure or select use of manure around plant roots instead of manure carpeting.

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Significance of Impact

The maximum impact of solid waste will occur during operations phase of the project life cycle and is anticipated to be beneficial with the provisions that adequate treatment measures are undertaken. The impact significance assessed is summarised as:

Factors Significance – Planning Significance – Significance – Phase Construction Phase Operational Phase Context - Local Local Duration - Short Long term Intensity - Minor Minor Overall - Moderate Adverse Moderate beneficial

6.4.3 Ambient Air Quality

Residential building projects do not contribute much to degradation of ambient air quality (AAQ) levels during its project life cycle. Whatever be the impact, the most air emissions is expected to happen during construction phase of the project. Baseline data and assessment indicates that the predominant wind direction at the site is west, north west or south west. Calm winds prevail for more than 65% of time period which is significant. As sensitive residential and institutional receptors are located on the immediate western side of the project site, any fugitive dust generation could potentially affect these sensitive receptors.

Baseline ambient air quality measurement undertaken as part of EIA study in post-monsoon season of 2008 indicates that air quality levels were well within the residential zone limits prescribed by current NAAQS standards published in 2009. Suspended particulate matter (SPM) ranged between 83-56 g/m3

while Respirable suspended particulate matter (RSPM or PM10) was in the 3 3 range of 30-15 g/m . SO2 and NOx were in the range of 0-4 and 0-8 g/m respectively. CO was observed in the range of 1.0-0.2 mg/m3. Major sources of air pollution near the site vicinity include the following:

 Heavy traffic movement through Paud road and Karve road opposite to Project site on its southern side; and  Dense residential and commercial zones abutting the project site on all three sides barring the northern side.

Besides, the future development proposal of a DP road and HCMTR passing through the Project site bifurcating it into eastern and western halves will add to deteriorating ambient air quality levels in the region.

In this background, during planning phase, it is necessary to include AAQ as a factor while siting sewage treatment plants (STP), Solid waste segregation centres and Composting yards etc near sensitive receptors within project site and in the immediate neighbourhoods. Locations for solid waste segregation

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centre and composting yard are currently in planning stage. Regarding STPs, two STPs of 1.2 MLD and 2.2 MLD capacities are being planned near sale and rehab building components respectively. One of the STP planned on the south western side near rehab buildings could be located closer to boundary line abutting which are residential buildings located along the Paud Road which could be sensitive to foul smell emanating from STPs.

During construction phase which is critical as far as ambient air quality is concerned, following are the key sources of air emissions:

 Use of fire wood for cooking and burning of garbage in labour camp sites; Indoor air quality issues due to cooking inside shelters in labour camp sites;  Fugitive dust generation at/due to: vehicular movement on unpaved surfaces; at material handling yards; construction operations such as excavation, loading and unloading of excavated earth material; demolition of existing slum structures; and  Gaseous emissions from heavy construction equipments, machinery, RMC trucks and vehicular fleet.

During construction phase, project plans to use minimum number of vehicle fleet as there is no space to move around or park inside the construction areas. As construction proceeds in phases after clearing dense slum settlements, project authorities have planned to commission the vehicular fleet as and when required and hence no significant number of vehicles will be deployed so that daily life in surrounding slum colonies are not affected. Construction machinery and equipments will also be deployed in minimum numbers as construction activity will be taken up in phases. Due to staggered construction schedule that allows slum areas to be cleared in time for creating construction space, limited number of machinery and equipments will be deployed. Considering that project is located in the midst of Pune City, gaseous emissions from construction equipments and machinery will not significantly alter the AAQ environment in the region.

During operational phase, foul smell emanating from STPs, Solid waste segregation centres, composting yards could be potential sources for local air quality deterioration. However, measures would be taken to reduce odor pollution by maintaining green buffer around the STP.

Green house Gas emissions

It is expected that during the operational phase of the project major sources contributing towards green house gases emissions are LPG combustion as fuel for households and usage of gasoline in vehicles. It has been estimated that there would be approximately 6924 MT/year of CO2 emissions from vehicles and LPG combustion would contribute 155 MT/year of CO2 emissions. Hence, the project operation would contribute nearly 7079 MT/year of CO2 emissions. These emissions would further degrade the ambient ait quality.

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Note: KUL has not yet undertaken any additional studies on green house gas emissions or clean development mechanisms. Thus, a more detailed description of impacts/anticipated measures cannot be provided other than what has been discussed.

Table 6.5 Summary of Anticipated Impacts on AAQ

Impacts to consider during Impacts during Construction Impacts Operational Phase Planning Phase Phase Locating STP, Solid waste Fugitive dust along access Foul smell from STPs, Solid segregation centres, roads, construction sites waste segregation centres, Composting yards etc near composting yards sensitive receptors - Gaseous emission from Indoor air quality issues in vehicles, machinery and individual rehabilitation flats equipments that use fossil fuel - Indoor air quality, garbage Green house gases Emissions burning and fire wood use are from vehicles and LPG critical AAQ issues. combustion.

Significance of Impact

The maximum impact on AAQ levels will occur during construction phase of the project life cycle and is anticipated to be minor adverse. Else, during operational phase, depending upon the location of STPs and other such facilities and by maintaining green buffer zones, AAQ levels will not be impacted significantly by the project. The impact significance assessed is summarised as:

Factors Significance – Planning Significance – Significance – Phase Construction Phase Operational Phase Context - Local Local Duration - Short Long term Intensity - Minor Minor Overall - Minor adverse Minor adverse

6.4.4 Soil and Water Environment

The Project Nirvana site is located on a minor hill slope with a rolling to undulating gradient (with gradients of approximately 1:135). The top layer of the soil at the site is of hard strata and the texture is largely sandy loam with low to moderate erosion potential. The depth of this textured soil layer varies from 1.0m to 2.5m. The area is surrounded by plains containing murrum and soft rock.

Due to hilly terrain, there is no surface water bodies located within the site premises. Average annual rainfall received by Pune City is around 885mm and the range is from 300mm to 1200mm per year. Hydrogeology of the city (located on the Deccan Plateau) indicates that basaltic hard rock is the primary geological formation over the entire district. Depending upon the local weathering, fracturing and jointing in the basaltic rock formations, the

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potential aquifers could be in the shallow range (depth of 20- 22 m bgl) to deep confined aquifers (occurring below the depth of 40 m bgl).

The project will source water from Pune Municipal Corporation (PMC) as the site is well served by water supply infrastructure developed and maintained by PMC both during construction and operational phase of the project. Water requirement during construction phase for meeting domestic needs (of construction staff and labourers) and construction purpose (primarily curing) will be met from currently available PMC supply. In normal construction, the water demand is roughly 10-20% of the volume of brick and concrete used in construction. To put it simply, about 100 litres of water will be required for every 1 ft2 of building constructed. Considering that the Project will be developing over an FSI of 464537 m2, the construction phase water demand could be conservatively estimated around 500 MLD spread over the entire construction period of 5 years. This roughly translates to 0.3 MLD of water requirement per day (if we assume 300 days of working at construction site barring rainy days). Project has requisite permission to source water from PMC supply lines as development charges and water usage charges are being paid by the Project. According to SRA, PMC checks the capacity of water supply infrastructure before giving permission to draw water from its supply lines. Hence, project will not cause any indirect impact on the immediate residential and institutional neighbourhood causing water shortage to them.

The total amount of water required during operational phase is about 4.1 Million Litres per day (MLD) which comprise of water consumption of about 3.9 MLD required by the residential buildings (rehab and sale components) and 0.2 MLD required by the commercial buildings in proposed project. The project has proposals to construct water storage facilities below ground (underground water tank) of 5.6 million litres capacity and elevated storage reservoir (ESR) of 2.2 million litres capacity.

In this context, during planning phase, contamination related impacts that will be caused on sub-surface soil and ground water environment should be taken into account while planning for infrastructure facilities over land such as sewage treatment plants, composting yards, sewerage systems and transformer yards. Due to favourable hydro-geological condition, the anticipated contamination related impact is minor to insignificant.

Project Nirvana has rain water harvesting component (targeting 200 MLD /year of rainwater received by the site) as part of the project proposal which will have a positive impact on the ground water environment and will be a major sustainable measure along with other water conservation measures proposed (such as recycling of treated wastewater). Planning for meeting long term water demand at an appropriate level of quality will be a critical issue considering the human health impacts that it could pose. As water is sourced from PMC, the project will be impacted if there are quantity or quality issues associated with PMC supply. However, the project will not be isolated in bearing the impact as the whole city will face such a prospect in case PMC fails to deliver water supply at required quantity and quality.

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Anticipated impacts on soil and water environment during construction phase will be caused at labour camp sites, site office, batching plant, material storage and scrap yards, transit tenement site and active construction sites. The key source of soil and water pollution at these sites could be due to:

 Liquid and solid waste disposal such as wastewater, solid wastes, construction wastes (arising from various works such as earthwork, electrical, plumbing, painting, carpentry etc)  Transport, handling, storage and use of construction chemicals, paints, solvents, oil, grease, fossil fuel and other hazardous materials used in construction site.  Erosion at construction material storage sites and choking of downstream drainage lines.  Soil erosion at construction sites and slum demolition areas.

At site office and labour camp sites, soak pits have been provided to dispose off the wastewater generated. At the existing transit tenement site PMC sewer lines have been used to dispose off the waste water. Considering the favourable hydro-geological environment at the site, the soil and water pollution anticipated due to waste water disposal from construction sites is minor to insignificant.

During operational phase, surface and subsurface soil and water contamination and resultant polluted storm water runoff from STP areas, sludge storage/drying areas, Compost yards and leaking building and underground sewerage systems are anticipated. Water quality aspects will depend largely on the effective O&M practices adopted for periodical cleaning and up keep of the entire water supply system consisting of supply pipelines (both above ground and below ground), valves and other pipelines fixtures, metering points/pits, storage tanks (both underground and above ground) etc. Meeting the daily water demand during lean months depends on PMC as it regulates the water supply rationing, if any during lean months.

Table 6.6 Summary of Anticipated Impacts on Soil and Water Environment

Impacts to consider during Impacts during Construction Impacts Operational Phase Planning Phase Phase Soil and water contamination Increase in soil erosion from Soil and water contamination due to sewage treatment construction sites/slum due to sewage treatment plants, composting yards, demolition sites and choking plants, composting yards, sewerage systems and of drainage lines downstream sewerage systems and transformer yards. transformer yards. Meeting long term water Transport, handling, storage Water quality aspects will demand with appropriate and use of construction depend largely on the effective quality levels chemicals, paints, solvents, oil, O&M practices adopted for grease, fossil fuel and other periodical cleaning and up hazardous materials used in keep of the entire water construction site supply system - Change in local drainage Daily water demand during pattern lean months will depend on PMC regulations on rationing

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Impacts to consider during Impacts during Construction Impacts Operational Phase Planning Phase Phase - Liquid and solid waste disposal such as wastewater, solid wastes, construction wastes (arising from various works such as earthwork, electrical, plumbing, painting, carpentry etc) Water demand during construction phase and conservation measures required

Significance of Impact

The impact on soil and water environment will be minor adverse during operational phase considering the long term sustained impact. Else, during construction phase, insignificant adverse impact is anticipated.

Table 6.7 Impact Significance – Soil and Water Environment

Factors Significance – Planning Significance – Significance – Phase Construction Phase Operational Phase Context - Local Local Duration - Short Long Intensity - Insignificant Insignificant Overall - Insignificant adverse Minor adverse

6.4.5 Ambient Noise levels

The background noise levels measured at Project site during the earlier EIA study done in 2008 indicates that the daytime ambient noise levels (ANL) hover around 54 dB(A) while the night time level is around 41 dB(A). Both day and night time ANLs are closer to residential ANL limits of 55 dB(A) and 45 dB(A) respectively which is same for IFC guidelines value. Major source of noise in the baseline environment are the following:

 Heavy traffic movement through Paud road and Karve road opposite to Project site on its southern side; and  Dense residential and commercial zones abutting the project site on all three sides barring the northern side.

Besides, the future development proposal of a DP road and HCMTR passing through the Project site bifurcating it into eastern and western halves will add to deteriorating ambient noise levels in the region.

In this context, the project is expected to adversely contribute to high ANLs during construction phase essentially due to:

 Noise from vehicular fleet deployed for transportation purpose;  Noise generated by construction plants (batching plant, concrete pumps etc) and equipments (DG sets, pneumatic vibrators etc) during their

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operation at various construction sites (buildings, ancillary infrastructure facilities, amenities etc);  Noise generated by earth moving equipments and debris loading operations at slum clearance sites; and  Noise generated by earth moving equipments and rock breakers at foundation construction sites.

As the site is abutted by dense residential and institutional receptors on all three sides barring the northern side, the ANLs is anticipated to increase around all construction sites. In order to estimate the impact of raised ANL due to construction plant operations (such as batching plant and concrete pumps), an estimate of safe distances for locating such plants was undertaken using Inverse Square Law equation for noise decay over distance. The noise level generated from a source will decrease with distance from source as per the following Inverse Square law.

SPL2 = SPL1 – 20 log10 (r2/r1)

Where, SPL1, and SPL2 are Sound pressure levels [dB(A)] at distance r1 and r2 metres respectively.

Considering the stationary construction equipment as a point source generating 90 dB(A) at a reference distance of 2m, computed distance required to meet the permissible limits during day time for various land use categories is presented subsequently

Table 6.8 Minimum distance required for operating stationary equipments

Land use category Permissible limits in day Minimum distance required, time, dB(A) m Silence zone 50 200 Residential 55 113 Commercial 65 36 Industrial 75 11

The minimum distances estimated in the above table, needs to be maintained from the corresponding nearest land use category. As there are residential receptors located closer than 113m specified above, impact on them could be significant whenever the construction activities move closer to western site boundary line. . Construction of rehab buildings will be taken up in phases and appropriate mitigation measures would be adopted to reduce the noise at the source itself by adopting engineering control measures. In line with the IFC guidelines, mufflers will be installed on engine exhausts and compressor unit, and acoustic barriers would be installed to reduce the noise levels and DG sets would be provided with acoustic enclosure Due to planned phase development construction activities and vehicular deployment will be kept to minimal level possible.

During operation phase, no major impact on ANLs is anticipated out of the Project activities. Noise could be generated due to traffic movement within

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the project site and operation of STP and water supply system which is however insignificant.

Table 6.9 Summary of Anticipated Impacts on ANL

Impacts to consider during Impacts during Construction Impacts Operational Phase Planning Phase Phase NA Noise from vehicular fleet Noise from internal traffic deployed for transportation movement purpose NA Noise generated by Future development proposals construction plants (batching of DP road and HCMTR plant, concrete pumps etc) and corridor passing through equipments (DG sets, Project site pneumatic vibrators etc) NA Noise generated by earth Operational noise from water moving equipments and pumps and STP debris loading operations at slum clearance sites NA Noise generated by earth - moving equipments and rock breakers at foundation construction sites.

Significance of Impact

The impact on ANLs will be moderately adverse in the medium context both during construction and operation phases at moderate intensity. During operation phase, however, the impact will be longer during the entire operational phase and hence needs to be managed at receptor locations besides controlling the source. During decommissioning, impact on ANLs is expected to be minor adverse in the local context.

Factors Significance – Planning Significance – Significance – Operation Phase Construction Phase Context - Local Local Duration - Short Long Intensity - Minor Insignificant Overall - Minor adverse Insignificant

6.4.6 Ecological Environment

Impacts

The project site comprises of dense slum settlements covering almost the entire plot area with limited number of trees and other ecological features. The EIA study undertaken in 2008 based on a field survey has concluded that the site is devoid of tree cover and the plant species observed in the area included trees, shrubs, climbers and herbs that are common and found in other parts of Maharashtra as well. There are no endangered flora and fauna in the project region. The list of tree species and their respective numbers proposed for plantation as suggested in the earlier EIA Report is presented at Figure 6.2.

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Figure 6.6.2 List of Trees suggested in the earlier EIA Report for the Project

Source: EIA report, 2008 prepared for the Project Nirvana

During construction phase, project will try to minimise tree felling though there is hardly any tree cover. As part of project development, landscaping and recreational spaces will be constructed over 66,500 sq.m of area (which is 27% of the total plot area). The landscaping plan formulated for the project and presented in the earlier EIA Report prepared in 2008 has proposed to plant about 2000 trees of different species. Key impacts are summarised subsequently.

Table 6.10 Summary of Anticipated Impacts on Ecological Environment

Impacts to consider during Impacts during Construction Impacts Operational Phase Planning Phase Phase Creating landscaped spaces, Tree felling which is Project proposal to construct parks and gardens to add to anticipated to be insignificant landscaped spaces, parks and poor ecological environment considering the poor tree gardens with variety of tree prevailing at the site. cover at project site species will impart positive impact on prevailing poor ecological environment

Significance of Impact

The impact on ecological environment will be insignificant during construction phase and moderately beneficial during operational phase.

Factors Significance – Planning Significance – Significance – Operation Phase Construction Phase Context - Local Local Duration - Short Long Intensity - Insignificant Moderate Overall - Insignificant Moderate beneficial

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6.4.7 Cultural Environment

Impacts

Physical cultural resources are defined as movable or immovable objects, sites, structures, groups of structures, and natural features and landscapes that have archaeological, paleontological, historical, architectural, religious, aesthetic, or other cultural significance. Physical cultural resources may be located in urban or rural settings and may be above or below ground or under water. Their cultural interest may be at the local, provincial, national, or international level. The Project site is devoid of any irreplaceable physical cultural resources as defined under ADB’s Safeguard Policy Statement 2009.

Stakeholder consultations especially with local community members reveal that following religious places exist in and around the project site which are of some local significance and cannot be classified as physical cultural resources as defined under ADB’s SPS 2009:

 Patan Baba Mandir located on the southern boundary of the project site.  Khwaja Peer Sayed Hisamuddin Kattal-E-Zanjani Chisti Trust owned religious structure located on the southern boundary of the project site.  Number of temples and religious idols/ symbols located within the slum settlements inside the project site.  Thulja Mahalakshmi Mandir located outside the Project site at about 2-4 kms from the site on its western side.  Very old Ganesh mandir (temple) located at about 200m from project site on its southern side.

Besides the above tangible forms of heritage, there are about 300 religious groups or associations among slum community (locally known as Ganesh Mitra Mandals) within the project site that primarily organise and celebrate religious festivals and also undertake social development work. As part of project proposal, the local temples, idols and other such religious symbols will be resettled near the rehab buildings to the extent feasible in consultation with concerned community stakeholders. Project proposes to build a larger temple complex within the project site.

During the planning phase of the project, based on community consultations covering all religious groups and sections, re-building proposals to the extent feasible for the local temples and religious symbols/idols must be integrated into project design and disclosed with local community. As the project is governed by SRA regulations, re-building all locally significant cultural properties is not feasible and practical. Hence, it is critical to consult communities in time during planning phase and disclose the final plans to placate any misgivings among various religious groups at the early stage of project life cycle.

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During construction phase, following key issues and impacts must be considered:

 Locating labour camps or other such construction facilities/plants/yards near or next to culturally important sites for local community could violate the sentiments of community;  Community consultation and prior consent for demolition of locally significant religious structures;  Respecting local religious customs, traditions, systems and procedures before initiating demolition of locally significant religious structures;  Chance find procedures;  Respecting local religious customs, traditions, systems and procedures while handing over re-built religious structures.

During operational phase, no major impacts on cultural environment are anticipated as summarized subsequently.

Table 6.11 Summary of Anticipated Impacts on Cultural Environment

Impacts to consider during Impacts during Construction Impacts Operational Phase Planning Phase Phase Community consultations Locating labour camps or - covering all religious groups other such construction and sections over religious facilities/plants/yards near structure re-building culturally important sites proposals. Disclose religious structure Community consultation and - redevelopment plans with prior consent for demolition of local community to placate locally significant religious any misgivings among various structures religious groups at the early stage of project life cycle. Involve community in the Respecting local religious - layout and architectural customs, traditions, systems design of religious structures and procedures before initiating demolition and during handing over re-built religious structures. Obtain consent for relocation Chance find procedures - of locally significant religious structures.

Significance of Impact

In this context, the impact on cultural environment due to Project Nirvana is insignificant through the project life cycle.

Factors Significance – Planning Significance – Significance – Operation Phase Construction Phase Context Local Local - Duration Short Short - Intensity Minor Minor - Overall Minor adverse Minor adverse -

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6.4.8 Visual Impacts

Impacts

An analysis of baseline visual environment in the region indicates well developed residential and commercial zones along all three sides of the site in the immediate vicinity:

 Kothrud in the west (comprising of Rambaug Colony, Janaki Nagar, Gujrat Colony, Anand Nagar, Ideal Colony, Mayur Colony);  Deccan Gymkana in the east (comprising of residential and commercial zones developed along major and minor arterial road networks such as Senapati Bapat Road, Bhandarkar road, Prabhat Road, Law College road, Paud Road) and  Southern region (comprising of Sadashiv peth, Ganesh Nagar and Dattavadi developed along major road networks such as Canal Road, Bimal Path, GA Kulkarni Path, Gulwant Maharaj Park to name a few)

On the northern side, hill top-hill slope region and ARAI campus marks the visual environment. In the entire regional environment that is located within 500m – 1000m from the site boundaries, visual environment comprises of planned development of residential (multi-storey buildings) and commercial zones along well laid out road network. Paud road and Karve road are the two major road segments in the region to which individual residential and commercial zone road networks connect to form a grid. The slum-like developments at Datta Nagar, Kishkinda Nagar and Sutardada Nagar located on the west of Rambaug Colony are the only eyesores in an otherwise well developed region.

The slum settlements located within the Project site is one of the largest in terms of spatial extent and is a major negative input to visual environmental prevailing in the region. In this context, Project Nirvana which proposes to build the largest slum zone in the region into a formally planned development of residential and commercial areas will add positively to the prevailing visual environment.

During planning phase, following visual aspects needs to be considered during master planning, infrastructure planning and architectural designs:

 Layout planning of the entire project site that integrates well with background visual environment and hill side rolling topography;  Aesthetically pleasing infrastructure component planning and designing such as above ground structure that integrates well with background visual environment and hill side rolling topography in terms of form, color, shape and layout etc.  Aesthetically pleasing architectural planning and design of rehab buildings (on plan, front and side elevation sections) that integrates well with background visual environment and rolling hill side topography in terms of form, color, shape, layout etc.

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Review of the layout planning proposals (Refer to Figure 2.2) and artistic representation of the slum rehab buildings (Refer to Figure 2.4) indicates that Project Nirvana has attempted to integrate the project into prevailing visual environment on rolling hill side topography. The rehab building layout runs along ground contour lines and due to which minimal ground modification work will be required.

During construction phase, following key visual issues and impacts needs to be considered:

 Haphazard and indiscriminate location of construction phase facilities (such as site office, labour camps, batching plants, material storage yards etc) causing visual impact in terms of its location, material, layout, use, upkeep and maintenance etc.  Visually pleasing design and construction of transit buildings even if it is meant to be temporary structure followed by daily house keeping and maintenance;  Swift demolition of slum structures and clearing of debris;  Swift completion of clearing and grubbing activity and clearing of grub debris; and  House keeping and regular debris clearance at all construction sites.

At the ongoing rehab construction sites, project authorities have erected painted GI sheets of 3m height all along the perimeter line of work areas. This painted GI sheet fencing avoids adverse visual impacts of a typical construction site from outside. Significantly, Project Nirvana is proposing to use two of the permanent rehab buildings that are currently under construction as temporary transit buildings till all 21 rehab buildings are completed. This avoids the visual impacts associated with temporary transit building construction and its upkeep and maintenance during its occupation.

All the construction phase facilities (such as site office, labour camps, batching plants, material storage yards etc) are located within the fenced project site premises avoiding the visual impact anticipated. As these sites are located on areas that are to be developed later as part of the Project, none of these facilities will remain forever through project life cycle and add to adverse visual environment.

During operational phase, following aspects and issues will adversely impact on visual environment:

 House keeping and facility management services;  Regular painting and whitewashing of buildings and associated infrastructure components;  Abuse and misuse of building components such as roof area, walls, sunshades, stair walls, stair wells, parking space etc. Abuse and misuse

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could be due to spitting, urinating, advertising, scribbling graffiti, pasting posters etc;  Leaking sanitary pipes and fittings and overflowing underground sewerage systems;  Maintenance of road infrastructure and road furniture’s;  Up keep and maintenance of project infrastructure (water tanks, STPs, Compost yards, waste segregation centres, transformer rooms/yards etc) and social infrastructure (such as community halls, anganwadi, women centres etc) without abusing and misusing them;  Up keep and maintenance of landscaped gardens, parks, recreational spaces, playgrounds etc without abusing and misusing them;  Regular solid waste and garbage removal from the rehab area; and  Sweeping and regular cleaning of open/public places/spaces.

Table 6.12 Summary of Anticipated Impacts on Visual Environment

Impacts to consider during Impacts during Construction Impacts Operational Phase Planning Phase Phase Layout planning of the entire Haphazard and indiscriminate House keeping and facility project site that integrates well location of construction phase management services with background visual facilities (such as site office, environment and hill side labour camps, batching plants, rolling topography material storage yards etc) Aesthetically pleasing Visually pleasing design and Regular painting and infrastructure component construction of transit whitewashing of buildings planning and designing buildings followed by daily and associated infrastructure house keeping and components maintenance Aesthetically pleasing Swift demolition of slum Abuse and misuse of building architectural planning and structures and clearing of components design of rehab buildings debris Swift completion of clearing Leaking sanitary pipes and and grubbing activity and fittings and overflowing clearing of grub debris underground sewerage systems House keeping and regular Maintenance of road debris clearance at all infrastructure and road construction sites furniture’s Up keep and maintenance of project infrastructure and social infrastructure Up keep and maintenance of landscaped gardens, parks, recreational spaces, playgrounds etc Regular solid waste and garbage removal Sweeping and regular cleaning of open/public places/spaces.

Significance of Impact

The impact on visual environment will be insignificant during construction phase and moderately beneficial during operational phase.

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Factors Significance – Planning Significance – Significance – Operation Phase Construction Phase Context - Local Medium Duration - Short Long Intensity - Insignificant Minor Overall - Insignificant Moderate beneficial

6.4.9 Sustainable Resources Management

Impacts

Residential and commercial buildings consume significant amount of resources through their project life cycle. Conventionally designed buildings consume more resources than the modern buildings that incorporate latest sustainable technologies and concepts. This section presents the sustainable resource initiatives proposed under the project and its positive impact in the long run.

Water: The total water required during the operational phase of the project is about 4.1 MLD (3.9 MLD for residential buildings and 0.2 MLD for commercial buildings). Project proposes to utilise the available PMC water supply at the site premises and accordingly utility agency permission has been received. In order to reduce the water consumption at site during the rest of project life cycle, Project proposes to recycle at least 50% of treated wastewater from in-house STPs.

Storm Water Management: Storm water drains made of 600mm wide RCC trench will be constructed all along the plot area. These drains will carry storm water and discharge it into municipal storm water drains with a design capacity of 1202 cum/hr. All the surface drains will be covered with RCC gratings. The storm water from the unpaved surface will be allowed to percolate in the ground.

Rainwater Harvesting: Project Nirvana has formulated rainwater harvesting (RWH) scheme which will be constructed as part of other project proposals. The site receives a peak rain fall rate of 55 mm/hr and the system has been designed to meet the maximum rainfall rate. Rain water is proposed to be injected into the fracture zones under the land. Project is proposing to construct recharge bores and soak pits to aid in recharging ground water resource. Excess water will be drained to Municipal drains. Two RWH tanks of capacity 250 cum and 570 cum each for rooftop rainwater storage has been proposed along with 51 recharge pits/ soak pits all through the plot area.

Wastewater: The sewage generated from proposed project will be about 3.25 MLD. About 55% of wastewater will be of sullage (grey water) type and remaining 45% will be of black water type. About 2-4 STPs have been planned to treat the 3.25 MLD of wastewater generated per day. Almost 50% of wastewater received will be recycled back for gardening, flushing and landscape maintenance purposes after treatment and disinfection at STP and excess treated wastewater will be disposed off to PMC sewerage system.

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Energy: About 17.4 MW of power supply will be required for the project at an estimated rate of 4 watt of power per sq.ft of developed area. The power will be made available from the government power utility company - MSEDCL. As part of sustainable initiatives, the project proposes to have energy efficient building services, equipments, public area lighting and exterior lighting systems. Four numbers of DG sets (of 380 KVA, 320 KVA, 250 KVA and 140 KVA capacities) will be provided for power back-up for essential services such as fire fighting systems and lift systems.

Project has extensive plans to use solar energy for achieving energy conservation and the proposals include:

 Solar hot water systems for sale buildings up to top 9 floors  Solar panel lights will be installed for common facilities  Solar street lights are proposed for common areas such as open spaces, pathways, RG etc

Solid waste: About 12.2 tonnes per day of solid waste will be generated at the project site. The project plans to segregate the solid waste into wet (bio- degradable) and dry (non bio-degradable) wastes at source and deal with them accordingly. The non-biodegradable waste will be disposed off through an authorised contractor. The bio-degradable waste will be treated by vermi- composting technology and the compost generated will be used as manure in the internal landscaped gardens. The STP sludge would also be used as manure.

Others

Some other sustainable measures proposed under the project include:  All rooms are designed with adequate opening to have proper natural light and ventilation.  All public areas will have CFC or solar lights for lighting.  External aluminium windows with glass which is reflective type to reduce heat gain.  Fly-ash will be used in concrete work, block masonry work, external and internal plaster work.  All masonry work will be done with cement concrete block instead of burnt brick  All internal brick masonry walls will have gypsum plaster.  The project authorities have applied for Eco-Housing certification for sale building components of the project. The eco-housing certification program is operated by the Pune Municipal Corporation (PMC). Project hopes to attain four (4) star rating under the program where 5 star rating is the maximum.

Key impacts are summarised in Table 6.13.

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Table 6.13 Summary of Anticipated Impacts on Sustainable Resource Use

Impacts to consider during Impacts during Construction Impacts - Operational Phase Planning Phase Phase Sustainable resource Use of sustainable alternate Monitor the resource management initiatives to be technologies, materials and consumption and Implement integrated into project design practices that conserve continual improvement resources measures to sustain resource consumption over the long run.

Significance of Impact

The impact due to sustainable resource management initiatives integrated in the Project design will be significantly beneficial during project life cycle.

Factors Significance – Planning Significance – Significance – Operation Phase Construction Phase Context - Local Local Duration - Short Long Intensity - Moderate Major Overall - Minor beneficial Major – beneficial

6.4.10 Traffic and Transport

Impacts

The site can be accessed through Paud Road and Karve road on the western and southern side respectively. In the Pune City Development Plan (DP), as part of future development proposal, a DP road and HCMTR has been proposed. The alignment of both the DP road and HCMTR corridor is passing through the Project site bifurcating it into eastern and western halves. These two transport corridors will add to the transport infrastructure and circulation capacity available in the region. Land values are bound to rise higher as soon as these proposals bear fruition brining economic benefits to slum dwellers resettled at Project Nirvana site.

Project Nirvana has integrated provisions for parking of vehicles both in residential and commercial areas. In compliance of National Building Code (NBC) 2005 and SRA regulations in this regard, Project Nirvana has made provisions for parking of vehicles and the details are listed subsequently.

Table 6.14 Provisions for Parking of Vehicles in the Project

Parking Residential areas Commercial areas Cars 3739 720 Scooters 9811 963 Cycles 11159 683 Total 27075 2366 Source: EIA Report for the Project Nirvana, 2008

Besides, traffic management at the entry and exit gates of the site will be manned by Security personnel guarding the gate.

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In this context, during planning phase, following traffic and transport aspects shall be integrated in layout planning and design:

 adequate primary and secondary road network providing access to all buildings and amenities;  avoiding vehicle-pedestrian conflict through well marked pedestrian/elderly citizen movement facilities;  road side parking space;  road signs and furniture provisions;  Safe movement of vehicles and pedestrians at crossings/intersections etc.  Road side storm water drainage systems; and  Tree plantation and landscaping along medians, traffic islands, round- about etc.

During construction phase, key traffic and transport related impacts with respect to Project Nirvana site are as below:

 increased traffic volume on external network roads such as Paud Road and Karve road;  incidents and accidents involving construction site bound vehicular fleet;  material transport trucks creating hazardous situations on external network roads due to material spills and fugitive dust generation;  ensuring safe road network access to existing road users especially the school going children and surrounding residential community;  increased load on local network roads within the site;  haphazard and indiscriminate road side parking and stopping of vehicles along external and internal road networks;  avoiding incidents and accident prone spots near entry/exit gates; and  Ensuring free road access through demolition period for existing slum dwellers.

Discussions with project management team of KUL indicates that traffic movement is co-ordinated in consultation with local community and the school-going time for children are avoided to move in transport fleet vehicles and other heavy machineries. The community relationship team consisting of KUL staff and local community members take lead in safe movement of construction site bound traffic, especially within project site.

As part of the EIA study done in 2008, traffic survey was conducted near the Project site at Paud Road. The traffic survey results indicate that about 14,381 vehicles ply on Paud road per day on both sides. The EIA study assessed the capacity of Paud road vis-à-vis peak hour traffic volume as per Indian Road Congress (IRC) specifications and found that the 2008 traffic volume levels are at 54.05% and 40.81% of available design capacity of Paud road on each side of the traffic. On the Law college road the 2008 traffic volume was at 34.72% of design capacity of the road. As the main access road still has capacity to bear

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an increase in traffic volume during the construction phase of the project, congestion is not anticipated.

During operational phase, no major impact on traffic and transport infrastructure is anticipated as the existing roads (Paud road and Karve road) and proposed transport infrastructure (DP road and HCMTR corridor) will be adequate enough to meet the increased traffic volume originating from Project Nirvana site. However, up keep and maintenance of road infrastructure including road surface, signs, furniture, islands, round-about, medians, landscaping and plantation is critical to effective and safe functioning of road infrastructure. Key impacts are summarised subsequently.

