Initial Environmental Examination IND: Inclusive, Resilient And

Initial Environmental Examination

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

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

Prepared by the Tamil Nadu Slum Clearance Board for the Asian Development Bank. CURRENCY EQUIVALENTS (as of 1 June 2020) Currency Unit – Indian rupees (₹) ₹1.00 – $0.015 $1.00 = ₹72.18

ABBREVIATIONS

ADB – Asian Development Bank ASI – Archaeological Survey of India CPCB – Central Pollution Control Board CtE – Consent to Establish CtO – Consent to Operate EA – Executing Agency EAC – Expert Appraisal Committee EARF – Environmental Assessment and Review Framework EC – Environmental Clearance EHS – Environmental Health and Safety EIA – Environmental Impact Assessment EMP – Environmental Management Plan ESS – Environmental and Social Safeguards EWS – Economically Weaker Section GOI – Government of India GoTN – Government of Tamil Nadu GHG – Greenhouse Gases GRM – Grievance Redress Mechanism IA – Implementing Agency IEE – Initial Environmental Examination MOEFCC – Ministry of Environment, Forests and Climate Change NOC – No Objection Certificate PMU – Project Management Unit PCR – Physical Cultural Resources PID – Project Implementation Division PPE – Personal Protective Equipment REA – Rapid Environmental Assessment RF – Resettlement Framework ROW – right-of-way SEIAA – State Environmental Impact Assessment Authority SPS – Safeguard Policy Statement STP – sewage treatment plant TNPCB – Tamil Nadu Pollution Control Board TNSCB – Tamil Nadu Slum Clearance Board ULB – urban local body WHO – World Health Organization

WEIGHTS AND MEASURES

C – Degree Celsius km – kilometer LPCD – liters per capita per day m – meter Mgd – Million gallons per day MLD – Million Litres per day mm – millimeter nos. – numbers km2 – square kilometer dBA – A-weighted decibels LAeq – Equivalent Continuous Sound Pressure Level μg/m3 – micrograms per cubic meter KLD – kiloliters per day

NOTE

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

This initial environmental examination is a document of the borrower. The views expressed herein do not necessarily represent those of ADB's Board of Directors, Management, or staff, and may be preliminary in nature. Your attention is directed to the “terms of use” section on ADB’s website.

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

CONTENTS

EXECUTIVE SUMMARY ...... i I. INTRODUCTION ...... 1 A. Background ...... 1 B. Subproject Scope and Location ...... 2 C. Purpose/ Objectives of IEE ...... 7 D. Report Structure ...... 8 II. POLICIES, LEGAL AND INSTITUTIONAL FRAMEWORK ...... 9 A. ADB Safeguard Policy Statement (2009) ...... 9 B. National and State Laws ...... 10 C. Applicable International Standards and Best Practices ...... 17 D. International Treaties/Conventions/Declarations on Environment Management .... 22 III. DESCRIPTION OF THE PROJECT ...... 24 A. Subproject Overview ...... 24 B. Proposed Subproject Interventions at the Resettlement Site...... 26 C. Proposed Subproject Interventions at the Encroachment Sites Identified for Relocation ...... 40 D. Existing Condition of the Encroachment Sites Identified for Relocation ...... 40 E. Project Proposal for the Relocated Sites ...... 45 IV. DESCRIPTION OF THE ENVIRONMENT (BASELINE DATA) ...... 47 A. Area of Impact ...... 47 B. Methodology used for Environment Baseline Study ...... 47 C. Physical Environment ...... 47 D. Biological Environment ...... 56 E. Social Environment ...... 58 V. ANALYSIS OF ALTERNATIVES ...... 61 VI. ANTICIPATED ENVIRONMENTAL IMPACTS AND MITIGATION MEASURES...... 66 A. Assessment of Environmental Impacts ...... 67 B. Pre-construction Impacts and Mitigation Measures ...... 67 C. Construction Impacts and Mitigation Measures ...... 70 D. Post-Construction Impacts and Mitigation Measures ...... 74 VII. INFORMATION DISCLOSURE, CONSULTATION AND PARTICIPATION ...... 77 A. Consultation and Participation ...... 77 B. Public Consultation ...... 77 C. Information Disclosure and Future Consultations ...... 80 VIII. GRIEVANCE REDRESS MECHANISM ...... 81 IX. ENVIRONMENTAL MANAGEMENT PLAN ...... 85 A. Environmental Management Plan ...... 85 B. Implementation Arrangements ...... 141 C. Monitoring and Reporting ...... 148 D. EMP Implementation Cost ...... 149 X. CONCLUSION AND RECOMMENDATIONS ...... 152

