Halol Godhra Shamlaji Tollways

Environment and Social Due Diligence Report

September 2012

IND: India Infrastructure Project Financing Facility II –Halol Godhra Shamlaji Tollways

Prepared by

India Infrastructure Finance Company Limited for the Asian Development Bank

This report is a document of the borrower. The views expressed herein do not necessarily represent those of ADB's Board of Directors, Management, or staff, and may be preliminary in nature.

In preparing any country program or strategy, financing any project, or by making any designation of or reference to a particular territory or geographic area in this document, the Asian Development Bank does not intend to make any judgments as to the legal or other status of any territory or area.

Environment and Social Due Diligence Report L&T Halol Shamlaji Tollway Private Limited

IIFCL

Due diligence Report on Environment and Social Safeguards

Sub Project: Construction of Additional Two lane for Halol Godhra Shamlaji Road to make it Four lane Divided Carriageway Facility on BOT Basis

Sub-Project Developer: L&T Halol Shamlaji Tollway Pvt. Ltd

September 2012 1

Environment and Social Due Diligence Report L&T Halol Shamlaji Tollway Private Limited

CONTENTS

PROJECT BACKGROUND: ...... 5 1. SUB-PROJECT TITLE: ...... 5 2. SUB-PROJECT DESCRIPTION: ...... 5 3. CONCESSIONAIRE: ...... 6 4. EPC CONTRACTORS:...... 7 5. INDEPENDENT CONSULTANT: ...... 7 6. PROJECT MANAGEMENT CONSULTANT: ...... 7 7. LENDER’S ENGINEER: ...... 7 8. STATUS OF SUB-PROJECT IMPLEMENTATION: ...... 7 DUE DILIGENCE ON ENVIRONMENTAL SAFEGUARDS: ...... 9 9. AVAILABILITY OF EIA/EMP REPORTS: ...... 10 10. VISIT TO SUB-PROJECT LOCATION: ...... 10 11. ENVIRONMENTAL SENSITIVITY AND DUE DILIGENCE: ...... 10 12. CATEGORIZATION OF SUB-PROJECT: ...... 11 13. STATUS OF REGULATORY CLEARANCES: ...... 11 14. PUBLIC CONSULTATION AND INFORMATION DISCLOSURE: ...... 14 15. ALTERNATIVE ANALYSIS: ...... 16 16. IMPLEMENTATION OF EMP: ...... 17 16.1. Concession Agreement and EPC Contract : ...... 17 16.2. Environment management plan (EMP): ...... 18 16.2.1. Contractors HSE Plan: ...... 18 16.2.2. EMP Implementation Matrix: ...... 18 16.2.3. Environmental Monitoring: ...... 22 16.2.4. Overall Implementation Framework for Environment Management Plan: ...... 22 17. SITE VISIT:...... 24 18. CONCLUSION AND RECOMMENDATION: ...... 24 DUE DILIGENCE ON SOCIAL SAFEGUARDS ...... 26 19. DUE DILIGENCE OF SOCIAL IMPACTS: ...... 27 20. ALTERNATIVE ANALYSIS: ...... 27 21. MINIMIZATION OF SOCIAL IMPACTS: ...... 28 22. PUBLIC CONSULTATION: ...... 28 23. LAND ACQUISITION IN THE SUB-PROJECT: ...... 30 24. RESETTLEMENT IMPACT IN THE SUB-PROJECT: ...... 31 25. COMPENSATION AND ENTITLEMENT: ...... 32 26. INCOME RESTORATION MAESURES: ...... 32 27. COMMUNITY DEVELOPMENT ACTIVITIES: ...... 32 28. SITE VISIT:...... 32 29. CONCLUSION AND RECOMMENDATIONS: ...... 33

LIST OF FIGURES:

FIGURE 1 : OVERALL IMPLEMENTATION FRAMEWORK FOR EMP IMPLEMENTATION ……………..22

LIST OF TABLES: DUE DILIGENCE ON ENVIRONMENTAL SAFEGUARDS: TABLE 1 : PROJECT SALIENT FEATURES…….………………………………………………………………………………4

Environment and Social Due Diligence Report L&T Halol Shamlaji Tollway Private Limited

TABLE 2 : CUMULATIVE ROAD WORK PROGRESS STATEMENT……………………. …………………..6 TABLE 3 : CUMULATIVE PHYSICAL PROGRESS STATEMENT FOR STRUCTURAL WORKS.……………….7 TABLE 4 : FINANCIAL PROGRESS FOR THE PROJECT………………………………………………………………….7 TABLE 5 : STATUS OF REGULATORY CLEARANCES OBTAINED …………………………………………………..11 TABLE 6 : PUBLIC CONSULTATION DETAILS……………………………………………………………….……………13 TABLE 7 : PUBLIC CONSULTATION DURING IMPLEMENTATION STAGE…………….……………………..15 TABLE8 : EMP IMPLEMENTATION MATRIX……………………………………..…………………………………….18 DUE DILIGENCE ON SOCIAL SAFEGUARDS: TABLE 9 : ISSUES RAISED DURING PUBLIC CONSULTATION AND THEIR ADDRESSAL…………………….27 TABLE10 : PUBLIC CONSULTATION DURING IMPLEMENTATION STAGE …………….………..………….29 TABLE 11 : LAND ACQUISITION FOR THE SUB-PROJECT ……………………………………….………..………..30 TABLE12 : AFFECTED FAMILIES AS PER THE TYPE OF STRUCTURE ……………...... ………..………..30

APPENDICES:

Appendix I: EIA/EMP Report Appendix II: Copies of Relevant Clearances, Consents and Permits

Appendix III: Public Hearing Proceedings Appendix IV: Concession Agreement-Environment Management and Safety Clauses

Appendix V: EPC Agreement-Environment Appendix VI : HSE Plan Management and Safety Clauses

Appendix-VII : Project Implemented Appendix VIII: Copy of Environmental Monitoring Report Environment Management Plan Matrix

Appendix IX: Six Monthly EC Compliance Report Appendix-X : Land Acquisition Procedure

Photoplate-I: Site Visit Photographs

Photoplate-II: Relocated Religious Structures

Photoplate-III: CSR Activities Undertaken by Concessionaire

Environment and Social Due Diligence Report L&T Halol Shamlaji Tollway Private Limited

Sub Project: Construction of Additional Two lane for Halol Godhra Shamlaji Road to make it Four lane Divided Carriageway Facility on BOT Basis

Due diligence Report on Environment and Social Safeguards

Environment and Social Due Diligence Report L&T Halol Shamlaji Tollway Private Limited