Table 6.15 Summary of Anticipated Impacts on Traffic and Transport

Impacts to consider during Impacts during Construction Impacts Operational Phase Planning Phase Phase adequate primary and increased traffic volume on Upkeep and maintenance of secondary road network external network roads internal road infrastructure components avoiding vehicle-pedestrian incidents and accidents Project Nirvana site adding to conflict involving construction site traffic volume on existing and bound vehicular fleet proposed road networks road side parking space material transport trucks - creating hazardous situations on external network roads road signs and furniture ensuring safe road network - provisions access to existing road users especially the school going children safe movement of vehicles and haphazard and indiscriminate - pedestrians at road side parking and crossings/intersections stopping of vehicles Road side storm water avoiding incidents and - drainage systems accident prone spots tree plantation and ensuring free road access - landscaping along medians, through demolition period traffic islands, round-about

Significance of Impact

The impact on traffic and transport infrastructure will be insignificant during construction phase and moderately beneficial during operational phase.

Factors Significance – Planning Significance – Significance – Operation Phase Construction Phase Context - Regional Local Duration - Medium Long Intensity - Minor Minor Overall - Moderate adverse Minor adverse

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6.4.11 Health and Safety

Impacts

As per ADBs SPS 2009, health and safety aspect comprises of both occupational health and safety aspects and community health and safety aspects.

The key requirement under ADBs SPS 2009 on occupational H&S aspect is providing a safe and healthy working environment for the site workers including protection from physical, chemical, biological, and radiological hazards. It warrants that an appropriate H&S management system comprising of following key elements are put in place:

 identifying and minimizing the causes of potential hazards to workers through expert oversight;  providing preventive and protective measures;  providing appropriate equipment to minimize risks;  training workers; and  documenting and reporting occupational accidents, diseases, and incidents; emergency prevention, preparedness, and response arrangements

The key requirement under ADBs SPS 2009 on community H&S aspects is to identify and assess the risks and ensure safety of affected communities during the entire project life cycle. Community H&S aspects also include potential exposure to both accidental and natural hazards. SPS 2009 requires project proponent to inform affected communities of significant potential hazards in a culturally appropriate manner and be prepared to respond to accidental and emergency situations. This preparation will include response planning document that addresses the training, resources, responsibilities, communications, procedures, and other aspects required to respond effectively to emergencies associated with project hazards. Appropriate information about emergency preparedness and response activities, resources, and responsibilities will be disclosed to affected communities.

Notably, KUL has established an Integrated Management System (IMS) at its corporate office. The IMS incorporates all three certification standards and systems such as ISO 9001:2008, ISO 14001:2004 and OHSAS 18001:2007. In line with ISO systems, KUL has promulgated a Quality, Environment and OHS Policy since 1st Jan 2009. The QE&OHS Policy clearly states that KUL strives to prevent injury and occupational related illness to its people by adopting appropriate safety measures with training and latest technology.

In this context, during planning phase, the key community H&S aspects that need to be integrated include the following:

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 Architectural planning and design of both rehab and saleable buildings to integrate adequate sunlight and ventilation requirement to each of the individual flats, indoor air quality issues and noise resonance aspects;  Mechanical (lifts) and electrical utilities (water pumps, transformer yards, MCB panel and metering rooms etc) planning and design to integrate safety precautions, procedures and fire proof systems.

Project has formulated a comprehensive fire fighting system and the salient features of its design include the following:

 Underground fire water storage tank (separate for each building) with baffle walls  Overhead water storage tank (for each building) and will be connected to the wet riser through a booster pump with a non return valve and gate  Valve arrangements.  Automatic sprinkler system will be provided in the car parking areas  Fire pump, Booster pump, Sprinkler pump and Jockey pump arrangements in the fire fighting system with adequate head and pressure  Power supply will be provided to fire fighting pumps on independent circuit with one pump run on diesel.  Stand by pump of equal capacity will be provided for each building.  A sprinkler pump along with jockey pump will be provided for automatic sprinkler system.  Alternate source of Power supply will be provided from a separate sub station DG set.  Portable fire extinguishers such as: one (1) dry chemical powder type fire extinguisher of 5 kgs capacity with wall mounting bracket having ISI certification mark and two buckets filled with dry, clean sand will be kept in electric meter room;  20 dry chemical powder type fire extinguishers of 5 kgs capacity having ISI certification mark and four buckets of dry, clean sand will be kept in the each car parking area.  Manual fire alarm system will be provided with main control panel at ground floor and pill boxes and hooters at each floor level. The layout of fire alarm will be in accordance to relevant IS specifications  Access for fire tenders will be through the 18 m wide road on the south of the plot layout  Car parking will be restricted to stilted areas at ground level  Flat entrance and kitchen doors of each wing will be of solid core having fire resistance of not less than half an hour (solid wood of 45mm thickness)  Electric cable shafts will not open in the staircase enclosure  Electric meter room will be at ground floor level and adequately ventilated. Electric shafts will be sealed at each floor level with non combustible material such as vermiculite concrete. Inspection door for the shaft will have two hours fire resistance.

The fire fighting system has been designed is in compliance to Fire Safety guidelines of PMC. The system components will be inspected and certified by

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Fire Safety Officers from Pune Municipal Corporation after installation after which the building occupancy certificate will be issued which is critical document to move slum dwellers into the new rehab tenements. Hence, fire related incidents and accidents anticipated can be well managed with minimal loss of life and property.

During construction phase, the key H&S impacts anticipated include the following:  Health and hygiene issues at labour camp sites.  Occupational H&S issues at batching plant site, material storage and scrap yards, onsite material testing laboratory, building construction sites (covering all activities such as (Clearing and grubbing, foundation excavation and construction, superstructure construction, electrical works, plumbing works, carpentry works, tiling works, painting works) and construction of infrastructural facilities and utilities.  Community H&S issues at transit tenement site, utility relocation sites, demolition of cleared slum areas.  Community H&S issues along road networks used by construction vehicle fleet.  At demolition sites (of existing slum structures), presence of asbestos wastes (in the form of corrugated asbestos roofing sheets) could be a potential OHS hazard.

The typical occupational H&S risks and associated hazards at construction sites has been identified and presented as part of KULs IMS Manual (Refer OHS/501/Rev-1). The manual identifies about 30 hazard-risk scenarios based on processes and activities. About 20 work instructions have been formulated under KUL’s IMS to guide safe execution of various construction activities. KUL has also instituted auditing, reporting, training and documentation systems as part of its IMS pertaining OHS element.

The community H&S issues anticipated during construction phase include the following:

 Health and hygiene issues of residents of transit tenements due to following aspects: o Leaking sanitary pipes and fittings on buildings o Overflowing underground sewerage systems o Dumping solid waste and floor sweepings into sewerage system manholes o Indiscriminate dumping of domestic solid waste o Indiscriminate spitting and urinating in open/public spaces o Maintenance of underground and over ground drinking water tanks and integrity of supply systems including metering pits o Health and hygiene issues (clean drinking water, upkeep and maintenance of washrooms/bathrooms, safe cooking habits, cleaning floors, washing clothes etc)

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o Health impacts due to poor indoor air quality such as cooking without adequate ventilation using firewood or kerosene  Exposure of transit tenement residents to fire hazards (due to electrical short circuiting, LPG cylinder blasts or other such incidents), electrical hazards and mechanical failure of lift machinery.  Exposure to fugitive dust, electrical hazards, structural failure etc at demolition sites and utility relocation sites.

During operational phase, the key H&S issues could be the following:

 Community H&S issues as highlighted above for transit tenements.  Occupational H&S issues during routine building repair and maintenance such as plumbing works, electrical maintenance, lift maintenance, carpentry works, painting works and associated infrastructure utility/facility O&M activities.

Table 6.16 Summary of Anticipated Impacts on Health and Safety Aspects

Impacts to consider during Impacts during Construction Impacts Operational Phase Planning Phase Phase Integrate adequate sunlight Health and hygiene issues at Community H&S issues at and ventilation requirement to labour camp sites rehab buildings. individual flats, indoor air quality issues and noise resonance aspects; Mechanical and electrical Occupational H&S issues at Occupational H&S issues utilities planning and design construction sites during routine building repair to integrate safety precautions and maintenance and systems. Community H&S issues at transit tenement site, utility relocation sites, demolition of cleared slum areas At demolition sites, presence of asbestos wastes

Significance of Impact

The impact on H&S aspects will be minor adverse during both construction and operational phase.

Factors Significance – Planning Significance – Significance – Operation Phase Construction Phase Context - Local Local Duration - Medium Long Intensity - Minor Minor Overall - Minor adverse Minor adverse

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6.4.12 Natural Disasters

Impacts

Among the natural disasters, earthquakes could be the potential disaster that could strike the project region as Pune City falls under Zone III as per seismic zone map for India prepared by Bureau of Indian Standards (BIS). Zone III is defined as a moderate risk zone having a maximum intensity of around VII on MSK scale. An analysis of historical earthquake incidents in Pune reveals that the city has experienced some moderate to many low-intensity earthquakes. None of the major earthquakes have originated in Pune City. Recent incidents of earthquake of low intensity were observed in the region near Pune in May, 2004 and another one in July 2008.

Earthquake resistant design of building structures have been incorporated into Development Control Rules and SRA regulations. Regulatory permits and building plan approvals are issued only after the structural design satisfies the earthquake resistant design criteria defined in the NBC 2005.

Though the project site is located on the foot hills with rolling topography, landslides are uncommon even during heavy monsoon season due to the rocky geological setting. Urban flooding is again not anticipated due to favourable topography of the project site.

Fire hazard (due to electrical short circuiting or LPG cylinder blast) is one of the key emergency events anticipated in a typical residential and commercial building project.

In this context, during planning phase, the key aspects to be integrated include:  Account for natural disaster and emergency situations probable at the Project site and integrate them in master plan and infrastructure planning and design.  Account for natural disaster and emergency situations in the architectural planning and structural design of both rehab and saleable buildings.  Integrate fire prevention systems in the design of mechanical and electrical utilities.  Review and integrate disaster management and emergency response guidelines issued by regulatory authorities.

During construction phase, the major emergency event could arise due to fire accidents, electrical short circuits/electrocution at construction sites and transit tenements. At transit tenements, additional emergency situations could arise due to major earthquake events leading to structural failure, LPG gas leak/blast, lift failure and emergency health situations of individual residents.

During operation phase, emergency situations cited above for transit tenements will be applicable through the rest of project life cycle. Preventive

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maintenance of fire systems, lift systems and electrical MCB is key to avoid emergency situations. Awareness programs and mock drills among resident community along with clear division of emergency management responsibilities among the residents’ building society management are critical to manage emergency situations.

Table 6.16 Summary of Anticipated Impacts due to Natural Disasters

Impacts to consider during Impacts during Construction Impacts - Operational Phase Planning Phase Phase Account for natural disaster fire accidents, electrical short fire accidents, electrical short and emergency situations in circuits/electrocution at circuits/electrocution master plan and infrastructure construction sites and transit planning and design. tenements Account for natural disaster major earthquake events major earthquake events and emergency situations in leading to structural failure of leading to structural failure of the architectural planning and transit buildings buildings structural design of buildings. Integrate fire prevention LPG gas leak/blast, lift failure LPG gas leak/blast, lift failure systems in the design of and emergency health and emergency health mechanical and electrical situations of individual situations of individual utilities. residents residents Review and integrate disaster - - management and emergency response guidelines issued by regulatory authorities.

Significance of Impact

The impact due to natural disasters and emergency scenarios will be minor adverse during construction phase and insignificant during operational phase.

Factors Significance – Planning Significance – Significance – Operation Phase Construction Phase Context - Medium Local Duration - Short Short Intensity - Minor Minor Overall - Minor adverse Insignificant

6.5 ASSESSMENT OF SOCIO-ECONOMIC IMPACTS

The proposed slum redevelopment project by KUL involves a multitude of stakeholders, each of whom would be required to co-ordinate and align together for the successful commissioning of the project. This alignment is likely to result in socio-economic impacts of differing magnitudes due to the prevalent nature and context of the area and location as previously discussed in the socio-economic baseline. Key parameters of the socio-economic environment have been merged to indicate the range of potential impacts from project activities. Where relevant, distinction between the construction and operations phase has also been made.

Social impacts have been discussed under the following sub-sections:

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 Physical displacement of ineligible tenements: o Impact on livelihoods, social networks; o Impacts on Vulnerable Households;

 Impact on livelihoods: o Impacts on Commercial Structures; o Impacts on Income Generating Opportunities;

 Impact of in-situ rehabilitation: o Shifting/Eviction of Families o Improvement in the Quality of Life; o Upgradation of Local Infrastructure.

 Impacts on Local Demography and Resources: o Exponential Population Increase in the long-term; o Additional Pressure on Local Infrastructure; o Impact on adjacent land in the construction phase.

 Impact on community health & safety: o Community health & safety during construction; o Demolitions of Households; o Nuisance and Traffic Impacts;

 Local Economic Impacts; o Creation of employment and procurement opportunities during construction; o Escalation in land prices; o Income Restoration.

 Community Issues: o Local Community Development; o Increase Community Dependence.

6.5.1 Physical Displacement of Ineligible Tenements

“Eligibility” of a slum dweller for Project Nirvana is determined by the ownership of the existing structure and his/her domicile in the census slum before or as on January 1st 1995. Those slum dwellers who do not meet this criterion as per the SRS are declared non-eligible and hence not eligible of the benefits under the SRS scheme. At present, the Annexure II survey by the Slum Rehabilitation Authority and the Pune Municipal Corporation is under progress. In addition to the SRA entitlements, KUL is also coming up with an ineligibility policy which would document the approach of dealing with the ineligibles. The subsequent figure discusses the number of tenements that are likely to be ineligible for in-situ rehabilitation under the SRS:

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Figure 6.3 Estimates of Ineligible Tenements

100% 90% 80% 70% 60% Percentage 50% 40% 30% 20% 10% 0% Total Non Eligible Nagar Park Rautwadi Hanuman Eligible Park Wadarvasti Vasant Nagar Rajeev Gandhi Kilewadi/Indira Name of Block

*Source: KUL

Overall, it is likely that approximately 25% of the total number of slum tenements is likely to be declared ineligible for rehabilitation in accordance to the government regulation of cut-off date as January 1st 1995. However, discussions with the SRA officials indicate that KUL is planning the Nirvana Hills Phase 2 project on the basis of a target of 5000 families that will be rehabilitated.

Senior officials indicated that even if the Government of Maharashtra increases the eligibility cut-off to 1st January 2000, up to 500 slum dwellers are likely to be declared ineligible. There are plans in place to incorporate these ineligible households for rehabilitation through the Central Government low cost housing scheme of the “Rajeev Awaas Yojana” which is in its inception stage. However, as of now there are no definitive plans to accommodate the ineligibles in the proposed rehabilitation buildings at KUL’s own expense/initiative and individual negotiations or settlements with such households are already in progress.

Box 6.2 Residual Issues at Wadar Vasti

Under the first phase of the project which was carried out in the Wadar Vasti area, back in 2000, the erstwhile Megapolis Developers had already shifted 463 slum dwellers and 25 shops into eight rehabilitation towers. However as per the SRA scheme, there were about 8-10 non-eligible families who were still residing in slums inside the complex. KUL have over the past month or two managed to reach an agreement with all but three families. Around five (5) families from this area who have given conditional consent for their rehabilitation have been relocated temporarily to the transit building in Rajiv Gandhi park and two (2) families have been successfully rehabilitated into the Wadar Vasti rehabilitation buildings itself.

In this context, it should be noted that if families voluntarily agree to move out of the slum on the basis of a negotiated settlement, their physical displacement

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cannot be termed as involuntary. This issue/impact is discussed in further detail in the Rehabilitation Plan.

Impact on the Vulnerable Households

Currently there is a lack of system/mechanism in place to trace/track/ monitor the status of the families/households that were rendered ineligible and hence not entitled to tenancy and other benefits. These categories of impacted families are likely to be most adversely impacted with eviction/separation form their established networks and accesses. There needs to be a process/mechanism in place to document/record and monitor these families and provide support in their coping mechanisms, in case they are facing difficulties.

Significance of Impact

In terms of significance, although physical displacement is likely to lead to other adverse impacts such as temporary disruption of livelihoods and loss of social networks, overall, the impact has been assessed to be moderate due to the existence of mechanisms by which negotiated settlements can be reached with slum dwellers.

Context Duration Intensity Overall Impact Moderate Long-term Moderate Moderate

6.5.2 Livelihood Impacts

Consultations with slum dwellers indicate that the occupation and livelihood profile among the habitants and is dependent upon education levels, existing job opportunities in the area and the demand and supply of labour within the unorganized sector.

Impacts on Commercial Structures

It is understood that of the slum tenements awaiting rehabilitation, 78 structures are commercial, of which broad estimates indicate that more than 30-40% of these commercial tenements are likely to be ineligible for rehabilitation. Such a displacement is likely to cause adverse economic impacts on the structure owner as well as his/her dependents. Inspite of negotiated settlement with KUL, there are likely to be short to medium term income losses and potential business interruption risks for structures such as flour mills, tailoring, provision stores which were dependent upon the customer base provided by the slum community.

Consultations with owners of commercial structures rehabilitated in Wadarvasti also indicate the following issues during the construction phase:

 Commercial owners are given the option of opting for transit arrangements to set-up shop or a monthly commercial rental allowance. In

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case of the latter, there are known to be business and profit losses due to shifting/transition;  For those that avail of rental allowance each month, the amount of rent for commercial structure is the same as that for residential, i.e. INR 7000/month. This is inadequate to rent out similar property in the nearby area and hence the owner prefers to live off the rent, thus leading to business interruption;  The areas of commercial structures within rehabilitation buildings are generally less than 200 ft2 and depending upon the nature of activity, this area is inadequate to continue the earlier activity. This is the case with garages/mechanics as well as existing institutes that offer training, computer education etc.

During the operations phase, the rehabilitated commercial tenements are likely to experience an increase in their customer base and business due to an improved overall quality of life in the area. For instance, at Wadarvasti, discussions with an erstwhile provisions store owner brought out his expansion into a provision cum medical store thus leading to a direct increase in income and profits post rehabilitation.

Significance of Impact

In terms of significance, the impacts on commercial structures can be summarised as follows:

Phase Context Duration Intensity Overall Impact Planning Local Long-term Moderate Moderate Construction Local Medium Moderate Moderate Operations Local Long-term Major Major Beneficial

Impact on Income Generating Opportunities

The socio-economic survey indicates that average monthly incomes of households’ ranges from INR 1000 to over INR 20,000. Consultations indicate that the settlement pattern and socio-economic dynamic within the slum also creates the following stream of income-generation which are likely to get disrupted post-rehabilitation:

 Loss of income from rent of additional storey or part of hut. This may be up to the extent of 30 to 40% of all households in any slum society;  Discussions with the corporator indicated that there are approximately 25 individuals who illegally own over 15-20 tenements in the slums onsite and who earn income from the same through rent. These “slum lords” are likely to create a pressure group unless KUL manages to meet/exceed their expectations on the settlement;  Loss of income for those employed with commercial stalls or galas which have been deemed ineligible.

Significance of Impact

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Context Duration Intensity Overall Impact Moderate Long-term Moderate Moderate

6.5.3 Impacts from In-situ rehabilitation

As discussed in the report, Project Nirvana involves the in-site rehabilitation of approximately 5000 households into vertical buildings with modern amenities and apartments of 269 ft2 as per the guidelines of the Slum Rehabilitation Authority. Such large-scale slum rehabilitation has overall beneficial impacts on the quality of life and livelihoods of the slum dwellers; however, there are several aspects within the same that needs closer consideration.

Shifting/Eviction of Families

The SRA scheme has safeguards in terms of provision of transit housing for the people who are likely to be impacted by the proposed development. The transit housing cannot accommodate non-eligible slum dwellers. Typically, the practice of building a transit house (mostly multi-storeyed) either within or close to the site area is practiced by the developers where the eligible households are provided temporary dwelling units and common infrastructure/service facilities (like sanitation, drinking water etc) on the basis of a lottery system. Issue like poor condition/services at these transit accommodation, long period (sometimes as long as 3-4 years) are common resulting in hardships to the impacted families.

However in the case of KUL, they propose to use two of their fully constructed towers as the transit building. People to be evacuated will be accommodated in this building temporarily until they are moved into their allotted apartments. Once a phase is rehabilitated, the next phase of evacuated families will occupy these buildings would be finally reconverted into rehabilitation building for the final phase of evicted households.

The eligible households, as has been discussed above, are provided with a secure tenure during the transit/construction phase. However, the SRA scheme lacks provisions for the ineligibles (tenants, those residing after the cut off date, families residing on first and second floors etc) who have no safeguards to mitigate the adverse impact of shifting or physical displacement. Many a times this shifting/eviction results in direct impact on their livelihoods rendering them either vulnerable or exposed to the vulnerability of the situation. The other fall out of these is the adverse impacts on the overall family and their access to education, health care, social networks other support mechanisms.

Significance of Impact

Phase Context Duration Intensity Overall Impact Planning Local Short-term Moderate Moderate Construction Local Medium Moderate Moderate

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Operations Local Long-term Major Major Beneficial

Severance of Community Bond and Impact on Social Networks

The community living within the mosaic of an old slum settlement of mostly Marathi families inherently possesses strong bonds and kinship due to their cohabitation and combined existence within the setting of the slum. The displacement of ineligible families as well as rehabilitation into organized housing may lead to the severance of these networks. In addition, the change in the dynamic from a flat settlement pattern to living behind closed doors is likely to entail adjustment in the social norms and way of life.

Significance of Impact

Context Duration Intensity Overall Impact Moderate Long-term Moderate Moderate

Improvement in the Quality of Life

The objective of the slum rehabilitation scheme that is being implemented through Project Nirvana is to bring about an improvement in the quality of life and several other human development indicators by the rehabilitation of slum dwellers living in sub-standard conditions into organized housing with security of tenure. Consultations with the local corporator as well as the local community across Indira Park, Kilewadi etc indicates that the slum dwellers perceive the following benefits:

 Improved access to drinking water and sanitation and thus amelioration of the health & hygiene conditions;  Increased potential of rehabilitated slum dwellers to avail of credit facilities due to security of tenure;  Addition to existing income generating opportunities due to the parallel development of the sale component.

Significance of Impact

Context Duration Intensity Overall Impact Local Long-term High Major Beneficial

Up-gradation of Local Infrastructure

SRA Guidelines make it mandatory for KUL to provide not only basic facilities and utilities required for housing but also amenities, such as community halls, temples, anganwadis etc. which can upgrade common resources. In addition, the key infrastructure benefits perceived by the local community during the operations phase of Project Nirvana are (a) improvement of access due to widening and strengthening of the existing ARAI road and the proposed DP Road; (b) Improved access to health and social infrastructure as the shifting of existing hospitals and municipal schools will also entail expansions in their

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capacities; and (c) improved availability of water in the immediate vicinity of the site due to the proposed emphasis on rainwater harvesting, reusing treated water etc.

Significance of Impact

Context Duration Intensity Overall Impact Local Long-term High Major Beneficial

6.5.4 Impacts on Demographic Changes and Local Resources

The socio-economic baseline discusses that the slum tenement density in the project area, i.e. 55 tenements/hectare is significantly lower as compared to the city of Pune. At present, the total population on site (inclusive of the completed rehabilitation at Wadarvasti) is approximately 20,000 people. There will be a directly proportional increase in the population of the project area during the construction and operations phase.

Increase in Population Density

Over the next five years, i.e. during the construction phase, it is expected that as KUL has adopted a strategy of in-situ transit arrangement to the extent possible, there will be a short-term increase in population which will include the construction workforce as well as the local community. This population in the operations phase is likely to see an exponential growth due to the sale of residential and commercial property in the open market. At present, there are no reasonable estimates of the total number of people likely to inhabit the project area subsequent to completion of construction activities. However, discussions with the project proponents and local authorities indicate that at least 75,000 people (i.e. a change in the baseline by over 200%) are likely to either reside or access (for commercial establishments) the area.

Significance of Impact

In terms of significance, an exponential increase in population can lead to adverse impacts such as stress on local infrastructure but can also create significant economic benefits in the project area.

Context Duration Intensity Overall Impact Moderate Long-term Major Major

Pressure on Local Infrastructure

Project Nirvana will need to incorporate a town planning approach in terms of infrastructure planning for key utilities such as power, water (including re- use) and sanitation/drainage networks. As discussed in the baseline, the current utilities onsite have been installed by the Pune Municipal Corporation to meet the requirements of the slum dwellers and have not taken into account long-term development of the area. In case there is no upgradation of existing systems, especially sewerage, power transmission lines etc. the rapidly

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expanding population density will create significant pressures on the local infrastructure and may become unsustainable in the long-run. Significance of Impact

Context Duration Intensity Overall Impact Moderate Long-term Major Major

Impact on Adjacent Land in the Construction Phase

In the absence of adequate management systems, some of the potential impacts on adjacent land include:

 Typically, construction activities can temporarily impact the land immediately adjacent to the existing site area if excavated soil or other material is haphazardly stored;  There may also be issues of community conflict if private lands of ARAI or even adjacent slums are accessed for temporary storage or usage without formal permission; and  The prevalence of economic opportunities could attract several businessmen, workers in search of employment and other such community which may lead to encroachment on the existing land in the immediate vicinity.

For Project Nirvana, the significance of such impacts is likely to be minor due to the adequacy of existing land availability to contain any major construction activity. However, adjacent land is likely to be impacted during the construction of the access road as well as transmission lines.

Significance of Impact

Context Duration Intensity Overall Impact Local Medium-term Low Minor

6.5.5 Community Health & Safety

Influx of Workers during the Construction Phase

The construction phase for Project Nirvana began in March 2011 (with the construction activities near Kilewadi area and continuing construction of the sale component at Wadarvasti) and is likely to carry on up to March 2016. Peak construction period is likely to last for over 3 years which is likely to see around 700 to 1500 construction workers to be deployed project site. Construction workers will be sourced by contractors engaged in foundation, civil works and other jobs and are likely to include requirement for unskilled, semi-skilled and skilled workforce.

Labour camps on site are being managed by respective EPC Contractors who are responsible for the construction of temporary labour camps and provide the workers with water supply, electricity, sanitary facilities, medical aid and other basic amenities. Due to the proximity of the site to nearby slum areas, if ERM ESIA: KUMAR SINEW DEVELOPERS PROJECT # I8390/ 0138632 MARCH 2012 172

the contracted labourers are not adequately managed, there may be adverse impacts to the local community. The influx of migrant workers in the short to medium term is likely to have the following risks:

 Pressure on key local infrastructure such as water, healthcare, electricity;  Spread of communicable diseases, especially sexually transmitted diseases, which accompany many major constructions;  Lack of hygiene and adequate sanitation facilities would create health ailments related to food poisoning or diseases like malaria, viral fever, gastroenteritis which could spread within the community; and  Risk of labourers (especially migrant) encroaching upon land in the adjoining slum area.

Significance of Impact

Context Duration Intensity Overall Impact Local Short-term Moderate Moderate

In spite of the risks from influx of migrant workers, there are also positive effects which are likely to benefit the local community in the immediate vicinity of the project area:

 There would be sub-contractors or casual labourers who are typically “camp followers” who would find their own accommodation in adjoining and existing slums. This leads to short-term income generating opportunities;  Short-term petty business opportunities targeted to the labour camps;  Increase in daily wage rates for labour, and an enhancement of local skills and skill sets through interaction of local labourers with the skilled migrant workers.

Significance of Impact

Context Duration Intensity Overall Impact Medium Short-term Moderate Moderate Beneficial

Demolition of households

As mentioned earlier, KUL plans to rehabilitate the entire area in phases and their plan of operation is to immediately demolish those hutments whose families have signed the agreement. Therefore, the demolition of hutments would take place in rather haphazard manner. This might result in the existence of demolished structures in between the settlement areas. This will pose a significant health and safety risk to the families who are yet to evacuate from that area. The resulting debris will especially be a safety risk especially as roofing sheets are known to contain potential asbestos containing material which in a friable state is extremely dangerous to the respiratory system.

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Significance of Impact

Context Duration Intensity Overall Impact Medium Medium-term Moderate Moderate

Nuisance Impacts and Traffic Movements

As the construction of transit accommodation as well as rehabilitation buildings are in phases, the construction activity could lead to increased nuisance level from air emissions and noise due to transportation of material and equipment as well as labourers. The construction activity will also result in water logging in mud pockets which will then become the fertile breeding ground for mosquitoes and eventually lead to diseases like malaria. In construction sites, there is an apparent degradation of the water and air quality and therefore greater vigilance have to be maintained by the KUL authorities to prevent any disease outbreaks. There is also likely to be temporary traffic impacts like accidents, loss of property, diversions or blockage of access etc due to narrow roads.

Significance of Impact

Context Duration Intensity Overall Impact Medium Medium-term Moderate Moderate

6.5.6 Impacts to the Local Economy

Creation of employment and procurement opportunities

Project Nirvana is likely to create the following direct and indirect employment opportunities:

 Civil works for the rehabilitation buildings may require local subcontractors and unskilled labour from the local area;  Self- employment options for individuals possessing vocational or technical training skills like electricians, welders, fitters etc, which are likely to be sourced locally;  Project Nirvana and associated construction of the sale building will eventually lead to permanent job opportunities in the organized and unorganized sector. There is likely to be increased demand for security, kitchen help, need for drivers etc;  A multiplier effect will be felt on the creation of indirect employment through the local community establishing small shops like tea stalls, supply of intermediate raw materials, repair outlets, hardware stores etc. However, these are likely to be temporary.

Significance of Impact

Context Duration Intensity Overall Impact Local Medium-term Moderate Moderate

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Beneficial

Escalation of Land Prices

Project Nirvana is being developed in the model of a township project wherein the slum rehabilitation will be integrated with commercial and residential real estate as well as other amenities and welfare facilities. The project area is centrally located amid a neighbourhood comprising of educational institutes and limited industrial development thus making it a prime location. Discussions with the local corporator indicate that there has been a trend in rise of land values in anticipation of the project and associated development in the immediate vicinity. The adjoining slum areas (not included in the scheme) have seen buying and selling of structures as well as increase in rental values, most of which is manipulated by existing slum lords and property brokers.

Significance of Impact

Context Duration Intensity Overall Impact Medium Medium-term Moderate Moderate

Income Restoration

In the long-term, the gradual increase in the occupation of residential and commercial structures is likely to lead to creation of additional income- generation opportunities through potential for markets, vocational centres etc. all of which are particular to a township project. In addition, the local economy is likely to be cushioned by the post-construction boom and bust effect due to the “phased approach in development” and simultaneous construction of the rehabilitation and sale component. The local economy is likely to be strengthened as a result.

Significance of Impact

Context Duration Intensity Overall Impact Medium Medium-term Moderate Moderate Beneficial

6.5.7 Community Issues and Expectations

Community Dependence

The experience of the rehabilitation of Wadarvasti as well as the ongoing activities at the transit arrangement suggest that the community expects KUL to offer significant support in terms of maintenance in the post-construction phase. Legally, the defect liability period of the builder, in accordance to the SRA guidelines is 3 years, however, the corporator has insisted that KUL commit to at least 10 years of defect liability wherein the cooperative society would need to be managed and the builder would need to provide for a corpus fund per tenement to cover this agreement. Such an agreement is likely

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to create dependence of the cooperative society on the project proponent and it is not sustainable in the long-run.

Significance of Impact

Context Duration Intensity Overall Impact Local Medium-term Long-term Moderate

Community Development in the Construction and Operations Phase

The project proponents are likely to undertake community development activities which would aim at improving livelihoods and social infrastructure networks of the local community. NGOs and Community Based Organizations, such as Vatsalya, are likely to be involved in health camps, educational literacy initiatives and even plantation activities in the hill-top hill-slope area. In addition, the amenities that are mandated by the slum dwellers can be used by existing CBOs, mahila mandals to improve community networks and activities.

Significance of Impact

Context Duration Intensity Overall Impact Local Medium-term Moderate Moderate Beneficial

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Box 6.3 A perspective on the challenges ahead

Subsequent to the construction phase, all eligible families will be rehabilitation into r allotted apartments from the transit buildings. These slum dwellers are then required to register their societies with 11 to 15 members and select a chief promoter. One of the biggest challenges to KUL during the implementation will be to bring about an alignment and integration of formal and informal systems of functioning of the various stakeholder groups. These include but are not limited to:

 Informal grievance redressal systems within a slum society;  Strong internal systems within a slum to provide for safeguards to any ineligible households;  Power dynamics and influence of external agents like the local municipal corporator;  The ways adopted by the industry to deal with or manage the local community issues historically;  The guidelines as proposed by the Slum Rehabilitation Authority;  KUL’s own systems which have been successfully applied to other SRS projects; and  The required systems by the Lenders.

Experience of slum redevelopment projects in other parts of Pune as well as a first-hand observation of the completed buildings at Phase I indicate that there is a tendency of the slum community to carry on the same “habits” and way of living from their earlier settlements into their rehabilitation units. This implies that there may not be a real time change in the overall standard of living in terms of hygiene and sanitation practices. Secondly, there is a risk to the overall upkeep and maintenance of the society. In such a scenario the outcomes and objectives a slum redevelopment scheme, in terms of helping the slum community to avail of indirect opportunities to enhance their living conditions and income generating capacities, are diluted and slum communities can go back to living in their old ways.

The slum dwellers will be exposed to a different lifestyle once they are rehabilitated. To ensure a successful orientation to the new lifestyle, it is absolutely essential that KUL arranges the concerned vendors for activities like solid waste management, plumbing and electricity works, lift maintenance, grievance redressal mechanisms etc. Such support is essential to ensure that the rehabilitated population do not slip away into old practices and maintain basic hygiene factors.