LIST OF TABLES

Table 1: Details of Subproject Scope Table 2: Encroachment sites Identified for Relocation Table 3: Environmental Guidelines for Subproject Selection under Output 1 Table 4: Environmental Regulatory Compliance (National and State Laws) Table 5: Clearances and Permissions Required by the PMU for Project Construction Table 6: Clearances and Permissions Required by the Contractor for Project Construction Table 7: National Ambient Air Quality Standards and WHO Guidelines Table 8: National Noise Standards and WHO Guidelines Table 9: National Drinking Water Quality Standards and WHO Guidelines Table 10: Standards for Sludge Reuse as Manure Table 11: International Treaties/ Conventions/ Declarations on Environment Table 12: Salient Features of the Reddiyarpatti Resettlement Site Table 13: Plinth Area Details of Proposed Residential Units at the Resettlement Site Table 14: Overall Built-up Area Details of the Buildings at the Resettlement Site Table 15: Built-up Area Details for ADB Portion Table 16: Site Infrastructure Details Table 17: Subproject Interventions at the Resettlement Site Table 18: Overall Power Requirement at the Resettlement Site Table 19: Power Requirement at the Resettlement Site (ADB Portion) Table 20: Water Requirement at the Resettlement Site Table 21: Estimated Rainwater Table 22: Green Area Details Table 23: Solid Waste Generation at the Resettlement Site Table 24: Subproject Interventions Table 25: Existing Condition of the Encroachment Sites Identified for Relocation Table 26: Rainfall information for Tirunelveli District Table 27: Central Pollution Control Board Table 28: Tamirabarani River Water Quality (annual average values), 2014-2015 Table 29: Groundwater Quality in Tirunelveli, 2014 Table 30: Ambient Air Quality in Tirunelveli Table 31: Ambient Noise Levels in Tirunelveli Table 32: MSME Industrial Units in Tirunelveli City – Zone wise Table 33: Information on the Archaeological Monuments Table 34: DWATS Salient Features Table 35: Alternative Approach in Building Plan Table 36: Outcome of the Analysis of Alternatives Table 37: Meetings/Discussions between various stake holders Table 38: Environmental Management Plan for Construction Site - Reddiyarpatti, Tirunelveli District Table 39: Environmental Management Plan for Operation and Maintenance - Reddiyarpatti, Tirunelveli District Table 40: Environmental Management Plan for Building Demolition Works (Encroachment Sites identified for Relocation) Table 41: Environmental Management Plan for Water body Restoration Works Table 42: Pre-construction & Construction Stage Environmental Monitoring Plan Table 43: Operation Stage Environmental Monitoring Plan

Table 44: Institutional Roles and Responsibilities for Safeguards Implementation Table 45: Outline Capacity Building Program on EMP Implementation Table 46: Indicative EMP Budget

LIST OF FIGURES

Figure 1: Map Showing Sites Chosen for Relocation and Resettlement Figure 2: Map Showing Existing Public Amenities around the Resettlement Site Figure 3: Relocation sites within 10km radius from Reddiyarpatti Figure 4: Photograph of the Resettlement Site Figure 5: Master Plan of the Reddiyarpatti (Resettlement Area) Figure 6: Proposed Sewer Line (ADB Portion) Figure 7: Proposed Water Supply Line (ADB Portion) Figure 8: Proposed Storm Water Drain (ADB Portion) Figure 9: Proposed Green Belt Area Figure 10: STP Process Flow Diagram and SBR Structure – Water Balance for Reddiyarpatti Resettlement Site Figure 11: Rainwater Harvesting Structure Figure 12: Layout for Micro Composting Center Figure 13: Enlarged View of the STP location and Micro Composting Centre Figure 14: Typical Cross section for Approach Road and Internal Roads Figure 15: Construction Schedule Bar Chart Figure 16: Reddiyarpatti (Project area ) Location Figure 17: Elevation profile for the Resettlement site at Reddiyarpatti Figure 18: Annual Rainfall Distribution in the Reddiyarpatti (Project Area) Figure 19: Seismic Map for Reddiyarpatti Project Area Figure 20: Landuse Pattern (Google earth image and Bhuvan Landuse map) of the Subproject Area Figure 21: Groundwater Prospects for Reddiyarpatti Subproject Area Figure 22: Location of Vallanadu Blackbuck Wildlife Sanctuary Figure 23: Location of Koonthankulam Wildlife Sanctuary Figure 24: National Monuments surrounding the Project Area Figure 25: Snap Shots from the FGDs conducted at Water Body Encroachment sites Figure 26: Grievance Redress Process

APPENDICES

Appendix 1 : Confirmation letter - Encroachments in the Water body Appendix 2 : Land Transfer certificate Appendix 3 : Land Use Classification Government Order Appendix 4 : Rapid Environmental Assessment (REA) Checklist Appendix 5 : Environmental Clearance from SEIAA Appendix 6 : Salient Features of Major Labor Laws Applicable to Establishments Engaged in Construction of Civil Works Appendix 7 : Confirmation letter from Tamil Nadu Electricity Board Appendix 8 : Certificate Indicating Resettlement site is not Vulnerable for Flooding Appendix 9 : Acceptance Letter for Collection of Municipal Solid Waste

Appendix 10 : Permission letter for Discharge of Treated Sewage Water Appendix 11 : Tamil Nadu Water Supply and Drainage Board (TWAD) Acceptance/ Acknowledge for the Supply of Water to Reddiarpatti Resettlement Site Appendix 12 : Confirmation Letter for Collection and Disposal of Sludge Generated from the STP installed at Reddiarpatti Resettlement Site Appendix 13 : Compliance matrix for the Environmental Clearance Conditions Appendix 14 : Groundwater Quality Test Result for Reddiarpatti Resettlement Site Appendix 15 : IBAT Study for the Subproject Area Appendix 16 : Health and Safety Plan/ Response and Measures for COVID 19 Appendix 17 : Sample Grievance Form Appendix 18 : Sample Environmental Site Inspection Report Appendix 19 : Quarterly Environmental Monitoring Template Appendix 20 : Outline of Daily Monitoring Sheet for Contractors Appendix 21 : Source sustainability study for supply of water to the Reddiarpatti Resettlement Site

EXECUTIVE SUMMARY

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

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

This subproject proposed under Output 1 is for (i) the construction of 2,124 residential housing units (which includes 876 residential units proposed under ADB funding and 1,248 residential units proposed under government of Tamil Nadu funding) and associated facilities at the resettlement site at Reddiarpatti in Tirunelveli district; (ii) demolition of 807 structures located in 9 encroachment sites identified for relocation to Reddiarpatti; and (iii) restoration of 9 water bodies. It is estimated that 807 households will be relocated to Reddiarpatti site.