PPRROOJJEECCTT BBAACCKKGGRROOUUNNDD:::

1. SSUUBB---PPRROOJJEECCTT TTIIITTLLEE:::

1. The Gujarat State Road Development Corporation (GSRDC) has decided to construct of additional Two Lane for Halol-Godhra-Shamlaji Road to make it Four Lane divided carriageway Facility under Viability Gap Funding Scheme of Government of India on Built, Operate and Transfer Basis. 2. SSUUBB---PPRROOJJEECCTT DDEESSCCRRIIIPPTTIIIOONN:::

2. The Project Road i.e. Halol-Godhra-Shamlaji section of SH-5 is located in eastern part of the state of Gujarat. The starting point of the project corridor is at Km. 335.170 (existing chainage) and the terminal point is at Km. 501.400 (existing chainage) including the existing bypass and proposed bypass at Godhra. The road passes through urban areas of Halol, Kalol, Godhra, Sehera and Lunawada of Panchmahal district where major settlements exist and also through major settlements of Malpur and Modasa in Sabarkantha district.

3. Halol-Godhra-Shamlaji (SH-5) acts as parallel corridor to SH-8, running from North to South on eastern extreme of the Gujarat state. It also acts as good connector between two National Highways, NH-8 with NH-59 in between Shamlaji to Godhra and further Vadodra with NH-8 again.

4. Gujarat State Road Development Corporation (GSRDC) has awarded the Concession to L&T- HSTPL for four-laning of the existing two lane road from Km 335/170 to Km 501/400 (Length Km) of SH-5 in the state of Gujarat on BOT (Toll) basis under Gujarat Infrastructure Development Act, 1999.

5. The proposed widening and strengthening work would mainly involve: (i) widening of existing two lane road into four lane divided carriageways; (ii) Pavement strengthening and provision of drains, service roads, sidewalks, pedestrian crossing, cattle crossing, underpasses, bus bays and truck lay byes etc. The project salient features are given in table 1.

Table 1: Project Salient Features

Particulars Project Road (Km 335.170 to 501.400) Length 173.057 Km Terrain Mostly Plain and hilly terrain at some places. 3 to 5 m in Rural sections and 1 to 5 m in Urban and Semi Median Width urban sections Lane Width 3.5 m Paved Shoulders 1.5 m Godhra (Existing Bypass)- 10.22 km Bypass Godhra (New By Pass)- 6.776 km 11 Nos. Major Bridges

44 Nos. Minor Bridges

Railway Over Bridge 2 Nos.

Environment and Social Due Diligence Report L&T Halol Shamlaji Tollway Private Limited

Pipe Culverts 241 Nos. Cattle Underpass 05 Vehicular Underpass (VUP) 01 Nos. Pedestrian Underpass 07 Nos. Box/Slab Culverts 37 Nos. Toll Plaza 04 Nos. Source: LIE’s Monthly Progress Report, May 2011

Project Facilities: Further as part of the project, various project facilities shall be provided which will also put advantage to the environmental and safety safeguards of the project. The project facilities to be provided as part of the concession agreement include:

 Road side ,furniture (e.g. Traffic Signs and Pavement Markings, Guard Rail and Traffic Safety Devices, Boundary Stones, Hectometer / Kilometer Stones, Traffic Blinker Signal (L.E.D) at intersections, Delineators and Guard Posts)  Toll Plaza at four locations (km 356.000, 401.500, 447.000 and 481.000);  Highway Lighting (Conventional / Non-conventional energy (like solar, wind) lighting system shall be provided at all major intersections, cattle crossings, pedestrian underpasses);  Pedestrian facilities at all major villages, towns and junctions along the project highway. These will include Zebra Crossing, with separate flashing beacon  Landscaping and Tree plantation including median plantation;  Truck Lay Bays of varying lengths (500m to 1000m), along the Project Highway, on both sides  Bus bays and Bus shelters  Cattle crossings, Pedestrian and vehicular underpasses;  Administration, Operation and Maintenance of Base Camp;  Medical Assistance  Traffic Control Measures with the help of Traffic Aid Posts  Vehicle rescue posts  Highway Petrol Units  Highway traffic management system (HTMS)  Integrated Modern Toll Collection System (IMTCS)  Rain water Harvesting Structures  Landscaping/Tree Plantation

3. CCOONNCCEESSSSIIIOONNAAIIIRREE:::

6. GSRDC has appointed M/s. L&T-Halol-Shamlaji Tollway Private Limited as the concessionaire for this sub-project. The Concession Agreement signed on 17th September 2008 between GSRDC and M/s. L&T-Halol-Shamlaji Tollway Private Limited. The financial close has been achieved on 28th August 2009 .

Environment and Social Due Diligence Report L&T Halol Shamlaji Tollway Private Limited

4. EEPPCC CCOONNTTRRAACCTTOORRSS:::

7. M/s. L&T-Halol-Shamlaji Tollway Private Limited has signed the EPC contract agreement with L&T Infra Operating Company (L&T ECC Division) .

5. IIINNDDEEPPEENNDDEENNTT CCOONNSSUULLTTAANNTT:::

8. M/s Louis Berger Inc. has been appointed as the independent consultant for the project.

6. PPRROOJJEECCTT MMAANNAAGGEEMMEENNTT CCOONNSSUULLTTAANNTT:::

9. M/s. Feedback Ventures Pvt. Ltd. has been appointed as the Project Management Consultant (PMC) for the project and M/s. Mott Mc Donald has been appointed as safety Consultant.

7. LLEENNDDEERR’’’SS EENNGGIIINNEEEERR:::

10. M/s. Frishmann Prabhu (India) Pvt. Ltd. has been appointed as Lender’s Engineer for the project.

8. SSTTAATTUUSS OOFF SSUUBB---PPRROOJJEECCTT IIIMMPPLLEEMMEENNTTAATTIIIOONN:::

11. Physical Progress: According to project construction plan, the project completion date is 9th December 2011. The physical progress of the project as per May 2011 is given in table 2 and table 3.