ERM ESIA: KUMAR SINEW DEVELOPERS PROJECT # I8390/ 0138632 MARCH 2012 177 Annex 1

Ownership related Details of the land

Environmental and Social

Management Plan for Project Nirvana: Pune, India

Kumar Sinew Developers Private Final Report Limited March 2012

www.erm.com

Delivering sustainable solutions in a more competitive world FINAL REPORT

Kumar Sinew Developers Private Limited Environmental and Social Management Plan for Project Nirvana: Pune, India

23 March 2012

Reference : I8390

Rutuja Tendolkar Prepared by: Consultant

Neena Singh Reviewed & Partner Approved by:

This report has been prepared by ERM India Private Limited, with all reasonable skill, care and diligence within the terms of the Contract with the client, incorporating our General Terms and Conditions of Business and taking account of the resources devoted to it by agreement with the client.

We disclaim any responsibility to the client and others in respect of any matters outside the scope of the above.

This report is confidential to the client and we accept no responsibility of whatsoever nature to third parties to whom this report, or any part thereof, is made known. Any such party relies on the report at their own risk.

ABBREVIATIONS

ADB Asian Development Bank ADB SPS Safeguards Policy Statement By ADB ARAI Automotive Research Association Of India BOD Biological Oxygen Demand CAG Community Audit Group CBOs Community Building Organisations CDGR Community Disclosure and Grievance Redressal CLO Community Liasion Officers CO Carbon Monoxide CPCB Central Pollution Control Board CRO Community Relations Officer CRT Community Relations Team CTE The Consent To Establish CTO Consent To Operate DEOC District Emergency Operation Centre EC Environmental Clearance ECC Emergency Control Centre EHS Environmental Health And Safety EP Rules Environment Protection Rules EPC Engineering, Procurement and Construction ERM Environmental Resources Management Pvt Ltd ESIA Environmental And Social Impact Assessment ESMP Environmental And Social Management Plan FSI Floor Space Index GAP Gender Action Plan GRCO Grievance Redressal Consultation Officer GSDA Groundwater Survey and Development Agency HC Hydrocarbons HCMTR High Capacity Mass Transport Route IFC International Finance Corporation KUL Kumar Sinew Urban Developers Limited LPG Liquefied Petroleum Gas MIS Management Information Systems MoEF Ministry Of Environment And Forests MPCB Maharashtra Pollution Control Board NAAQS National Air Ambient Air Quality Standards NDZ No-Development Zones NGO Non-Governmental Organisation NOx Oxides Of Nitrogen NSDF National Slum Dwellers Federation O&M Operation And Maintenance OHS Occupation Health And Safety PERT Program Evaluation and Review Technique PMC Pune Municipal Corporation

PPE Personal Protection Equipment PWD Public Works Department RAP Resettlement Action Plan RMP Risk Assessment Plan RSPM Respiratory Suspended Particulate Matter RTI Right to Information SEAC State Level Expert Appraisal Committee SEIAA State Environment Impact Assessment Authority SOx Oxides of Sulphur SPM Suspended Particulate Matter (), SRA Slum Rehabilitation Authority SRS Slum Rehabilitation Scheme STP Sewage Treatment Plants TDR Transferable Development Rights VOCs Volatile Organic Compounds

Contents

1 ENVIRONMENTAL AND SOCIAL MANAGEMENT PLAN 1

1.2 IMPLEMENTATION MECHANISMS FOR THE ESMP 21 1.2.1 Organizational Roles and Responsibilities 21 1.2.2 Inspection Monitoring and Audit 23 1.2.3 Documentation and Record Keeping 24 1.2.4 Community Disclosure and Grievance Redressal 25 1.2.5 Capacity Building and Training 25 1.3 BUDGETARY ALLOCATION AND TIMELINES 26

1 ENVIRONMENTAL AND SOCIAL MANAGEMENT PLAN

The Nirvana Hills Phase II Project (Project Nirvana); to be developed on Survey Number 44/1, Erandwane in the city of Pune; will be constructed over a 5 year period and will broadly comprise of a rehabilitation component, a sales component as well as associated utilities and infrastructure facilities. In accordance to the ADB SPS 2009 as well as the IFC Performance Standards (2006), the impacts over the project lifecycle need to be adequately mitigated and managed through an Environmental and Social Management Plan (ESMP). The project proponents will need to work together with their contractors, state government and local bodies as well as the local community to achieve a sustainable housing project.

This section illustrates a site-specific ESMP to mitigate significant adverse environmental and social impacts that are identified for the planning, construction and operations phase in the ESIA. The ESMP would help improve the supportive capacity of the impact area and also preserve the assimilative capacity of the impacted environmental and social baseline. KUL is in the process of formulating the critical elements of a Social and Environmental Management System which include the following:

 An EHS and Construction Management Plan and Manual applicable to EPC Contractors;  A Community Relations set-up to cover the planning, transit and shifting phase for slum dwellers and also to address any grievances;  A corporate strategy on KUL’s position on slum rehabilitation and maximizing the benefits thereof.

The ESMP illustrated in Table 1.1 covers mitigation measures that are specific to key (major and moderate) social and environmental impacts over the pre- construction, construction and operations phase of the project lifecycle. To illustrate, the ESMP in the construction phase will aim at controlling the pollution at source wherever possible with available and affordable technology. This section also provides linkages to specific management plans (sub-plans):

 Annex A: Demolition Management Plan;  Annex B: Labour Management Plan;  Annex C: Stakeholder Engagement Plan;  Annex D: Grievance Redressal Plan;  Annex E: Gender Action Plan;  Annex F: Risk Management Plan; and  KUL Rehabilitation Plan (separate document).

The ESMP concludes with an outline of the key institutional arrangements, budget, timelines and a monitoring & evaluation plan.

ERM KUMAR SINEW URBAN DEVELOPERS LIMITED-ESMP PROJECT # I 8390 / 0138632 FEBRUARY 2012 1 Table 1.1 Environmental and Social Management Plan for Project Nirvana

S. No Issues Suggested Mitigation Measures Monitoring/Resource and Training Requirements Management Responsibility 1 Planning Phase 1.1 Regulatory approvals  Ensure regulatory clearances and approvals (such as SRA,  Monitor the PERT chart committed dates for Project Director/ EHS and clearances MPCB, SEIAA, PMC, Fire Office, Lift Inspectorate etc.) are applying and obtaining all regulatory clearances and Community applied and received well in time of planned construction and approvals covering major to minor ones and Relations Team of KUL schedule that is planned in five (5) phases. local to national regulators, if any.  Integrate all the regulatory clearances and approvals (covering  Environmental and Social Manager will need to major to minor ones) schedule in the project PERT chart (a train a representative on various applicable legal register) with flexible deadlines without affecting the regulations and clearances; regulatory systems overall project schedule; and procedures; supporting documents; timelines; regulatory offices etc. at least once a year. 1.2 Action Plan for  Adopt the Entitlement Framework and Institutional  KUL Staff dealing with Community Relations to Project Rehabilitation of Slum Arrangements indicated in the Rehabilitation Plan to draft an obtain training on the essential elements of the Director/Community Dwellers Action Plan for managing the slum rehabilitation process; Rehabilitation Plan and for operationalizing the Relations Team  Develop a Corporate Strategy/Policy on Displacement of monitoring indicators; Non-eligible slum dwellers on the basis of the  Outcomes of the rehabilitation process will need to recommendations suggested in the Rehabilitation Plan. be monitored internally every quarter and externally once every six months over the next 3 years and yearly for the next 2 years. 1.3 Meet the commitments  Formulate and maintain a Commitment Register that manages  Subject the commitment register to internal and Project Director/ EHS made to slum to track all the commitments made to individual slum families external auditing systems and Community community and collectively to the slum community resettled under the Relations Team of project. KUL  Commitment Register can be managed through the Stakeholder Engagement and Grievance Redressal Plan 1.4 Displacement of  KUL has committed to rehabilitation of ineligible families into  Subject the shifting/compensation and relocation Community Relations ineligible families Rajeev Awaas Yojana; and rehabilitation process to internal and external Team of KUL  Ineligible slum dwellers should be compensated as outlined in auditing systems the Rehabilitation Plan;  Ineligible slum dwellers should be facilitated with provisions for transit accommodation as well as relocation support. 1.5 Locate STPs, Solid waste  Review the locations and designs identified for siting foul  Review the planning and design efforts Project Director/ segregation centres and smell generating amenities (if not properly maintained) such undertaken to avoid foul smell affecting Project Layout composting yards away as STPs, Solid waste segregation centres and composting downwind sensitive receptors; Planners and

ERM KUMAR SINEW URBAN DEVELOPERS LIMITED-ESMP PROJECT # I 8390 / 0138632 MARCH 2012 2 S. No Issues Suggested Mitigation Measures Monitoring/Resource and Training Requirements Management Responsibility from sensitive receptors yards vis-à-vis sensitive receptors such as schools, hospitals Architects and residences (both inside and outside project premise).  Predominant wind direction at the site seems to be towards west (north-west) and any sensitive receptor on western side will be impacted if appropriate mitigation strategies are not integrated in the planning phase.  Maintaining maximum physical distance possible between the source and the receptor; putting up natural barriers in the form of trees on upwind and down wind sides or plain walls on upwind side; constructing the amenities fully or partially underground etc could be the potential mitigation strategies. 1.6 Soil and water  To avoid soil and water contamination issues at STP design  Review the planning and design efforts Project Director/ EHS contamination the waste water holding tanks and sludge storage rooms leak undertaken to avoid soil and water contamination Team of KUL or seep proof with secondary containment, if possible. at the facilities mentioned here.  At compost yard, transformer room and storage room (where  Train the KUL staff responsible for designing chemicals, paints, solvents, oil, grease, fossil fuel and other these facilities and preparing construction hazardous materials are to be stored during O&M phase) drawings about soil and water contamination design the floors to be leak or seep proof with bunds on all issues, once in a year. sides and secondary containment, if possible.  Provide effective storm water drains all around such facilities to prevent storm water contamination. 1.7 Rainwater harvesting  Project has proposals to implement roof top rainwater  Review the planning and design efforts Project Director/ EHS and ground water harvesting. undertaken to enhance water harvesting at site in Team of KUL recharge  As specified in Environmental Clearance issued by SEIAA, consultation with GSDA as directed by SEIAA engage with State Groundwater Survey and Development  Train the KUL designers and architects Agency (GSDA) to identify potential groundwater recharge responsible for designing water harvesting zones and implement recharge measures especially on hill top facilities about the latest techniques and site hill slope areas within the site. conditions once in a year.  The Project has a favourable topography and best suited to  Train the Housing Societies on maintenance of source rain water and storm water for project purposes. such structures. 1.8 Enhance ecological  Project has integrated proposals to create landscaped spaces,  Record and document the ecological enhancement Project Director/ EHS environment parks and gardens to add to poor ecological environment measures undertaken by the Project on a monthly Team of KUL prevailing at the site. or half-yearly basis  Additionally, plant trees to form dense vegetative screen all  Document the number of trees planted and along the proposed DP road and HCMTR (which bifurcates survival rates. Subject the documentation and the site) on either side to protect the residents from pollution implementation to internal and external auditing that would emanate from these transport corridors in future. systems.

ERM KUMAR SINEW URBAN DEVELOPERS LIMITED-ESMP PROJECT # I 8390 / 0138632 MARCH 2012 3 S. No Issues Suggested Mitigation Measures Monitoring/Resource and Training Requirements Management Responsibility  In consultation and approval of SRA, PMC and Forest Department, undertake plantation on hill top hill slope areas where no development is permitted. 1.9 Sustainable resource  Project has integrated many sustainable resource  Record and document the sustainable resource Project Director/ EHS management management initiatives into project design. management measures undertaken by the Project Team of KUL with  In the rehab buildings, the cost of maintenance of buildings specifically for rehab buildings. support form an and common utilities per flat owner is the critical factor in  Submit the rehab building design, construction NGO/consultancy sustaining the quality of life. It will be prudent to review and and operation proposals under PMC Eco-housing partner. include as many resource conservation measures (water, certification program energy, waste etc) as possible in the rehab building design,  Train the KUL designers and architects construction and operation. responsible for sustainable designs about the latest  Subject the rehab building designs to PMCs Eco-housing technologies available for resource conservation all certification program through project life cycle and green building certification systems, once in a year  Train housing societies in basic resource conservation including energy and water. Explore options to incentivise societies on good resource management. 1.10 Displacement of Cultural  Undertake slum community consultations covering all  Verify the community consent for each of the Project Director/ CR Environment religious groups and sections over religious structure re- religious structure proposed for Team of KUL building proposals. demolition/relocation.  Disclose religious structure redevelopment plans with local  As part of internal/external auditing systems, take community to placate any misgivings among various community stakeholders feedback on the process religious groups at the early stage of project life cycle. adopted by KUL  Involve community in the layout and architectural design of  Train the Community Relationship Team, Project religious structures Construction Management Team and Contractors  Obtain consent for relocation of locally significant religious responsible for project implementation about the structures. cultural issues, sensitivities and the methods to deal with them once in a year preferably before construction phase starts. 1.11 Internal road layout  Design internal road layout with following features:  Verify the internal road designs and drawings and Project Director/  Provide adequate primary and secondary road network other related proposals for compliance. Project Layout access to all buildings and amenities; Planners and  Avoid vehicle-pedestrian conflict through well marked Architects pedestrian/elderly citizen movement facilities;  Provide road side parking space;

ERM KUMAR SINEW URBAN DEVELOPERS LIMITED-ESMP PROJECT # I 8390 / 0138632 MARCH 2012 4 S. No Issues Suggested Mitigation Measures Monitoring/Resource and Training Requirements Management Responsibility  Provide road signs and road furniture;  Plan for safe movement of vehicles and pedestrians at crossings/intersections etc.  Provide road side storm water drainage systems; and  Undertake tree plantation and landscaping along medians, traffic islands, round-about etc. 1.12 Community H&S  Architectural planning and design of both rehab and saleable  Verify the architectural designs and drawings of Project Director/ buildings to integrate: adequate sunlight and cross individual rehab buildings Project Layout ventilation requirement to each of the individual flats and  Verify the safety provisions built into the Planners and noise resonance aspects mechanical and electrical utilities that are to be Architects  Mechanical (lifts) and electrical utilities (water pumps, operated by slum community during O&M phase transformer yards, MCB panel and metering rooms etc)  Train the KUL designers and architects planning and design to integrate safety precautions, responsible for electrical and mechanical utility procedures and fire proof systems. designs about the latest systems and technologies available for ensuring health and safety of users all through the project life cycle, once in a year 1.13 Disaster Management  Account for natural disaster (such as earthquakes) and  Verify the disaster management and emergency Project Director/ and Emergency response emergency situations (fire accidents) in master plan and response systems integrated in the planning and Project Layout infrastructure planning and design. design of entire re-development and individual Planners and  Account for natural disaster (such as earthquakes) and rehab buildings. Architects emergency situations (fire accidents) in the architectural  Train the KUL designers and architects about the planning and structural design of each rehab buildings. disaster management and emergency response  Integrate fire prevention systems in the design of mechanical issues that needs to be integrated in residential and electrical utilities. and commercial building design and  Review and integrate disaster management and emergency development, once in a year. response guidelines issued by regulatory authorities. 1.14 Community  Regularly engage and consult the slum dwellers and/or their  Record all consultations and meetings with Community Relations participation nominated representatives like the Housing Societies on the communities and review actions/commitments Team of KUL planning and design aspects of the project; through the Commitments Register;  Facilitate discussion forums among housing societies and provide periodic training.  Encourage the formation of a Community Audit Group to regularly meet senior management/inspect site etc. 1.15 Livelihood Impacts  Ensure that commercial structures are provided with rental  Review income indicators obtained through the Community Relations allowance/transitional support in excess of the rate provided socio-economic survey at least once every quarter; Team of KUL to residential structures and adequate to allow them to  In case there are families with increased

ERM KUMAR SINEW URBAN DEVELOPERS LIMITED-ESMP PROJECT # I 8390 / 0138632 MARCH 2012 5 S. No Issues Suggested Mitigation Measures Monitoring/Resource and Training Requirements Management Responsibility continue their business; vulnerabilities due to income disruption, provide  Assist commercial owners in finding transit spaces and priority support for some period. Document and include them to the extent possible in KUL’s local track such support. procurement strategy for labour camps etc;  Encourage women to form Self-Help Groups and assist these groups in undertaking any self-employment activities which can be coordinated during the transition phase. 1.16 Shifting of Families and  Any families identified as vulnerable should be given first  Shifting processes should be subjected to the EHS and Community Transit Accommodation preference for shifting into transit accommodation; Community Audit Group that has to be Relations Team of KUL  Transit accommodation should be located in-situ to the constituted; extent feasible or within an immediate vicinity of 2-3 km;  Ensure monitoring as suggested in the  Ensure that the specifications of the Demolition Plan and the Demolitions Plan and the Rehabilitation Plan. Rehabilitation Plan vis-à-vis shifting are adhered to 2 Construction Phase 2.1 Demolition of Structures  Dust generated to be arrested within the site through  Handle complaints efficiently and promptly; EPC Contractor and sprinkling;  Demolition Procedures to be subject to Community Relations  All health and safety precautions to be taken prior to Community Audit Group; Team of KUL demolition activities;  Ensure adequate documentation of the demolition  Workers should be provided with adequate PPE to ensure no process in terms of consent for demolition, exposure to friable potentially asbestos containing material; retrieval of salvageable material etc;  Debris to store carefully for use in backfilling later;  Training of personnel to ensure mitigation of  Community to ensure collection of salvageable material from health & safety risks during demolition; the site.  Maintenance of records for disposal of asbestos  Adequate disposal of hazardous wastes such as roofing sheet containing roofing sheets in prescribed format as with asbestos containing material to a secured landfill site at provided by the Haz Waste Rules, 2008. near Pune.  Ensure adequate debris management Note: The Maharashtra State Pollution Control Board  Prior information provided has designated M/s. Maharashtra Enviro  Adequate opportunity to salvage material to the dwelling Power Ltd for common haz waste disposal at owners; Ranjangaon near Pune. The site has an area of  Any damages to neighbouring units avoided. approximately 30 hectares with a capacity of Sanitary Land Fill of 60,000 MT/year and incineration of 3 tonnes per hour. 2.2 Landuse, vegetation and  Follow up of overall architecture and landscaping design of  Ensure documentation of number of trees, EHS Team and EPC landscaping the proposed project; approvals from PMC etc; Contractor  Transplantation of the existing trees required to be dislocated  Consult a local ecologist to assist in the

ERM KUMAR SINEW URBAN DEVELOPERS LIMITED-ESMP PROJECT # I 8390 / 0138632 MARCH 2012 6 S. No Issues Suggested Mitigation Measures Monitoring/Resource and Training Requirements Management Responsibility for the project in the green areas; landscaping and botanical garden design.  Trees cut felling to be avoided wherever possible;  Prior approval for tree felling to be obtained;  Most of the trees to be transplanted within the project site. 2.3 Site Clearance,  Disturbance to land surface contours to be kept to minimum  Provisions should be clearly described in the EHS Team and EPC Topography and due to sensitivity of hill-top-hill slope land. Site contour contract of the EPC Contractors; Contractor Drainage Aspects levels to be brought to the levels of the surroundings;  Monitoring of these provisions on a monthly basis.  Adequate drains and slopes to be laid across the project area prior to start of excavation work to ensuring adequate cross drainage for quick evacuation of catchment water;  Construct diversion dykes to channel runoff around the excavated site to avoid surface runoff of excavated materials;  In areas where grass or any form of vegetation is found, efforts to conserve topsoil shall be undertaken;  Segregated topsoil shall be stored in stockpiles of 1 to 1.25-m height. The stockpiles shall be located such that disturbance to construction work is minimal. 2.4 Construction material  Sourcing of construction material should be from legally  Verify the licenses, permits and consents issued to EHS Team sourcing, transport and compliant vendors. A copy of currently valid licenses/ construction material supplier at least once in 6 storage permits/ consent issued to construction material supplier months; should be obtained as part of office records;  Randomly inspect the vehicles used for  During transportation of construction materials to transporting construction materials to see if they construction site, vehicles engaged shall not create hazardous are complying to mitigation measures condition on the network roads en route to site due to over recommended here; speeding or material spills. No dust generation from loaded  Undertake training on E&S aspects covered in the trucks; sand or water spilling all along the network roads will mitigation plan for constructing internal access be permitted; roads at least once during inception of contract  Fugitive dust generation from transport vehicles will not be work allowed. All material transport trucks will be covered effectively with tarpaulin sheets;  Material storage will be in only designated, least E&S sensitive locations; Material washout during heavy rains; blockage of natural drainage systems; erosion and sedimentation of construction materials downstream will be prevented by taking appropriate control measures.

ERM KUMAR SINEW URBAN DEVELOPERS LIMITED-ESMP PROJECT # I 8390 / 0138632 MARCH 2012 7 S. No Issues Suggested Mitigation Measures Monitoring/Resource and Training Requirements Management Responsibility 2.5 Engaging Construction  Establish a list of all construction workers, identity proof,  Ensure the training and applicability of such EHS Team and Workers contact details etc and any other provisions under the provisions within the contractor’s agreement; Community Relations Building and Other Construction Workers Act and Inter-state  Ensure adequate compliance of all labour Team Migrant Workers Act; legislations through the PERT Chart that has to be  Ensure provisions for local employment and contracting maintained through the project lifecycle within the slum community to the extent feasible.  A regular monitoring of contractors on compliance as well as good practice. 2.6 Labour Camp  Camp size kept as small as possible and to be contained  Develop and Monitor a Labour Camp Inspection EHS Team and EPC Management within the present quarry location Checklist at least once a week; Contractor  Maximum number of unskilled labours to be employed from  Labour Camps should be subject to training on local areas having their residences in the nearby areas; health & safety, other aspects at least once a week;  Construction of toilet facilities and sewage collection system  Ensure adequate training and monitoring as per for disposal; the Labour Management Plan.  Five septic tanks each catering to 300 users provided at the construction site, as per the specifications given in IS 2470 1995 Part I and Part II.;  The contractors shall instruct all staff to use the ablution facilities and under no circumstances shall indiscriminate excretion and urinating be allowed other than in the provided facilities;  Arrangements for first aid;  Arrangement for kitchen waste disposal- identify locations for establishing humus pits, which can be covered with soil for anaerobic composting;  Awareness programmes on AIDS etc.;  The site shall be kept visually and aesthetically pleasing, especially in and around the campsite. The workforce shall also be sensitized about health issues. 2.7 Concrete Batching Plants  Obtain permits from MPCB regarding installation of batching  Obtaining license from concerned authority; EHS Team and EPC plant;  Documentation of air quality, noise barriers etc; Contractor  Water sourcing must be in compliance of the regulations;  Effective treatment and reuse systems put in place  Procurement of stone aggregates and sand shall be from to achieve zero discharge; licensed/ government authorised sources only;  Good Practices and measures adopted near cement  Wind-borne erosion shall be prevented by sprinkling water storage and mixing sections; on the surface of stockpiles;  Provision of PPEs to staff and workers and  wastewater shall be collected at point and discharged into an training on the use of the same;

ERM KUMAR SINEW URBAN DEVELOPERS LIMITED-ESMP PROJECT # I 8390 / 0138632 MARCH 2012 8 S. No Issues Suggested Mitigation Measures Monitoring/Resource and Training Requirements Management Responsibility impermeable settling pond where minimum retention time of  Compliant to NAAQS, Noise standards and waste 30minutes shall be achieved. The settling pond outlet water water disposal standards shall be reused in process or dust control applications suitably;  The artificial barriers in the form of plantation, landforms, GI sheet walls, material stockpiles etc around the process machinery will dampen noise generation to greater extent ;  Where possible waste concrete should be used for construction purposes at the Batching Plant and Casting yard or project site 2.8 Utility Shifting  Ensure minimum nuisance/interruption to communities that Utility shifting work contract shall be under the direct Planning Team, EHS especially power lines, do not need to be shifted (such as Rautwadi, Hanuman supervision and control of concerned service agency Team sewer lines and Nagar etc) as they are mostly on hill top-hill slope land; and KUL. KUL shall ensure that agreed time schedule municipal water supply  Utility services that need to be relocated or shifted from is followed and any eventualities if occurs shall be system project site shall be estimated and mapped during project brought to the notice of concerned utility agency. preparation stage itself;  During shifting, drop in service quality shall be monitored by KUL. Eventualities such as water pipeline contamination, sewage wastewater flooding/ponding, electrical cable leaks and associated accidents shall be averted by monitoring the utility shifting work 2.9 Air Quality Impacts  Dust generating activities to be avoided in conditions of high  Air monitoring shall be taken up time to time by EHS Team and EPC wind (particularly during summer season) and covers to be appropriate external monitoring agency; Contractor provided for loose construction material at construction site;  Carryout vehicle pollution check programme at  Trucks/ dumpers to be covered by tarpaulin sheets during regular intervals off site transportation of friable construction materials and  Once a month monitoring (during construction spoil; phase) at three locations on the boundary of the  Surfaced roads to be cleaned and un-surfaced roads will be premises for SPM, RPM, SO2, NOx, CO & HC stabilized to reduce offsite transport of soils and avoid dust  Daily audit by Construction Supervisors and generation; Weekly audit by internal team of KUL  Diesel generators meant for emergency power requirement to be optimally operated and regularly maintained so as to ensure that emissions from fuel combustion remain at design levels. Also to have appropriate stack height as per the MPCB guidelines;  Machinery to be turned off when not in use;

ERM KUMAR SINEW URBAN DEVELOPERS LIMITED-ESMP PROJECT # I 8390 / 0138632 MARCH 2012 9 S. No Issues Suggested Mitigation Measures Monitoring/Resource and Training Requirements Management Responsibility  Housekeeping of the area to be maintained by deputing sweepers to remove dirt/debris from the floors/sites on daily basis;  Paints, polishes, building fittings and flooring material etc. to be procured carefully to minimize emission of VOCs; 2.10 Surface and Ground  Sufficient and suitable toilet facilities for workers to be Quarterly monitoring of surface and ground water EHS Team and EPC Water Quality maintained for proper standards of hygiene (done during quality (to check any contamination) for parameters Contractor phase I); specified under Schedule VI of Environment Protection  Five septic tanks each catering to 300 users will be provided Rules, 1986. Depending on method of disposal (public at the construction site as per the specifications given in IS sewers or inland water sources), key parameters such 2470 1995 Part I and Part II (done during phase I); as SS, O&G, Ammonical Nitrogen, BOD, SS and heavy  Bund to be provided around excavated soil or loose metals shall be monitored against Schedule VI of construction material to prevent runoff to nearly water Environment Protection Rules, 1986 standards. bodies;  Storage area to be kept away from the storm water to prevent any wash away;  All the debris resulting from construction activities to be removed from the site on regular basis to prevent their runoff. 2.11 Groundwater Resources  In case groundwater is to used for construction purposes, To be discussed and implemented through EHS Team and EPC ensure approvals from groundwater authority prior to construction contractors; Contractor initiation of construction activities; To be taken up during designing stage with help of  Water usage to be optimised by creating awareness among plumbing expert; the labour force through construction supervisors; Educate construction contractor and supervisors to  Proper storage and internal supply facilities to be developed help optimising water usage before undertaking construction activities;  Installation of temporary rain water collection arrangements at the proposed site 2.12 Traffic, Transport and  Heavy Vehicle holding areas to be provided for vehicles To be implemented through contractor who in turn EHS Team and EPC Access Issues waiting to deliver loads at work sites so as to avoid queuing would ensure that their suppliers and transporters Contractor outside the site or at other connecting roads; meet the requirements;  Vehicle movement and parking within the premises shall be manned properly to avoid accidents; Also to be briefed to the contractor before the start of  Routes for use by construction traffic to be planned to the construction work; minimize impact on residential areas and unsuitable parts of the road network; Traffic management to be taken up from time to time by KUL management together with construction

ERM KUMAR SINEW URBAN DEVELOPERS LIMITED-ESMP PROJECT # I 8390 / 0138632 MARCH 2012 10 S. No Issues Suggested Mitigation Measures Monitoring/Resource and Training Requirements Management Responsibility  Providing dedicated path within the site for entry and exit of contractors and transporters the construction vehicles;  Necessary training to the driver of construction vehicles for As the access road to ARAI is through the project area, speed restrictions and to crewmembers on do’s and don’t appropriate authorities to coordinate traffic movement during construction vehicles movements; will also need to be consulted.  Developing Code of Practice for Construction to include traffic for construction phase environmental management;  Arrangements and routes for abnormal loads to be agreed in advance with the police, emergency services and the roads authority;  Construction vehicles to be routed only during non- peaking hours i.e. other than during 0800 to 1100 hours and 1600 to 1900 hours. Heavy vehicles should operated only after 2100 hours;  Movement of vehicles owned by local to be completely restricted;  The contractor shall properly mark all access roads with proper signage. 2.13 Noise and Vibration  Middle noise sources such as cranes, earth moving Ambient Noise Quality Monitoring and Reporting to EHS Team and EPC Impacts equipment and heavy vehicles to be routed in such a way be undertaken as provided in the Environmental Contractor that there is minimum disturbance to receptors; Clearance conditions. The EC condition clearly states  Use of inherently quiet equipments (as far as reasonably that Ambient noise levels should confirm to residential practicable) and regular maintenance to ensure noise level standards both during day (55 dB(A)) and night are maintained at design level; (45dB(A)) time. Incremental pollution loads on noise  Avoid loud, sudden noises wherever possible. Fixed noise quality should be closely monitored during sources to be located away- more than 50 m away from the construction phase and adequate measures site fencing; implemented to meet the stipulated residential  Integral noise shielding (including provision of tin sheets as standards of CPCB/MPCB. Noise levels should be noise barrier) to be used where practicable and fixed noise monitored along the boundaries of the site to check the sources to be acoustically treated, for example with silencers, compliance. acoustic louvers and enclosures. All diesel generators to be installed in conformance with the statutory requirement of Provision of training so that measures are discussed acoustic enclosure to achieve the required norm 75 dB(A) and implemented through contractors, suppliers and level at 1 m from its enclosure; transporters.  Provision of rubber paddings/ noise isolators at equipment/machinery used for construction;  Noise prone activities need to be restricted to the extent

ERM KUMAR SINEW URBAN DEVELOPERS LIMITED-ESMP PROJECT # I 8390 / 0138632 MARCH 2012 11 S. No Issues Suggested Mitigation Measures Monitoring/Resource and Training Requirements Management Responsibility possible during night particularly during 2200 to 0600 hours to reduce the noise impact. There is also requirement of providing make shift noise barriers surrounding the high noise generating construction equipment;  Site workers working near high noise equipment use personal protective devices to minimise their exposure to high noise levels;  Breaking of surfaces, if any to be done using the highest possible weight of breaker capable of doing the job without extending its duration;  Construction vehicles to be well maintained and not idling equipment or vehicles when not in use; and  Regular maintenance of vehicles to be taken up. 2.14 Community &  Attempts shall be made to keep the construction site clean by Regular inspection is required for house keeping and EHS Team and EPC Occupational Health & providing extra manpower for the purpose; EHS issue; Contractor Safety  Proper marking to be made for identification of locations of To be managed during building, designing and storages and waste collection and disposal as per their use; implementing measures through suitable contractors.  The vehicle maintenance area to be located in such a manner to prevent contamination of surface and ground water sources by accidental spillages of oil;  Unauthorised dumping of used oil and other hazardous wastes should be prohibited;  All the required safety measures based on individual job profile will be provided (as per working guidelines, use of personal protective equipments like gloves, helmets, ear muffs, safety belts etc.) for construction worker through the contractors. Personal protective equipment for everybody present at site to be made available;  For safety of people occupying the site, regulations concerning fire safety to be followed. Some of the requirements include:  Installation of fire extinguishers;  Provision of water sprinklers for unpaved roads;  Emergency exit;  Proper labelling of exit and place of fire protective system installation;

ERM KUMAR SINEW URBAN DEVELOPERS LIMITED-ESMP PROJECT # I 8390 / 0138632 MARCH 2012 12 S. No Issues Suggested Mitigation Measures Monitoring/Resource and Training Requirements Management Responsibility  Trained personnel to use fire control systems; and  Display of phone numbers of the city/ local fire services, etc.  Provision of Sewage Disposal at labour campsite;  Construction contractors to provide first aid as well generate awareness programmes on health and communicable diseases. 2.15 Demobilisation of  Remove all construction equipment from construction site Daily inspections EHS Team and EPC construction material with due care on health, safety and environment; Auditing immediately before and after the construction Contractor temporary sheds etc.  Remove all demobilisation waste from the construction site demobilisation having impact on and dispose of non hazardous civil waste in low lying area Aesthetics & EHS within the site, while any hazardous waste is to be disposed as the requirement of MPCB;  Re-vegetate bare area as per the landscape development plan. 3 Operations Phase 3.1 Periodical maintenance  During the defect liability period, KUL to demonstrate and  One training session delivered to individual Project Director, KUL/ of permanent rehab train the 21 residential building society members and building societies and Federation society on the 21 Building societies buildings through its life Federation Society members on the importance of operation maintenance of permanent rehab buildings during and Federation society cycle and maintenance of rehab buildings defect liability period  KUL to prepare and hand-over simple and easy to use  Availability of Maintenance manuals in building maintenance manuals applicable to individual flat Marathi/Hindi covering individual flat owners owners and at Society level in local language and Society level issues.  Maintenance of rehab buildings will include: structural  Terms of reference and contract documents repairs such as cracks, member failures; painting and prepared in Marathi for engaging building whitewashing; sweeping, cleaning and washing; lifts and maintenance service providers. related machinery; electrical wiring, fittings and fixtures;  Fruitful attempts to identify building maintenance sanitary fittings, piping and fixtures; water supply pipelines, service providers from the rehabilitated local fittings and fixtures; and carpentry etc. community population.  KUL to help the 21 housing societies and Federation Society  During defect liability period and later during the in identifying and appointing appropriate facility entire project life cycle, effective building management service providers who deliver building maintenance shall be monitored using following maintenance services at renewable periods and at parameters which include: competitive rates. The terms of reference for delivering such o Neatly painted and whitewashed exterior services shall be drafted by KUL in consultation with and interior walls at least once in 3 years with Societies. no graffiti, dirt signs and worn out markings  Strive to identify the building/facility management service etc; providers from within the rehabilitated community o Completely intact water and wastewater population itself. pipelines and sewerage system with no signs