Executing and implementing agencies. The Government of Tamil Nadu through the Housing and Urban Development Department (HUDD) will be the executing agency (EA) and responsible for overall project management and compliance with loan assurances. The Tamil Nadu Slum Clearance Board (TNSCB) will be the Implementing Agency for Output 1. TNSCB will also be responsible for the management, coordination and execution of all subproject activities funded under IRSHUPSP. The TNSCB has set up a Project Management Unit (PMU) that will be responsible for overall supervision and coordination during subproject implementation. The PMU will be supported by Project Implementation Circle located at Salem and three Project Implementation Divisions (PIDs) are located at Madurai, Salem and Villupuram and they will be responsible for day-to-day activity and compliance with safeguards during project implementation. The PMU will be headed by Joint Managing Director/ Project Director and will be assisted by the Chief Engineer and the Superintending Engineer. They will be supported by technical, financial, safeguards and administrative staff. It is proposed to have 3 PIDs under the PMU. An Executive Engineer will head each PID. PIDs will be responsible for the implementation, management and monitoring of the subprojects.

Subproject Scope: The Reddiarpatti subproject scope of work includes (i) Construction of 2,124 residential housing units (which includes 876 residential units proposed under ADB funding and 1,248 residential units proposed under government of Tamil Nadu funding) at new settlement site, (ii) Demolish 807 housing units identified for relocation across 9 encroachments, (iii) Regeneration works across 9 water bodies (that were encroached). The subproject scope of work is enclosed in Table 1.

Table 1: Details of Subproject Scope Sl.no Subproject Subproject Interventions 1 Construction and • Main Entry operation of 2,124 • Bus Bay residential units • Visitors Centre (including 876 • Open Market residential units funded • Community Hall ii

Sl.no Subproject Subproject Interventions by ADB) and supporting • Convenience Store services • Anganwadi • Ration Shop • Fruit Orchard • Community Farming • Hilltop Walk • Hill Walking Path • Discovery Zone • Demonstration Farm • Approach roads and internal roads • Livelihood Centre • Play Park • Outdoor Gym • Surface Parking • Driveway • Sewage Treatment Plant • Rainwater Harvesting Structures • Health Sub Centre • Solar Power streetlights • Solid Waste Management • Micro-composting Center

2 Demolishing structures • Demolition of 807 structures in the 9 encroachment in the encroachment sites site (prone to flooding) • Provide fencing to prevent further encroachment 3 Water body restoration • Clearance and fencing • Restoration of water bodies, which were encroached • Provision for public parks/ recreation areas as per the community’s requirement • Avenue plantation/ landscaping • Re-greening / re-vegetation along water body / canal banks • Clearing and preventing new solid waste / sewage disposal in water bodies / channels • Implementation of site-specific plans in close coordination with ULBs or Public Works Department (PWD) e.g., waste management plan, sewerage collection and management plan, etc. • Source: TNSCB

Project Categorization. The due diligence has confirmed the project Environment Category is “B” requiring an Initial Environmental Examination (IEE) including Environmental Management Plan (EMP) in accordance with ADB Safeguard Policy Statement (SPS, 2009) and requirements of the Environmental Assessment Review Framework for IRSHUPSP– Table 1.3 (Key Exclusion Criteria) and Table 1.4 (Environmental Guidelines for Subproject Selection under Output 1). Based on the project activities, a consolidated IEE and 4 EMPs ((i) EMP for construction phase (C-EMP), (ii) EMP for operation phase, (iii) EMP for demolishing works (D-EMP) and (iv) EMP for regeneration works (R-EMP)) cover environmental impacts and associated risks in the project area of influence. The IEE and EMPs have been prepared based on the detailed engineering designs and will be updated where necessary to further meet the final detailed engineering designs. This subproject mandates Environmental Clearance (EC) as per the EIA notification 2006 (under category B2 and project schedule 8(a) for Building and Construction Projects and accordingly the Form 1 and Form 1A have been submitted to the State Environment Impact Assessment Authority (SEIAA) and the EC for the same is in the progress. Other statutory requirements include (i)

iii addressing the conditions (General and Specific Conditions), as given in the Environmental clearance for Reddiarpatti Resettlement Site;(ii) Update of IEE and EMP based on the water source sustainability study report (including water quality) from TWAD and (iii) Consent to Establish and Consent to Operate under air and water act for the hot mix plant /batching plant, Construction (workers) camps and proposed STP. Other project-related permissions/consents to be obtained by the Contractor are detailed in the IEE report.

Project Benefits. The key objective of this project is to provide affordable housing for the people who are living in the encroached areas (encroached water bodies), which is prone for seasonal flooding. This project also benefits, the low-income families, female-headed households. Based on the climate risk assessment and heat modelling, the building plan has been developed to withstand the climate change including the high temperature. The proposed infrastructures including provision of toilets, water supply arrangement, electric connection, community center, play area shall provide an improved standard of living.