Table 2: Cumulative Road Work Progress Statement

Sl. % of work achieved till this month (May 2011) Description No. Existing Carriageway New Carriageway 1 95.11 99.65 Clearing & Grubbing 2 Embankment 95.11 98.11

3 Sub grade 95.11 96.35

4 95.11 95.91 Granular Sub Base 5 95.11 95.67 Wet Mix Macadam 6 Dense Bituminous 95.11 91.83 Macadam 7 BC 81.11 67.17

Environment and Social Due Diligence Report L&T Halol Shamlaji Tollway Private Limited

Source: LIE’s Monthly Progress Report, May 2011

Table 3: Cumulative Physical Progress Statement for Structural Works

S.No. Description No. of Structures

Total In Completed Yet to be started Number progress

1 ROB 02 02 - -

2 Major Bridges 11 11 - -

3 Minor Bridges 44 0 44 0

4 Pedestrian 07 01 02 04 Underpass 5 Vehicular 01 0 01 0 Underpass 6 Slab and Box 37 0 36 01 Culverts

7 Pipe culverts 241 0 241 0

8 Cattle 05 02 01 02 Underpasses

Source: LIE’s Monthly Progress Report, May 2011

12. Financial Progress: The financial progress of the major works carried out at the site in the month of May 2011 is given in table 4.

Table 4: Financial Progress for the Project Cumulative Financial Cumulative % of Financial % of Financial Progress (Planned) Financial Progress Progress Planned up Progress achieved up (Achieved) to this month to this month

(Crores) (Crores) % %

667.65 865.76 59.50 77.16

Source: LIE’s Monthly Progress Report, May 2011

Environment and Social Due Diligence Report L&T Halol Shamlaji Tollway Private Limited

DDUUEE DDIIILLIIIGGEENNCCEE OONN EENNVVIIIRROONNMMEENNTTAALL SSAAFFEEGGUUAARRDDSS:::

Environment and Social Due Diligence Report L&T Halol Shamlaji Tollway Private Limited

9. AAVVAAIIILLAABBIIILLIIITTYY OOFF EEIIIAA///EEMMPP RREEPPOORRTTSS:::

13. GSRDC through its consultant M/s SAI Consulting Engineers Pvt. Ltd. has prepared the Environmental Assessment and Environment Management Plan. A copy of the EIA/EMP report is given in Appendix-I.

10. VVIIISSIIITT TTOO SSUUBB---PPRROOJJEECCTT LLOOCCAATTIIIOONN:::

14. As part of the preparation of the ESDDR, the sub-project was visited by the Environmental and Social safeguard specialists of IIFCL during 23rd -24th of May 2011 for field verification of Environmental safeguards as reported in the EIA/EMP reports and consultation with the concessionaire. The site visit photographs are given in Photoplate-I.

11. EENNVVIIIRROONNMMEENNTTAALL SSEENNSSIIITTIIIVVIIITTYY AANNDD DDUUEE DDIIILLIIIGGEENNCCEE:::

15. The environmental sensitivity of the SH-5 section between Halol-Godhra-Shamlaji sections has been assessed by reviewing the Environmental Assessment and Management Plan, prepared as part of the project preparation, supplemented by field visit and consultation with the concessionaire. The environmental sensitivity assessment is given below:

 The project road passes mostly through flat terrain, also passes through protected and reserve forest areas;

 There is no declared wildlife/protected area situated within 10 km of the project corridor;

 There are no known rare, threatened or endangered fauna species within the project area;

 The widening and up-gradation of this SH section involves diversion of 117.073 Ha of protected forest and 24.77 Ha of reserve forest land;

 6883 nos. of road side tree cutting is involved as part of the project. To compensate thrice number of tree plantation shall be undertaken. For the diversion of reserve forest land, compensatory afforestation will be taken up at the equivalent non-forest land by the forest dept. at the cost of project authority for which necessary funds will be submitted with Compensatory Afforestation Fund Management & Planning Agency (CAMPA), Delhi. The saplings shall be maintained for 3 years. The cost provision for felling, and plantation of new saplings has been made;

 There are no fisheries and fish habitats in the study area as the existing water sources as the existing water sources cannot sustain fisheries throughout the year. However, fishing of small scale is being practiced by local people in the private ponds, rivers and reservoirs; 10

Environment and Social Due Diligence Report L&T Halol Shamlaji Tollway Private Limited

 There are archeological monuments and sites within 10 km of project corridor but all of these sites are located at the significant distance so no impact is envisaged due to this project;

 There are some cultural properties as well as other Government properties/facilities within the RoW that are likely to be affected due to proposed project As the affected properties have been properly relocated so impacts have been minimized;.

 There are 11 major bridges, 23 minor bridges and 278 cross drainage structures along the entire length of the project road. ;

 Public consultations have been conducted during the environmental studies to disseminate the project information and to record the views/aspirations of the local people along this SH section. Public hearing were carried out on 06.02.2008 at Modasa, Dist. Sabarkantha and on 04.03.2008 at Godhara, Dist. Panchmahal for the respective portion of the project ;

 Elaborate environmental management and monitoring programme has been suggested for this SH section;

 The concessionaire has undertaken the implementation of environment management measures as per agreed EMP including physical monitoring of environmental parameters during the construction stage of the project;and,

 A cost provision of INR 363.25 Lacs has been proposed for Environment Management and monitoring plan. As per the details available from Concessionaire, amount of Rs. 185 Lacs has been spent till date on Environmental Management measures which involves Continuous environmental monitoring, air pollution control measures, structures enhancement , plantation and landscaping etc.

 Periodical environmental management and monitoring during the project implementation is being carried out by the concessionaire.

12. CCAATTEEGGOORRIIIZZAATTIIIOONN OOFF SSUUBB---PPRROOJJEECCTT:::

16. The sub-project can be classified as category B based upon ADB’s EA requirements as per their Safeguard Policy Statement (2009). This classification is based on the review of the EA report and other available documents, field verifications of the sub-project with respect to the environmental sensitivity among others.

13. SSTTAATTUUSS OOFF RREEGGUULLAATTOORRYY CCLLEEAARRAANNCCEESS:::

17. The statutory clearances required as part of the proposed widening and strengthening of SH-5 section between Halol-Godhra-Shamalaji section was assessed and current status of

Environment and Social Due Diligence Report L&T Halol Shamlaji Tollway Private Limited

availability of such clearances are given in Table 5. The Environment (Protection) Act, 1986 (EPA-1986) provides holistic framework for the protection and improvement to the environment. Under the EPA-1986, certain development projects have been identified requiring environmental clearance as defined under EIA notification dated 14th September 2006 including all its amendments.