ERM KUMAR SINEW URBAN DEVELOPERS LIMITED-ESMP PROJECT # I 8390 / 0138632 MARCH 2012 13 S. No Issues Suggested Mitigation Measures Monitoring/Resource and Training Requirements Management Responsibility of leaks, seeps, spills, overflows; o Neat and clean lift cabins in working conditions; o Neat and clean corridors, stairs, stairwells, stair hand rails and other such public places within building without any signs of spitting, graffiti and other forms of abuse/misuse o Presence of all electrical fitting and fixtures in working condition. o No waste accumulation on sunshades, roof tops, ground floor space and other open areas. o Neat and clean parking spaces with vehicles parked in an orderly manner.  The building and federation society shall institute and inspection and auditing system to check the effectiveness of maintenance services from the 6th month of occupying the rehab flats.  The inspection and auditing shall be done at various frequencies focussing on various issues: weekly, monthly and quarterly. 3.2 Maintenance of  KUL to help the Federation Society in identifying and  Appointment of experienced infrastructure facility Project Director, KUL/ associated infrastructure appointing one or many infrastructure facility operators who O&M operators 21 Building societies facilities – water supply; have the experience and expertise in operating the following  Terms of reference and contract documents for and Federation society sewerage system; facilities: delivering facility infrastructure O&M services sewage treatment plant o Water supply system; prepared in local language. (STP); Solid waste o Sewerage system; o Fruitful attempts to identify facility collection, transport, o Sewage treatment plant (STP); infrastructure O&M services providers from storage, segregation and o Solid waste collection, transport, storage, segregation within the rehabilitated community disposal; Composting and disposal; population itself. yard; Electricity o Composting yard; o One training session delivered by KUL to 21 distribution systems – o Electricity distribution systems – Transformer yard, residential building society members and Transformer yard, metering rooms, MCB panel board etc; Federation Society members on the metering rooms, MCB o Lift machinery in each of the buildings; importance of operation and maintenance of panel board etc; Lift o Road infrastructure; each of the associated infrastructure facilities machinery; road o Storm water drainage and rainwater harvesting; and their functions. infrastructure; Storm o Landscaping o As part of the inspection and auditing systems

ERM KUMAR SINEW URBAN DEVELOPERS LIMITED-ESMP PROJECT # I 8390 / 0138632 MARCH 2012 14 S. No Issues Suggested Mitigation Measures Monitoring/Resource and Training Requirements Management Responsibility water drainage;  The terms of reference and contract documents for delivering suggested earlier above, include infrastructure landscaping and facility infrastructure O&M services shall be drafted by KUL facility management services as well as part of rainwater harvesting etc. in consultation with Societies in local language. the audit scope. o Strive to identify the facility infrastructure O&M services o Audit shall formulate performance assessment providers from within the rehabilitated community parameters facility-wise and the frequency of population itself, if possible. auditing of each facility depending upon the o During the defect liability period, KUL to demonstrate and priority and significance attached to each train the 21 residential building society members and facility by the local society. Federation Society members on the importance of operation  Associated infrastructure such as the following and maintenance of each of the associated infrastructure shall be monitored periodically as specified facilities and their functions. against each of them: o Appoint well experienced operators with institutional o Water supply system – Drinking water experience of not less than 10 years of operating such quality shall be monitored for all parameters facilities for delivering O&M services to STP and Compost specified under IS 10500 standards at 6 yard. monthly intervals or as and when necessary. o Ensure effective O&M of STPs, Solid waste segregation One of the sampling shall be done during centres and Composting yards to avoid foul smell emanating monsoon season to detect wastewater from them. Institute stand-by mechanisms to store or contamination. Sampling shall be conducted dispose off wastewater and solid wastes in case of system at Underground /Overground storage failure at STP and compost yards. reservoirs across all buildings and at 10% of o No leaks, seeps or spills shall be allowed in the STP system, household taps selected randomly; sludge storage/drying areas, Compost yards, sanitary piping o Sewerage system – the entire sewerage on rehab buildings and underground sewerage systems to system network shall be physically inspected avoid soil and groundwater contamination. If any such once in a month for leakages, seepages, leaks, seeps or spills is observed in any of the systems, the overflow and manhole cover integrity etc. same shall be rectified within a week. Any indications of network repair shall be o Water quality aspects will depend largely on the effective addressed immediately. O&M practices adopted for periodical cleaning and up keep o Sewage treatment plant (STP) – the operation of the entire water supply system consisting of supply of STP will be regulated by the Consent to pipelines (both above ground and below ground), valves and Operate (CTO) issued by Maharashtra other pipelines fixtures, metering points/pits, storage tanks Pollution Control Board (MPCB). The (both underground and above ground) etc. monitoring program as specified under o If PMC announces rationing or cut in water supply at any MPCB CTO or in the absence of any time of the year, the same shall be published in all building guideline, effluent standards specified under notice boards and respective building society informed about Schedule VI of EP Rules, 1986 shall be such measures. followed; o If abnormal high noise is generated during operation of STP  For other facilities such as the following,

ERM KUMAR SINEW URBAN DEVELOPERS LIMITED-ESMP PROJECT # I 8390 / 0138632 MARCH 2012 15 S. No Issues Suggested Mitigation Measures Monitoring/Resource and Training Requirements Management Responsibility and water supply pumps, the same shall be attended to operational monitoring parameters to gauge the within a week to avoid inconvenience to nearby sensitive quality of service rendered shall be specified in the receptors. service contract agreements and monitored accordingly: o Solid waste collection, transport, storage, segregation and disposal; o Composting yard; o Electricity distribution systems – Transformer yard, metering rooms, MCB panel board etc; o Lift machinery in each of the buildings; o Road infrastructure; o Storm water drainage and rainwater harvesting; 3.3 Maintenance of social  Implement similar measures suggested earlier for building Refer to Point 3.1 above. Project Director, KUL/ infrastructure facilities maintenance; 21 Building societies  Ensure capacity building and training of new residents on and Federation society the use and minor upkeep of new sanitation and water facilities (toilets and taps) as well as general hygiene and sanitation. 3.4 Ecological conservation  Ascertain the alignment of transport corridors proposed such  As part of inspecting and auditing systems Project Director, KUL/ and development as DP road and High Capacity Mass Transport Route proposed earlier include the ecological 21 Building societies (HCMTR) and plant dense tree plantation to form bio-screen conservation efforts and any developments in and Federation society on either side of the alignment to save the resident NDZ as part of audit scope. community from air and noise pollution aspects through  Monitor the number of trees planted every year, annual plantation programs. survival rates and total trees alive in the project  Identify and plant as much variety of trees as possible along site vis-à-vis targets set for the site. road side, along perimeter of parks and playgrounds, around  Monitor the density of trees planted along building/facility sites and other such open spaces through proposed DP road and High Capacity Mass sustained annual plantation programs. Transport Route (HCMTR) – Density of vegetation  The residential societies must keenly monitor and report any should be such that none of the buildings should development in the regulated hill top - hill slope region and be visible from the alignment corridor. other no-development zones (NDZ) within project site. 3.5 Sustainable resource  During the defect liability period, KUL to demonstrate and  Training sessions as suggested in the mitigation Project Director, KUL/ management train the 21 residential building society members and measures 21 Building societies Federation Society members on sustainability concepts in  Sustainability monitoring and measurement and Federation society building operation, maintenance and management. systems run by 21 building Society members and  During defect liability period, KUL to formulate and institute Federation Society

ERM KUMAR SINEW URBAN DEVELOPERS LIMITED-ESMP PROJECT # I 8390 / 0138632 MARCH 2012 16 S. No Issues Suggested Mitigation Measures Monitoring/Resource and Training Requirements Management Responsibility simple sustainability monitoring and measurement systems  Continual improvement systems run by 21 for resource consumption in consultation with Society building Society members and Federation Society representatives such that they can continue operating the system in KULs absence as well.  During defect liability period, KUL to formulate and implement continual improvement systems to sustain resource consumption over the long run. The society members shall be trained on operating the continual improvement systems.  During defect liability period, KUL to increase awareness among 21 building society members and federation society members on green building certification systems, PMC eco- housing schemes and other such sustainability rating systems and their benefits. 3.6 Visual environment During operational period, address following aspects and issues See Points 3.1 and 3.2 above Project Director, KUL/ that will affect visual environment through measures suggested 21 Building societies earlier above: and Federation society  House keeping and facility management services;  Regular painting and whitewashing of buildings and associated infrastructure components;  Abuse and misuse of building components such as roof area, walls, sunshades, stair walls, stair wells, parking space etc. Abuse and misuse could be due to spitting, urinating, advertising, scribbling graffiti, pasting posters etc;  Leaking sanitary pipes and fittings and overflowing underground sewerage systems;  Maintenance of road infrastructure and road furniture’s;  Up keep and maintenance of project infrastructure (water tanks, STPs, Compost yards, waste segregation centres, transformer rooms/yards etc) and social infrastructure (such as community halls, anganwadi, women centres etc) without abusing and misusing them;  Up keep and maintenance of landscaped gardens, parks, recreational spaces, playgrounds etc without abusing and misusing them;  Regular solid waste and garbage removal from the rehab area; and

ERM KUMAR SINEW URBAN DEVELOPERS LIMITED-ESMP PROJECT # I 8390 / 0138632 MARCH 2012 17 S. No Issues Suggested Mitigation Measures Monitoring/Resource and Training Requirements Management Responsibility  Sweeping and regular cleaning of open/public places/spaces. 3.7 Road infrastructure  Prohibit honking and over-speeding of vehicles inside project  As part of inspection and auditing systems Project Director, KUL/ inside project site site and empower society members to take action against suggested earlier, include up keep and 21 Building societies violators of the society rules. maintenance of road infrastructure as part of audit and Federation society  As suggested earlier, up keep and maintenance of road scope. infrastructure including road surface, street lighting, signs,  As part of audits, review the fatal and non-fatal furniture, islands, round-about, medians, landscaping and accidents/ incidents on internal roads and plantations shall be included as part of the scope of corrective actions taken. infrastructure facility management service contract.  Training sessions at lease once as suggested under  Monitor fatal and non-fatal accidents/ incidents on internal mitigation measure roads and take corrective actions within a month.  KUL to deliver training on safe/good road user habits, parking along roads and inside buildings, safe driving methods etc to 21 building Society members and Federation Society. The society members shall in turn train the residents of individual buildings using the training resources shared by KUL or other resources. 3.8 Community H&S During defect liability period, KUL to train and increase  Training session as suggested in the mitigation Project Director, KUL/ awareness levels among the 21 Building Society members and measures. 21 Building societies Federation Society members on typical health, safety and hygiene  Monitor the drinking water quality as specified and Federation society issues of residents such as the following: under Item 3.2 .  Leaking sanitary pipes and fittings on buildings  Monitor health, safety and hygiene related  Overflowing underground sewerage systems accidents/ incidents involving residents and  Dumping solid waste and floor sweepings into sewerage implement corrective actions immediately. system manholes  Presidents of Building Society and Federation  Indiscriminate dumping of domestic solid waste Society shall walk-through and visually check for  Indiscriminate spitting and urinating in open/public spaces the signs of following community H&S issues at  Maintenance of underground and over ground drinking least once a month: water tanks and integrity of supply systems including o Leaking sanitary pipes and fittings on metering pits buildings  Health and hygiene issues (clean drinking water, upkeep and o Overflowing underground sewerage systems maintenance of washrooms/bathrooms, safe cooking habits, o Dumping solid waste and floor sweepings cleaning floors, washing clothes etc) into sewerage system manholes  Health impacts due to poor indoor air quality such as o Indiscriminate dumping of domestic solid cooking without adequate ventilation using firewood or waste kerosene o Indiscriminate spitting and urinating in

ERM KUMAR SINEW URBAN DEVELOPERS LIMITED-ESMP PROJECT # I 8390 / 0138632 MARCH 2012 18 S. No Issues Suggested Mitigation Measures Monitoring/Resource and Training Requirements Management Responsibility  Exposure of residents to: fire hazards (due to electrical short open/public spaces circuiting, LPG cylinder blasts or other such incidents); o Maintenance of underground and over earthquakes; electrical hazards; and mechanical failure of lift ground drinking water tanks and integrity of machinery etc. supply systems including metering pits  The individual building societies and Federation Society in o Health and hygiene issues (clean drinking turn to propagate awareness among residents on above listed water, upkeep and maintenance of community health, safety and hygiene issues through washrooms/bathrooms, safe cooking habits, periodical awareness cum training programs using resources cleaning floors, washing clothes etc at 10% shared by KUL households every month) o Number of awareness programs conducted every year on different subjects. 3.9 Occupational H&S  KUL to train the 21 Building society members and Federation  Training session as suggested in the mitigation Project Director, KUL/ Society members on typical OHS issues associated with measures. 21 Building societies building repair and maintenance and their legal  Contractual provisions as suggested in the and Federation society ramifications, contractual provisions, risk and liability mitigation measures that transfers liability on management, risk insurance products etc. service provider and empowers societies to cancel  Occupational H&S i(OHS) issues associated with routine the contract if OHS record is unsatisfactory building repair and maintenance (such as plumbing works,  Monitor OHS records of each of the service electrical maintenance, lift maintenance, carpentry works, providers engaged and implement corrective painting works and associated infrastructure utility/facility actions. O&M activities) will arise through project life cycle. This can be managed by the Societies by engaging service providers who have OHS systems in place and implement the same during contract period.  Building societies and Federation society to put contractual obligations and liability on service providers on all matters pertaining to OHS aspects.  Building societies and Federation society to retain contractual powers to disengage the service providers if the OHS systems and its implementation track record is found to be poor/ unsatisfactory as per internal audit systems. 3.10 Disaster Management  During operation phase, the major emergency event could  Availability of Disaster and Emergency Project Director, KUL/ and emergency response arise due to: fire accidents; electrical short Management manuals in local language as 21 Building societies circuits/electrocution; major earthquake events leading to suggested in mitigation measure and Federation society structural failure; LPG gas leak/blast; Lift failure and  Training and awareness sessions as suggested in emergency health situations of individual residents. the mitigation measure.  KUL to prepare simple and easy to understand manuals in  Document the periodical awareness programs and

ERM KUMAR SINEW URBAN DEVELOPERS LIMITED-ESMP PROJECT # I 8390 / 0138632 MARCH 2012 19 S. No Issues Suggested Mitigation Measures Monitoring/Resource and Training Requirements Management Responsibility local language with illustrations and graphics on how to mock drills conducted among resident community respond and manage each of the disaster and/ or emergency  Identification of institutional mechanism to situations and respective government authorities to contact. manage disaster and emergency events within the These manuals shall be widely published and circulated residents’ building society management. among all building societies and individual residents.  Operational records of preventive maintenance  KUL to train and increase awareness among 21 building systems.. society members and Federation Society members about the probable disaster and/ or emergency situations in the project site and the management manuals prepared by it.  The manuals prepared by KUL should include conduct of periodical awareness programs and mock drills among resident community along with clear division of emergency management responsibilities among the residents’ building society management to manage emergency situations.  KUL to formulate and implement preventive maintenance of fire systems, lift systems and electrical MCB to avoid emergency situations. KUL to hand-hold Building societies and Federation society in running these preventive maintenance systems.

ERM KUMAR SINEW URBAN DEVELOPERS LIMITED-ESMP PROJECT # I 8390 / 0138632 MARCH 2012 20 1.2 IMPLEMENTATION MECHANISMS FOR THE ESMP

This section discusses the implementation mechanisms for the ESMP and key commitments that would be required from KUL to ensure environmental and social performance of Project Nirvana as per the applicable reference framework. The key commitments that have emerged from the ESMP are the following:

 Capacity Building and Expansion of the EHS and Community Relations Team which will be responsible for implementation of the ESMP and related management plans;  Completion of the socio-economic survey for Wadarvasti in order to have an updated baseline of all slum dwellers impacted by the project whose status will need to monitored bi-annually up to the end of the construction phase;  Formation of a Community Audit Group comprising of slum dwellers of each settlement/block to regularly monitor the performance of the project and its scheduling/design/completion status. These groups should be created in consultation with the Housing societies/Building Federations;  Providing each EPC contractor, whether for civil works, or any other specialization with the ESMP requirements for the construction phase;  Incorporation of a Training Program which will draw up a training calendar to implement the specific training requirements indicated by the ESMP.  Determining a monitoring plan for environmental and social impacts on the basis of the ESMP and monitoring indicators.

1.2.1 Organizational Roles and Responsibilities

The implementation of the ESMP for Project Nirvana will be lead and managed by a designated Environmental and Social Manager (ESM) with direct reporting responsibilities to the Project Head/Engineering and Construction Head. The ESM will need to put in place a team of two coordinators (EHS and Community Relations) who would be further supported by project and site level officers as indicated in Figure 6.1.

The organizational structure for the implementation of the ESMP will need to take into account that construction works are likely to have separate EPC Contractors, such as a contractor for civil and another for foundation works etc, each of whom would have sub-contractors for securing construction material, labour etc. This implies compliance risk for environmental and social regulations and hence emphasizes the need for training of contractors and specifying the requirements for EHS personnel within the contractor’s team.

The designated Environmental and Social Manager will also need to coordinate across KUL functions, such as with the Liaisoning Department, the Planning & Design Department as well as Human Resources and Administration. As indicated in the ESMP, independent consultants, subject- matter experts etc. will also require to be engaged.

ERM KUMAR SINEW URBAN DEVELOPERS LIMITED-ESMP PROJECT # I 8390 / 0138632 MARCH 2012 21 Figure 1.1 Organizational Structure for ESMP Implementation

*Suggested Organizational Structure

ERM KUMAR SINEW URBAN DEVELOPERS LIMITED-ESMP PROJECT # I 8390 / 0138632 MARCH 2012 22 Box 1.1 Roles and Responsibilities of External Agencies

As indicated in the suggested organizational structure, the ESMP implementation will need to be linked with roles and responsibilities of external agencies who would be involved primarily in (a) Implementation of the Rehabilitation Plan; (b) Providing Clearances, Permits and Approvals; (c) External Regulatory Monitoring. The indicative responsibilities are provided subsequently:

 Slum Rehabilitation Authority (SRA): Nodal agency for the rehabilitation of slum dwellers. The SRA does not have a direct implementation responsibility over the ESMP and is more of an overseeing authority for demolition management, progress of shifting/evacuation/transit and other formation of housing societies. It is suggested that the SRA should be informed about the progress of ESMP implementation;  Pune Municipal Corporation (PMC): KUL will need to directly liaise with the PMC as it is the local agency responsible for the provision of utilities and other services (such as waste disposal) and granting of permits;  Environmental Authorities: Other than the State Environmental Impact Assessment Authority which has the responsibility of providing Environmental Clearance to Project Nirvana, KUL will need to involve the regional office of the Ministry of Environment and Forests (MOEF), the regional Pollution Control Board (PCB) for submission of reports (as per the frequency) for monitoring on environmental indicators. These environmental authorities will also be a part of the external regulatory monitoring;  Community Audit Group: The CAG should be involved in undertaking regular checks of the progress of the project, specifically the Rehabilitation Plan and construction activities. The CAG should be trained by an external agency to develop a checklist of key indicators from the RP and ESMP and should also be given the role of liaising with the Engineering Head and the Head of Rehabilitation;  Housing Societies: Housing Societies will be formulated and registered by the SRA, subsequent to which they will be handed over the management of various buildings. The housing societies will need to be adequately trained in order to manage and implement the operational aspects of the ESMP.

1.2.2 Inspection Monitoring and Audit

In order to implement the ESMP, the Environmental and Social Manager (in consultations with senior management of KUL) will develop a time-bound and action-oriented Environmental and Social Action and Monitoring Plan and assign roles and responsibilities among the ESM staff as well as contractors for the mitigation measures. The Environmental and Social Action and Monitoring Plan should be developed as soon as possible and at least 6 months prior to peak construction activities. The plan should be developed on the basis of the ESMP provided in this section. The budget for implementing the ESMP will need to be finalized in conjunction with formulating the action plan by the KUL and ESM team.

Inspection and audit systems will need to be put in place to ensure that mitigation measures are being effectively put in place to address social and environmental sensitivities. This will be in the form of an Audit Program. The monitoring mechanism will cover all stakeholders including contractors, labourers, suppliers and the local community impacted by the project activities and associated facilities. Frequency of monitoring of the ESAP will be determined by the ESM staff. However, the implementation of the ESMP should be externally audited once every six months by an independent third-

ERM KUMAR SINEW URBAN DEVELOPERS LIMITED-ESMP PROJECT # I 8390 / 0138632 MARCH 2012 23 party monitoring agency during construction period and one every year during operations. The entire audit and monitoring process will be documented and corrective actions will need to be implemented.

KUL will develop and implement a programme of reporting through all stages of the project construction and commissioning through EHS and Social performance reports, inspection checklists, monitoring of grievances etc. The program of reporting prepared within one month of instatement of the ESM team. In particular, for the rehabilitation plan, as the Nirvana Hills Phase II Project is categorized as Category A for Involuntary Resettlement, submission of semi-annual internal (KUL) and external monitoring reports is mandatory.

1.2.3 Documentation and Record Keeping

Documentation and record keeping system has to be established to ensure updating and recording of requirements specified in ESMP. Responsibilities have to be assigned to relevant personnel for ensuring that the ESMP documentation system is maintained and that document control is ensured through access by and distribution to, identified personnel in form of the following:

 Master Social and Environmental Information System (MIS) that will be tracked by the ESM;  Legal register/PERT Chart and its updation;  Grievance Redressal Management Database;  Consultation related documentation;  Socio-economic database of all slum dwellers;  Operation control procedures and work instructions;  Incident Reports and Accident Registers;  Emergency preparedness and response procedures;  Training records, modules and annual calendar;  Auditing and monitoring reports.

KUL will need to develop internal monthly environmental and social monitoring reports. Project Nirvana has been categorized as Category B for Environment and Category A for Involuntary Resettlement. Hence, there will be a mandatory requirement to submit semi-annual internal (KUL) and external (ERM or similar consultancy) monitoring reports. A suggested outline for the internal monitoring report is provided hereunder:

 Current project status and schedule;  Organizational structure;  Update on the monitoring indicator for each suggested action in the ESMP;  Status of Regulatory Permits and Approvals;  Number of Stakeholder Consultations;  Current status report on grievances received till date (total received/closed/pending closure/follow-up stage).

ERM KUMAR SINEW URBAN DEVELOPERS LIMITED-ESMP PROJECT # I 8390 / 0138632 MARCH 2012 24 1.2.4 Community Disclosure and Grievance Redressal

KUL will establish a Community Disclosure and Grievance Redressal (CDGR) system that will be part of the Stakeholder Engagement Plan and that will be applicable for the entire project lifecycle. KUL will formulate a Community Relations team to implement the CDGR system and lead the community engagement process which would have the following tasks:

 Interface between KUL, contractors, sub-contractors and the slum dwellers;  Disclosure of project specific information across the slum blocks;  Establish a mechanism to obtain, report and monitor all grievances from the local community;  Regular engagement with any slum societies that get formulated and other external stakeholder groups identified in this report; and  To plan, implement and evaluate community development programs: To the extent possible the CSR activities should be relevant to the needs of the locality and in no case should be detrimental to the E&S sensitivities of the project area.

The Community Relations Team will consist of 2-3 personnel/Community Liaison Officers for each slum block who would be lead by the Head (Community Relations). The Grievance Redressal procedure will outline the process and steps to be taken, the key people responsible, and the upper limit to the time taken to resolve a conflict to the satisfaction of the complainant. In case there are grievances that have reached a stalemate, a third party mediation may be considered.

The framework to develop a Stakeholder Engagement and Grievance Redressal Plan is provided in Annex C and Annex D respectively.

1.2.5 Capacity Building and Training

The implementation of the ESMP will require a robust social and environmental, health and safety training plan which will ensure that the job specific training and EHS induction training needs are identified based on the specific requirements of ESMP and capacity of site and project personnel (including the Contractors and Subcontractors) to undertake the required actions and monitoring activities. General environmental awareness will be increased among the project’s team to encourage the implementation of environmentally sound practices and compliance requirements of the project activities. This will help in minimising adverse environmental impacts, compliance with the applicable regulations and standards, and achieving performance beyond compliance. The same level of awareness and commitment will be imparted to the contractors and sub contractors prior to the commencement of the project.

ERM KUMAR SINEW URBAN DEVELOPERS LIMITED-ESMP PROJECT # I 8390 / 0138632 MARCH 2012 25 1.3 BUDGETARY ALLOCATION AND TIMELINES

Table 1.2 provides an indicative budgetary allocation on the basis of the key mitigation measures that have been proposed in the ESMP. The ESMP cost for Project Nirvana will include recurring cost as well as fixed capital expenses. The indicative estimates provided subsequently do not include expenses associated with an increase in the organizational capacity.

Table 1.2 Indicative Budgetary Allocation for the ESMP

S. Particular Capital Cost Recurring Cost (INR in No (INR in million) Million) per annum A) Construction Phase 1. Provision of adequate drainage and Included in project cost Included in project cost bunds/ diversion dykes, water sprinkling etc. to prevent soil/ raw material escape 2. Development of vegetation and Included in project cost Included in project cost landscaping 3. Toilets for workers and sewage disposal Included in 0.25 facility subcontractor agreement 4. Air and Noise quality monitoring 0.2 0.50 5. Water Quality monitoring 0.0 0.25 6. Disposal of hazardous waste and ACM 1.0 0.20 7. Miscellaneous expenses for construction 1.5 0.25 phase EMP implementation B) Operation Phase 1. Sewage Treatment Plant Included in project cost Included in O&M cost 2 Wastewater quality monitoring Included in project cost Included in O&M cost 3. Solid Waste Management Included in project cost Included in O&M cost 4. Greenbelt & landscape maintenance 1.0 1.5 5. Environment, health and safety training 1.5 1.0 and EMP evaluation C) Associated Plans 1. Rehabilitation Plan Included in Project Cost Included in the Corpus Fund 2. Demolition Management Plan; Included in Project Cost 3. Labour Management Plan; Included in Project Cost Included in the Corpus Fund 4. Stakeholder Engagement Plan; Included in Project Cost 5. Grievance Redressal Plan; Included in Project Cost 6. Gender Action Plan; Included in Project Cost 7. Risk Management Plan Included in the Corpus Included in the Corpus Fund Fund D) Implementation of ESMP 1. Capacity building and identification of Included in the Project Included in the Project resources (Environmental and Social Cost Cost Manager) 2. ESMP Monitoring (Semi-annually) 0.5 0.5 3. Engagement of an NGO for capacity 0.25 0.25 building 4. Implementation of Grievance Mechanism Included in Project Cost

Note: The rehabilitation plan (separate document) has a distinct budgetary allocation that has been formulated by KUL.

ERM KUMAR SINEW URBAN DEVELOPERS LIMITED-ESMP PROJECT # I 8390 / 0138632 MARCH 2012 26 Table 1.3 Timeline for Implementation of ESMP

S No Components Remarks Year 1 Year 2 Year 3 Year 4 Year 5 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 A) Construction Phase 1 Provision of adequate drainage and bunds/ diversion dykes, water sprinkling etc. to prevent soil/ raw material escape 2 Development of vegetation and landscaping 3 Toilets for workers and sewage Immediate disposal facility 4 Disposal of hazardous waste and ACM Immediate 5 Air and Noise quality monitoring Quarterly 6 Water Quality monitoring Quarterly B) Operation Phase 1 Sewage Treatment Plant 2 Wastewater quality monitoring 3 Solid Waste Management 4 Greenbelt & landscape maintenance 5 Environment, health and safety training and EMP evaluation C) Associated Plans 1. Rehabilitation Plan Formulated by KUL and ERM 2. Demolition Management Plan; Suggested Framework in Annex A 3. Labour Management Plan; Suggested Framework in Annex B 4. Stakeholder Engagement Plan; Suggested Framework in Annex C 5. Grievance Redressal Plan; Suggested Framework in Annex D 6. Gender Action Plan; Suggested Framework in Annex E 7. Risk Management Plan Suggested Framework in Annex F

*Note: The implementation schedule herein highlights key actions of the ESMP. The KUL ESMP Manager will need to develop a concise plan based on the present project status, construction priorities and stage of demolition activities.

ERM KUMAR SINEW URBAN DEVELOPERS LIMITED-ESMP PROJECT # I 8390 / 0138632 MARCH 2012 27 Annex A

Demolition Management Plan

ESMP: ANNEX A-DEMOLITION MANAGEMENT PLAN

1.1 BRIEF SCOPE AND DESCRIPTION

The following demolition plan has been prepared for M/s Kumar Sinew Developers Limited (hereinafter referred to as “KUL”) for managing their undergoing demolition activities in their slum redevelopment and commercial cum residential project at “45 Nirvana Hills” in the city of Pune.

A demolition plan is a structured protocol that is undertaken by any agency for undertaking deconstruction activities in an organized manner so as to mitigate adverse impacts with respect to Environmental, Social and Health and Safety aspects and risks on the immediate and neighbouring surroundings of the site where the work is to be carried out.

This plan provides detailed guidance on managing the aforementioned demolition activities. Also, it outlines the roles and responsibilities of the client and its various agencies who would be involved in undertaking this deconstruction and demolition process.

Overview on the Demolition Process

The demolition activities for Project Nirvana have already commenced and are being carried forwards in phases in the respective slum pockets. These slum pockets are namely:  Kilewadi and Indira Park  Rajiv Gandhi Park  Hanuman Nagar  Vasant Nagar  Rautwadi

KUL are undertaking the demolition drive themselves, and are using their own machinery and manpower in these activities. They are coordinating with their Community Relations Team (CRT) to carry out the entire demolition process right from signing of the sale agreement to filling up of handover sheets and demolition checklists before commencing to demolition of the structure.

During the demolition and deconstruction process, the entire area of the project site where the present slum pockets are presently located will come under the demolition drive. It is expected that a total of approximately 3400 structures might be deconstructed during the entire process. The following table is indicative of the various types of structures that could possibly come under the purview of the deconstruction:

Types of Structures to be Demolished and Deconstructed

SNo. Type of Structure Approximate Number of Structures* 1. Slum Residences, shops and 3307 establishments 2. Temples 26 3. Mandal Samities (Community Places) 5 4. Public Toilets 15 5. Gymkhana 1 6. Cow Sheds 2 7. Hospitals 3 8. Samaj Vikas Kendra (Community 1 Development Building) 9. Schools 5 10. Charitable Trusts 2 Total 3366 Source: KUL Socio-Economic survey *List is only indicative. Figures might vary during actual deconstruction at the discretion of the developer

1.1.2 Applicable Hours of Operation for the Demolition Process

For undertaking demolition of the structures by KUL and their personnel, the following hours for carrying out operations would be followed:

 Monday to Saturday: 7:00am to 5:00pm  Intermittent Break: 1:30pm to 2:00pm  Sunday and Public Holidays: No Work

Note:

 No demolition work will be carried out outside of the applicable hours nominated unless any approval or consent has been obtained from the concerned regulatory authority.  Deliveries of heavy machinery including transfer of debris from the demolition sites to the landfills and other debris and waste management sites may be carried out of the proposed hours of operation but are required to be in conformance to the overriding requirements of the Roads & Traffic

1.1.3 Public Safety and Protection

The demolition drive is currently underway in a highly congested and densely inhabited location where almost 4800 people are presently residing. It is of prime importance that the safety of the people is taken into account and consideration before proceeding with any form of demolition activities. Therefore, certain precautionary measures that should be taken by the developer before the demolition process include:  Cordoning off the area by proper perimeter fencing using Caution Tape or similar indicators;  Limiting movement or trespassing of people around the area; and  Providing security.