Description of the Environment. The Reddiarpatti subproject site (8°40'30.13"N, 77°44'56.68"E) is located in the Tirunelveli District. The maximum elevation is at 84m AMSL and the lowest is 74m AMSL. The soil type is deep red soil, which is suitable for cultivating coconut and palmyrah trees. The maximum temperature is 39.4°C in the month of May and minimum is 21.7°C in the month of January. The minimum recorded rainfall is 107.7 mm and maximum rainfall is 639.9 mm. Annual average rainfall is 845.1 mm. The wind direction is predominantly towards North and West in the mornings and South and East in the evenings. The subproject site is in Low Damage Risk Zone II. River Tamirabarani1 is located close to the Reddiarpatti site at a distance of 7 km. Groundwater quality is observed to be good, in general it is colourless, odourless and slightly alkaline in nature. There are no sensitive areas like forest or protected areas that are located within a radius of 10km surrounding the sub project area. According to the 2011 Census, Reddiarpatti's population is 5,166. Out of this, 2,629 are males while the females count 2,537. There are no ASI sites in the near vicinity to the subproject area. Water supply to the subproject area is from the River Tamarabarani. The subproject site is well connected by the Railways, Highways (National Highways and State Highways).

Potential Environmental Impacts and Mitigation Measures. The subproject is unlikely to cause significant adverse impacts that are irreversible, diverse or unprecedented because: (i) the components will involve straightforward construction and operation, so impacts will be mainly site specific and localized; and (ii) there are no significant sensitive environmental features in the subproject sites although careful attention needs to be paid to minimize disruption to the community. Land acquisition related issues are not envisaged in this project, because the proposed resettlement site belongs to TNSCB. The primary areas of impact are (i) sites for proposed project components; (ii) main routes/intersections which will be traversed by construction vehicles; and (iii) quarries and borrow pits as sources of construction materials. The secondary areas of impact are: (i) other than the delineated primary impact area; and (ii) new resettlement site (Reddiarpatti) and the 9 encroachment sites (old settlement sites) in terms of overall environmental and socioeconomic improvement.

Pre-construction impacts are associated with: (i) shifting of utilities (including water supply, electricity, etc.) in the 9 encroachment sites (old settlement sites), which is chosen for relocation. Utility shifting is not envisaged in the resettlement site (Reddiarpatti) due to lack of habitation in the surrounding areas. (ii) Site selection for the source of construction materials have to be identified before construction commences with a proposed mitigation measure to procure construction materials from the government authorised / permitted quarries and

1 Tamirabarani is a perennial river; originating from Agastyarkoodam peak in the Western Ghats above Papanasam in Ambasamudram Taluk and flows through Tirunelveli and Tuticorin districts of Tamil Nadu and drains in Gulf of Mannar.

iv vendors, which will significantly reduce environmental impacts. (iii) Due to the topography of the resettlement site (which is located in a hillock with a gentle slope), in order for construction to occur it is anticipated to level the area. This will subsequently generate a huge quantity of debris, which has to be disposed in authorised areas or in low-lying areas (as long as it does not impede water flow or cause flooding) as per the direction of the PID. Similarly, the 9 encroachments sites (old settlement sites) that are chosen for resettlement will also be demolished which will generate significant quantity of construction debris, which shall be disposed in authorised areas in consultation with the Tirunelveli Municipal Corporation. (iv) Site selection of construction work camps, stockpile areas, storage areas, and disposal areas. Construction camp should be located 500 m away from the nearby settlements. Residential areas will not be considered for setting up construction camps to protect the human environment (i.e., to curb accident risks, health risks due to air, water and noise pollution, social conflicts and shortage of amenities). (v) Construction traffic will utilise existing roads for access to the work site therefore potential impacts will be of short duration, localized and can be mitigated.

Construction related impacts are standard and site specific to the construction activities and not expected to be significant. Key impacts during construction are envisaged on the following aspects: (i) transportation of materials; (ii) dust generation, air and noise pollution from construction activities; (iii) sourcing of water for construction activities; (iv) handling of construction materials at site; and (v) adoption of safety measures during construction. Erosion hazards are anticipated during the project construction due to the sloping topography, hence compaction at the site will have to be conducted to maintain soil stability. Similarly, cut and fill is also anticipated which may generate significant quantity of debris, which should be disposed at the pre identified sites (identified and approved during the pre-construction stage). There are no water bodies surrounding the resettlement sites and hence impact due to runoff from the construction site is not envisaged. However, for the demolition sites (9 encroachment sites), there are surrounding water bodies and hence demolition activity and runoff from the sites will have a significant impact to the water bodies. A mitigation measure has been proposed to use silt trap to prevent pollution of water bodies.

Air quality impacts due to the construction activity in the resettlement site is not expected to have a major health impact onto the surrounding areas, because of the lack of human habitat/ settlement in the project area. However, the movement of construction vehicles transporting construction materials and debris/materials to be disposed may cause increase in air pollutants within the construction zone for the resettlement site as well as the 9 encroachment sites. These are inherent construction impacts which are site-specific, low magnitude, short in duration and can be easily mitigated.

For noise and vibration impacts, with exemption to piling works, most of the construction activities (including construction and demolishing works) shall be done manually with minimum use of machinery and equipment and with necessary safety precautions, for example, barricades around demolition sites, restricting pedestrian and vehicular movements. Noise from demolition works should not exceed the noise standards as set by CPCB. Hence noise and vibration impacts are not expected to be significant. However, for the piling operation, Piling Rig will be used, it will generate noise and vibration to the surrounding, since there are scattered habitations (the nearest settlement is located at a distance of 250 m), the anticipated noise and vibration impacts shall be minimal. The demolition activities shall not have any impact on the physical cultural resources since no heritage buildings are located near the encroachment sites or the resettlement site.