Table 5: Status of Regulatory Clearances Obtained

Sl. No. Clearances Statutory Current Status of Clearance Required Authority 1 Environmental SEIAA, GoG GSRDC has been granted the Environmental Clearance Clearance on 25th September, 2008 by MoEF. The concessionaire sends regular compliance report to MoEF through GSRDC. During site visit, it was observed that major conditions are complied with. IIFCL has requested the developer to send copy of such compliance reports periodically to IIFCL. 2 Forest Forest and Approval for diversion of 15.70 Ha of reserve Clearance Environment forest land falling at Chainage 335/2 to 440/6 Dept., Govt. of received on 11.09.2009 Gujarat Compensatory Afforestation is required to be taken up by the forest department over 15.70 ha and on non- forest land {survey no. 168pt/30 , Village- Vidi Jambudiya, Ta. Wankaner, District-Rajkot at Ministry of the cost of project authority. This Non-forest land Environment will be declared as Reserve Forests. and Forests, Bhopal Approval for diversion of 7.67 Ha of Reserve Forest falling on chainage 0/0 to 10/2 at Godhra By-pass road and NH Bypass km 6/7 to 13/4 received on 13.04.2010. Compensatory Afforestation is required to be taken up by the forest department over 7.67 ha on non- forest land {survey no. 41/A/Bpt , Village- Kadana, Ta. Kadana, District-Panchmahal at the cost of project authority. This Non-forest land will be declared as Reserve Forests.

Approval for diversion of 0.55 Ha of Protected Forest at Godhra By-pass road received on 27.07.2009.

Approval for diversion of 31.323 Ha(Reserved Forest 1.40 Ha + Protected Forest 29.923 Ha) of Forest land in Sabarkantha District received on 19.09.2008. Compensatory Afforestation is required to be taken up by the forest department over 1.40 ha on non- forest land {survey no. 26 pt , Village- Fansarel, Ta. Malpur, District-Sabarkantha) and 60 Ha of degraded protected forest(roadside),at the cost of project authority within 2 years from 12

Environment and Social Due Diligence Report L&T Halol Shamlaji Tollway Private Limited

the transfer of forest land to the user agency. This Non-forest land of 1.40 Ha will be declared as Reserve Forests.

Approval for diversion of 86.60 Ha of Protected Forest falling on chainage 335/2 to 440/6 km received on 13.05.2009. Compensatory Afforestation is required to be taken up over 173.20 ha of degraded forest land {survey no. 169 pt ,162,181,182,184 & 157, Village-Dhamod, Ta. Lunawada, District- Panchmahal at the cost of user agency. 3 Consent and Gujarat State Consolidated Consents and authorisations has Authorisation Pollution been received from Gujarat State Pollution Control Board Control Board for construction work of the highway under section 25 of the water (prevention and control of pollution) Act, 1974, and under section 21 of Air (Prevention & Control of Pollution) Act, 1981 and Authorisation under rule 3(c) & 5(5) of the Hazardous Waste (Management, Handling and Transboundary Movement) Rules, 2008 notified under the E (P) Act -1986. These consents are taken for four camp offices at 1. Vejalpur (Consent Order no. AW-34351, date of issue: 11-09-2009,Validity: 19-08- 2014), 2. Lunavada(Consent Order no. AW-37048, date of issue: 07-04-2010,Validity: 21-01- 2015), 3. Shehra Consent Order no. AW-34342, date of issue: 09-09-2009,Validity: 19-08- 2014) and 4. Modasa Consent Order no. AW-40564, date of issue: 07-02-2011,Validity: 11-01- 2012) Sites which are valid for the production of :

 Asphalt: 18000 MT/Month  Concrete: 16000 MT/Month  Wet Mix Macadam: 20000 MT/Month

4 NOC Gujarat State Consent to Establish (NOC) under section 25 of Pollution the water (prevention and control of pollution) Act, Control Board 1974, and under section 21 of Air (Prevention & Control of Pollution) Act, 1981 has been obtained for running the crusher plant at Two locations,i.e. 1. Kheda (Consent Order no. GPCB/CE/SK-NOC- 553/ 15561,, date of issue: 10-09-2009,Validity: 10-09-2014), 2. Savali (Consent Order no. 35564, Validity: 16- 08-2014) sites 13

Environment and Social Due Diligence Report L&T Halol Shamlaji Tollway Private Limited

5. License/Permit Chief Permits/Licenses obtained from CCoE regarding Controller of fuel storage, Shotfirer’s permit ,Road Van for Explosives carrying the explosives and Explosives use for blasting work

18. Copies of all relevant clearance, approvals and permits are given in Appendix-II.

14. PPUUBBLLIIICC CCOONNSSUULLTTAATTIIIOONN AANNDD IIINNFFOORRMMAATTIIIOONN DDIIISSCCLLOOSSUURREE:::

19. Public hearings have been carried out during the month of February and March, 2008 at Modasa, Distt. Sabarkantha and Godhra, Distt. Panchmahal. An advertisement in English was published in the Western Times, dated 05-01-2008 and in Gujarati language,it was published in Gujarat Samachar, dated 05-01-2008, Mehsana-Sabarkantha Edition. For Godhra district public hearing, advertisement was published in the Western Times, dated 1/2/2008 and in Gujarati language,in the Loksatta, dated 02/02/2008 The district officials, representatives from local bodies, and large number of project affected persons have attended the meetings. The various points raised in the meeting mostly concentrated on provision of different facilities, preventive measures for safety of existing utilities and compensation criteria. All those attended the meetings are unanimously in favor of the project.

20. As reported in the EIA report, discussions were held with the stakeholders and their suggestions were incorporated in mitigation measures. Based upon the public consultation and understanding the possible impacts from the consultation, the matrix of adverse environmental Impacts due the project and preliminary mitigation measures has been prepared. The details of the issues raised and actions taken in this regards are given in Table 6 below: Table 6: Public Consultation Details

Sr. Key issues raised Addressal to the issues by Relevance & compliance of No. project authority issues in EIA 1 Access for school located in Provision of median opening, Incorporated in Highway other side of existing road at traffic/blinker signals and zebra Design Report. village Khandiya. crossings for safe access 2 Prevention of water logging Provision of road side drain Incorporated in Highway around houses and rain water harvesting Design Report and also In system EIA. 3 Road should be 10 to 15 mt. Carriage way of the proposed Incorporated in Highway away from nearby houses / road will be at least 10 m away Design Report. habitation from the houses

4 Widening of road on both To avoid increase in undue Incorporated in Highway side Instead of only on one expenditure, the road will be Design Report. side of existing road widened as per the requirement.

Environment and Social Due Diligence Report L&T Halol Shamlaji Tollway Private Limited

5 Since road is passing near A Four lane has been Incorporated in Highway a temple, chances of temple completed near Temple and Design Report. damage near village foot path with paver blocks has . Chhabanpur. been provided for the pedestrians so there is no damage to the temple.