1.2 FRAMEWORK/STAGES OF DEMOLITION PROCESS

The following diagram is an indicative representation of the various stages of work activities that are required to be carried out during the demolition activities:

Stage wise demolition plan for Project Nirvana

Source: Prepared by ERM in association with KUL

The various stages that are represented in the above thematic representation can be discussed as:

Stage I: Completion of Legal Requirements and Transfer of Land  It is the preliminary or preceding stage to the demolition activities that takes into account the completion of all the legal and statutory requirements including signing of the sale agreement between the owner and the developer, biometric registration of the owner and payment of applicable amount (including compensation, rent et.) as promised by the client;  Once and only when the legal requirements are complete, the structure is required to be taken over from the owner in a free and fair manner without any external force. The consent of the same is required to be registered by the client in form of the Handover Sheet signed by the respective owner;  The builder will then collate the Demolition checklist and prepare the site for deconstruction  In case the site owner does not comply with the sale agreement, or refuses to transfer land, no undue and unfair force or external pressure should be used by the client. The same should be resolved amicably between the owner and the developer and if required with some form of participation from either the SRA or the local administration representative

Primary Role and Responsibility: Community Relations Team of KUL

Stage II: Deconstruction of the Internal Components of the Site  During this phase, the builder will dissemble all the internal fixtures of the structure including wall mounts, fixed furniture, electrical installations, sewer lines, sanitation utilities etc.  The parts and components if desired by the owners can be given back to them;  The remaining components can be segregated according to their type, collected and sold off to recycler or a scrap dealer  Hazardous wastes if found should be properly disposed in landfills and should not be recycled

Primary Role and Responsibility: Demolition team of KUL

Stage III: Preparation for Structural Demolition  Once all the internal fixtures, utilities etc. have been deconstructed, the demolition team is required to prepare the site for structural demolition i.e by demolition by usage of heavy tools and machineries;  The primary step before proceeding for demolition is cordoning of the site with the help of a caution tape along its perimeter;  Proper warning and hazards signs are required to be setup wherever deemed necessary;  Trespassing by local public should not be allowed in this area for the duration of the demolition and the clearance of the debris;  It is to be ensured that the personnel on the ground handling the demolition drive are provided with Personal Protective Equipments (PPE);  Ensure that the machinery used is in good condition and the tools and equipments provided are also in functioning order  Ensure the presence of a safety engineer and a first aid kit at close proximity to the site of demolition

Primary Role and Responsibility: Demolition team and H&S officer KUL

Stage IV: Demolition of the structure  The demolition should be carried out as per a structured plan as suggested by the site in charge;  The demolition should commence from using lighter tools and equipments to moving towards heavy machinery and excavators during the demolish of bare concrete structure and crushing of large particles;

 Large debris should be destructed into smaller sections;  Debris should be segregated and collected at particular locations of the site and made ready for transport to land fills and waste yards

Primary Role and Responsibility: Demolition team and H&S officer KUL

Stage V: Transfer and disposal of generated Debris  Debris is required to be loaded by scoops and excavators into Lorries and dump trucks;  The debris is required to be taken to authorized landfills properly disposed off;  Debris which include metals, plastics, GI sheets can be transferred to authorized recyclers or sold off to scrap yards

Primary Role and Responsibility: Contractor hired for debris clearance and management

1.3 STRUCTURE DEMOLITION PROCEDURE

This section defines the structure demolition procedure that is mandatory to all KUL implementation staff as well as contractors. The demolition procedure has been developed with a view to minimize any risk that may occur for dwelling units within the scheme implementing under Slum Rehabilitation Authority Pune at Kelewadi.

1.3.1 Step 1: Consultation and Agreement

 The Community Relation officer (CRO) will understand from the Project Manager, the area required for construction, and properly mark on structure survey plan the numbers of structure and freeze the same by taking approval from Head Technical of the project.  The Community Relation officer will start consultation with slum dwellers, concerned for vacation of structure and to shift in-transit accommodation in consultation with local leader and to involve local corporator, if required. He will explain the SRA scheme and methodology of rehabilitation. He will explain each and every details of amount to be paid towards rent, livelihood support and other information’s, when the dweller will reside on transition.  The Community Relation officer will discuss the demolition process with community and neighbours to apprise them of the risks involved and what measures are to be taken to minimize those risks i.e safety measures being adopted and their participation co-operation.  On agreeing to go for transition by the dweller, the CRO will furnish the consent agreement duly signed by the dweller to the Company.  The CRO will furnish the rent requisition sheet (on prescribed format) towards payment of livelihood amount and rental cheques which he will give to structure owner at the time of vacation from structure.  The CRO will ensure the empty possession of structure from the structure owner.  The CRO will take the photograph of structure along with owner and his/her spouse as evidence of his entity being owner of structure within the scheme.

 If dweller wishes to shift in transit building, then the CRO will ensure the accommodation in the transit building and furnish the Transit flat allotment letter.  The CRO will take care during shifting of dweller in the transit building till the dweller is shifted in the building/ own arranged accommodation.  The CRO will fill the Livelihood Consultation Sheet to assess present livelihood status of the dweller and for monitoring of livelihood during transition. Also CRO will maintain the livelihood monitoring data of dweller to know the improvisation in his/her livelihood.  The CRO will hand over empty structure to Project Manager on duly filled Structure Hand Over Sheet for further demolition.  The Back Office In charge will acknowledge and submit the agreements to SRA for such demolition.

1.3.2 Step 2: Demolition of Structure/Tenement

 The Project Manager In-charge will execute the demolition process. He will ensure that structural stability of the adjacent structure/s has been verified by engineering team and their suggestions have been taken to account and assess the risk factor towards safety of human life that no inconvenience is evinced to social society by demolition.  The Project Manager In-charge will ensure towards minimum environmental pollution by the demolition.  The In-charge Project Manager will engage licensed contractor to remove electrical connection with prior acknowledgement /approval of Maharashtra State Electricity Board.  The Project Manager In-charge will engage licensed contractor to remove pipe line connection with prior acknowledgement /approval of Local Municipal Office.  The Project Manager In-charge will engage licensed contractor to sewer line with prior acknowledgement /approval of Local Municipal Office.  The Project Manager In-charge will check and ensure the following key issues are completed:  Formal document of handing over of possession and no objection to demolition from the pitch holder has been obtained. Last paid bills of amenities have been collected Electric Meter has been duly surrendered;  Water connection has been duly surrendered;  Sewer lines have been duly disconnected;  Structural Stability of the adjacent structure/s has been verified by engineering team and their suggestions taken to account;  SRA authorities has been informed of the demolition plan date and time;  Safety cordon placed to ensure no movement of people through demolition area;  Recheck – and ensure that structure and surroundings are vacant;  Provision for Announcement over the Public Address system to inform people to remain away from demolition area and maintain safe distance;

 The Demolition team has safety equipment and aware of all Safety procedures. Hard hat area clearly demarcated and signage are in place. First Aid Team on standby;  The In-charge Project Manager will ensure the barricading of clean area and make proper arrangement towards further encroachments till construction starts.

1.4 POTENTIAL IMPACTS ON ENVIRONMENT, SOCIAL AND HEALTH AND SAFETY DURING THE DEMOLITION PROCESS

During the demolition and deconstruction process, there are certain concerns that are generated with regards to environmental, social and health safety impacts. Some of these concerns have been identified and the mitigation measures for the same has been suggested in the following sections

1.4.1 Environment

There are certain environmental impacts that arise from any form of structural demolition process. Some of these impacts can be broadly classified under the categories of:  Dust Emissions  Noise Impacts  Storm Water run-off  Storage of Dangerous Goods  Hazardous waste management

The client is required to understand these impacts and implement mitigation measures for the same in order to prevent any serious escalation of these impacts which can cause both contamination and damage to the surrounding environment. Therefore, the above mentioned points are broadly discussed and suggestive mitigation measures are specified for the same.

1.4.2 Fugitive Dust Emissions

Dust is a significant problem during any demolition process. Significant amount of dust plumes arise during destruction of concrete structures. The primary line of action to control these fugitive emissions include  Spraying of Water is at the source of origin, over demolished materials (concrete) and on to the materials before loading to settle the dust particles and avoiding the migration of the same into the surrounding environment. It is advisable to install mobile water points at locations of ongoing demolition for providing faster access to water;  Using smaller to medium tools for preliminary demolition with heavy machineries such as bull dozers and excavators being used only at the latter stage as their use and movement exponentially increase the amount of dust generated; and  Covering dump trucks and lorries carrying debris with tarps so as to prevent continuous generation of dust cloud while it is transferring debris to a landfill.

1.4.3 Noise Impacts

The Noise generated from demolition activities are another form of environmental impact that can pose problems and annoyance to the surrounding vicinity. In any demolition site, noise can be primarily managed by primarily two types of controls. These include:

Administrative Control: Include management decisions which can drastically reduce the impacts of noise on the immediate surrounding. These administrative controls include:  Suitable timings of undertaking demolition activities. All demolition activities are required to be carried out only during designated working hours. No machine work will be allowed outside the prescribed timeframe.

 Relegating demolition activities near sensitive receptors such as schools and hospitals to Saturdays or during timeframes where the impacts due to the generated noise would be minimal;  Shutting down noisy machinery when not in use

Engineering Control: This sort of control requires usage of physical components (such as dampers, mufflers, enclosures etc.) on the tools, machineries and vehicles used in the demolition process. Some examples of engineering controls include  Substituting existing equipment with quieter equipment;  Retro-fitting existing equipment with damping materials, mufflers, or erecting enclosures and barriers.  Reducing Vehicular noise by regular maintenance and servicing

1.4.4 Storm Water runoff

During the period of rainfall, a lot of the loose rubble, soil gets washed off by the rainwater. This rainwater is channelled through the storm water drainage systems already constructed by the local municipal corporation in the area. Due to this, a lot of sedimentation occurs in the storm water drainage channels because of which clogging is possible leading rain water stagnation and accumulation. This situation can be controlled by:  Regular clearance of debris from the site;  Ensuring no blockage of existing drainage channels so as to allow surface run-off along existing contours (down slope) with the existing drainage system on-site of kerbs, gutters, gully pits and pipes etc.  Using drainage control devices if need arises

1.4.5 Storage of Dangerous Goods

There is a possibility that during the demolition activities, dangerous materials like diesel, petrol, oxyacetylene etc. would be required. It is suggested that following safety measures are kept in mind while using these materials:  Proper storage of these materials in sheds, secondary containments providing proper ventilations and also providing proper signage, warning signs for indicating the same;  Restrict entry to authorized personnel only; and  Providing fire safety equipments such as extinguishers, sand buckets for emergency use.

1.4.6 Disposal of Hazardous Wastes

There are various forms of hazardous wastes that might be generated during the demolition process especially during demolition of commercial establishments. These hazardous wastes include Asbestos, oils sludge, acid alkali residues, plastics, used batteries, hospital wastes etc The client is required to properly handle such wastes by using proper PPE and dispose the same only via proper channels and authorized agencies. They should be recycled only if possible, but otherwise be properly disposed in designated land fills and disposal sites.

1.4.7 Community Health and Safety

During the demolition drive, certain considerations are required to be provided to the health and safety of the community in the immediate surroundings. Some of these considerations include:  Identification of key sensitive receptors like hospitals, schools colleges and other public places such as temples, prayer halls, and community halls near to the site of demolition and synchronizing demolition activities after taking their suggestions and due recommendations;  Manage movement of people around the demolition site especially with regards to movements of construction vehicles, excavators, dump trucks etc. The drivers should be trained and provided guidance on safe driving measures;  A traffic management plan can be followed for the movement of debris vehicles in and out of the site so as to avoid any traffic jams and snarls and road blockages

 Exposed pits and excavated areas should be properly barricaded and put out of reach from general public;

1.4.8 Key Performance Indicators

There are certain key performances indicators that are required to be managed and monitored during the entire time span of the demolition and deconstruction activity. The following table details these indicators as well as advocates roles and responsibility to the client, its various agencies as well as any other external agency that might be a direct or indirect participatory party in the exercise.

Performance Indicator Table

Key Monitoring Indicators Role and Responsibility Deliverables and Timeframe Provision of adequate time to  SRA (Strictly Monitory)  Time to evacuation would the Slum Residents for  Community Relations Team be evaluated based on removal of their personal (CRT) of KUL mutual agreement between belongings and artefacts the CRT and the individual slum dweller Registering complaints and  CRT  Continuous during the grievances of the Slum  Demolition Team demolition process. Residents caused by the demolition activities. Special  A complaint register can be priority should be given to maintained by the CRT and vulnerable classes of the updated regularly with society including old, these grievances impaired, widows, orphans and disables Number of complaints  CRT  The same complaint registered by the neighbouring  Demolition team register can be functional community including and utilized for registering residents, schools, colleges, complaints and grievances hospitals etc. on fugitive dust, arising from the non- noise generation and other rehabilitated community as construction related activities ; well during the demolition process. Safety incidence among on-site  H&S Officer of KUL (Periodic  Continuous Process workers, as well as the Verification and Monitoring) residents  H&S Officer/Incharge of the Subcontractor (Direct Verification and Monitoring)  Onsite manager (Direct Verification and Monitoring)  Project Management Consultant (PMC) Hazardous Waste  Demolition Team  Documentation of Debris Encountered during  Subcontractor clearances which will demolition  PMC include logging of time of clearance, type of Evidence of Debris removal clearances (material type), and site cleaning mode of clearance, vehicle no. (if applicable) and dumping site location details

Annex B

Labour Management Plan

ESMP: ANNEX B-LABOR MANAGEMENT PLAN

1.1 INTRODUCTION

The construction phase of the project, 45 Nirvana Hills, has significant involvement of construction labor. It is for this purpose that a labor management plan is required to manage the labor issues, including the migrant laborers. This plan will be applicable not only for the direct contractors, but also for the various sub contractors whose services would be engaged for the project. The plan first puts together the present status of the project in terms of the construction and the hiring of the laborers and a brief description of the future component which would require engaging of laborers.

1.1.1 Project Location and Components

The project can be broadly divided into three components: (a) Rehabilitation Component; (b) the Sale Component, i.e. commercial and residential buildings; and (c) Construction of associated infrastructure and other facilities to support development of Nirvana Hills Phase 2 Project. The entire project is to be developed over an area of approximately 79.75 acres or 3, 22,736.799 m2 and will be in a phased-approach over the next 5 years. Table 1.1 provides details on the slum blocks that are to be considered under the scheme.

Slum Zone and Number of Tenements

Name of the Zone Number of Tenements Phase of Development Wader Vasti 488 Phase I (completed) Kilewadi and Indira Park 1145 Phase II Rajeev Gandhi Park 985 Phase II Rautwadi 498 Phase III Hanuman Nagar 1145 Phase IV and V Vasant Nagar 571 Phase V Total 4832 From Phase II to Completion *Source: Phase II to Phase V data from KUL Socio-economic Survey 2011

The Rehabilitation Component (not including the completed rehabilitation of Wadarvasti in Phase I of the development) involves the construction of 21 buildings, each having 11 floors with 13 flats on each floor. The net carpet area provided for each of these apartments is equivalent to 25m2 or 269 feet2 as per SRA guidelines. KUL has obtained sanction or commencement certificate for 725 tenements for Rajeev Gandhi Park (KUL is yet to receive a sanction/commencement certificate for the 711 slum dwellers eligible for rehabilitation at Kilewadi and Indira Park).

Component 1: Slum Rehabilitation Component  Includes construction of two transit buildings  Area of Construction: Kilewadi and Rajiv Gandhi Park  Contractor: M/s Karan Builders  Labor licence for 70 laborers  No. of Laborers – approximately 40 laborers working at site  Labor camp has been setup behind the KUL Community Relations office (as well as site office) at Rajiv Gandhi Park  Most of the laborers are migrants from and Bengal  Facilities of portable toilets, water and electricity has been provided on site

ENVIRONMENTAL RESOURCES MANAGEMENT 1

 PF, insurance/mediclaim documents were shown for review during ERM visit

The Free Sale Component will involve utilization of transferable development rights and a Floor Space Index of 2.5 from the construction of the rehabilitation buildings to develop commercial and residential spaces inside the project zone. Out of the 41 towers, KUL will establish 18 residential and commercial towers in the area allocated as per TDR and FSI by the SRA for their own sale.

Component 2: Free sale Component  Includes development of commercial and residential towers to be put up for sale by KUL in the allotted TDR and FSI space near Wader Vasti  Presently, construction of C2 tower is ongoing in this area  The contractor is M/s Man Infra Construction Limited  Possess a labor licence of 100 laborers currently. Will apply for more as and when required  Present temporary labor camps are located next to the construction site itself adjacent to the Karve road and laborers are camped here.  The camps presently house approximately 50 laborers.  New labor camps are been constructed at the quarry site also located adjacent to the construction site. The capacity of these camps would approximate to about 300 laborers  Most of the present laborers are migrants from Bihar, Orissa and West Bengal  Facilities of mobile toilets, water and electricity has been provided on site  Man Infra has a project execution plan that they maintain when it comes to managing the laborers (a scanned copy is attached with the mail)  PF, insurance/mediclaim documents were shown for review during ERM visit

The Amenities and Infrastructure Component is one of the most significant aspects of the Nirvana Hills Phase II Project which distinguishes it from a housing project to incorporate elements of a planned township project. In terms of welfare amenities, KUL will provide additional amenities such as temples, playgrounds, library, community halls etc. in the immediate vicinity of the rehabilitation component. Some of the general multipurpose utilities include shopping malls, community centre, kids’ playgrounds, crèche, temples and green zones. The key infrastructure facilities that will be planned for the project area includes: (a) a proposed development plan road in addition to expansion of the existing ARAI road; (b) water supply, storage and rainwater harvesting systems; (c) sewage treatment and disposal systems; (d) Fire fighting systems; and (e) Power Supply and Back-up System.

1.1.2 Purpose

This code relates to labor management throughout the life cycle of the project. The understanding of the labor or the workers for the purpose of this plan has been considered to be wide, including the full time employees of the KUL and not only the construction workers employed at the site. This also includes the non employee workers who will be working as sub contracted workers through the many small scale contractors that may be hired from time to time.

The purpose of the labor management plan, especially keeping the context of the KUL operations and the nature of the present work is to identify and incorporate desired actions and monitoring indicators for various aspects related to handling labor/ worker related issues effectively.

ENVIRONMENTAL RESOURCES MANAGEMENT 2

1.1.3 Scope:

The scope of the KUL Operations is understood to be starting from construction, and ending at decommissioning of the housing projects. However, there will be a section of employees who will continue to work as regular staffs even after the completion of the present housing project.

The scope of the present labor management plan has been broadly categorised into two components:

Aspects for Ensuring Proper Labor Management

 Human resource Policy  Working Relationship Policy  Working Conditions & Terms of Employment Policy  Workers’ Organizations  Non-Discrimination & Equal Opportunity  Retrenchment  Grievance Mechanism  Child Labor  Forced Labor  Occupational Health & Safety  Non-Employee Workers

Setting up and management of Labor Camp

 Site Selection and construction  Facilities at the labor camp including safety, amenities etc.  Use and maintenance  Dismantling and reinstatement of labor camp occupied land

Setting up and management of labor camp has been dealt with separately as they are considered to be an integral part of any construction project involving influx of migrant workers travelling alone or with their families including the children in some of the cases. Labor camp is mainly envisaged to be set up during the construction phase and the laborers would mostly fall in the category of either inter state or intra state migrant laborers.

Note: The grievance redressal mechanism for labors/ workers has been separately dealt in the Grievance redressal plan.

References and Recommended further reading

 The Building and other Construction Workers (Regulation of Employment and Conditions of Service) Act, 1996 and Central Rules, 1998 made thereunder stipulates that all establishments employing more than ten (10) workers will have to meet the provisions of the act and rules made thereunder.  For engaging twenty or more labor on contract on any day the Contractor shall also abide by the provisions laid down in the Contract Labor (Regulation & Abolition) Act, 1970. Under this Act, the Contractor shall secure a license from the Labor Commissioner after certification from the Employer (KUL). The contractor shall maintain all wage, attendance, PF, leave registers as applicable under the Act and shall keep them available for any inspection by the Employer.

ENVIRONMENTAL RESOURCES MANAGEMENT 3

 Similarly the provisions of Interstate Migrant Workmen Act 1979 shall become applicable in case 5 or more interstate migrant workmen are engaged by the Contractor.  Child labor prohibition Act shall be universally applicable to the Contractor which prohibits employing of any workmen/labor below the age of 14 years. In addition compliance to labor laws like payment of wages, payment of PF, equal remuneration, hours of work, overtime, weekly holiday etc shall be observed by the contractor as per applicable laws.  Chapter 6 of The Building and other Construction Workers Act and Chapter 28 of Central rules stipulate the basic welfare measures that are to be provided by the employer or establishment. Similarly Chapter 5 of Contract Labor Act stipulates the basic welfare measures. The stipulations shall be reviewed and followed.  http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STA NDARDS&p_id=9791

 www.whoindia.org/.../Water_Quality_neeri_Annexure- I_DRINKING_WATER_–_SPECIFICATION.pdf

ENVIRONMENTAL RESOURCES MANAGEMENT 4

Different Aspects of Ensuring Labor Management

Aspects for Ensuring Proper Labor Management

SNo. Guiding principles Desired Actions Responsible Agency Monitoring Indicators 1 Human resource Policy  KUL will have a  Centrally organize all policies and  KUL Management  Complete review of all policies and documented policy and procedures; Team procedures procedure related to Human  Identify and record responsible  Review of management-worker committee resources. person and last date modified meeting minutes  KUL will inform workers of  Conduct an annual review of all  Communications (memos, letters, etc.) to their rights under national policies and procedures workers, suppliers, contractors and multi- labor and employment law  Prominently display policies and stakeholder groups (Kindly refer ANNEXURE procedures in all local languages  Interviews with management and workers to the plan)  Appoint a person responsible for  Interviews with external stakeholders  Policy must be clear and monitoring policies and procedures  Budgets related to implementing labor understandable to all related to labor law implementation policy workers  Implement standardized routine  Training curricula and logs training

2 Working Relationship Policy  KUL will document and  Provide all workers with a contract in  KUL Management  Contracts for all workers communicate working their native language Team  Policies and procedures related to worker conditions and terms of  Provide documented training on contracts and wages employment to all workers contracts, wages, benefits and  Communication and training on wage  Wages and benefits must be deductions for all workers calculation, including local laws clearly communicated and  Routinely provide workers with a  Payroll records, time sheets and pay stubs understood by all workers clear record of pay calculations  Piece rate or performance pay calculations verified against minimum wage  Worker interviews

3 Working Conditions & Terms of Employment Policy  If there is a collective  Ongoing internal verification that all  KUL Management  Collective bargaining agreement (if one bargaining agreement, the workers are receiving wages and Team/ Human exists) company will respect its benefits as prescribed by law Resources &  Worker contracts terms  Ongoing communication and training Administration  Policies and procedures related to wages,  KUL must provide on legal labor rights and company benefits, hours and leave reasonable working personnel policies  Wage calculations as they relate to local conditions and terms of  Worker representatives meets laws

SNo. Guiding principles Desired Actions Responsible Agency Monitoring Indicators employment, at a minimum regularly with HR and company  Worker and external stakeholder interviews complying with the various management  National law as it relates to wage and local laws as attached in  Training on minimum legal benefits benefit minimums ANNEXURE to this plan for all workers, including contractors,  Employment and termination records and employment agencies

4 Workers’ Organizations  KUL will recognizes  Clear communication to workers on  KUL Human  Documented policy regarding collective workers’ rights to form and their rights to collective bargaining Resources and bargaining to join workers’  Allow workers to meet to address Administration  Minutes and records from collective organizations workplace issues bargaining sessions, reviews or other actions  KUL cannot interfere with  Regular training on worker-manager  Procedure for workers to select worker or discriminate against communications representative without management workers who choose to  Regular meetings of management and interference organize worker representatives  Interviews with workers, NGOs and trade  Worker representatives  Periodic documented communication unions must have access to with local unions and NGOs  Collective bargaining agreements management  Grievance mechanism  Worker organizations are expected to fairly represent the workforce

5 Non-Discrimination & Equal Opportunity  People should be hired,  Clearly define anti-discrimination  KUL Human  Discrimination policy and related promoted and compensated policy in hiring, training, promotions Resources and employment policies and procedures solely based on their ability and compensation Administration  Company policy and procedure to address to do the job  Regularly review worker and and manage discrimination issues when  All workers should have manager demographics found equal access to training,  Develop long term remediation plan  Comparative demographics of workers and tools and opportunities for to address past discrimination managers advancement  Provide regular training to workers  Documentation of handled discrimination  All workers should be free and managers cases from harassment by  Establish confidential and secure  Diversity training curriculum and management or other communication channels for workers attendance log workers to reach managers  Interviews with workers and managers,  Positive discrimination may  Actively promote a harassment-free including those who may be likely to be be allowable in cases where workplace discriminated against it protects disadvantaged or  Interviews with local NGOs and trade

SNo. Guiding principles Desired Actions Responsible Agency Monitoring Indicators excluded groups and unions provides them special  Hiring, promotion and termination records opportunities  Local laws related to discrimination 6 Retrenchment  KUL will develop and  Policy and procedure for workforce  KUL Human  Policy and procedure related to workforce implement a plan to reduction, including worker selection Resources and reduction, severance and transition mitigate the adverse impact  Analysis of alternatives to workforce Administration  Analysis of alternatives of retrenchment if it reduction  Procedures for selecting workers impacted anticipates a large number  Engage workers in discussions with by workforce reduction of layoffs workers related to workforce  Documentation of prior instances of  The plan will incorporate reduction as early as possible workforce reductions non-discrimination  Communication to all workers about  Minutes from management meetings and principles and include the why and how the reduction will take discussions input of workers, their place  Communications with workers related to organizations, where  Discussions with local NGOs about workforce reduction appropriate, the how the community impact of  Communications with external stakeholders government workforce reduction could be and community groups minimized Note: The contractors may be asked to prepare such a lay off plan especially if the local community is engaged as laborers, as most of the migrant laborers are shifted to other sites for work by the contractor itself.

7 Grievance Mechanism  KUL will establish a  Establish clear policies and  Community  Documented policy and procedure for transparent process for procedures for grievances Relations Team, KUL worker grievances workers to express concerns  Communicate the grievance process Human Resources  Worker and manager interviews and file grievances to all workers in a clear, and Administration  Training curriculum and log on grievance  There will be no retaliation understandable manner handling or discrimination against  Provide ongoing training to all  Communications to workers, supervisors those that express workers and managers grievances  Document all grievances and the  Records of complaints lodged and actions  KUL Management will treat resulting actions taken on grievances the grievances seriously and  Make worker representatives a key  Employment and termination records take appropriate action part of the process  KUL’s grievance mechanism

SNo. Guiding principles Desired Actions Responsible Agency Monitoring Indicators does not replace other channels as defined by law or collective bargaining agreements Note: Kindly refer to the grievance redressal Plan for KUL for detailed information

8 Child Labor  KUL will not employ  Write clearly defined policies and  Community  Policies and procedures for age verification workers under the procedures for age verification – Relations Team, KUL in hiring minimum age for make them publicly available Human Resources  Interviews with workers, local children, employment as defined by  Develop remediation plan for use in and Administration trade unions and NGOs national law (.i.e below 18 cases where children are  Visual observation years of age) unknowingly employed despite  Pay records, medical records, birth  Workers between the KUL’s No Child Labor policies and certificates, panchayat certificate minimum age and 18 will procedures (ex: child presents false not be employed in ID) dangerous work or work  Engage with local stakeholders to that interferes with their develop proactive plans to address education or development child labor issues  Communicate child labor policies to KUL’s suppliers and contractors – and provide them with the training and tools to address the issue 9 Forced Labor  KUL will not employ forced  Clearly define worker’s freedom in  Community  Employment contracts in all appropriate labor employment contract Relations Team, KUL languages  Workers have the right to  Provide employment contracts to all Human Resources  Contracts with employment or recruitment retain their personal workers in their language - direct or and Administration agencies documents and money contracted  Payroll records, timesheets and wage  Workers are free to leave the  Define and enforce policy regarding deduction calculations workplace after work use of employment agencies and  List of permanent workers and contracted  Workers have the right to expectations workers at KUL facility resign  If employment agencies are used,  Worker passports or IDs audit relationship between the agency  Interviews with all workers, employment and the workers agencies and external stakeholders  Provide training for all workers to  Interviews with security guards explain their rights

SNo. Guiding principles Desired Actions Responsible Agency Monitoring Indicators  Pay all job related training and equipment expenses 10 Occupational Health & Safety  KUL will take all reasonable  Structuring an OHS team and an OHS  Contractors,  Visual observation precaution actions to protect accountability framework (including Community  Exposure to hazardous agents monitoring the health and safety of production area) Relations Team and log workers  Conducting a comprehensive job KUL Human  Manager and worker interviews  KUL will ensure that safety or job hazard analyses Resources  Accident and medical treatment logs workers are not exposed to  Developing a Corrective OHS Action  Equipment maintenance logs unnecessary or Plan based on the likelihood and  Fire and safety drill logs unreasonable risks at the severity of the consequence of  Health and safety risk analysis workplace, dormitories etc. exposure to the identified hazards  Health and safety inspection logs with test  KUL will implement an  Proper equipment design, results OHS management system maintenance and procedures, such as:  Government health inspection reports consistent with international Designing machines and equipments  Training curriculum and logs standards such as OHSAS like stairs, to eliminate trap hazards 18001.  Turning off, disconnecting, isolating,  KUL will systematically and de-energizing (Locked Out and assess all of the OHS risks, Tagged Out) machinery with exposed conducting a or guarded moving parts or being comprehensive job safety or serviced job hazard analyses.  Marking and checking all energized  KUL will implement electrical devices, cords and lines with preventive and protective warning signs measures according to the  Implementing proper monitoring order of priority: systems of hazardous agents and Eliminating the hazard, proper control measures (eliminating Controlling the hazard at its risk, PPC, PPE) source, Minimizing the hazard, Providing Some examples of things to be done include: appropriate personal  Integrity of Workplace Structures – protective equipment reachable, easy to clean, fore resistant,  KUL will document, floors investigate and report all  Workspace and exits – unobstructed, accidents and occupational clearly marked, consider disabilities diseases.  Fire Precautions  KUL will investigate and  Amenities- toilets, potable water, lighting identify the root causes of  Safe Access –even pathways, falling all accidents with working objects, railings

SNo. Guiding principles Desired Actions Responsible Agency Monitoring Indicators time loss, and implement  First Aid- training appropriate corrective  Fresh air supply actions  Physical Hazards- Working at heights, Note: This can be done through Vibrations, Electrical, Ergonomics, the involved contractors also. illumination  PPEs  Communication- Induction orientation, training

11 Non-Employee Workers  KUL will extend the  Provide employment contracts to all  Contractors,  Contracted labor contracts in all appropriate previously discussed workers in their language - direct or Community languages indicators to contractors contracted Relations Team and  Contracts with employment or recruitment hired directly or through  If employment agencies are used, KUL Human agencies employment agencies. audit relationship between the agency Resources  Payment records, timesheets and wage  KUL will not use and the workers deduction calculations for contracted contracting as a means of  Provide training for all contracted workers circumventing labor rights workers to explain their rights  Listing of direct employees and contracted and laws.  Include contracted workers in workers at KUL facility  Employment and grievance process access and training  Interviews with managers, employment recruitment agencies will be agencies and external stakeholders monitored to verify their  Interviews with contracted workers - adherence to labor rights directly contracted and through agencies and laws.

Labor Camp management

Procedures and Responsibilities

SNo. Key areas of work Description Responsibility Format/ Record Reference 1. Need for Labor Camps  It will be the responsibility of Contractor to make his own arrangement Contractors and  Site selected keeping Weigh the options for the land required by him for setting up site offices, labor camps and Sub contractors environmental issues stores. as one of the criteria  For small duration works, Contractor may not require a dedicated labor camp to be set-up. Instead, Contractor can analyse all the best available options such as rental or leased housing stock available with the local community for providing housing to his labor staff.  Contractor may also analyse the option of hiring local laborers in both skilled and unskilled category to avoid setting up dedicated labor camp under the project.  However, if the Contractor decides to set-up labor camp(s), the management measures recommended in this SOP shall be fully complied as a minimum requirement.

2. Site Selection during  EPC Contractor shall identify probable labor campsites both within Contractors and  Site selection criteria Project planning stage project area and outside after having consultations with KUL. Sub contractors adopted  The selected sites shall be evaluated against environmental impacts  Site identified in anticipated at each site. The site with least environmental problems tender documents which are mitigable shall be identified and reported to KUL for approval.  Assistance of KUL shall also be sought in order to identify a land which has no local issues and ownership conflicts since the contractor will have to pay rent for using the land.

Other best practices:  Building Standards –construction material, fire and electrical safety (where cooking is allowed), plumbing and sanitation.  General Living Facilities: a. Avoid areas of water logging and natural hazards b. Reasonable distance to place of work c. Transportation is safe and free d. Good repair and kept clean

3. Land Use  Ideal land use at probable construction campsites could be open, barren Contractors and  Vegetation removal and non-agricultural land devoid of any vegetation or minimum Sub contractors with permission

SNo. Key areas of work Description Responsibility Format/ Record Reference vegetation. In urban areas, unused and isolated private/public lands shall be preferred over properties located in midst of residential or forested land use. Vacant, unused lands that are located at least 500-1000 m away from nearest habitation areas shall be preferred.

4. Tree Felling  At selected site, no trees above 100-mm girth size shall be felled. All Contractors and efforts to reduce felling of trees shall be encouraged by working out Sub contractors alternate layout plans. Tree felling is a regulated activity.

5. Agreement with  Contractor shall obtain the approval of landowner even in the case of Contractors and  Agreement with Landowner government owned land. The agreement or approval letter shall Sub contractors landowner specifically state that land will be returned to the owner in pre-project Note: to be applicable stage status after the agreed duration. only if the camps are  Payment of fair land rent value, clause for payment of compensation for constructed outside the any damages due to project work and time period within which the land project area. shall be returned etc shall be explicitly mentioned in the agreement with the landowner.  To record the pre-construction stage status, contractor shall take photographs of the site from every angle and document the same.  During the agreement period Contractor will be responsible for discouraging encroachers and hawkers around the campsite. A copy of final agreement shall be kept ready for any inspection by the KUL.

6. Soil Environment  Before setting up construction camps, during clearing operation, topsoil Contractors and  Practices adopted to of about 100-150 mm thick, shall be removed, if the site selected is having Sub contractors save and store topsoil vegetation even in the form of ground grass cover. The removed topsoil shall be preferably used for landscaping efforts at project site or within the camp site.  Stacking at camp site should be exercised as the last option. If stored in stacks, care should be taken to avoid anaerobic condition developing in the stacks by limiting stack height to a maximum of 1.5 m and overturning the stacks after every 3-6 months.

7. Sensitive receptors  Sensitive receptors such as residential areas, educational institutes, Contractors and  Location with respect hospitals, religious places, community playgrounds, water bodies used Sub contractors to nearby sensitive for public purposes, declared forested areas etc shall not share boundary receptors. Document with camp site. the selection process.  Preferably, the campsite should be located at the farthest location possible.