During the project construction and operation, there is a moderate negative impact anticipated on the water resources. This is due to the utilisation of water for construction purposes and use of water for domestic purposes during operation, which will have a moderate stress on the available water resources. For construction purposes, the water shall be sourced from the

ULB’s or the Tamil Nadu Water Supply and Drainage Board (TWAD). During the operation phase of the project, TWAD will supply water to the Reddiarpatti resettlement sites. The quality of the water will meet IS 10,500 (potable/ drinking water standard). The estimated water demand of 0.67MLD will be sourced from River Tamirabarani at Thirumalaikolundupuram, which is located at a distance of 24 km from the Reddiarpatti resettlement site. The water supply is a surface water source, as such impact on the groundwater is not envisaged. However, TWAD is carrying out various methods / procedures for groundwater recharge, which includes check dams, percolation ponds, artificial recharge pits, recharge trench, ooranies (artificial lakes) and recharge shaft, which will enhance the groundwater recharge potential. For the resettlement site rainwater harvesting structures including 19 rainwater collection pits and an 1125 m rainwater collection trench has been provided. It is estimated that 5,400,000 (54 lakh) litres of rainwater will be collected within the resettlement site.

Impact on the flora and fauna during the project construction (comprises of resettlement construction works encroachment demolishing works and water body regeneration works) and operation will be negligible. This is because tree cutting is not required in the resettlement site and there are no protected areas or environmentally sensitive areas surrounding the resettlement sites. However, a few trees are observed in the encroachment areas (demolition work sites), which shall be preserved and included in the landscaping design during the water body restoration works.

Impact on Occupational, Health and Safety (OHS) including exposure to work-related chemical, physical, biological and social hazard is likely to occur during proposed construction and demolishing works. Potential impacts are negative and short-term but reversible by mitigation measures including provision of PPE’s, preparation of comprehensive site-specific health and safety (H&S) plan (including asbestos material management) provided with management strategy (including training) and applying practices that are intended to eliminate, or reduce, fatalities, injuries and illnesses for workers.

Major post construction impacts are specific to site clean-up activities, which include backfill of any excavation and trenches, reuse of topsoil, re-establishing the drain pattern if impacted, and removal all tools, equipment, barricades, surplus materials, debris and rubbish.

Major project operation impacts include: (i) municipal solid waste generation; (ii) wastewater generation from the resettlement site, (iii) health and safety issues (including communicable diseases, fire hazard etc.) and (iv) operation of infrastructures/ amenities including STP, rainwater harvesting structures and maintenance of lawn/ green belt. For the identified impacts the TNSCB has obtained necessary permissions from the competent authority (Tirunelveli Municipal Corporation) for handling and disposing municipal solid waste (MSW) and the discharge of the treated sewage. Hence, the impact anticipated during project operation is manageable. TNSCB have obtained confirmation for the supply of water to the resettlement site from TWAD. Since water will be supplied by the TWAD, the water quality will be maintained as per the IS 10500 drinking water standard requirements. The supply of estimated water demand of 0.67 MLD shall not have detrimental impact on the total water supply estimated for the Tirunelveli Municipal Corporation.

The main project risk is the low institutional capacity of the PMU, PIDs and contractors and their failure to implement the EMP effectively during construction and operation stages. These risks will be mitigated by: (i) hiring of environmental specialists at PMU and PID level; (ii) providing training and capacity building on environmental and social safeguards to the PMU, PIDs, contractors and workers, (iii) developing and implementing site specific EMPs (C-EMP/ D-EMP/ R-EMP) and Standard Operation and Maintenance Plans (SOMPs); (iv) following appropriate project implementation, mitigation, monitoring and reporting arrangements; and (iv) adequate site supervision including audits of contractor’s environmental, health and safety (EHS) performance. Monitoring parameters will be identified in the environmental monitoring

vi plan to check the effectiveness of EMP measures and to ensure any unidentified impacts can be readily addressed. The project risks will also be mitigated through inclusion of environmental specifications in contracts, bids and tenders for contractors.

For the identified impacts, mitigation measures have been developed to reduce all negative impacts to acceptable levels for pre-construction, construction, post-construction and project operation phases. Mitigation will be assured by a program of environmental monitoring to be conducted during construction and operation phases. The environmental monitoring program will ensure that all mitigation measures are implemented and will determine whether the environment is protected as intended. It will include observations on and off-site, document checks and consultation with workers and beneficiaries. Any requirements for corrective action will be reported to the ADB.

Relocated vulnerable population, especially low-income households, will be the major beneficiaries of the project. The most noticeable net environmental benefits to the population will be observed for those residing surrounding the restored water bodies.

Environmental Management Plan. The identified potential environmental impacts can be managed through effective implementation of the Environmental Management Plan (EMP). An EMP is included as part of this IEE, which includes (i) mitigation measures for environmental impacts identified during the implementation stage; (ii) an environmental monitoring program, and the responsible entities for mitigating, monitoring and reporting; (iii) public consultation and information disclosure procedure; and (iv) grievance redress mechanism. A number of impacts and their significance have already been reduced by amending subproject design. The EMP will be included in the civil work bidding and contract documents. The Environmental Management Plan (EMP) Budget has been estimated to be ₹72.82 Lakh (USD 1,00,887).

Consultation, Disclosure and Grievance Redress. During the course of preparing this IEE, meetings with departmental officials and other relevant government stakeholders have been conducted. The subproject components and associated clearances/ permissions/ NoCs requirement as well as the way forward for the project were discussed. Focus Group Discussions (FGDs) were also conducted with the affected people in the encroachment sites located at (i) Elanthaikulam, (ii) Vettuvankulam, (iii) Pillaikulam, (iv) Melaveera ragavapuram, (v) Meenakshipuram, (vi) West Kokirakulam, (vii) Karupanthurai, (viii) Kurunthudaiyarpuram, and (ix) Vellakoil. These FGDs were informal but were attended by both women and men of the affected communities. Baseline socio-economic surveys were also undertaken with the affected people and have been incorporated into this report as required. Further consultations were hampered by the ongoing coronavirus (COVID-19) pandemic and as such additional formal consultations will be undertaken once it is safe to do so and before construction commences. These additional consultations will be incorporated into the draft IEE. The feedback and suggestions from the consultations that were collected to date were utilised in the design of the project, environmental impact assessment and the resettlement plan preparation. Consultations will continue throughout the project implementation period. The draft and final IEE and EMP will be disclosed on TNSCB and ADB websites.