6 Shifting of Bypass more The alignment of the road is Included in Highway Design than 0.5 km away from fixed with due technical Report. village Chhabanpur. checking, hence no change is possible. 7 Measures for accident Provision of Ambulance, Already included in EIA. prevention for chemical Doctors, Cranes, Patrolling carrying vehicles vehicles at control room 8 Alternative arrangement for Compensation given as per Included in EIA. house coming under provisions of Land Acquisition acquisition. Act 1894. 9 Residential and Agriculture Appropriate measure will be Design is such to improve area affected by incorporated in design report upon existing drainage accumulation of rain water condition. Localised ponding near village Meiji na will be controlled at pahadia. construction stage. 10 Provision of more culverts Appropriate measure will be to overcome the water incorporated in design report logging Issue near village by consulting local people. Khodampa. 11 Part of house comes under Compensation given as per Included In EIA. land acquisition. provisions of Land Acquisition Act 1894. 12 Shops covered In road Compensation given as per Included in EIA. alignment in front and provisions of Land Acquisition electric lines passes on Act 1894 rear. 13 Steps to be taken by Water sprinkling is being done Already proposed In EIA. contractors for controlling to suppress dusting air pollution during construction.

14 Steps to be taken by Due care has been taken to Included in EIA. contractors for cleaning of prevent chocking of drains chocked drains during during construction construction. 15 Use of fly ash for the Soil will be brought from Already proposed in EIA. construction and source of already open borrow land. Fly soil for the construction. ash notification has been adhered for use of fly ash from Wanakbori Thermal Power Station, Bala Sinor, Kheda Distt.

Environment and Social Due Diligence Report L&T Halol Shamlaji Tollway Private Limited

16 Protecting water supply line Due care has been taken to Incorporated in Highway during construction protect water supply line Design Report

17 Exemption of toll tax for Exemption for government As per Government Toll government vehicles. vehicles as per the Policy. government toll policy 18 Installation of bitumen plant Such plants are to be installed Already proposed in ER. in waste land. after obtaining necessary permission from Gujarat State Pollution Control Board. 19 Shifting in proposed As new alignment is within Under consideration of alignment to one side to ROW and as per the land GSRDC. facilitate farming on other given by GSRDC. The new side alignment has been designed as per the road geometry.

Source: EIA Report

21. Consultation during implementation: Since commencement of work in 2009 public participation has been given due importance. Some of the construction activities which were not included in the concessioning agreement but adopted only after public demand are given in table 7.

Table 7: Public Consultation during Implementation Stage

Sl. No. Chainage Demand Measures taken by concessionaire 1 345 km Villagers of Madhwas village Approach road has been provided and requested for approach road for construction of approach connecting their village and road,discarded material has been state highway utilized generated from removal of existing pavement 2 345 km Problem of rain water Drainage pipe has been provided for accumulation near village proper drainage of rain water school 3 354+178 Villagers at Dallol village Provision for School underpass has demanded for construction of been considered which is under School underpass construction presently Source: Discussion with the concessionaire

Public Hearing Proceedings are attached as Appendix- III.

15. AALLTTEERRNNAATTIIIVVEE AANNAALLYYSSIIISS:::

22. The likely changes due to the proposed improvement section have also been analyzed considering with and without project scenarios. The alternative assessment is summarized here.

Environment and Social Due Diligence Report L&T Halol Shamlaji Tollway Private Limited

23. “No Project Scenario”: The capacity of the present highway is insufficient for handling such volume of traffic and over time, significant impacts would result to traffic movements and safety as a result of congestion. The existing highway has continuous ribbon developments and the traffic flow is seriously impacted by several conflicts between the local traffic and the through traffic. The population growth, increase in traffic volumes and the economic development along the corridor would continue to occur and will exacerbate the already critical situation. The existing unsafe conditions and the adverse environmental consequences, in terms of environmental quality along the highway, would further deteriorate in the absence of the proposed improvements. Therefore, the no-action alternative is neither reasonable nor prudent, as it would amount to failure to initiate any further improvements and impede economic development.

24. “With Project Scenario”: The option “With Project” situation would have possible benefits including improvement in highway connectivity to the Northern parts of India including Rajasthan, New Delhi and in the south, towards Maharashtra including Mumbai. It will provide better road infrastructure to industrial complexes. This road widening project will facilitate traffic movement between rural areas to the National and State Highways networks and will also improve, maintain and augment the existing National and State Highways network. The project will help in implementation of road safety measures and environmental management and will improve socio-economic conditions of this developing region. The “With Project” scenario, has been assessed to be economically viable and will alleviate the existing conditions.

25. The analysis shows that positive/beneficial impacts of “With Project” scenario will outweigh those of the “Without Project” scenario, which will result in deterioration of the present environment, and quality of life. Hence., “With Project” scenario with few reversible impacts is considered a more acceptable option than the “Without Project” scenario.

16. IIIMMPPLLEEMMEENNTTAATTIIIOONN OOFF EEMMPP:::

26. As part of the project , detailed EMP measures has been undertaken including a budget for implementing the same. The EMP budget exclusively includes the following measures:  Environmental Monitoring and Training;  Road side Tree plantation and maintenance;  Landscaping;  Local structures enhancement measures  Quarry area restoration  Water sprinkling during construction;  Sanitation facilities and Drinking water facilities in the construction camps;

16.1. CONCESSION AGREEMENT AND EPC CONTRACT :

Environment and Social Due Diligence Report L&T Halol Shamlaji Tollway Private Limited

27. As per article 8 under obligations of Concessionaire in concession agreement, the concessionaire shall comply with all applicable laws and applicable permits in the performance of its obligations under this agreement. Environment and Safety related clauses of concession agreement are given in Appendix-IV. As part of the EPC contract between the concessionaire and the contractor the Safety, Environment and Labour related measures are described as per article 16.The clause specifically mentions that EPC contractor shall comply with all environmental requirements stipulated in the project requirements and with all environmental laws and regulations having application of the project. In the event of conflict or inconsistency among the standards stipulated in applicable laws and regulations and those stipulated in this agreement, the more stringent of these standards shall apply.EPC Contractor has appointed Environmental Compliance officer and Site Safety Officer to take care of the environmental and safety issues pertaining to the construction activities. There will be approved site safety plan which will be implemented for good industry practices during construction phase. Environment and Safety related clauses of EPC Contract are given in Appendix-V.