SNo. Key areas of work Description Responsibility Format/ Record Reference

8. Sanitary facilities  Toilet facilities adequate in number for the capacity of the camp shall be Contractors and  Adequate number in provided. Sub contractors compliance  A shared toilet facility shall be located at least 200 feet away of  Adequacy of facilities residential dwelling units. If less distance is available, the orientation provided for both sex shall be kept in such a way that facility faces away from residential area.  Location and No shared toilet facility shall be closer than 100 feet to any sleeping provision of sanitary room, dining room, lunch area, or kitchen. facilities  Separate toilet rooms shall be provided for each sex. These rooms shall be distinctly marked "for men" and "for women" by signs printed in English and in the native language of the persons occupying the camp, or marked with easily understood pictures or symbols. If the facilities for each sex are in the same building, solid walls or partitions extending from the floor to the roof or ceiling shall separate them.  Number of privy toilet seats shall be in the ratio of one unit to each 15 persons, with a minimum of two units for any shared facility.  Urinals shall be provided on the basis of one unit or 2 linear feet of urinal trough for each 25 men. Urinals shall be provided with adequate water flush.

Best practices:  Easily cleanable  Cleaned regularly  Adequate privacy  Separate for men and women  Adequate numbers (between 1/6 to 1/15)  Not far – 30mt to 60 mt from residence  Hand-washing facilities

9. Bathing facilities  In the campsite, shared bathing rooms in the ratio of one room for every Contractors and  Adequate bathroom 10 persons shall be provided. Sub contractors facilities  If bathing facilities for each sex are in the same building, solid walls or partitions extending from the floor to the roof or ceiling shall separate them.  Bathing room floors shall be made of smooth finish but not slippery materials; they shall be impervious to moisture. Floor drains shall be provided in all bathrooms.

Best practices:

SNo. Key areas of work Description Responsibility Format/ Record Reference • Adequate numbers (between 1/6 to 1/15) • Safe and clean floors – not slippery • Cold and hot running water, if possible

10. Laundry and washing  Hard floored washing area behind bathing facilities shall be provided in Contractors and  Adequate washing facilities the ratio of 20 sq.ft per 30 persons or 15 families. Sub contractors facilities  Flooring material shall be of smooth finish but not slippery. Floor drains shall be provided to clear wastewater. Facilities for drying clothes shall be provided.

11. Upkeep and maintenance  Each toilet rooms, bathing rooms and washing area shall be lighted Contractors and  Adequate lighting in of sanitary facilities naturally or artificially by a safe type of lighting at all hours of the day Sub contractors all enclosed rooms and night.  Each of toilet, bathrooms and wash area shall be kept in a sanitary condition. They shall be cleaned at least daily.

12. Lighting  Where electric service is available, each habitable room in a camp shall be Contractors and  Adequate luminance provided with at least one ceiling-type light fixture. Sub contractors  Laundry and toilet rooms and rooms where people congregate shall contain at least one ceiling- or wall-type fixture.  Light levels in toilet and storage rooms shall be at least 20 foot-candles 30 inches from the floor.  Other rooms, including kitchens and living quarters, shall be at least 30 foot-candles 30 inches from the floor.

13. Domestic garbage disposal  Common campsite garbage bins shall be provided at least 100feet away Contractors and bins from nearest residential unit. Sub contractors  Bins shall be made of metal barrels with lids and tarred inside or other equivalent container material.  The containers shall be kept clean and emptied when full, but not less than twice a week.  Disposal shall be at designated disposal sites as advised by the local Panchayat body or the municipal corporation.

14. Construction Camp  One residential unit shall be provided for each family at the campsite. Contractors and  Adequate dwelling facilities  Any dimension of the residential unit shall not be less than 7 feet. Each Sub contractors space adult person shall have minimum dwelling area of not less than 40 sq. feet. In case of dormitories, each person shall have a minimum of 50 sq. feet of dwelling area.

SNo. Key areas of work Description Responsibility Format/ Record Reference  In the units wherein workers cook, live and sleep in a single room, a minimum area of 100 Sq. feet per person shall be provided.  In addition, if the contractor is engaging women labor, the provisions regarding crèches shall also be observed as per law.

Best practices: Rooms and Dormitories  Density- 4-5.5 sq mt space  clean, ventilation  Clean floors  Ceiling height – at least 2.1 mt  Room sharing – range between 2-8  Lockable doors and windows  Mosquito screens/options  Mobile partitions, curtains  Every resident provided- bed, chair, table, bedside lamp, mirror  Separate sleeping area for men and women  Beds a. Separate bed for each worker- avoid hot bedding b. Space between beds at least 1 mt c. Double deck avoidable. If not, then at least 0.7-1.1 mt difference d. Triple deck- prohibited e. Clean mattress and bedding f. Storage space g. Space to PPEs and safety boots etc

15. Material of Construction  The residential units shall be constructed of reusable/ recyclable Contractors and  Reuseable materials materials, which are easy to construct and dismantle. Sub contractors used  Construction material shall be selected to provide protection against harsh natural elements such as heat, cold, monsoon etc.  If corrugated GI sheets are used as roofing material, to provide cool liveable environment inside, double roofing of the same material or providing a thatched roof above campsite units shall be considered.

16. Provision for drinking  Wholesome drinking water at the rate of 10 litres per person per day Contractors and  Adequate quantity of water shall be provided in the camps which shall be used for drinking and Sub contractors water provided cooking purpose only.  For bathing, washing and ablution purposes, potable water at the rate of 30 litres per person per day shall be provided.

SNo. Key areas of work Description Responsibility Format/ Record Reference  The water quality provided at the campsite for all purposes including bathing and washing should meet the ISO 10500-1993 specifications for desirable quality parameters (weblink provided at the end).  The contractor shall arrange for the testing of drinking water by way of personal equipment or through an analytical laboratory.

Best practices:  Water- a. Easy access to clean source of water. b. Clean storage c. Monitoring quality

17. Provision for cooking fuel  All laborers staying in the camp shall be provided with/or encouraged Contractors and  Cooking practices to use kerosene stoves at the least for cooking purposes. Sub contractors adopted at campsite  Use of firewood for cooking shall be discouraged or prohibited.  Within the residential unit good ventilation shall be provided if cooking is to be done inside. It will be better to cook outdoors than inside dark and enclosed living rooms of the unit.

18. Liquid waste generation  Liquid waste generation and disposal from labor camp site is a regulated Contractors and and disposal – Regulatory activity under the Water (Prevention & Control of Pollution) Act, 1974. Sub contractors Compliance  Any new discharge or disposal of liquid waste requires consent to establish (CTE) and operate (CTO) from the Maharashtra State Pollution Control Board (MSPCB).  The regulatory implications and applicability of the act on the construction labor camps needs to be ascertained from the local Regional Office of MSPCB. At any point during the contract period, Contractor is expected to comply with the regulations and directives of MSPCB.  If CTE and CTO are not required under the Water Act for labor camp facilities, an exemption letter issued by MSPCB shall be maintained as part of Project Records. A copy of the CTO/CTE or the exemption letter shall be kept available for any inspection by the KUL.

19. Liquid waste generation  A common kitchen utensil washing area shall be provided. Washing Contractors and  Practices adopted to and disposal outside dwelling units shall be prohibited. Sub contractors handle liquid waste  Liquid waste generated from bathing, laundry wash, kitchen utensils wash areas shall be collected at one point and disposed off to public sewer system if available.  If more than 1000 litres of water is consumed at a campsite for various

SNo. Key areas of work Description Responsibility Format/ Record Reference purposes, installing appropriate, onsite packaged treatment plant will be appropriate.  Treated wastewater can be used for landscaping and gardening purposes or disposed off in public sewer system.

Best practices:  Discharge should meet national and WB standards – see Pollution Prevention and Abatement Handbook, July 1998 – WB  Rubbish removal- containers at least 30 mt away from each shelter, at a height, easily cleaned, cleaned regularly, odour etc managed.  Vector control

20. Wastewater generated  Wastewater emanating from toilets and urinals shall be treated onsite Contractors and  Practices adopted to from toilets before disposal. Sub contractors handle toilet waste  Onsite options such as septic tanks and twin pit pour flush latrines shall be preferred.

21. Solid waste generation  Solid waste generated shall be collected in common campsite garbage Contractors and  Practices adopted to and disposal barrels as mentioned earlier. Sub contractors handle solid waste  Collected garbage shall not be burnt in open as it is prohibited under Solid waste (Management and Handling) Rules, 2000.  Salvageable dry waste (such as recyclable plastics, metal, glass, containers etc) shall be removed prior to disposal through the use of local scavengers.  Wet solid waste shall be transported to nearest municipal/Panchayat disposal site.  If area is available onsite treatment systems such as composting shall be encouraged for treating wet waste.

Best practices:  Discharge should meet national and WB standards – see Pollution Prevention and Abatement Handbook, July 1998 – WB  Rubbish removal- containers at least 30 mt away from each shelter, at a height, easily cleaned, cleaned regularly, odour etc managed.  Vector control

22. General Housekeeping  The entire campsite area shall be managed with better housekeeping Contractors and  General cleanliness of and Sanitation practices. Sub contractors campsite  Sweeping the area daily at least once, prohibiting spitting, bathing,

SNo. Key areas of work Description Responsibility Format/ Record Reference washing etc in open camp community space, avoiding cesspool formation of water/wastewater in low-lying areas, not throwing garbage and waste food indiscriminately in open areas, or feeding to local cattle, prohibiting open defecation etc.  Effective measures shall be taken to prevent infestation by and harbourage of animals (pigs and stray dogs) or insect vectors or pests especially at waste disposal locations

23. Reinstatement of Land  During reinstatement, all efforts to return the land in its pre-construction Contractors and  Satisfactory stage status shall be taken. Onsite treatment systems like septic tanks, Sub contractors reinstatement of land leach pits, composting yards, if established, shall be closed safely. occupied by campsite  Topsoil collected prior to establishment shall be re-spread and vegetation reinstated.  Any encroachers within or adjoining camp boundary shall be discouraged and Landowner/ KUL shall be kept informed about such developments.  A satisfaction certificate will be secured form the landowner upon handing back the land. This certificate as well as photographs of restored land shall be kept as a document of proof and shall be provided to KUL during any inspection.

24. Health and Welfare  If the project campsite is to be used and maintained for more than 6 Contractors and  Health and welfare Measures months duration at a location, the Works contractor may organise and Sub contractors measures provided arrange medical camps exclusively for the benefit of construction workers and their families staying in the camp.  The medical camp shall be organised under a registered medical practitioner.

Annex 1

Relevant Stipulations

Reproduced from

Construction Workers Act, 1996 and Central Rules, 1998

ENVIRONMENTAL RESOURCES MANAGEMENT 19

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

CHAPTER VI

Hours of Work, Welfare Measures and Other Conditions of Service of Building Workers

28. Fixing hours for normal working day, etc.- (1) The appropriate Government may, by rules, - (a) fix the number of hours of work which shall constitute a normal working day for a building worker, inclusive of one or more specified intervals; (b) provide for a day of rest in every period of seven days which shall be allowed to all building workers and for the payment of remuneration in respect of such days of rest; (c) provide for payment of work on a day of rest at a rate not less than the overtime rate specified in section 29

(2) The provisions of sub-section (1) shall, in relation to the following classes of building workers, apply only to such extent, and subject to such conditions, as may be prescribed, namely - (a) persons engaged on urgent work, or in any emergency which could not have been foreseen or prevented; (b) persons engaged in a work in the nature of preparatory or complementary work which must necessarily be carried on outside the normal hours of work laid down in the rules; (c) persons engaged in any work which for technical reasons has to be completed before the day is over; (d) persons engaged in a work which could not be carried on except at times dependent on the irregular action of natural forces.

29. Wages for overtime work-

(1) Where any building worker is required to work on any day in excess of the number of hours constituting a normal working day, he shall be entitled to wages at the rate of twice his ordinary rate or wages.

(2) For the purpose of this section,” ordinary rates of wages” means the basic wages plus such allowance as the worker is for the time being entitled to but does not include any bonus.

30. Maintenance of registers and records-

(1) Every employer shall maintain such registers and records giving such particulars of building workers employed by him, the work performed by them, the number of hours of work which shall constitute a normal working day for them, a day of rest in period of seven days which shall be allowed to them, the wages paid to them, the receipts given by them and such other particulars in such form as may be prescribed.

ENVIRONMENTAL RESOURCES MANAGEMENT 20

(2) Every employer shall keep exhibited, in such manner as may be prescribed, in the place where such workers may be employed, notices in the prescribed from containing the prescribed particulars. (3) The appropriate Government may, by rules, provide for the issue of wage books or wage slips to building workers employed in an establishment and prescribe the manner in which entries shall be made and authenticated in such wage books or wage slips by the employer or his agent.

31. Prohibition of employment of certain persons in certain building or other construction work-

No person about whom the employer knows or has reason to believe that he is a deaf or he has a defective vision or he has a tendency to giddiness shall be required or allowed to work in any such operation of building or other construction work which is likely to involve a risk of any accident either to the building worker himself or to any other person.

32. Drinking water-

(1) The employer shall make in every place where building or other construction work is in progress, effective arrangements to provide and maintain at suitable points conveniently situated for all persons employed therein, a sufficient supply of wholesome drinking water. (2) All such points shall be legibly marked “Drinking Water” in a language understood by a majority of the persons employed in such place and no such point shall be situated within six metres of any washing place, urinal or latrine.

33. Latrines and urinals-

In every place where building or other construction work is carried on, the employer shall provide sufficient latrine and urinal accommodation of such types as may be prescribed and they shall be so conveniently situated as may be accessible to the building workers at all times while they are in such place.

Provided that it shall not be necessary to provide separate urinals in any place where less than fifty persons are employed or where the latrines are connected to a water-borne sewage system.

34. Accommodation-

(1) The employer shall provide, free of charges and within the work site or as near to it as may be possible, temporary living accommodation to all building workers employed by him for such period as the building or other construction work is in progress. (2) The temporary accommodation provided under sub-section (1) shall have separate cooking place, bathing, washing and lavatory facilities. (3) As soon as may be, after the building or other construction work is over, the employer shall, at his own cost, cause removal or demolition of the temporary structures erected by him for the purpose of providing living accommodation, cooking place or other facilities to the building workers as required under sub- section (1) and restore the ground in good level and clean condition. (4) In case an employer is given any land by a Municipal Board or any other local authority for the purposes of providing temporary accommodation for the building workers under this section, he shall, as soon as may be after the

ENVIRONMENTAL RESOURCES MANAGEMENT 21

construction work is over, return the possession of such land in the same condition in which he received the same.

35. Creches-

(1) In every place wherein, more than fifty female building workers are ordinarily employed, there shall be provided and maintained a suitable room or rooms for the use of children under the age of six years of such female workers. (2) Such rooms shall- (a) provide adequate accommodation; (b) be adequate lighted and ventilated; (c) be maintained in a clean and sanitary condition; (d) be under the charge of women trained in the care of children and infants.

36. First-aid-

Every employer shall provide in all the places where building or other construction work is carried on such first-aid facilities as may be prescribed.

37. Canteens, etc.-

The appropriate Government may, by rules, require the employer-

(1) to provide and maintain in every place wherein not less than two hundred and fifty building workers are ordinarily employed, a canteen for the use of the workers; (2) to provide such other welfare measures for the benefit of building workers as may be prescribed.

ENVIRONMENTAL RESOURCES MANAGEMENT 22

The Building and Other Construction Workers (Regulation of Employment and Conditions of Service) Central Rules, 1998

CHAPTER XXVIII

WELFARE OF BUILDING WORKERS

243. Latrine and urinal accommodation-

Latrines or urinals, as the case may be required to be provided under section 33 of the Act shall be of the types as specified below, namely -

a) every latrine shall be under cover and so partitioned off as to secure privacy, and shall have a proper door and fastenings; b) i) where both male and female building workers are employed, there shall be displayed outside each block of latrines or urinals a notice containing therein “For Men Only” or “For Women Only”, as the case may be written in the language understood by the majority of such workers; ii) such notice shall also bear the figure of a man or of a woman, as the case may be; c) every latrine or urinal shall be convenient situated and accessible to building workers at all times; d) every latrine or urinal shall be adequately lighted and shall be maintained in a clean and sanitary condition all times; e) every latrine or urinal other than those connected with a flush sewage system shall comply with the requirements of the public health authorities; f) water shall be provided by means of tap or otherwise so as to be conveniently accessible in or near every latrine or urinal; g) the walls, ceilings and partitions of every latrine or urinal shall be white washed or colour washed once in every period of four months.

244. Canteens-

(1) In every place wherein not less than two hundred and fifty building workers are ordinarily employed, the employer of such building workers shall provide an adequate canteen in the manner as specified in this rule for the use of such building workers. (2) The canteen, referred to in sub-rule (1) shall consist of a dining hall with furniture sufficient to accommodate building workers using such canteen, a kitchen, store-room, pantry and washing places separately or building workers and for utensils. (3) i) The canteen referred to in sub-rule (1) shall be sufficiently lighted at all times when any person has access to it; ii) the floor of such canteen shall be made of smooth and impervious material and inside walls of such canteen shall be lime-washed or colour-washed at least once in every six months.

ENVIRONMENTAL RESOURCES MANAGEMENT 23

Provided that such inside walls of the kitchen of such canteen shall be lime-washed once in every three months. (4) i) The precincts of the canteen referred to in sub-rule (1) shall be maintained in a clean and sanitary condition; ii) waste water from such canteen shall be carried away in suitable covered drains and shall not be allowed to accumulate in the surroundings of such canteen; iii) suitable arrangement shall be made for the collection and disposal of garbage from such canteen.

(5) Building of the canteen referred to in sub-rule (1) shall be situated at the distance not less than fifteen point two metres from any latrine or urinal or any source of dust, smoke or obnoxious fumes.

245. Foodstuff to be served in the Canteen-

The foodstuffs and other items to be served in the canteen, referred to in sub-rule (1) of rule 244, shall be in conformity with the normal dietary habits of the building workers.

246. Serving of tea and snacks at the work places-

At a building or other construction work where a work place is situated at a distance of more than zero point two kilometres from the canteen provided under sub-rule (1) of rule 244, arrangement shall be made by the employer employing building workers at such place for serving tea and light refreshment to such building workers at such place.

247. Charges of foodstuff-

(1) The charges for foodstuff, beverages and other items served in the canteen provided under sub-rule (1) of rule 244 shall be based on “no profit no loss” and the price list of such items shall be conspicuously displayed in such canteen. (2) In arriving at the prices of items referred to in sub-rule (1) the following shall not be taken into consideration as expenditure, namely - (a) the rent for the land and building of such canteen; (b) the depreciation and maintenance charges for the building and equipment provided in such canteen; (c) the cost of purchase, repairs and replacement of equipments including furniture, crockery, cutlery, utensils and uniforms provided to the employees of such canteen; (d) the water charges and other charges incurred for lighting and ventilation of such canteen, and (e) the interest on the amounts spent for providing and maintaining furniture and other equipment for such canteen.

ENVIRONMENTAL RESOURCES MANAGEMENT 24

Contract Labor (Regulation and Abolition) Act, 1970

CHAPTER V

WELFARE AND HEALTH OF CONTRACT LABOR

16. Canteens.-

(1) The appropriate Government may make rules requiring that in every establishment-to which this Act applies, wherein work requiring employment of contract labor is likely to continue for such period as may be prescribed, and wherein contract labor numbering one hundred or more is ordinarily employed by a contract, one or more canteens shall be provided and maintained by the contractor for the use of such contract labor. (2) Without prejudice to the generality of the foregoing power, such rules may provide for- (a) the date by which the canteens shall be provided; (b) the number of canteens that shall be provided, and the standards in respect of construction, accommodation, furniture and other equipment of the canteens; and (c) the foodstuffs which may be served therein and the charges which may be made therefore. NOTES Provisions, held, are not unreasonable. Gammon India Lid. v. Union of India, (1974) 1 SCC 596.

17. Rest-rooms.-

(1) In every place wherein contract labor is required to halt at night in connection with the work of an establishment-to which this Act applies, and in which work requiring employment of contract labor is likely to continue for such period as may be prescribed, there shall be provided and maintained by the contractor for the use of the contract labor such number of rest-rooms or such other suitable alternative accommodation within such time as may be prescribed. (2) The rest-rooms or the alternative accommodation to be provided under sub- section (1) shall be sufficiently lighted and ventilated and shall be maintained in a clean and comfortable condition.

NOTES Provisions, held are not unreasonable. Gammon India Ltd. v. Union of India, (1974) 1 SCC 596.

18 Other facilities.-

It shall be the duty of every contractor employing contract labor in connection with the work of an establishment to which this Act applies, to provide and maintain-  a sufficient supply of wholesome drinking water for the contract labor at convenient places;  a sufficient number of latrines and urinals of the prescribed types so situated as to be convenient and accessible to the contract labor in the establishment; and washing facilities.

ENVIRONMENTAL RESOURCES MANAGEMENT 25

NOTES Provision, held, reasonable. Gammon India Ltd. v. Union of India, (1974) 1 SCC 596.

19. First-aid facilities.-

There shall be provided and maintained by the contractor so as to be readily accessible during all working hours a first aid box equipped with the prescribed contents at every place where contract labor is employed by him.

20. Liability of principal employer in certain cases.-

(1) If any amenity required to be provided under Section 16, Section 17, Section 18 or Section 19 for the benefit of the contract labor employed in an establishment is not provided by the contractor within the time prescribed therefore, such amenity shall be provided by the principal employer within such time as may be prescribed. (2) All expenses incurred by the principal employer in providing the amenity may be recovered by the principal employer from the contractor either by deduction from any amount payable to the contractor under any contract or as a debt payable by the contractor.

NOTES Ss. 20 & 21- Obligation to provide amenities conferred under the Act to the workers is on the principal employer. Government will be responsible for enforcement of those amenities where contractors engaged by it for executing its construction project fail to provide the amenities to its workers. Government's failure to perform its obligation amounts to violation of Art. 21 and workers can enforce their right by writ petition under Art. 32.

Peoples’ Union for Democratic Rights v. Union of India, (1982) 3 SCC 235 1982 SCC (L & S) 275.

21. Responsibility for payment of wages.-

(1) A contractor shall be responsible for payment of wages to each worker employed by him as contract labor and such wages shall be paid before the expiry of such period as may be prescribed. (2) Every principal employer shall nominate a representative duly authorised by him to be present at the time of disbursement of wages by the contractor and it shall be the duty of such representative to certify the amounts paid as wages in such manner as may be prescribed. (3) It shall be the duty of the contractor to ensure the disbursement of wages in the presence of the authorised representative of the principal employer. (4) In case the contractor fails to make payment of wages within the prescribed period or makes short payment, then the principal employer shall be liable to make payment of wages in full or the unpaid balance due, as the case may be, to the contract labor employed by the contractor and recover the amount so paid from the contractor either by deduction from any amount payable to the contractor any contract as a debt payable by the contractor.

NOTES

S. 21 -Payment of wages including overtime wages etc. must be made directly to the workers in full except with authorised statutory deductions, if any. Payment through

ENVIRONMENTAL RESOURCES MANAGEMENT 26

khatedars after deducting any advance repayable by the workers to the khatedars or any messing charges etc. was not proper. Due amounts could be recovered from the workers after paying full wages.

Laborers Working on Salal Hydro Project v.State of J. &. K., (1983) 2 SCC 181 1981 SCC (L & S) 289.

ENVIRONMENTAL RESOURCES MANAGEMENT 27

THE INTER-STATE MIGRANT WORKMEN (Regulation of Employment) AND Conditions of Service) ACT, 1979

I. Object

To regulate the employment of inter-state migrant workmen and to provide for their conditions of service and for matters connected therewith.

II Applicability

It extends to the whole of India and applies to (1) Every establishments in which 5 or more inter-state migrant workmen (whether or not in addition to other workmen) are employed or who were employed on any day of the preceding twelve months (2) To every contractor who employed 5 or more interstate migrant worker (whether or not in addition to other workmen) on any day of the Preceding twelve months.

III Who is an Inter-State Migrant Workman

Any person who is recruited by or through a contractor in one state under an agreement or other arrangement for employment in an establishment in another state whether with or without the knowledge of the Principle employer.

IV Registration of Establishments

Every principle employer of an establishment to which this Act applies shall make an application for registration in triplicate in Form No.1 to the registering officer, along with the Prescribed fees. On receipt of an application, registering officer shall issue a registration certificate in From-II based on the specifications stipulated in the concerned State Inter-State Migrant Workmen (regulation of employment and conditions of service) Rules

V Fee for Registration

(a) If the number of Inter-State Workmen is 5 but does not Exceed 20 Rs.50.00 (b) Between 20 - 50 Rs.100.00 (c) Between 50 - 100 Rs. 200.00 (d) Between 100 - 200 Rs. 350.00 (e) Between 200 - 400 Rs. 650.00 (f) Above 400 Rs. 800.00

VI Prohibition against Employment of Inter-State Migrant Workmen without Registration

No principle employer shall employ inter-state migrant workmen in the establishment unless a certificate of registration is obtained under this Act.

VII Licensing Of Contractors

No contractor shall

ENVIRONMENTAL RESOURCES MANAGEMENT 28

(1) Recruit any person in a state for the purpose of employing him in any establishment situated in another state except without obtaining a recruitment licence issued by the licensing officer of the area where the recruitment is done. (2) Employ any interstate workmen without obtaining an employment licence received from the licensing officer of the area where the establishment is situated.

VII Grant of Licenses

The contractor shall apply for a recruitment licence in triplicate in From-IV to the licensing officer having jurisdiction in relation to the area wherein recruitment is made.

ENVIRONMENTAL RESOURCES MANAGEMENT 29 Annex C

Stakeholder Engagement Plan

ESMP: ANNEX C -STAKEHOLDER ENGAGEMENT PLAN

1.1 BRIEF INTRODUCTION

The stakeholder engagement plan detailed here relates to Project Nirvana, a slum rehabilitation initiative of Kumar Sinew Urban Developers Limited (KUL), spread over an area of approximately 79 acres and covering six major slum zones. The project is being undertaken in phases and the client is implementing the second phase of the slum rehabilitation (first being Wadar Vasti) in the Kilewadi and Indira Park area that included about 1145 tenements.

Due to the prevalent nature and context of the project, the people of the area are likely to face few undesirable and temporary setbacks. Moreover, a project of the scale and nature such as Nirvana would have many other stakeholders too each of whom would be required to co-ordinate and align together for the successful commissioning of the project.

Note: The stakeholder engagement plan has taken into consideration the ADB Public Communications Policy which will be effective from April 2012. It is understood that the public disclosure requirements as relevant for the stakeholders identified will need to be compliant with the ADB Communications Policy.

1.2 PROBLEMS OF THE PROJECT AFFECTED PERSONS

Some of them have been detailed below:

 Issues of non-eligibility and compensation: The domicile cut off date is likely to result in about 500 slum households being declared ineligible for rehabilitation according to SRS. These categories of impacted families are likely to be most adversely impacted with eviction/separation form their established networks and accesses.

 Livelihood Disruptions: Displacement of ineligible households and closing down of ineligible commercial tenements is likely to cause short to medium term income losses to few of the slum dwellers

 Continuous Movement of Men and Material: Demolition of hutments, influx of migrants and increased movement of vehicles is likely to disturb the existing ambience of the community during the operations phase.

 Community Health and Safety: The resulting piles of debris and construction materials and subsequent degradation of the water and air quality during the operations phase are a health and safety threat to both labourers and the community people.

1.3 NEED FOR STAKEHOLDER CONSULTATIONS

 Managing community apprehensions about the project: Through consultations, the apprehensions and doubts in the minds of the community people due to the likely evictions, social disturbances and livelihood disruptions can be quelled to a great extent

 Creating Awareness about the project: Stakeholder consultations can help create awareness about the SRS scheme and the terms of agreement for rehabilitation to a large segment of the ignorant population.

 Garnering voluntary support for the project: Stakeholder consultations bring about greater transparency likely to result in greater acceptance of the rehabilitation scheme and people taking informed decision about the rehabilitation.

 Discussing in-transit arrangements: During stakeholder consultations, transit options could be discussed and finalised with individual households so that the process of transition would be carried out in a smooth and quick manner.

 Entitlement options: Consultations can bridge the expectations and limitations of the both parties resulting in a mutually agreeable entitlement options.

 Formation of housing societies: Through stakeholder consultations people can be oriented towards the new lifestyle and the importance of the societies can be embedded in the minds of the people to minimise possible conflicts and confusions that may arise during the actual process of establishment of societies.

 Ongoing consultation for the operation and maintenance of societies: Stakeholder consultations can also act as a monitoring mechanism to evaluate the progress of housing society operations and incorporate corrective action whenever necessary.

(This engagement plan has to be seen in conjunction with the stakeholder analysis in section 5 of the ESIA and the stakeholder section in the RAP).

1.4 LEGAL REQUIREMENT FOR STAKEHOLDER CONSULTATIONS

Right to Information Act, 2005

The Act applies to whole of India and includes the right to:  Inspects works, documents, records;  Take notes, extracts or certified copies of documents or records;  Take certified samples of materials; and  Obtain information in the form of printouts, diskettes, floppies, tapes, video cassettes or in any other electronic mode.

RTI act covers only government institutions and departments. However, there is an indirect implication in case a citizen wants to get information about any aspect of the project, s/he may approach the relevant govt official through a process outlined in the above regulation.

The SRA disclosure process

Stakeholder engagement and regular public consultations are also in-built into the SRA Guidelines. These responsibilities are shared by the Builder and the SRA as follows:  Disclosure requirements of (a) Letter of Intent with the Builder and Society Members; Intimation and Notice of the SRA Annexure II Survey; and Results of the SRA Annexure II Survey;

 Compulsory Consent of at least 70% of the tenement owners/occupiers to the builder’s development proposal;  Verification of the cooperative housing society by the SRA through a public meeting and subsequently a public hearing for general community grievances; and  The SRA expects the builder to keep the community informed at intervals as desired by the society on the project details, schedules etc.

The EIA public Consultation and Disclosure process

As per the EIA Notification, 2006 the public hearing is required to be conducted by the State Pollution Control Board (SPCB) or the Union territory Pollution Control Committee (UTPCC) concerned in the specified manner and the proceedings are required to be forwarded to the regulatory authority concerned (MoEF/SEIAA).

IFC Performance Standards

The 8 Performance Standards (PS) established by IFC stipulates that the project shall meet certain requirements throughout the life cycle of an investment by IFC or other relevant financial institution, who are signatory to the Equator Principles, 2006.

One of the main tenets of PS1 (Social and Environmental Assessment and Management Systems) is the engagement with the community to ensure free prior informed consultations (FPIC), community grievance redressal and constructive relationship all through the project life cycle.

ADB’s Public Communications Policy of the Asian Development Bank: Disclosure and Exchange of Information (2011)

ADB has recently completed a review of the 2005 Communications Policy in consultation with a range of stakeholders to gauge their perceptions of ADB’s performance and communications. This revised public communications policy takes into account the internal and external comments received, and the findings of the global perception surveys with respect to the public communications approach, disclosure details and implementation arrangements.

ADB’s Safeguard Policy Statement (SPS) and disclosure Policy

In July 2009, ADB's Board of Directors approved the new Safeguard Policy Statement (SPS) governing the environmental and social safeguards that applies to all ADB- financed and/or ADB-administered projects and SPS2 deals with involuntary resettlement and a project will be categorised in terms of the involuntary resettlement impacts.

 ADB’s safeguard policy imply the need for prior and informed consultation with affected persons and communities in the context of safeguard planning and for continued consultation during project implementation to identify and help address safeguard issues that may arise.

1.5 SUMMARY OF STAKEHOLDER ANALYSIS

An earlier section of this report has discussed the stakeholder identification and analysis. The major stakeholders for the project have been classified as internal and external stakeholders. The stakeholder analysis table had also detailed out the

expectations of each of the stakeholders along with overall influence of each of the stakeholder on the project and the level of priority that KUL has to give for each of the stakeholder that has been discussed. The table below summarises the stakeholder analysis.

Stakeholder Category Overall Influence on Priority for KUL the Project CATEGORIZATION OF INTERNAL STAKEHOLDERS Project Management Kumar Sinew developers and holding High High company Kumar Urban Developers Private Limited KUL Employees Medium Medium Contractors And Sub-Contractors Man-Infra Construction Limited Low Medium Karan Builders Low Medium Fusion India Management Private Limited Low Medium CATEGORIZATION OF EXTERNAL STAKEHOLDERS Project Financiers Banks and Local Financing Agencies High High Lenders, Investors, Financiers and High High Development Agencies Existing Slum Dwellers/Residents And Local Community Residents including Owners, Tenants and High High Squatters. Hawkers and other commercial entities High High Slum Lords (large, medium, marginal and Low to Medium Medium small) with multiple slum holdings Local concerned slum representatives Low to Medium Medium Anti-social elements and people with Medium Medium extortionist approach Women Low to medium Medium Vulnerable groups Low Low Nearby community Low Low Regulatory Authorities And Local Administration SRA Pune High Medium Ministry of Environment and Forest and Medium Medium State level Environmental Impact Assessment Authority (SEIAA) and State level Expert Appraisal Committee (SEAC) Maharashtra Pollution Control Board High High (MPCB) Pune Municipal Corporation (PMC) Medium Low Public Works Department (PWD), Low Low Government of Maharashtra Political And Local Groups Local Corporator and Other Political Groups High Medium

1.6 APPROACH TO STAKEHOLDER ENGAGEMENT

KUL project will be implemented with due regard to the guiding principles for public consultation and disclosure enunciated below:

 Early consultation: Early consultations for the KUL project facilitate identification of stakeholders and mapping out their influence and interest.  Identify and engage project stakeholders: This all-inclusive exercise will consult both internal and external stakeholders and the vulnerable and weaker sections of the society.  Grievance Redressal Mechanism; The scope of the Stakeholder Grievance Redressal Mechanism relates specifically to the following issues:

Definition of a complaint/grievance: If any internal or external stakeholder believes that the company’s business practices or activities are having an adverse impact on their quality of life, livelihood or environment, which they want the project team to address, such a grievance or concern can be classified as a complaint.