The IEE summary will be made available at public consultations with affected peoples, site locations and on the TNSCB website. The Draft IEE report will be disclosed to a wider audience via the ADB and TNSCB websites. The consultation process will be continued and expanded during project implementation to ensure that stakeholders are fully engaged in the project and have the opportunity to participate in its development and implementation.

A Grievance Redress Mechanism (GRM) is described within the IEE to ensure any public grievances are addressed quickly. The PIDs (Environmental / Social Cell) will set up a three- tier common GRM acceptable to ADB at project and divisional levels to address any

vii environmental and / or social issues that arise due to subproject activity. The GRM will constitute a suitable systematic process to receive, evaluate and facilitate resolution of affected persons and other stakeholder’s complaints and grievances about subproject environmental (and social) safeguards performance. It will aim to provide a time-bound, trusted and transparent mechanism to voice and resolve issues and concerns associated with the subproject implementation. The GRM will address concerns and complaints promptly via a transparent process. Complaints and their resolution will be documented and reported in quarterly project progress reports and annual safeguard reports to ADB.

Monitoring and Reporting. The key institutions involved in the IEE and EMP implementation will be the PMU and PIDs. To ensure effective implementation of environmental safeguards procedures, the PMU and PIDs will include designated and trained staff and focal point persons. The PMU will be responsible for the overall supervision and compliance with (i) environmental safeguards requirements including resubmission of revised documentation for ADB concurrence, (ii) coordinate the project GRM, (iii) coordinate with line departments to ensure smooth implementation of the project,2 (iv) supervise the procurement process, and (v) report to the ADB. In particular, the PMU will ensure consistency of safeguard documents with government policy, legal and administrative framework across all jurisdictions national, state and local level. The PIDs will be responsible for day to day activity and compliance with safeguards during project implementation in the field including engaging in project GRM, meaningful consultations, and oversight of the contractors or any third party consultants.

The PMU will be responsible for overall safeguards reporting and monitoring, including final approval of the site-specific environmental management plan (SEMP) prepared by the contractors. The PIDs (Environment Cell) with support of the PMU (Environment Team) will conduct environmental monitoring for each subproject and provide the environment input into reporting based on site inspections, compliance checks and prepare the subproject Quarterly Progress Reports (QPRs) for submission to the PMU for final submission to ADB till the project completion report is issued. Monitoring will also encompass tracking progress on regeneration works undertaken by the PMU of previously encroached water bodies / channels and surrounding areas. The environmental monitoring report for submission to ADB shall be on a quarterly basis during construction and on an annual basis during operation. Environmental monitoring reports will be required to be submitted to ADB within 30 days from the end of the relevant period. The environmental monitoring reports will be publicly disclosed on ADB public website. Reporting to ADB will continue until a project completion report is completed.

The PIDs will be responsible for safeguards monitoring and implementation, including initial review of the contractor’s SEMP before submission to PMU for final approval. The PIDs, will coordinate and interact with the PMU on compliance to ADB safeguards requirements and with relevant government agencies and local authorities on permits and clearances and update and finalize the IEE and EMP as needed. During the project implementation, the PIDs will conduct field visits and for the any identified noncompliance (with reference to EMP implementation) a suitable Action Taken Report (ATR) with a time bound corrective action plan will be prepared. The ATR will be shared with the Contractor for effective implementation of the EMP and included in the quarterly safeguard monitoring reports.

After completion of the construction stage, the facility operator/ contractor will continue to submit monthly progress reports to PIDs for the first year of the operation and quarterly progress reports thereafter; these will inform the annual safeguards monitoring reports.

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

viii

Conclusions and Recommendations. The proposed subproject is unlikely to cause adverse environmental impacts. The potential impacts that are associated with design, construction and operation can be mitigated without difficulty through proper engineering design and the incorporation or application of recommended mitigation measures and procedures. Based on the findings of the IEE, there are no significant impacts and the classification of the subproject as Category “B” is confirmed. No further study or detailed environmental impact assessment (EIA) needs to be undertaken to comply with ADB SPS, 2009 or Government of India EIA Notification, 2006. This draft IEE is based on preliminary detailed design and will be submitted to ADB for concurrence and disclosure. However, this draft IEE will be updated based on final detailed design and will also need to be updated every time detailed design is changed or updated. The updated IEE will be submitted to ADB for final review and disclosure.

I. INTRODUCTION

A. Background

1. Tamil Nadu is one of the largest states in India with acute housing shortage. According to the Government of India, the State’s housing deficit accounts for 6.66% of the national housing shortfall. Based on the income levels, the housing shortage mapping reveals that the Economically Weaker Section (EWS) adds to 56%, which is followed by Lower-Income Group (LIG) of 39% and Middle Income Group (MIG) by 4%. Tamil Nadu has 5.8 million slum residents, with the most slum residents from the EWS and the LIG. Slum areas are prone to disaster, environmental degradation and health risks. Informal settlements and slums are often situated in hazardous areas, which are congested and lack appropriate services (i.e., electricity, piped water supply, and sanitation/waste facilities).