16.2. ENVIRONMENT MANAGEMENT PLAN (EMP):

28. The environmental management plan as appeared in EIA report is given in Appendix-I, which briefly describes the proposed mitigation measures that would be adopted during the construction and operation stages of the project.

16.2.1. Contractors HSE Plan: 29. The EPC contractor, i.e. L&T ECC has developed Health, Safety and Environment (HSE) Plan for managing the HSE issues at construction sites for Halol Godhra Shamlaji project. This document works as a guidance manual for implementing good industry practices w.r.t. environmental management, worker safety and accident/hazard prevention at work site. L&T ECC has adopted HSE Policy which is given under section 4 and organization structure for the contractor is given as Annexure C in the HSE Plan attached as Annexure-VI.

16.2.2. EMP Implementation Matrix: 30. As part of project review and site visit, effort has been made to track the present status of implementation of the EMP. The status of the EMP implementation report is summarized in Table 8 as given in the monthly progress report, May 2011. Project Developer has provided Implemented environmental management plan matrix which is attached as Annexure-VII. Most of the activities are in compliance with the agreed EMP and compliance is being done continuously.

Environment and Social Due Diligence Report L&T Halol Shamlaji Tollway Private Limited

Table 8: EMP Implementation Matrix

Environment and Social Due Diligence Report L&T Halol Shamlaji Tollway Private Limited

16.2.3. Environmental Monitoring:

31. A comprehensive environment monitoring system is in place to assess the present environment scenario and to take the preventive measures. This monitoring is essential to judge the effectiveness of mitigation measures planned during construction. The environmental monitoring is primarily the responsibility of the EPC contractor. The Environmental Monitoring has been outsourced to an Environmental Laboratory namely M/s Metro Enviro-Chem Associates. The copy of Environmental Monitoring report is enclosed as Appendix-VIII. Frequency of air pollution monitoring will be done every quarter, water quality in non-monsoon season once a year and noise levels thrice a year. As per the report attached levels of ambient air quality are within the permissible limits at most of the locations. The measured results of noise levels are within the permissible limits of Noise quality as per the Indian Standards.

16.2.4. Overall Implementation Framework for Environment Management Plan:

32. The project institutional framework as given in the project EMP indicates that the overall implementation responsibility of the EMP lies with the Project Implementation Unit (PIU); Project Director at PIU is supported by the Environment Officer of GSRDC. GSRDC has appointed the safety consultant for carrying out safety audit of the project highway in accordance with the safety requirement and shall take all other actions necessary for securing compliance with safety requirements. During execution of works, the L&T HSTPL & EPC contractor have taken reasonable steps to protect the environment on and off the site and avoid damage or nuisance to persons or to property of the public or other resulting from pollution, noise or other causes arising as a consequence of their method of operation.HSE Plan has also been submitted by EPC Contractor. From the concessionaire end, the Chief Project Manager through his Environmental Officer and construction project managers of the contractor take care of the implementation of the Environment, Safety and labor related aspects. The monitoring of environmental aspects being implemented by the contractor is regularly monitored by the PMC team of concessionaire through its Environmental Specialist who visits the site to monitor the compliance of EMP implementation. Six-monthly compliance report as per the conditions of Environment Clearance letter is submitted to GSRDC by L&T HGSTPL at an interval of six months attached as Appendix-IX. Additionally, IIFCL has requested the project developer to update the EMP matrix on quarterly basis. The institutional arrangement made for the project implementation is given in figure 1.

Environment and Social Due Diligence Report L&T Halol Shamlaji Tollway Private Limited

Figure 1: Overall Implementation Framework for EMP Implementation

MoEF, Project Director

Regional Office (GSRDC) Chief Project Manager

(Concessionaire)

Project Manager

Team Leader (Contractor)

(Independent Engineer / State Pollution Consultant) Control Board

Environmental Environmental Officer Officer (Concessionaire) (SHAI)

Environmental Expert Environmental Officer (Independent Engineer / Consultant) (Contractor)

Direct Indirect

Environment and Social Due Diligence Report L&T Halol Shamlaji Tollway Private Limited

17. SSIIITTEE VVIIISSIIITT:::

33. A site visit was undertaken by IIFCL’s Environmental and Social Safeguard specialists during 23rd-24th of May 2011 to review the implementation of the project environmental safeguards. During the site visit it has been observed that:

 Regular water sprinkling is being done in high dust generation areas like road construction sites and crushing operation areas.  Fly ash based concrete is being used in every grade of concrete. Fly ash has been arranged from Wankbori Thermal Power Station,Bala Sinor,Distt. Kheda. Approximate quantity of 8276 MT of fly ash has been used in project construction till date.  Road side and median drains are being provided throughout the project highway. Side pavement works have also been undertaken.  Median plantation works have been undertaken at some of the locations and tree plantation has also been done at construction site offices.  Tree cutting for forest areas falling under RoW expansion has been completed.  Topsoil stockpiling has also been practiced during soil excavation activities for this project.  Proper traffic diversions and appropriate signages are being provided at the site to prevent any disruption to the highway traffic. Manpower is also deployed at diversion locations to ensure safety to prevent any traffic congestion..  Workers are being provided with the required safety gears to be worn during execution of work. Necessary barricading and safety precautions for deep excavations are also being ensured. Work safety signages have been provided throughout the project highway and also at Construction site offices.  Adequate number of vehicular, pedestrian, school and cattle underpasses has been provided at strategic locations incorporating the views of local people. In section-3 at Chainage 434.57 km, near reserve forest area, where diversion of forest land is involved, cattle underpass has been provided to facilitate the movement of wild animals in this area. School underpass is under construction at Dallol Village, chainage 354.178 km.  The construction camps are provided with adequate drinking water, canteen and sanitation facilities. Provision of soak pits of adequate capacity and septic tanks have been made. No labour camps are provided in this project. Housing allowances are given to labourers for local stay in nearby areas.

34. The site visit photographs are given in details of the some of the environmental safeguard measures and progress of construction work details are given in Photoplate-I. 18. CCOONNCCLLUUSSIIIOONN AANNDD RREECCOOMMMMEENNDDAATTIIIOONN:::

35. Based upon the available documents and site visit, it is concluded that the concessionaire through their EPC contractor has undertaken adequate environmental safeguard measures. The conclusions for the sub-project is given below: 24

Environment and Social Due Diligence Report L&T Halol Shamlaji Tollway Private Limited

 The sub-project has been prepared by GSRDC as per its own funding requirement and not anticipation to ADB operation.

 The widening and up gradation of this SH section has no major significant environmental impact.

 The sub project may also have a positive GHG emission reduction due to less fuel consumption for the same traffic density.