Reporting Procedures: The procedure for complaint registration has been suggested below: o Contacting the local Community Relations Team (CLT), for which contact number/address of CRT should be made available to all community members for any emergency o Obtaining a copy of the Complaint Reporting Form, which can be procured without any effort; o Creating systematic mechanisms within the organization to accept complaints and feedback and forward them to the relevant individual; o Reporting concerns via any media convenient to the complainant, i.e. telephone, post, internet, or in person/community meeting.

Procedure to address feedback: Any complaint has to be registered electronically and mechanisms to acknowledge receipt of the complaint or feedback and its nature must be laid down, which will consider the medium of response, confidentiality of the complainant and the timeliness of the response. Community Relations Officers will aim to acknowledge complaints within 7 days. KUL has to aim to investigate and resolve a complaint within a timelimit of 30 days. If a particular complaint has serious implications on KUL’s business practices or project activities, the lessons will be incorporated into internal systems to avoid the recurrence of the issue. One of the management representatives of KUL, who would be in charge of stakeholder engagement will be constantly kept in loop with respect to complaint registration and redressals.

Timelines: Generally complaints should be resolved within 30 days. These timelines may be dynamic or flexible as per the nature of the complaint (except for those governing acknowledgement) and must be communicated to the complainant in the acknowledgement process.

 Deliver on commitments: Commitments will only be made after internal consultation, alignment with the national and state laws as well as company’s policy and code of conduct, and are in line with the Project commitments. Delivering on commitment will result in developing a credible relation with the community and consequently built up the social licence required for the smooth implementation of the project

Documentation and Regular Feedback A consultation record/database, which addresses both technical and general queries and concerns, will be designed. This will also include the project uncertainties and the

inputs needed from the stakeholders to be used in decision making processes. Feedback will be provided to the stakeholders in the required format as early as possible. Prompt responses will help manage stakeholder’s concerns and build mutual trust. Managing the consultation database will help map stakeholder relationships and be informed on prevailing sentiment, for example from communities, and contractors, and will provide a more holistic picture of the effectiveness of the stakeholder engagement strategy, allowing for modifications where improvements are required.

1.7 STAKEHOLDER ENGAGEMENT PLAN

It is essential that KUL understands and follows a prescribed plan for stakeholder engagement.

The table below mentions the phases of the project that calls for stakeholder engagement, the objective of engaging at that particular phase, the form of addressing the community, the frequency of engagement with the community for each phase and the expected desirable outcome of each engagement

Table 1.1 Stakeholder Engagement Plan

Phase of Project Objective of Consultation Medium for Engagement Frequency for Engagement and Desired outcome Documents for Disclosure Stakeholder (Internal): Community

Pre- construction phase

Socio-economic  Awareness generation about SRS scheme  Approach each  Once during the course of  Increased awareness about SRS scheme Survey  Introduce the project proponent to the hutment and engage the survey  Changed perceptions (for the better) towards the community and initiate rapport building with families proposed rehabilitation scheme and the project  Early identification of potential issues, conflicts proponent and benefits On-going  To elicit the apprehensions of the community  One Consultation to  Two consultations in a  Increasing community cohesiveness by consultations towards the project. be held with key span of a month; facilitating the sharing the fears and expectations prior to  Understand the community expectations in people in the slum at  Results and updates of of the community in an open platform. finalisation of terms of compensation and facilities desired. a mutually agreeable Annexure II survey to be  Making community realise that the rehabilitation Annexure II  Increasing the confidence of people on the location in the slum displayed is an open and community friendly initiative and benefits of the project. area that everyone would be treated fairly.  To allay the fears of the households that are  Another consultation  Sensitise the likely ineligible households to the likely to be declared ineligible. for which open possibility of eviction. invitation has been  Develop various compensation plans for send out to all slum finalisation. dwellers  Informed decision making by the community. Consultations  Finalise compensations for the ineligible  Consultations both at  Continuous engagement  Minimise possibilities of community unrest by after the households. the household level with the ineligible positively channelizing the energy of ineligible finalisation of  Understand and arrange for the necessary and group level for households until smooth households towards favorable transition. Annexure II support required by the ineligible households ineligible households. transition  Reduce project delay by expediting the process for smooth transition.  Consultations at  Two to Three community of signing of agreements for rehabilitation.  Communicate the terms and references of group level with level meetings with eligible  Optimise in-transit costs by finalising the in- rehabilitation to the eligible households. eligible households households transit arrangements and establishing the time  Communicate the in-transit options available frame for eviction. for the eligible households. The eligible households are given two options of either moving into the in-transit tower or arrange for own in-transit facility, the expense of which will be compensated by KUL.

In-transit phase

Phase of Project Objective of Consultation Medium for Engagement Frequency for Engagement and Desired outcome Documents for Disclosure Shifting to the  Make the community comfortable with the  Consultations at  Schedule of transit  Increased acceptance of the new lifestyle before transit towers new arrangement. group level at accommodation actual rehabilitation.  Understand the problems faced and develop common locations in completion, demolition and corrective measures in collaboration with the the in-transit towers. shifting to be community.  Visits to individual communicated in advance  Orient the community towards life in an houses and displayed; apartment  Group meetings to be held twice every month until allotment and shift to the rehabilitation buildings.

 Household visits can be randomly conducted occasionally Prior to actual  To make the community aware of the  Group consultations  Three to four consultations  Creation of voluntary demand for effective rehabilitation formation of housing societies. at a common location to be held exclusively housing societies.  To make them aware of the functions and roles at the transit site. focusing on formation and  Increase in community participation pertaining of housing society and its members. Invitations to be send roles of housing societies. to housing society functions and activities.  To make the community aware of the election to all concerned  One separate group  Minimise conflicts and confusions during the process for the housing societies. households including consultation focusing on actual election process for the housing societies. those who have opted the election process for the for own transit housing societies. arrangements outside the project area. Rehabilitation phase

Election to the  To facilitate smooth elections for the formation  Group meeting at a  Display of appropriate  Formation of a strong and effective housing housing society of housing society common area in the notices on election society. rehabilitation tower procedure;  Smooth transition of community people into the  Once after the rehabilitated way of life. rehabilitation of the community. Ongoing  Integrate support services like solid waste  Meetings with the  Continuous interaction  Empowerment of community by increasing their consultations for management and maintenance services with housing society with housing society self-reliance to manage the day-to-day functions routine operations the housing societies. members during the first of the society. and maintenance  Empower housing communities to manage  Group meetings with two months of society day-to-day needs of the apartment and resolve community establishment.  Maintenance of aesthetic value of the apartments routine problems  Weekly meetings with

Phase of Project Objective of Consultation Medium for Engagement Frequency for Engagement and Desired outcome Documents for Disclosure society members for the  Increase in quality of life of the residents by next two months, followed ensuring a clean and comfortable apartment life. by monthly meetings for the next two months

 Group meetings with community members once a month for the first three- four months Stakeholder (Internal): Contractors

Operations Phase  To communicate the ADB and IFC standards  Group meeting with  Group meeting with  Timely completion of project and within the for slum rehabilitation projects. laborers. laborers and contractors budget.  To ensure compliance with national and state should be conducted  Meet all compliance requirements of ADB/IFC labor and contractor rules.  Individual and group separately once every and SRA.  Ensure compliance as per international meetings with month  Minimise social conflicts of laborers with standards pertaining to the provision of contractors community amenities to laborers and addressing their  Individual meeting with health and safety concerns. contractors could be held  Communicating the reporting and grievance once every three months redressal mechanisms to the contractors and laborers.  Minutes of meetings and  To monitor the progress of construction and stakeholder consultations address any bottlenecks for construction. to be maintained.  To monitor the expenses incurred by the contractors. Stakeholder (External): Slum Rehabilitation Authority

All phases of the  Updation of slum rehabilitation progress  Face to Face meetings  Face to Face meetings once  Building credibility of KUL with SRA project  To understand and comply with the phase  Site visits by SRA every 3 months.  Smooth transfer of the ownership of the slum specific requirements and standards of SRA representative  Site visits by SRA rehabilitation buildings from the developer to representative every six SRA months  Enthusiastic participation of SRA in formation of  Progress Reports to be housing societies maintained Stakeholder (External): Lenders

All phases of the  Regular updation of the timely progress of the  Face to Face meetings  Meeting can be conducted  Build credibility of KUL with the lenders. project project. with the lenders every

Phase of Project Objective of Consultation Medium for Engagement Frequency for Engagement and Desired outcome Documents for Disclosure  Regular updation of lenders on E&S impacts  Site visits by the three months.  Uninterrupted funding during the course of the and their addressal. lenders project.  To close any existing gaps in compliance to its  Site visits could be existing environmental and social safeguard undertaken by the lenders  Minimise project risk in the short and long term policies. every six months. especially from social and environmental perspective

1.8 MONITORING OF STAKEHOLDER CONSULTATION PLAN

For effective engagement with stakeholders it is essential that the stakeholder plan is strictly adhered to and a constructive feedback mechanism is established. This requires continuous monitoring of the engagement process by KUL representatives and the management. The Community Relations Team (CRT) would be primarily responsible for the implementation and monitoring of stakeholder engagement plan.

CRT Responsibilities Responsibilities of CRT will include as a minimum:  Maintaining a current list of all stakeholders as well as onsite contractors;  Communicating each and every instance of meeting and/or consultation with the community to the KUL management responsible for Community relationship;  Being seen as an open-door authority for the complainant to be contacted at any time.  Assuring the community that accurate and timely action on any grievance will be taken.  Providing onsite advice to the community and contractors on minor issues;  Supervising, investigation and Facilitating resolution of complaints and grievances of both the community and contractors;  Deciding upon severity and timelines to resolve complaints;  Monitoring the progress of the complaint through a Feedback Register;  Keeping the complainant informed about the progress of the complaint;  Following-up to avoid recurrence of the concern or issues; and  Facilitation and co-ordination, where appropriate, of communications between KUL, regulatory organisations, local people and other stakeholders on any social issue

The CRT team will be led by designated personnel from the KUL team who will have the responsibility of reviewing the stakeholder management plan internally every month. This is necessary considering the dynamic nature of stakeholder engagement process. Third party monitoring gives robustness to any monitoring system and in the case of Project Nirvana, ERM would be the external monitor who would examine the engagement plan and progress every six months. The KUL management will also have to ensure that the progress of stakeholder engagement is monitored every six months.

The documents pertaining to the external monitoring of the stakeholder engagement plan will be disclosed to the community and to the general public in accordance to ADB’s Communications Policy (2011). This is in cognizance of the fact that Environmental and social monitoring reports require disclosure to the affected community in a form and language they can understand and public disclosure of the report in full (English) on ADB website.

Annex D

Grievance Redressal Plan

ESMP: ANNEX D-GRIEVANCE REDRESSAL PLAN

1.1 INTRODUCTION

The grievance redressal for this project is primarily aimed to address the issues mostly pertaining to addressing conflicts and appeal procedures regarding eligibility and entitlements, implementation of the resettlement activities and degradation of environmental quality. However, this also covers the grievance redressal mechanism for the employees and workers engaged at the site, by the different subcontractors already engaged for the project, or the ones which are likely to be engaged for the future construction activity. As the project is being commissioned in an urban area, there may be likely issues for the local nearby community, especially during the mobilisation and the construction phase. It is therefore suggested that KUL has a streamlined grievance redressal mechanism in place to address the range of grievances which may arise from various quarters identified earlier.

1.1.1 Scope of the Grievance Redressal Plan

The scope of the grievance redressal plan is to assess the existing grievance procedures that have been constituted by KUL and further strengthen it by incorporating measures namely for the implementation of the rehabilitation plan, addressing the workers grievances effectively and in case there are issues with the nearby local community.

1.2 STRUCTURE OF THE GRIEVANCE REDRESSAL PLAN

The structure of the Grievance redressal plan is as follows: 1. Grievance Definition and Categorisation 2. Institutional Mechanism For Grievance Redressal a. Existing Grievance Mechanism at KUL b. Suggested Grievance Mechanism 3. Grievance Reporting Procedure a. Current Grievance Reporting Procedures b. Suggested Grievance Reporting Procedures c. Suggested Grievance reporting for specific identified groups 4. Grievance Redressal Procedure a. Suggested Grievance Redressal Procedure b. Suggested Grievance Redressal Procedure for specific identified groups 5. Disclosure 6. Monitoring and Evaluation 7. Budgeting

1.3 GRIEVANCE DEFINITION AND CATEGORIES

The grievance for this project can be broadly classified keeping in context the following stakeholder categories

Hutment dwellers covered under the rehabilitation scheme

The hutment dwellers are the main stakeholders for the project and the grievances from them is likely to be around the following concern areas:  Eligibility issues for SRS;  Lack of transparency in identifying the eligible beneficiaries;  Eligibility criterion for the various segments including the tenants and multiple house owners in the slum;  Entitlements for maximum number of families under SRS;  Negotiation on compensation for structures lost under the scheme;  Transition amount and facility;  Handing over of the flats in the stipulated time;  Community structures compensation;  Material used in the housing scheme;  Allotment of houses to the various groups.

Local Community Grievance

The surrounding community of the project are considered as important stakeholder by the organisation. The possible complains of the community could be  Risks to community, health & safety (e.g. traffic);  Failure to comply with legislation, standards and guidelines;  Unethical Behaviour by KUL personnel or its sub-contractors;  Noise/dust/air emissions or any other impact on environment caused by project or sub-contractors;

For the purpose of reducing the complications hutment dwellers and the local community can have joint grievance redressal system.

Contractors and Labour Related Grievance

The workers including the local and interstate migrant workers are likely to have the grievance related to the following issues:  Risk to health and safety of the labourers or workers hired by the Contractors;  Working condition of the labourers;  Wage discrimination among the labourers;  Timing of the payments;  Adequate facilities in the labour camps including water supply and sanitation;  PF, ESIC, Workmen’s compensation, adequate health facility related issues;  Unjustified deduction from the wages;  Minimum wage rates for the labourers;  Extended working hours;  Prevention and protection of child labour from hazardous work condition;  Issue of forced labour;  Gender discrimination.

Employees Grievance

This section provides likely grievance of the permanent employees of the organisation. Complains of the employee could include (but not be limited to):

 Complains pertaining to amount of wage, salary, other remuneration and benefits as per Company’s Human Resource policy;

 Timely disbursement of remuneration;  Risk to working condition, health and safety of the employees;  Unethical behaviour between senior and subordinate employees;  Discrimination on the basis of caste, creed, language, religion etc;  Gender discrimination; and  Issues related to workers organisation.

Suggested measures to reduce the grievances

The following measures will be taken by KUL in order to reduce grievance as possible:  Ensure compliance to local laws and regulations;  Ensure transparency in all the processes;  Ensure training and capacity building of all concerned on their rights and entitlements;  Ensure proper disclosure of important information to the concerned stakeholders;  Ensure participatory decision making to the extent possible with the stakeholders;  Ensure that the processes already in place work effectively.

These measures will facilitate KUL in substantially reducing the instances of grievance. However, in case there are grievances with respect to any of the stakeholders identified earlier, the grievance redressal system as suggested should be implemented as early as possible.

1.4 INSTITUTIONAL MECHANISM FOR GRIEVANCE REDRESSAL

Existing Grievance Mechanism at KUL

KUL’s community relations team operates as a repository for grievances and complaints and provides counsel on different project related apprehensions and queries. This team functions as an independent entity under the KUL-ESM Cell and seeks to address issues raised by the slum dwellers, the flat residents, the employee, contractors and labour/worker community, who are advised to approach the cell for any complaint/ grievance/ suggestion.

The present structure comprises of:

 A satellite Grievance Redressal Unit, comprising of Community Relations representatives, local resource person and external resource (where required) drawn from any NGO or Social Organization at Wadarvasti and Kilewadi.  Signboards/visuals defining the Grievance Redressal procedure and advising the community, employees, contractors and labour to register grievances if any; and

Note: It was observed that the CR representatives are members of the KUL CR team. Local resource persons are social welfare workers who have been appointed by the PMC Municipal Corporator for the area. At the time of our visit, there were about 4 of them and they were helping get development agreements from slum dwellers and reporting of any concerns.

Common grievances that are being registered through this process are related to maintenance of the transit accommodation; procedure of identification and registration of households; apprehensions on eligibility; family disputes pertaining to ownership/power of attorney/marital disputes etc.

Suggested Grievance Mechanism

A Grievance Officer will be appointed on behalf of the CR Head and KUL who will inturn appoint Community Grievance Officers for each of the 6-7 SRS Working Groups. For community grievances, there will also be a committee with representation from the community and the representative will be elected by the community than by single individual.

The two key institutional mechanisms that are proposed are (a) an SRS Working Group for each of the slum blocks in the scheme; (b) Officers responsible for specific functions, i.e. Grievance Redressal, Implementation and Liaisoning; (c) Community Audit Group with nominated representatives from each slum block. The organizational structure is also linked to that of the Environmental and Social Management Plan (ESMP) through a coordination channel between the Head of Community Relations and the Environmental and Social Manager for the ESMP as provided subsequently.

Recommended Organizational Structure

Project Head/Engineering and Construction Head

Environmental Head – Community SRA and Social Manager for Relations ESMP

Grievance Redressal Implementation Officer/ Liaisoning Officer PMC Consultation Officer CR Coordinator for ESMP

SRS Working Group for each slum block (6-7 in total)

SRS WG will consist of 3 CR General Slum Dwellers/ Officers representing the Community Audit Affected Community above functions and 1 Group PMC Welfare Officer

Implementation Partners: NGOs/CBOs

Source: Proposed RAP

SRS Working Groups

The organizational structure suggests that an SRS Working Group would need to be formed for each slum block. Each working group would comprise of 3 community relation/ liaison officers (CLOs) and one representative of the local corporator, i.e. the Welfare Officer. This working group would directly interface with the slum dwellers as well as any implementation partners. The activities of the working group would be monitored by a Community Audit Group, representing members of each slum block. Each of the 6-7 Working Groups that are formed would report to the Implementation Officer, who would be the same as the Community Relations Coordinator for the ESMP.

1.5 GRIEVANCE REPORTING PROCEDURE

Current Grievance Reporting Procedures

A satellite Grievance Redressal Unit, comprising of Community Relations representatives, local resource person and external resource ( including NGOs as applicable) units are responsible for collection of grievances, recording and registering them with appointed Focal Authority, Tracking, follow up on action and intimation of result/ solution and final closure of the issue.

Suggested Grievance Reporting Procedures

The channels for receipt of grievances can include:

 Complaints received through Project staff or employees;  Complaints received by Community Relations staff directly involved in handling grievances;  Complaints received from the workers/ labourers;  Complaints received through third parties such as the corporator/NGO.

All complaints/ Grievances will be documented from their original format into a prescribed format and will need a sign-off from the grievant or representative (if it is institutional).

The Grievance/complaint will be registered with the Grievance Redressal Consultation Officer (GRCO) responsible for administering grievance mechanism, which will then assign responsibility for completing the actions, and establish the schedule for completion in consultation with:

 The Grievant;  Personnel involved in grievance management;  Community Liaison officers (CLOs)  Operations/Project managers;  Senior management;  Third-party/ contractors.

Any one who considers himself/herself or themselves as complainant have the right to complain. Such a complainant must have a defined medium to register his/her/their concern.

Suggested Grievance reporting for specific identified groups

The section below lists the GR procedure for some of the stakeholders.

Hutment dwellers and the local outside Community:

The hutment dwellers and surrounding community of the project can choose one of the following ways/media to register their complaints/feedback;

 Contacting the local Community Liaison Officer (CLO) appointed by the project;  All complaints regarding entitlements, benefits, etc. for the hutment dwellers should be reported through this system;  Special care should be taken to address the needs of the vulnerable groups like elderly, disabled, widowed;

 CLOs should be trained in being gender sensitive especially keeping in mind the nature of the population, wherein women are significant contributors to the livelihood of the family and have special concerns;  Contact the number/address made available to the community members for any emergency – accidents, serious injury or loss of life need to be reported immediately;  Register complain through Complaint Reporting Form;  Creating hierarchies within the organization to accept complaints and feedback and forward them to the relevant department/individual;  Reporting concerns via any media convenient to the complainant, i.e. telephone, post, internet, or in person/community meeting.

Contractors

The grievance related to contractors operation can be lodged in following way;

 Contact Liaison Officer of the contactor ;  The officers of KUL monitoring the contractor’s operation may also be contacted.

Employees

The selection of the procedure may depend upon the nature of the grievance and accessibility of the employee. Some of the ways in which employees of the organisation can register his/her complain would include:

 Verbally report to immediate supervisor/reporting authority;  Report to Head of Department/Unit of the organisation;  Contacting HR division of the company and register his/her complain;  GRCO officer may be approached in case it is coordinated with the HR division;  Approach to Workers Union (if existent and applicable) of the company;  Register complain in court of the concerned territory.

Once a reporting framework has been established, it must be clearly communicated to all stakeholders involved in the project.

1.6 GRIEVANCE REDRESSAL PROCEDURE

Suggested Grievance Redressal Procedure

The Grievance Process should operate as follows:

 The CLOs will have the responsibility to take account of, and resolve, any grievances raised by communities;  Where the CLO and SRS Working Group cannot resolve grievances directly, the grievance mechanism will refer these grievances to the Grievance Officer and if required the CR Head;  Where grievances remain unresolved, slum dwellers should have the option to seek legal redress.

The grievance mechanism will also need to be adequately linked to the Dispute and Eligibility Resolution Process of the SRA, wherein a tribunal is formulated to decide on eligibility status of families. This can be ensured through the Liaisoning Officer.

Tracking Action

The Grievance Officer responsible for administering grievance mechanism in co- ordination with SRS Working Group will:

 Keep track of Details of the complaint (when, where, how it occurred; who was involved; complainant’s story and expectation; date and place the grievance was received and recorded);  Evidence, supporting documents and statements will be collected;  Complaints will be screened, reviewed and validated;  Follow-up with concerned parties;  Initiate corrective actions where required;  Progress recorded (pending, solved, agreements/commitments).

Each grievance will need to be lodged into a Management Information System which will be used to track the receipt, action, closure and any follow-up of grievances. This will be managed by the Grievance Officer and will need to be available for audit of the Community Audit Group.

Closure

The suggested actions are to include:

 Conveying outcome and response to the grievant(s);  Recording how, when, and by whom a decision was communicated;  Recording closure date, and confirmation that the complainant was satisfied;  Acceptance/Sign-off by grievants;  Documenting Management actions to avoid recurrence;  Linkage to the Grievance Mechanism under the ESMP.

Suggested Roles and Responsibilities for Persons handling grievances at various levels

The specific responsibilities of the concerned officials appointed for management of grievances i.e would include (but not be limited to):  Facilitate resolution of complaints;  Keeping the complainant informed about the progress of the complaint;  Assuring the complainant that accurate and timely action on any grievance will be taken;  Managing the Feedback Management Process and monitoring the progress of the complaint through a Feedback Register  Supervising investigation and resolution of reported complaints;  Deciding upon severity (in consultation with the Project Management Team) and timelines to resolve complaints;  Co-ordinating between KUL and Contractors to ensure timely redressal of the issue;  Signing off the complaint;  Following-up to avoid recurrence of the concern or issues;  Being seen as an open-door authority for the complainant to be contacted at any time.

Suggested grievance redressal mechanism specific to the nature of the complainants would be as follows:

Suggested Grievance Redressal Procedure for specific identified groups

Hutment Dweller and Local Community Grievance

Handling grievances of the community can be considered as part of community engagement programme of the company. Some issues can be immediately acted upon by the Community Liaison Officer (CLO) and resolved and for any other complaints, the following can be the framework to address complaints.

 Receipt of a feedback or complaint: Once a complaint has been received, the community liaison officer will try to get in touch with the concerned department. The complaint will in parallel be recorded in the complaint register (in physical and electronic form), which should be maintained to monitor the resolution of the complaint.

 Acknowledgement: Mechanisms to acknowledge receipt of the complaint or feedback and its nature must be laid down, which will consider the medium of response, confidentiality of the complainant and the timeliness of the response. CLO will aim to acknowledge complaints within 7 days.

 Investigation: The issues raised must be assessed, prioritised and then forwarded to the relevant department, through the person assigned. This person will then be responsible for co-ordinating attempts to investigate the context and the details of the complaint, which may include consulting the complainant, the individuals in questions etc.

 Resolution: Once an issue has been investigated by the person assigned to it, with the concerned department, the proposed course of action must be decided. This will have to be communicated to all parties involved. If the complainant is satisfied with the measures taken, the complaint may be signed off, and if there are concerns pending, there must be procedures to reassess it, and also look at inadequacies for why it was not resolved in the first attempt. The Project will aim to resolve each complaint within 30 days.

 Monitoring/Follow-up: If a particular complaint has serious implications on Projects business practices or Project activities, the lessons will be incorporated into internal systems to avoid the recurrence of the issue. This will have to be monitored by the concerned department. Alternatively, a parallel mechanism, involving the CLO can be constituted, where the complainant would be contacted at a later stage to ensure that the concern has not recurred.

In case the CLO is not able to handle the grievance, the matter can be directly taken to the GRCO.

Contractors Grievance

The projects managed by KUL will ensure that their contractors maintain the same spirit of grievance handling for their employees/workers. For this, KUL managed projects will have the right to check and monitor the grievance redress system of their contractors.

Employees Grievance

The procedure to deal with grievance of the employee of the companies managed by KUL is as delineated below:

 Most of the work related complaints or disputes can be settled in conversation between the employee and his superior. Hence they are encouraged to resolve any problem by seeing their superior.  The aggrieved employee may, consult with the head of Department/Unit or the HR Department instead of meeting his superior.  If the employee is not satisfied with the response of his superior to his complaint, following steps may be taken:

o The employee has to submit grievance description form, duly filled in, to his superior. The employee has to identify the resolution that is being sought. The superior is to send a copy of the form to HR Department.

o The superior has to give a written reply within 7 days of the receipt of Grievance Description Form and mark a copy of the same to HR department. The superior must discuss the HR department wherever policy matter is involved before replying to the employee. If additional time is required to give the response, superior will inform in writing to the employee of the date the written reply will be made available. If the superior doesn’t respond as mentioned above, employee can present the grievance to next level or to the HR department within 10 days from the date on which response from superior was due. If the employees fails to present the grievance within 10 days, the grievance will be considered as terminated;

o If the employee not satisfied with written response of the superior, the employee may request in writing, review of the matter before the Head of Department (HOD). The HOD will provide a written response to the employee within 10 days from the date of receive of such request. HOD will consult the HR Department before giving the response. If HOD requires additional time to give response, HOD will inform employee in writing of the date the written reply will be provided. If HOD doesn’t respond on time, employee can present the grievance to next level or to the Head of HR department within 10 days from the date on which response from HOD was due. If the employees fails to present the grievance within 10 days, the grievance will be considered as terminated;

o If the employee doesn’t feel satisfied with the response of HOD, employee may send request to HR department to review the grievance. HR Head will establish a grievance committee with members of relevant functionaries to consider the grievance. The committee will hear the employee and Management Representatives, review the documentation and will speak to any other individual it deem necessary to process the grievance. The committee shall submit its recommendation to HR Head within 15 days after formation of the committee. HR Head will render the final decision to the aggrieved employee;

 Employees can also approach to Worker’s Union of the project (if existent and applicable) for redress of their grievances.

1.7 DISCLOSURE

Some of the important points regarding disclosure of the plan are:  The grievance redressal process should be disclosed and the procedures mentioned therein should be properly disseminated to the identified stakeholders, where most of the grievances are likely to come from.  KUL should integrate it as a part of the training programme especially for the workers. For the rest of the stakeholders, it can be displayed at important places on the site, at office and on the website.

 The disclosure and the display should clearly mention the name and designation of the grievance redressal officials, office location and their respective contact numbers.

1.8 MONITORING AND EVALUATION

Monitoring and evaluation of the grievance redressal system in place is important to the success of any project. Like the other project components it needs to be monitored to ensure the stakeholders are having no or limited issues with the project and in case there are concerns, they are being adequately addressed as per the mandate. The mechanism will be based on two components of internal monitoring and reporting and external monitoring and reporting which will run simultaneously. Mostly they are aligned with simultaneous process monitoring rather than doing it separately all the time.

Internal Monitoring Process

This monitoring process will be undertaken by the SRS Working Groups and the Community Audit Group used to analyse progress and change at regular intervals of implementation. Monitoring should be done in close collaboration and consultation with local communities. The internal monitoring will be regularly tracked by the ESMP team.

External Monitoring Process

As and when there is a third party evaluation of the processes related to RAP implementation or annual monitoring or third party review or audits, it should ensure that assessment of the grievance redressal mechanism is done as a part of the monitoring and evaluation process. It is recommended that the external monitoring process should initially be conducted every quarter and as the process progresses, the frequency should be reduced to bi-annually and annually as required.

Monitoring Indicators

Some of the process, activity and outcome indicators that can be monitored include:

Indicative Monitoring Indicators

Aspect Monitoring Indicators

Grievance  What was the process of putting the grievance redressal system in Mechanism Process place? Indicators  Is it transparent enough?  Has the grievance redressal system been disclosed with the community, workers, employees, hutment dwellers, and other stakeholders?  How easy is it to lodge grievances?  Effectiveness of the process for lodging, tracking and following up on the grievances?  How easy is it especially for the vulnerable including disabled, widowed population to access the grievance redressal system?  Is it conducive from the gender perspective? How easy is it for the women to lodge grievances?  Are the literates only able to make complaints? What happens to the illiterate population?

Aspect Monitoring Indicators  What are the different ways in obtaining grievances?  Are people being stopped from making grievances? Is it discouraged?  Are vulnerable groups able to access the grievance mechanisms? Grievance  What is the awareness level of the people towards the existing Mechanism grievance redressal system? Outcome Indicators  What types of grievances have been identified & what were outcomes?  Is there proper documentation of all the grievances and are they being tracked?  How many of the grievances have been settled?  How many of the grievances are yet to be settled?  What is the average time taken for the grievance redressal?  Does the grievance redressal procedure stop people from accessing the redressal procedure as suggested under the local laws?  Percentage of grievances resolved by KUL channels versus government channels versus project-specific?  What is the satisfaction level of the people from the existing grievance redressal system?

1.9 BUDGETING

The KUL administration should ensure that there is adequate budgeting and resource allocation for implementing the grievance redressal plan. As KUL has already instituted the grievance cell, its enhancement and capacity building as required by the plan is covered in the Environmental and Social Management Plan.

1.10 TIMEFRAME

The Grievance Redressal Plan will need to be implemented throughout the lifecycle of the project. The collection, redressal and closure of grievances will need to take place in a real time and dynamic manner and will need to be tracked by the Community Relations. It is suggested that monitoring of the grievances should be undertaken on a monthly basis.

Annex E

Gender Action Plan

ESMP: ANNEX E –GENDER ACTION PLAN

1.1 INTRODUCTION

The Gender Action Plan (GAP) for the Nirvana Hills Phase II Project in Survey No. 44/1, Erandwane, Pune has been developed in adherence to the Asian Development Bank’s Gender and Development Policy (1998). The objective of the Gender Action Plan (GAP) is to ensure the mainstreaming of gender issues and concerns into all aspects of the ongoing slum rehabilitation project throughout its lifecycle through detailed planning, implementation, monitoring and evaluation activities.

The Nirvana Hills Phase II Project that is being implemented by Kumar Sinew Developers Limited can be classified as a Category III Project, i.e. “Some Gender Benefits” (1) wherein there have been specific efforts in project planning to identify possible impacts on women and to include mitigation features in the project design. The Project has potential to (i) improve access to economic resources (equal employment opportunities during construction phase, skills development and assistance to form self- help groups and undertake self-employment activities); (ii) improve urban infrastructure (improved living conditions and welfare facilities); and (iii) enhance women’s voices and rights (facilitating tenure rights for women, female representations in housing societies).

The Gender Action Plan that is discussed subsequently comprises of the following:  Socio-economic profile of the women in the project area;  Potential Gender-based impacts (adverse and beneficial) from the proposed slum rehabilitation scheme; and  Recommended actions to incorporate a gender-sensitive approach to Project Nirvana.

1.2 SUMMARY OF SOCIO-ECONOMIC PROFILE

The socio-economic baseline assessment that was conducted for the development of the ESIA and the Rehabilitation Plan has brought forth the following observations on gender-based issues in the project area.

Prevailing Gender Dynamics

The project area has a notably lower sex ratio of 888 females per 1000 males as compared to that of the district of Pune (917/1000). This indicator is observed across the slum blocks that are to be resettled. In terms of education, the socio-economic survey has captured gender-disaggregated estimates of higher education level as provided in Table 1.1.

(1) http://www.adb.org/documents/papers/gender_action_plan/IN291-02.pdf

Table 0.1 Education Profile of Women aged 15-65 years

Education Total % share of Proportion of Women (%) Level Number total Phase II Phase III Phase Phase V IV SSC 1173 55.2% 57.6 63.0 55.4 41.3 HSC 500 23.5% 24.0 20.9 24.0 25.7 Graduation 310 14.5% 15.5 12.9 16.7 12.6 Post 5.4% 115 Graduation 1.9 1.6 2.5 19.4 Vocational 26 1.2% 1.0 1.6 1.3 1.0 2124 100% 100 100 100 100

No estimates are available on the number of women that have had limited access to formal education and/or are illiterate. From the above table, it is evident that the majority of the women in Phases II-V have attained only secondary education. Approximately 20% of the total female population in the area has at least a graduate degree, while only 1% has vocational education. Phase V has a much better educational profile of women with almost a third of its women having attained at least graduate education, while Phase III is at the bottom with 63% of its women having only secondary education.