2. As per National Urban Housing and Habitat Policy (NUHHP), several comprehensive urban initiatives have been undertaken. The most recent initiative is the Pradhan Mantri Awas Yojana-Housing for All (PMAY-HFA). In Tamil Nadu, TNSCB has been identified as the entity responsible for implementing PMAY (Urban). In its recent survey, TNSCB estimated the total demand for affordable housing at 1.4 million units. Affordable housing also needs to be made accessible to low-income migrant workers, working women and female-headed low-income households for sustainable urban development.

3. In view of this, the proposed project will promote access to an inclusive, resilient, and sustainable housing and urban development in Tamil Nadu by supporting the state in (i) relocating vulnerable communities living in high-risk areas to safe shelter; (ii) providing affordable and proper housing for urban poor households as well as for migrant workers from the economically weaker section (EWS) and lower-income group (LIG); and (iii) in regional planning. The project covers 3 proposed components as follows.

4. Component 1: Affordable Housing for Vulnerable Communities. The project will support the resettlement of slum households vulnerable to hazards to safe relocation sites. The project will work with government to introduce gradual changes in the delivery of affordable housing to the urban poor through: (i) improved design including robust O&M mechanisms including women’s participation in design, (ii) increased beneficiary consultation and participation, and (iii) a graduation approach to sustain vulnerable relocated households.3 The output will include protection of cleared waterways to restore ecological functions and prevent re-encroachment.4

5. Component 2: Affordable Housing for Urban Poor and Migrant Workers. The project will support the government’s shelter fund by piloting a public-private partnership (PPP) structure and will provide industrial housing and working women’s hostels for low-income and migrant workers. Financing will be deployed as Government of Tamil Nadu’s equity into the

3 The graduation approach is a holistic, time-bound, and carefully sequenced set of interventions to place households on an upward trajectory from poverty. This includes four key components: (i) social assistance to support immediate needs such as subsistence and health services during transition in the relocation site; (ii) livelihood promotion through localized market assessment and household-level enterprise/employment matching; (iii) financial inclusion through financial literacy and improving access to savings and financial services to promote economic resilience; and (iv) social empowerment by improving social dynamics, including gender relations, in the families and communities. 4 Removing encroachments in waterways will have the benefit of restoring capacity to absorb water and reduce future flooding, recharge groundwater, and potentially be alternative sources of water in water-scarce areas. Regeneration of urban areas can also result from creating public spaces. Impacts of investing in the subsector can be further increased by improving TNSCB’s design and implementation practices and policies, and further strengthening the institution. Protecting cleared areas ensures that it will not revert back to a slum. The works from protecting the cleared areas including the re-greening of banks can provide temporary construction employment for beneficiary households and provide an initial market for transport services. 2 shelter fund, which may be provided as catalytic first loss capital instrument. The shelter fund would leverage the Government of Tamil Nadu equity (including the loan proceeds from ADB that would be injected as equity into the fund) to attract private sector investment into specific special purpose vehicles (SPVs) that would be established to deliver affordable housing for working women and industrial workers.

6. Output 3: Regional Planning. The project will support regional planning that integrates existing and proposed development plans and makes provisions for economic development and affordable housing to balance growth throughout the State with regard to infrastructure development, environmental protection, and disaster risk management.5

B. Subproject Scope and Location

7. Tamil Nadu Slum Clearance Board (TNSCB) have taken initiatives to relocate vulnerable communities living alongside the water bodies across the state. In the district of Tirunelveli, TNSCB have identified 9 locations (refer Table 2 and Figure 1) where vulnerable communities are living in conditions at high risk of flooding due to the water bodies. Accordingly, a screening survey has been conducted and the number of households that would be affected are identified. It was estimated to relocate 807 households to a safe location. However, the actual number of households being affected will be assessed after the social survey. This draft IEE will be updated following this and submitted to ADB for final review and disclosure.

8. Based on the land availability (preferably government land), the TNSCB has selected the Reddiarpatti site (Geo-coordinates 8°40'30.13"N, 77°44'56.68"E) as a potential resettlement site. Upon clearance of the old settlement sites/ encroachment sites, adequate measures shall be taken to prevent any encroachment and the water body catchment area shall be restored.

Table 2: Encroachment sites Identified for Relocation S.No. Location No. of Households Geo-coordinates 1 Pillaikulam 70 8°44'10.30"N 77°45'37.60"E 2 Karuppanddurai 36 8°42'31.46"N 77°41'42.14"E 3 West Kokkirakulam 52 8°43'26.11"N 77°42'40.35"E 4 Meenachipuram 113 8°43'18.62"N 77°42'21.46"E 5 Mela Veeragavapuram 42 8°44'21.55"N 77°42'51.26"E 6 Kurundhudaiyarpuram 10 8°43'9.012"N 77°42'22.75"E 7 Vellakoil 10 8°44'37.96"N 77°43'45.73"E 8 Vettuvankulam 9 8°43'50.44"N 77°44'28.02"E 9 Elanthakulam 465 8°42'42.30"N 77°44'7.41"E Total 807 Source: TNSCB

5 Land use regulation plays an important part in determining the pattern of service land and housing occupation in urban areas. It should be ensured that housing is provided where it is needed, rather than supporting segregation (for example at the periphery of cities) is critical in policy. Policy should provide diversity of housing at scale, typology, and price.