 The sub-project has the required national and local level environmental clearances as well as permits and approvals for project implementation as given in Appendix-II.

 Concessionaire has confirmed that continued compliance has been carried out with statutory environmental regulations by the facility owner and the civil works contractor;  The institutional arrangement available for the implementation of EMP appears to be adequate as there is a sufficient number of staff available for implementing and monitoring the EMP implementation.

 During site visit and discussion with the project developer, the implementation of EMP and environmental monitoring system were found adequate.

 Periodical environmental management and monitoring during the project implementation is being carried out by the concessionaire.

 Based on the site visits and due diligence findings,it can be deduced that the sub- project has no significant environmental safeguard issue.

 The Sub-project, therefore does not appear to involve any kind of reputational risk to ADB funding on environmental safeguards and recommended for funding under the proposed project.

Environment and Social Due Diligence Report L&T Halol Shamlaji Tollway Private Limited

DDUUEE DDIIILLIIIGGEENNCCEE OONN SSOOCCIIIAALL SSAAFFEEGGUUAARRDDSS

Environment and Social Due Diligence Report L&T Halol Shamlaji Tollway Private Limited

19. DDUUEE DDIIILLIIIGGEENNCCEE OOFF SSOOCCIIIAALL IIIMMPPAACCTTSS:::

36. The Social safeguard due diligence of the SH-5 section between Halol-Godhra-Shamalji sections has been assessed by reviewing the socio-economic study included in the Environment Impact Assessment (EIA) report, prepared as part of the project preparation, supplemented by field visit and information provided by the concessionaire.

20. AALLTTEERRNNAATTIIIVVEE AANNAALLYYSSIIISS:::

37. The likely changes due to the proposed improvement section have also been analyzed considering with and without project scenarios. The alternative assessment is summarized here.

38. “No Project Scenario”: The capacity of the present highway is insufficient for handling such volume of traffic and over time, significant impacts would result to traffic movements and safety as a result of congestion. The existing highway has continuous ribbon developments and the traffic flow is seriously impacted by several conflicts between the local traffic and the through traffic. The population growth, increase in traffic volumes and the economic development along the corridor would continue to occur and will exacerbate the already critical situation. The existing unsafe conditions and the adverse environmental consequences, in terms of environmental quality along the highway, would further deteriorate in the absence of the proposed improvements. Therefore, the no-action alternative is neither reasonable nor prudent, as it would amount to failure to initiate any further improvements and impede economic development.

39. “With Project Scenario”: The option “With Project” situation would have possible benefits including improvement in highway connectivity to the Northern parts of India including Rajasthan, New Delhi and in the south, towards Maharashtra including Mumbai. It will provide better road infrastructure to industrial complexes. This road widening project will facilitate traffic movement between rural areas to the National and State Highways networks and will also improve, maintain and augment the existing National and State Highways network. The project will help in implementation of road safety measures and environmental management and will improve socio-economic conditions of this developing region. The “With Project” scenario, has been assessed to be economically viable and will alleviate the existing conditions.

40. The analysis shows that positive/beneficial impacts of “With Project” scenario will outweigh those of the “Without Project” scenario, which will result in deterioration of the present environment, and quality of life. Hence, “With Project” scenario with few reversible impacts is considered a more acceptable option than the “Without Project” scenario.

Environment and Social Due Diligence Report L&T Halol Shamlaji Tollway Private Limited

21. MMIIINNIIIMMIIIZZAATTIIIOONN OOFF SSOOCCIIIAALL IIIMMPPAACCTTSS:::

41. During the project planning stage efforts has been taken to minimize the social impacts due to the project. As detailed in the EIA report, provision of New Godhra bypasse has been considered to minimize the social impact of the project. The project road is passing through Godhra city which is a heavily densed area with a mixed land use of residential, commercial, industrial and institutional. The road is having sharp curves dotted with ribbon development on both the sides. Further, religious structures and other structures at the existing road edge. Thus, it was analysed that though the widening of the existing road is technically possible, but it is not socio-economically feasible. To avoid any adverse impact, a new alignment has been finalized bypassing the Godhra city.

42. The NH-59 also passes through Godhra city from west to east. There is already a proposal to provide a bypass on NH-59 passing through northern side of the Godhra city. The new bypass for the project road is finalized in such a way that part of finalized NH-59 bypass can be used for proposed bypass.

22. PPUUBBLLIIICC CCOONNSSUULLTTAATTIIIOONN:::

43. Public consultation has been carried out during the project planning and implementation stage. Public opinion and their suggestions have been considered during the design finalization. In this regard, public hearing was conducted in Godhra City in Panchmahal district and Modasa city in Sabrakantha district of Gujarat. The various issues as raised by the local people have been summarized in the following table 9. The proceedings of the public hearing is attached as Appendix III.

Table 9: Issues raised during public consultation and their addressal

Environment and Social Due Diligence Report L&T Halol Shamlaji Tollway Private Limited

5 Since road is passing near Proper care will be taken as far A Four lane has been a temple, chances of temple as possible in order to not completed near Temple and damage near village disturb the temple. foot path with paver blocks Chhabanpur. has been provided for the pedestrian so there is no damage to the temple..

11 Part of house comes under Compensation as per Included In EIA. land acquisition. provisions of Land Acquisition Act 1894.

12 Shops covered In road Compensation as per Included in EIA. alignment in front and provisions of Land Acquisition electric lines passes on Act 1894 rear.

13 Steps to be taken by Water sprinkling is being done Already proposed In EIA. contractors for controlling to suppress dusting air pollution during construction. 14 Steps to be taken by Due care has been taken to Included in EIA. contractors for cleaning of prevent chocking of drains chocked drains during during construction construction. 15 Use of fly ash for the Soil will be brought from Already proposed in EIA. construction and source of already open borrow land. Fly soil for the construction. ash notification has been adhered for use of fly ash from Wanakbori Thermal Power Station, Bala Sinor, Kheda Distt.

Environment and Social Due Diligence Report L&T Halol Shamlaji Tollway Private Limited

16 Protecting water supply line Due care has been taken to Incorporated in Highway during construction protect water supply line Design Report

17 Exemption of toll tax for Exemption for government As per Government Toll government vehicles. vehicles as per the Policy. government toll policy 18 Installation of bitumen plant Such plants are to be installed Crusher Plants are installed in waste land. after obtaining necessary only after obtaining NOC permission from Gujarat State from the Pollution control Pollution Control Board. board 19 Shifting in proposed Matter is under consideration As new alignment is within alignment to one side to for probable correction In road ROW and as per the land facilitate farming on other geometry. given by GSRDC, the new side alignment has been designed as per the road geometry. Source: EIA Report

44. Consultation during implementation: Since commencement of work in 2009 public participation has been given due importance. Some of the construction activities which were not included in the concessioning agreement but adopted only after public demand are given in table 10.