Figure 0.1 Age and Gender Profile

Age and Gender Profile

1000 800 600 400 Units 200 0

Sex Ratio ) k) Age % of women from 15 to 65 Phase IV Phase II Phase III (HanumanNagar) Phase V (Rautwadi)

(Kelewadi/IndraPar Slum Blocks (R.G.P/VasantNagar

Livelihood Status

It can be observed that women represent the economic mainstay of the household within the slum community due to the prevalence of vices (such as substance abuse, alcohol addiction etc.) among the male members. As a result, one observes good participation in day-to-day economic activities. Women are generally engaged in unorganized activities such as employment as maids/household help and a small (but steadily increasing) minority of women can be seen in the forefront of shop keeping, self-help groups and vocational courses (tailoring, beauty etc.). Discussions with the Corporator indicate that although the prevailing gender dynamics are skewed in favour of men, women are more vociferous and vocal with their demands for benefits under in-situ rehabilitation during frequent community-based meetings.

Box 0.1 Case Study - Mahila Milans

Mahila Milan is is a CBO made up of collectives of women pavement and slum- dwellers whose central activity is the operation of savings and credit activities. Set up in 1986, as a result of SPARC's work with the Muslim pavement dwelling women of the Byculla area of Mumbai, the rationale behind the formation of Mahila Milan lay in the recognition of the central role of women in the family as well as the enormous potential that women's groups had in transforming relations within society and in improving the lives of poor families. Mahila Milan, as a CBO has been used extensively in resettlement projects in urban areas that have involved the World Bank and infrastructure agencies in the city of Mumbai.

Mahila Milan now conducts informal training and support activities, as well as savings and credit groups, and aims to empower women to play a greater role in community management and to work with NSDF on broader policy issues at state and city levels. Mahila Milan thus represents both an opportunity to satisfy the credit needs of poor women and a strategy to mobilise them towards taking a more pro- active role in relation to their own poverty. The organisation lays less emphasis not so much on concrete achievements and outputs as on the learning process and the building of confidence among poor women. In the Byculla area, approximately 600 women are members of Mahila Milan, but together with NSDF, Mahila Milan now has a total of over 300,000 households as members across the country. *Source: Burra (1999), R&R of the Urban Poor: The story of Kanjur Marg; Working Paper Number 99

Vulnerability

The ESIA has indicated that there are several categories of vulnerable people based on demographic characteristics, income levels and physical/mental handicap. No specific data is available from the socio-economic survey on the extent of women-headed households. However, based on an aggregate estimation of 5-10% of the households, approximately 169 households are likely to be women headed.

1.3 GENDER ISSUES IN THE PROJECT AREA

A study by the Centre on Housing Rights and Evictions (2008) indicates that as women mostly end up migrating to slum along with their spouses, the slums reflect a “gendered social fabric where women are in a subservient and exploitable position relative to men”. No specific gender disaggregated information on household income, disabilities etc is available from the socio-economic survey. However, consultations indicate the following issues which need further attention:

 Security of Tenure: While the SRA guidelines acknowledge joint ownership, the concept excludes a large number of women who are not legally able to prove any relationship with a man. This gap is a major challenge for single women, widows, deserted women and elderly women. Women in the slum areas are not fully aware of their right to security of tenure, and hence will need to be engaged to explain the same. In addition, women who are destitute or socially vulnerable due to their marital status will not be in position to assume responsibility for security of tenure without provision of support and supervision/monitoring;  Usage of Public Space: Studies (Pukar, 2008) indicate that the public space available to women outside of the tenements is an important aspect of their

recreation, and low-rise structures with easy access to corridors and laneways help channelize increased interaction with other groups of women;  Participation in Planning: Cooperative societies often tend to be dominated by men or the perceived decision makers within a slum and hence women are constrained in meaningfully participating in conceptualisation, design and implementation phases of slum rehabilitation; and  Other Social Issues: Consultations with womens’ groups across slum blocks indicate that the most important issues that are key to welfare are (a) improving the health status of women as well as their health-seeking behaviour; (b) assessing the vulnerabilities of households that are led by disadvantaged women, such as estranged wives, widows etc; (c) mapping of livelihood activities that are currently prevailing within self-help groups and other small to medium scale ventures.

Overall, it can be ascertained that the rehabilitation of the Nirvana Hills Phase II Project will need to adopt a gender sensitive approach in order to improve the perceived benefits of access to improved housing, quality of life and most importantly, access to improved and personalized sanitation and health & education networks.

1.4 ADDRESSING GENDER-BASED CONCERNS

This section summarizes the specific actions that have been undertaken during the planning phase and the recommended actions during construction and operations to ensure gender-based benefits of the proposed project. In general, the stakeholder consultation plan underscores the importance of participation of women (across slum blocks) in a free, prior and informed manner across various activities of engagement.

Overall, it is recommended that KUL engender the support of existing self-help groups as well as NGOs to mainstream the activities and measures as described in Table 1.2.

The basic objectives of the Gender Action Plan are:

 to identify and understand the profile of women in the slum area and whether they face any unique vulnerabilities;  Mitigate impacts that are primarily felt by women;  Use the opportunity in the project to address some root causes of gender based discrimination, including asset ownership and participation in decision making; and  Intervene to develop long terms programmes to improve the lives of the women living in the rehabilitation tenements and buildings.

Based on these objectives the gender action plan should include:

 Livelihood measures as outlined in the Livelihood Restoration Plan;  Compliance to the Housing Society norms on women participation – ensure that the women members in the Housing society are made aware and trained to play a more effective role in the society’;  Decision making during the planning phase, i.e. linking up womens’ opinions in design, location, use of common spaces & amenities;  Joint ownership of the flats (already mandated under SRA)  Mahila Milans to be trained to become drivers for pushing the Housing Societies to function;

 Monitoring role of progress of the project, as well as formation and development of the housing society. Women can also play a key role in aspects like social behaviour, resolution of conflicts etc;  Skill develop and training to add income generation potential. Provision of micro credits for entrepreneurial activities; and  Gender-sensitive community engagement through focused groups etc.

Table 0.2 Measures for the Gender Action Plan

Activity/Measures Performance/Target Indicators Responsible agency/unit Timeframe Measures of Engagement Ongoing Activities Participation: % of meetings conducted with Through NGOs and Ongoing – up to the time Women have been encouraged to participate and female participation Community Relations Teams of demolition of structure present their views and opinions during the series of and finalization of design consultations that have involved responding to % of women participating in socio-economic surveys and community meetings meetings with the senior management at KUL; This includes inputs into the design and layout of % of suggestions brought forth the rehabilitation flat and the amenities therein; and their incorporation Identification of Development Opportunities: Number of skills and/or Specific programs that cater To be completed as soon Community liaison officers have identified entrepreneurial training to such issues will need to be as possible to ensure that opportunities, such as self-help groups and programs conducted for women developed through NGOs programs are entrepreneurial ventures, to facilitate gender-based in collaboration with an NGO. and training will need to be implemented during the initiatives to promote self-employment. Efforts are conducted (preferably transit phase ongoing to understand how similar activities can be Number of gender-specific during transit phase) continued during transit and post rehabilitation. programs conducted each year and proportion in total CSR Budget;

Number of women participating in each of the venture;

Tracking impacts of such ventures by concrete measurable impact indicators such as improved income, better employment of women, etc Design Issues: Record of design inputs and their - Completed Sample rehabilitation plan that has been constructed perceived benefits for the by KUL has encouraged feedback from women women; across slum blocks for aspects of utility, design, usage of space and furnishings. Specific feedback of Incorporation of the gender-

Activity/Measures Performance/Target Indicators Responsible agency/unit Timeframe Measures of Engagement women in the community has been incorporated into specific design evident in the the modifications of the sample rehabilitation flat facilities (such as the additional space for a porch in front of main entrance). Recommended Measures Resourcing & Staffing: Number of women as a part of Sensitization as well as Ongoing – contingent to Identify female community liaison officers for the CR team (at least 30-40%); identification availability of candidates Community Relations Team in order to better access and resources and understand any specific concerns and problems Number of meetings/discussions of the women in the slum community; led by women recruits and participation in the same Skill Mapping: Tracking number of women Sensitization as well as To be completed within Conduct a skill mapping of women enrolled in identified and proportion that identification two months of higher education/vocational training and any find gainful employment demolition relatively good profiles should be provided to recruitment agencies in the city for them to avail of opportunities; SRA-based Initiatives: Rehabilitation Assistance Number of societies wherein Training and formation of Monthly and Security of Tenure female participation exceeds 33%; housing societies and modules/programs Identify women-headed households as an indication sensitization about the during the transit of vulnerability and facilitate assistance for Tracking eligibility, and income participation of women; accommodation phase establishing eligibility, transit accommodation etc. profile of the women headed Training programs on households operating and running SRA recommends that ownership titles of the housing societies rehabilitation tenements will need to be in the name Ownership titles of rehabilitation of the wife along with the husband (in case of a male tenements to be named and head of household). In addition, women are required awarded to both wife and to have a representation of at least 33% within husband. housing societies that will be formulated and registered before handing over the Number of women participating society/rehabilitation building to the occupants. in trainings on housing societies and gender awareness Grievance Redressal: Number of grievances raised by Selection of female CLOs, Immediate The appointment of female community liaison women; tracking and maintaining the

Activity/Measures Performance/Target Indicators Responsible agency/unit Timeframe Measures of Engagement officers would be useful in furthering the grievance grievance MIS redressal mechanism through the construction, Number of appointed female transit and rehabilitation phase community liaison officers. Community Audit Group: Number of women participating Sensitization as well as Immediate – CAG audits It is recommended that women are made to assist in CAG activities. identification to be undertaken during with the proceedings of the Community Audit pre- Group (CAG) activities that are to take place on a % of CAG participants that are construction/constructio monthly and/or quarterly basis. KUL should ensure female n and operations that specific feedback from women gets heard as well as addressed during such initiatives

1.5 CONCLUSION

The Gender Action Plan that has been formulated will need to be revisited and reassessed as the project continues. Emphasis will need to be made on the importance of women’s involvement in leadership and community development. The central role that women will need to play in the successful implementation of the Nirvana Hills Phase II Project is justified not only on the grounds of gender equity but also upon the demonstration of their skills as managers of the family. With their experience of running households on inadequate budgets, poor women take easily to managing projects when given exposure, training and opportunity. Representative community organizations are crucial for developmental initiatives that target the poor and a significant women's presence not only makes the representation more even but more effective as well.

Annex F

Risk Management Plan

ESMP: ANNEX F –RISK MANAGEMENT PLAN

1.1 INTRODUCTION

Any project or activity will have certain underlying risks associated with it both due to internal or external factors. Therefore, from the perspectives of health and safety and investment it is essential to identify the potential hazards and risks that may pose a major threat to the project.

The Risk Assessment Plan (RMP) for the Nirvana Hills Phase II Project in Survey No. 44/1, Erandwane, Pune has been developed in adherence to the Asian Development Bank’s Safeguards Policy (2009). The objective of the Risk Management Plan (RMP) is primarily to identify and enlist the possible risks that the project may face. The Plan outlines the responsibilities of Project Management, its contractors and employees at the construction site of Project Nirvana. It provides a reference document that can be used for risks and hazard analysis and outlines the steps to be taken if incidents occur during the construction as well as operation phases of the project.

The key hazards identified have been broadly classified as man-made and natural hazards. The risks subsequently discussed have been mentioned below:  Operational Risk associated with actual engineering, procurement, construction execution, contractual risks etc:  Financial and Economic Risk- This may be attributed to mismanagement of project, unforseen delays or changes in macroeconomic scenario  Natural or Environmental Risks like inundation and earthquakes  Social and Political Risks  Health and Safety Risks

1.2 OBJECTIVES

The key objectives of the Plan are to:

 To localize the risks and if possible eliminate it;  To avoid confusion, panic and to handle the emergency with clearly defined actions;  To reduce the incidence and severity of injury in case of accidents;  Identify the designated personnel and responsibilities for dealing with emergencies on and ;  To take remedial measures in a quickest possible time to contain the incident and control it with minimum damage; and  To mobilize the internal resources and utilize them in the most effective way.

1.3 HAZARDS AND RISKS OF THE PROPOSED PROJECT

The potential hazards associated with the present project have been outlined in the following sections.

Type of Risk Actions to be taken Implementation & Monitoring Indicators Resources Operational Risk associated with  Proper inventorisation of all construction material Engineering Team Instances of deviations from actual engineering, procurement,  Understanding and adherence to legal requirements Contractors the proposed construction construction execution, contractual  Adherence to contractual requirements Legal Team plan; risks etc:  Use of construction materials meeting approved standards Procurement Team Instances of delay in material  Re-verification of construction plan diagrams and measurements Project procurement; Management Instances of disagreements with contractors pertaining to committed or expected output Financial and Economic Risk: This  Systematic approach to strategic and business planning Project Communication channels with may arise either when funder  Focus to internal audit programs Management Lenders refuses to continue the partnership  Decision making on effective use of resources Financial Team due to any identified  Develop a vehicle for communication with stakeholders, investors and Progress on agreed actions mismanagement by the company or other interested parties due to improper budgeting and  Proper estimating budgeting and cost control planning  Provisions for accommodating contingencies like hike in construction cost, inadequate manpower; delay in procurement etc.

Natural or Environmental Risks Inundation Architectural team; Adequacy of the slope and  Adequate storm water drainage systems Construction and drainage patterns on site;  Better land use management engineering team; Instances of water  Proper storage of equipments, construction materials and chemicals Contractors accumulation during the  Develop emergency response plan for evacuation of labor camps and Health and Safety construction phase response to spread of diseases among workers Team; Instances of inundation; Project Earthquake Management Pune lies very close to the seismically active zone around Koyna dam about 100 Indicators are based on the km south of the city and has been rated in Zone 4 (on a scale of 2 to 5, with 5 assumption that regular being the most prone to earthquakes). Therefore high rise structures such as disaster management drills Project Nirvana should be constructed such that they are resistant to high will be carried out: intensity and frequent quakes.  Appropriate architectural and structural configuration  Frequency of drills v/s  Accurate determination of earthquake load proportion of successful  Proper dimensioning of beams and columns drills;  Good quality of construction with proper mixing and quantity of water;  Average time taken for good quality sand and aggregates; designed quantity of cement in the mix; completion of drills; proper mixing of all ingredients with control on water cement ratio; proper  Time taken for emergency placement of steel and adequate curing response services onsite  Stabilisation of infill wall panels by properly attaching either to the column or top beams  Adequate separation between buildings to avoid pounding damage  Since the project is being constructed on stilts, clause 7.10 of IS: 1893-2002 (Part I) is recommended which provides two alternative design approaches: 1) dynamic analysis of the building including strengths and weaknesses of infills 2) Bare frame analysis of building neglecting infills and columns and beams to be designed 2.5 times the storey shear and moments

Social and Political Risk  Managing social and cultural impacts of the project on the community Community Instances of complaints from through project disclosures and community engagement at appropriate Relations Team community intervals. Compliance Team Number and frequency of  Managing labor colonies such that they do not become a nuisance for the stakeholder consultations held residents  Meeting the requirements of the ineligible residents adequately and skilfully by adhering to the provisions of the ineligibility policy  Identifying and managing issues of local protectionism skilfully  Anticipating and overcoming regulatory impediments  Taking into confidence the local political powers convincing them the social benefits of the project  Documentation and Follow-up on consultation meetings Health and Safety Risks

1. Traffic Management on Site Construction site vehicle incidents can and should be prevented by the effective Health and Safety % of incidents reported management of transport operations throughout the construction process. Team Contractors Number of diversions/traffic issues caused and time for resolution of the same

Keep Pedestrians and Vehicles The majority of construction transport accidents result from the inadequate Health and Safety Maintaining records for vehicle apart separation of pedestrians and vehicles. Officer movements; Community This can usually be avoided by careful planning, particularly at the design Relations Team Monitoring adequate signage, stage, and by controlling vehicle operations during construction work. their visibility and location; The following actions will help keep pedestrians and vehicles apart:

Entrances and exits - provide separate entry and exit gateways for pedestrians and vehicles;

Walkways - provide firm, level, well-drained pedestrian walkways that take a direct route where possible;

Crossings - where walkways cross roadways, provide a clearly signed and lit crossing point where drivers and pedestrians can see each other clearly;

Visibility - make sure drivers driving out onto public roads can see both ways along the footway before they move on to it; Obstructions – do not block walkways so that pedestrians have to step onto the vehicle route; and

Barriers - think about installing a barrier between the roadway and walkway.

Minimising vehicle movements Good planning can help to minimise vehicle movement around a site. For Health and Safety Maintaining records for vehicle example, landscaping to reduce the quantities of fill or spoil movement. To limit Officer movements; the number of vehicles on site: Community Relations Team  provide car and van parking for the workforce and visitors away from the work area;

 control entry to the work area; and

 plan storage areas so that delivery vehicles do not have to cross the site.

People on Site Employers should take steps to make sure that all workers are fit and Health and Safety Occasional checking of licenses competent to operate the vehicles, machines and attachments they use on site Officer and competencies of drivers or by, for example: Compliance team operators Contractor for  checks when recruiting drivers/operators or hiring contractors; transport vehicles

 training drivers and operators;

 managing the activities of visiting drivers. People who direct vehicle movements (signallers) must be trained and authorised to do so.

Accidents can also occur when untrained or inexperienced workers drive construction vehicles without authority. Access to vehicles should be managed and people alerted to the risk.

Turning Vehicles The need for vehicles to reverse should be avoided where possible as reversing Installation of appropriate is a major cause of fatal accidents. signages and systems for guiding vehicular movement. One-way systems can reduce the risk, especially in storage areas.

A turning circle could be installed so that vehicles can turn without reversing.

Visibility If vehicles reverse in areas where pedestrians cannot be excluded the risk is Health and Safety Occasional checking of the elevated and visibility becomes a vital consideration. Officer functionality of aids for Contactors for drivers. You should consider: transport vehicles Monitoring of lighting facilities Aids for drivers - mirrors, CCTV cameras or reversing alarms that can help

drivers can see movement all round the vehicle;

Signallers - who can be appointed to control manoeuvres and who are trained in the task;

Lighting - so that drivers and pedestrians on shared routes can see each other easily. Lighting may be needed after sunset or in bad weather;

Clothing - pedestrians on site should wear high-visibility clothing.

Signs and Instructions Make sure that all drivers and pedestrians know and understand the routes Contractors Occasional awareness checks and traffic rules on site. Use standard road signs where appropriate Health and Safety of drivers and pedestrians on Officer traffic rules and routes. Provide induction training for drivers, workers and visitors and send instructions out to visitors before their visit.

2. Working at height Assessing work at height - Assess the risks, take precautions, and issue clear Contractors Occasional awareness checks method statements for everyone who will work at height. Health and Safety about the precautions for Officer working at height Roof work - Plan safe access, and prevent falls from edges and openings.

Fragile surfaces - The hierarchy of controls for working on or near fragile surfaces is avoid, control, communicate, co-operate.

Ladders - When it’s appropriate to use ladders – and the three key safety issues – position, condition and safe use.

Tower scaffolds - Select the right tower for the job; erect, use, move and dismantle the tower safely; ensure that it is stable; inspect it regularly; prevent falls.

3. Structural Stability Assess the risks and prevent unintentional structural collapse during Engineering team - alterations, demolition and dismantling; and the measures you need to take to Contractors Health and Safety prevent accidents in excavations. Officer  Structural stability in alterations demolition and dismantling - Key issues include survey and assessment, preventing structural collapse, arrangements for demolition and consulting building control departments

 Structural stability in excavations - Making excavations safe so that people are not injured by collapse of excavation, by material falling on them, or by falling into the excavation.

4. Cranes Tower and mobile cranes are used extensively on construction projects and Construction Monitoring of incidents, near- present two principal hazards: Contractor misses, accidents of cranes; Crane owning  Collapse of the crane – such incidents present significant potential for company Adequate signage; multiple fatal injuries, both on and off-site; Training of crane operators;  Falling of the load – these events also present a significant potential for

death and major injury. Effectiveness of safety buffer All lifts operations must be planned carefully to ensure that they are carried out around zone of crane safely. movement

 planning – including site preparation, crane erection and dismantling;

 selection, provision and use of a suitable crane and work equipment

 including safe slinging and signalling arrangements;

 maintenance and examination of the crane and equipment;

 provision of properly trained and competent personnel;

 supervision of operations by personnel having the necessary authority;

 thorough examinations, reports and other documents;

 measures to secure safety of persons not involved in the lifting.

 preventing unauthorised movement or use of the crane; and

5. Slips and Trips Uneven Surfaces Site Contractors Number of signpost erected Engineering Team Many slips and trips occur when people are walking on uneven surfaces. The Health and Safety risk can be reduced by providing walkways that are; Officer

 clearly designated as a walkway;

 provided with good conditions underfoot;

 signposted and provided with adequate lighting.

Obstacles

Other slips and trips happen because there is something in the person’s way, such as building materials or waste. You can help avoid these incidents by:

 Housekeeping - everyone keeping their work and storage areas tidy;

 Deliveries - planning deliveries to minimise the amount of materials on site;

 Waste - designating areas for waste collection, providing skips and bins where needed and making clear the responsibilities for waste removal.

Trailing Cables If you can use cordless tools you may not need to use cables. Where you need cables for temporary lighting or mains-powered tools, run them at high level, especially along corridors especially along corridors

Wet or Slipper Surfaces

Treat slippery surfaces with stone (mud) or grit (for ice) or provide temporary covering.

Signpost any slippery areas and make sure footwear with a good grip is worn.

Changes in level

Where you cannot avoid small changes in level, such as in doorways, consider installing ramps. If you cannot do this, use signs to warn workers to look out for the change in level.

6. Fire Risk Assessment Principal Number of mock drills Contractor conducted 1. Identify hazards: consider how a fire could start and what could burn; responsible for the site Number of signages erected 2. People at risk: employees, contractors, visitors and anyone who is Health and Safety vulnerable, e.g. disabled; Officer or Incident 3. Evaluation and action: consider the hazards and people identified in 1 controller and 2 and act to remove and reduce risk to protect people and premises;

4. Record, plan and train: keep a record of the risks and action taken. Make a clear plan for fire safety and ensure that people understand what they need to do in the event of a fire; and

5. Review: your assessment regularly and check it takes account of any changes on site.

Means of Escape

Routes: your risk assessment should determine the escape routes required, which must be kept available and unobstructed;

Alternatives: well-separated alternative ways to ground level should be provided where possible;

Protection: routes can be protected by installing permanent fire separation and fire doors as soon as possible;

Assembly: make sure escape routes give access to a safe place where people can assemble and be accounted for. On a small site the pavement outside may be adequate; and

Signs: will be needed if people are not familiar with the escape routes. Lighting should be provided for enclosed escape routes and emergency lighting may be required.

Signs: will be needed if people are not familiar with the escape routes. Lighting should be provided for enclosed escape routes and emergency lighting may be required.

Warning Systems

Set up a system to alert people on site. This may be temporary or permanent mains operated fire alarm (tested regularly), a klaxon, an air horn or a whistle, depending on the size and complexity of the site. The warning needs to be distinctive, audible above other noise and recognisable by everyone.

Fire Fighting Systems

Fire extinguishers should be located at identified fire points around the site. The extinguishers should be appropriate to the nature of the potential fire:  wood, paper and cloth – water extinguisher;  dry powder or foam extinguisher;  electrical- carbon dioxide extinguisher Nominated people should be trained in how to using extinguishers

7. Electrical risks Electrical equipment must be safe, and properly maintained. Only in Maintenance Team Number of electrical risk exceptional circumstances should work be carried out on live systems, and then Principal incidents recorded Contractor only by a competent authorised person. Health and Safety  Electrical systems in buildings - Refurbishment work in buildings presents Officer or Incident Controller the greatest risk and must be planned, managed and monitored to ensure

that workers are not exposed to risk from electricity.  Overhead power lines - Any work near electric overhead power lines must be carefully planned and carried out to avoid danger from accidental contact or close proximity to the lines.  Underground cables - Damage to underground electrical cables can cause fatal or severe injury you must take precautions to avoid danger. These precautions include a safe system of work based on planning, use of plans, cable locating devices and safe digging practices.

1.4 DISASTER PREPAREDNESS

Disaster preparedness provided for hazard identification and risk analysis. It indicates basic information about the resources, demography, and existing organisational setup, administrative facilities at that level, both at state and district levels.

The primary aim is to create awareness through disaster education and training and information dissemination to the people to cope with disasters.

The disaster management activity comprises certain key components as indicated in the Figure 0.1.

Figure 0.1 Disaster Management-Key Components

DISASTER IMPACT

PREPAREDNESS RESPONSE

RECOVERY MITIGATION

PREVENTION DEVELOPMENT

1.4.1 Emergencies and Post Disaster-Assistance

The overall aims of emergency and post-disaster assistance are:  To ensure survival of the maximum possible number of victims, keeping them in the best possible health in the circumstances;  To re-establish self-sufficiency and essential services for all with special attention to those whose needs are maximum, the most vulnerable.  To repair or replace the damaged infrastructure and regenerate viable economic activities.

1.4.2 Emergency Response Procedure

Responses are structured as per the nature of disaster. Three levels of each type of disaster have been identified-potential, limited and full emergency conditions. The process takes place in the following steps:  Trigger Mechanism: It is an emergency quick response mechanism which would spontaneously set the vehicle of management by evolving an effective signal or warning system, identifying activities and levels, determining the response type of each activity, undergoing preparedness drills;  Emergency Operations Centre to plan, manage and execute operations.

1.4.3 Emergency Facilities

Emergency Control Centre (ECC)

For the purpose of handling emergency, separate emergency control centre should be established in close proximity of the slum buildings. All communications to and from should originate from this control centre. The area in project site office complex has been identified for establishment of ECC. All the key personnel such as Site Controller/ Incident Controller Officers, Senior Personnel would be located here or have access to the ECC. The ECC will also coordinate with District Emergency Operation Centre (DEOC).

Infrastructure at Emergency Control Centre

Emergency control centre should therefore contain the following: 1. A copy of on-site emergency plan; 2. A copy of evacuation plan; 3. An adequate number of internal and external telephones lines; 4. A copy of layout plan showing areas of large inventories of hazardous and explosive materials and sources of safety and first aid equipments; 5. Layout of fire-fighting system including locations of fire extinguishers with their type, hydrant system; 6. Location of assembly points; 7. Information on additional sources of water; 8. Site entrance and roadways, including up-to-date information on road traffic; 9. List of important telephone numbers such as Police, Fire Brigade, Hospitals, and other outside Emergency Services, etc.; 10. List of key Personnel with addresses and telephone numbers; 11. List of Personal Protective Equipment; 12. First Aid box; 13. Alarm Control system.

Emergency Medical Facilities

Stretchers, gas masks and general first aid materials for dealing with burns, burns, fractures etc. would be maintained in the Medical Centre as well as in the ECC. A range of medicines should be maintained in the ECC/ Medical Centre. Breathing apparatus and other emergency medical equipment should be provided and maintained. Apart from the project site first aid facilities, external facilities would be augmented. Checklist of name of medical personnel, medical facilities available in the surrounding area to be prepared and updated.

1.4.4 Emergency Response Coordinators

First-aid Team

Members of first-aid Team will report to the Incident Controller on hearing of the alarm. The Emergency vehicle driver, if safe to do so, shall collect the emergency vehicle and park nearest to the scene of the incident. First aider shall inform the incident controller that the Emergency Vehicle is leaving the site, giving the name of the patient and destination i.e. hospital or doctor’s room and request the Incident Controller to inform the destination (hospital, etc.) advising them about the casualties reaching there.

Training and Education

Major emergency procedure should be laid down clearly and convincingly to everyone on site particularly Key Personnel. For this purpose, on site training and mock drills should be conducted periodically and documented. The duties and responsibilities of each person and the emergency procedure to be followed by him should be very clear.

Procedure for Mock Rehearsal

 Inform all the employees about mock drill;  Fix the date for mock drill;  Observers (senior personnel) will not be involved in the exercise. They will monitor the Mock drill;  Emergency Siren / alarm will be raised;  After hearing the Siren /alarm, Emergency procedure will be followed as mentioned in the Onsite Emergency Plan;  Observer will note down the activities with respect to the time and identify any gap.

1.5 EMERGENCY ACTION PLANS

1.5.1 Action Plan for Personnel Medical Injury

During construction operations, accidents may occur during transport of dumpers, trucks, dozers and other heavy vehicles attributing to mechanical failure and human errors.

Following Line of Action shall be followed if any worker is injured during operational activities: 1. If a person finds someone injured, he shall immediately tell his shift in charge about the accident; 2. The shift in charge shall inform the ECC and First Aid Team about the injury and location of accident. 3. On receiving the information, First Aid Team should go to the accident site immediately; 4. First Aid team shall provide the first aid to the injured person and make necessary arrangements for taking him to the hospital, if required; 5. After this, First Aid Team shall report the ECC and make entries in the register about the incident, it’s cause and measures taken.

1.5.2 Action Plan during Fire

The potential sources of have been mentioned in the above sections. The following line of action shall be followed during fire accident at site:

1. Any person noticing any sign of fire in the area shall start shouting to attract other people working in that area; 2. Siren installed in the area to be blown; 3. Steps to be taken to control the fire by using fire fighting equipments available in that area; 4. Switch off the power supply of the area in case of electrical fire; 5. In the meantime, the ECC shall be informed about the incident; 6. The shift Incharge shall conduct a head count to determine whether any individual is missing;

7. On receiving the information at ECC, ECC should immediate contact the incident controller, fire squad team, first aid team and security personnel and direct them to reach the incident site; 8. On reaching at site, the fire squad shall take steps to extinguish the fire depending on its nature, class and extent. The persons to be rescued if any involved in the fire; 9. The first aid team shall provide immediate first aid to burnt person, if any and make arrangements to send him to nearest hospital; 10. The security staff should prevent the unauthorized entry in the area and keep the workers beyond the safety zone; 11. The incident controller shall supervise the fire fighting operation and keep updating the site controller about the situation. 12. Once the situation is controlled, the Emergency Response Team shall carried out a detailed analysis of the causes of the accident, evaluate them and minimize them for future.

1.5.3 Action Plan for Earthquake

According to BIS seismic map, 2002, Project Site falls in Zone III. Zone III is defined as a zone having medium damage risk and vulnerable to earthquakes of intensity MSK VII or less (as defined by Building Materials and Technology Promotion Council). Thus, the Project accordingly is required to have provisions of earthquake resistant construction of building structures. Structural designers should use this factor for earthquake resistant design of structures. The steps to be followed during an earthquake are as below:

Before (in office building) 1. Check first aid supplies; 2. Secure all cabinets and shelving to prevent tipping; 3. Remove heavy items from high shelves; 4. Keep passage clear of stacked materials and file cabinets; 5. Ensure that computers, printers, and typewriters will not fall; 6. Arrange work areas to prevent “trapping” of personnel; 7. Make sure that exits are clearly marked.

During Earthquake 1. When first tremors are sensed during an earthquake, the siren should be blown to declare emergency by ECC; 2. Hearing the siren or self experiencing the tremors of earthquake, all personnel should evacuate the building and assemble at pre designated assembly point. The assembly point should be an open space away from any structure; 3. If inside the building, try to occupy a safe place, such as beneath sturdy table; 4. Remain calm and don’t get panic; 5. Listen battery operated radio for latest information;

After Earthquake 1. After major earthquake, there are likely to be aftershocks and great confusion. So remain at your place for few minutes and prepare for possibilities of aftershocks; 2. Once, the earthquake stops, the check for injured workers. Do not attempt to move injured persons unless they are in immediate danger; 3. If the office building appears to have significant damage, evacuate to a safe place; 4. After earthquake, don’t enter the damaged buildings immediately; 5. Check for fire hazards, electrical dangers; 6. Do not spread rumours; 7. ECC should coordinate with DEOC in rescuing the trapped people.

1.5.4 Action Plan during Floods

The action plan to be followed during floods is as below:

Before Floods 1. ECC to identify highest locations at site in advance to assemble during floods; 2. During floods, the project site may experience the debris flow along with the construction material and the roads may become unapproachable. Therefore, separate evacuation route to be designed which should be tried and made familiar to workers during mock drills; 3. During monsoon season, all emergency supplies to be kept handy at ECC and assembly point, such as flashlights, portable battery operated radios, extra batteries, emergency food and water, essential medicines, first aid kits etc.; 4. ECC should keep track on rainfall intensity and local weather forecast during the monsoon season.

During Floods 1. Getting first sign of abnormal high rains or local announcement of flood declaration, ECC should blow the emergency siren; 2. On hearing the siren, evacuate the area through pre designed evacuation route and assemble at the earlier identified safe areas; 3. The electricity supply to be shut down and emergency lights to be operated; 4. Listen the battery operated radio for latest information; 5. Do not try to escape through using cars or other vehicles as these may be washed away by force of water current; 6. Help the affected persons; 7. The site controller should get into communication with DEOC and informing about the current situation at the site; 8. The onsite Emergency Response Team to help the Government Relief team in guiding them about the site and rescuing the people in the affected areas.

After Floods 1. Don’t return until the district authorities declares safe to return; 2. After restoring the situation, the Emergency Response Team should examine carefully project site office building, storage areas and other areas for danger of collapsing, fire hazards etc.; 3. Watch out the closed areas for animals especially snakes that may have come along with flood water; 4. Pumped out the water gradually through installing pumps at site; 5. ECC to document the damages happened and take photographs for further damage cost assessment;

1.5.5 Post Emergency Analysis and Evaluation

When the emergency is over, the Emergency Response Team will carry out a detailed analysis of the causes of the accident, evaluate the influence of various factors and minimize them for future. At the same time, the adequacy of the Disaster Preparedness Plan will be evaluated and shortcomings will be rectified for subsequent improvement of the plan.

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