Table 10: Public Consultation during Implementation Stage

Sl. Chainage Demand Measures taken by No. concessionaire 1 345.000 km Villagers of Madhwas village Approach road has been provided requested for approach road and and discarded material connecting their village and state generated from removal of existing highway pavement has been utilized for construction of this approach road 2 345.000 km Problem of rain water Drainage pipe has been provided accumulation near village school for proper drainage of rain water 3 354.178 km Villagers at Dallol village Provision for School underpass has demanded for construction of been considered which is under School underpass construction presently

Source: Discussion with concessionaire

23. LLAANNDD AACCQQUUIIISSIIITTIIIOONN IIINN TTHHEE SSUUBB---PPRROOJJEECCTT:::

45. The total length of the project road is 173.057 Km and the existing ROW of the project road is 30 m. A uniform ROW of 60 m width is proposed in the entire project length including forest land and village stretches except at few urban locations where there is major built-up area along the road. At such locations, the proposed ROW is confined to within 45 m. The total land to be acquired for the project road is 232.7845 Ha. The land acquisition has been carried 30

Environment and Social Due Diligence Report L&T Halol Shamlaji Tollway Private Limited

out by GSRDC after publishing Gazette notification for the entire stretch as per Land Acquisition Act 1894. The type of ownership of land involved in land acquisition is given in Table 11: Table 11: Land acquisition for the sub-project

Land in hectare Sl. No. Type ownership of land (ha.) 1 Forest Land

a. Reserve Forest 24.77

b. Protected Forest 117.073

2 Government Land 22.995 3 Private Land 68.4965 Total 233.3345 Source: Information from Concessionaire and Forest approvals obtained

24. RREESSEETTTTLLEEMMEENNTT IIIMMPPAACCTT IIINN TTHHEE SSUUBB---PPRROOJJEECCTT:::

20.1 Impact on private structure

46. As informed by the concessionaire, 359 families are being affected due to the widening of the project road. Out of these affected families, 251 are losing their residential structures and 47 are losing their commercial structures. The details of the affected families as per the type of structure is given in table 12 below:

Table 12: Affected families as per the type of structure

Sl. No. Type of structure Number of affected families 1 Residential structure 251 2 Commercial structure 47 3 Residential cum commercial structure 0 4 Kiosks/ Khokha 61 Total 359 Source: Information from Concessionaire

47. As informed by the Concessionaire, the project does not involve any physical resettlement of affected families. Thus, there is no outstanding resettlement issue.

20.2 Impact on Religious properties

48. As documented in EIA report, 23 religious structures were likely to be impacted due to the widening of the project road. However, as informed by the concessionaire, only 9 temples

Environment and Social Due Diligence Report L&T Halol Shamlaji Tollway Private Limited

including one temple gate were required to be relocated. Relocation of the religious structures has been carried out after consultation with the local people. Few photographs of the relocated religious structures have been attached as Photoplate II. 25. CCOOMMPPEENNSSAATTIIIOONN AANNDD EENNTTIIITTLLEEMMEENNTT:::

49. The land acquisition has been done by GSRDC and the compensation for the land has been paid by them. The compensation for the loss of properties has been decided by Competent Authority of GSRDC. The procedure of land acquisition and the payment of compensation as informed by the concessionaire is attached as Appendix X.

50. As informed by the Concessionaire, compensation amount has already been declared by GSRDC and the cheques have already been issued but not all the affected families have collected the cheques because of their own delays. And no grievances have been received from these affected families.

26. IIINNCCOOMMEE RREESSTTOORRAATTIIIOONN MMAAEESSUURREESS:::

51. As part of income restoration measures adopted by the concessionaire, they are employing local labour for various construction activities. As informed by the concessionaire, till date they have employed 712 local labours which is 43% of the total labour employed.

27. CCOOMMMMUUNNIIITTYY DDEEVVEELLOOPPMMEENNTT AACCTTIIIVVIIITTIIIEESS:::

52. As part of Community Development activities, the concessionaire has been doing various activities for the local people as briefed below:  Concessionaire has organized many health checkup camps for the local people.  Distributed note-books along with stationeries to 580 students from 13 different schools in Lunawada Taluka  Donated – Fans and Tub lights to newly constructed wing of ‘Vradhhashram (old age home)’ at Godhra 53. Photographs of the various CSR activities as undertaken by the concessionaire is attached as Photoplate III.

28. SSIIITTEE VVIIISSIIITT:::

54. A site visit was being undertaken by IIFCL’s Environmental and Social Safeguard specialist during 23rd-24th of May 2011 to review the implementation of the environment and social safeguards. The observations of the site visit is briefed below:  As informed by the concessionaire, local labour is being employed for unskilled activities during the construction stage.  The developer has relocated the affected temples along the project road. 32

Environment and Social Due Diligence Report L&T Halol Shamlaji Tollway Private Limited

 Proper drainage facilities have been provided along the road which has been an issue raised in Public hearing  The concessionaire has provided drinking water tank along the project road which is accessed by the nearby villages. Apart from this, they have also provided an approach road and discarded material generated from removal of existing pavement has been utilized for construction of this approach road.  An underpass has also been provided by the concessionaire near a school on the demand of the local people. 29. CCOONNCCLLUUSSIIIOONN AANNDD RREECCOOMMMMEENNDDAATTIIIOONNSS:::

55. Based upon the available documents and site visits it is concluded that the concessionaire has undertaken adequate social safeguard measures for the implementation of the project. The conclusions for the sub-project is given below:

 The sub-project has been prepared by GSRDC as per its own funding requirement and not anticipation to ADB operation.

 The land acquisition has been done by GSRDC and the compensation has been paid to the affected families before handing over the land to the concessionaire.

 Adequate measures have been adopted for the minimization of social impacts during the planning stage of the sub-project. The design has been finalized with due consideration so that the alignment do not pass through any congested settlement area. The congested settlement area has been avoided by providing bypasses and provision of new alignment, realignment and geometrical improvement of the project road.

 Local people’s view have been given due consideration during the implementation of the project. The affected religious properties have been relocated by the concessionaire after consultation with the local people.

 The Current Sub-project, therefore does not appears to involve any kind of reputational risk to ADB on social safeguards.