Figure 1: Map Showing Sites Chosen for Relocation and Resettlement

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

Table 3: Environmental Guidelines for Subproject Selection under Output 1 Guidelines for Subproject Selection Remarks I. All Subprojects including supporting services Complies with key exclusion criteria6 The resettlement site (Reddiarpatti) and 9 encroachment sites (old settlement sites) that are proposed to be demolished and renovation of water bodies are in compliance as per the exclusion criteria.

6 Subproject Exclusion Criteria: 1. Environment Category A subprojects. 2. No subprojects to be located within 10 km of a national park, sanctuary, wetland, mangroves, coastal areas, backwaters, recognized biodiversity hotspots and/or within reserved forests, village forests, protected forests. 3. Subprojects that involve activities in the ADB Prohibited Investment Activities List (ADB SPS, 2009, Appendix 5). 4. Subprojects that are highly complex and sensitive. 5. Subprojects that are category A or have adverse impacts on indigenous people safeguards. 6. Subprojects which result in significant adverse impacts on any sensitive natural and human receptors e.g., species or habitat of high conservation value, significant number of trees of economic value (such as fruit bearing trees), water bodies (such as wetlands, backwaters, rivers, lakes or ponds), existing host communities / neighborhoods, schools and/or Physical Cultural Resources (PCRs). 7. Subprojects in unsafe proximity of electricity substations, high voltage transmission lines, underground cables, solid waste dumping yards, Oil /Gas pipelines, Coastal Regulatory Zone hazard line and/or polluting (heavy emissions / noisy) industrial activities. 8. Subproject sites in flood prone areas, areas with a history of flooding. 9. Subprojects that are not technically, financially, or economically viable.

Guidelines for Subproject Selection Remarks Complies with ADB SPS 2009, EARF and The subproject activities proposed at the resettlement the national and state legal and site, 9 encroachment sites and the water bodies comply regulatory framework with ADB SPS 2009, EARF and the national and state legal and regulatory framework. The primary environmental criteria for Since the 9 encroachment sites to be demolished are selecting subproject sites to be relocated located in encroached land of water bodies is vulnerability to flooding of targeted non- (tanks/ponds), they are vulnerable to flooding. The titled project beneficiaries without tenure resettlement site has no history of flooding and it is not security residing in encroachments (i.e., prone to flooding. waterbodies / waterways).

No new development sites in flood areas, areas with a history of flooding or areas zoned for coastal protection The selected subprojects (new It is estimated to demolish 807 dwelling units in 9 development / resettlement sites) should encroachment sites and it is proposed to construct 2,124 have sufficient land for the residential units (876 residential units under ADB accommodation of all project financing) which is more than the actual requirement. The beneficiaries / resettled households and buildings are designed in line with housing space and community members in line with housing design ratio considerations based on the TNSCB space and design ratio considerations. guidelines. The selected subprojects (new All the 9 encroachment sites are located within 10km development / resettlement sites) should radius with travelling distance less than 1hr from the be within one-hour travel time on public Reddiarpatti resettlement site. transport from existing encroachments such that project beneficiaries / resettled households and community members have continued access to livelihood generation activities. The selected subprojects (new Public amenities are located within 2.5 km radius of the development / resettlement sites) should resettlement site. The existing public amenities along be within a 2.5 km radius of public with distance have been depicted in the Error! amenities or be within prescribed social Reference source not found.. infrastructure access norms. The selected subprojects (new The residential units are designed as per the building development / resettlement sites) are norms adopted by the TNSCB. All required infrastructure greenfield, therefore opportunity should and supporting services are proposed at the resettlement be taken to ensure that these are site. As per the proposed design the green area comes connected to existing neighborhoods / around 15% and OSR comes around 10% which is in host communities, provide compliance as per the subproject selection criteria of comprehensive infrastructure and open space / green zone. supporting services, generate new optimally sited open spaces of adequate size, and community spaces. The selected subprojects should have The resettlement site (Reddiarpatti) is proposed to have access to or include supporting services the following infrastructure facilities: (within the scope of this EARF)7 at new • Main Entry development / resettlement sites for • Grand Boulevard project beneficiaries / resettled • Bus Bay households and community members for • Visitors Centre better environmental outcome. • Open Market If there is no access to supporting • Community Hall services, then the subproject shall • Convenience Store integrate supporting services in the • Anganwadi subproject detailed engineering design • Ration Shop for the new development / resettlement • Fruit Orchard sites and for any other housing plans

7 Refer to EARF Section 1.3. Subproject Scope under Output 1 for list of supporting services.

Guidelines for Subproject Selection Remarks under consideration in the immediate • Community Farming vicinity of new resettlement sites. • Hilltop Walk • Hill Walking Path • Discovery Zone • Demonstration Farm • Approach roads and internal roads • Livelihood Centre • Play Park • Outdoor Gym • Surface Parking • Driveway • Sewage Treatment Plant • Rainwater Harvesting Structures • Health Sub Centre • Solar Power streetlights • Solid Waste Management • Micro Composting Center

Currently there are no supporting services present at the site. Hence an EHS audit in line with the ADB SPS is not required Resettlement of project beneficiaries As per the TNSCB policy, the resettlement process shall shall only take place after all supporting start only after completion of the construction activities services are available and operational at (including all the amenities/ infrastructure facilities). new development / resettlement sites. Before resettlement, appropriate meaningful consultation shall be conducted. Subprojects will conform to land use As per the land use map (recently updated) for the project classification and relevant development area it is identified as a built-up area (residential use) control regulations and municipality (refer to Error! Reference source not found.). Land approved master plan. Subprojects (new transfer certificate to TNSCB is enclosed in the Appendix development / resettlement sites) not 2. covered by the master plan will require further due diligence for consideration for subproject selection as long as it meets the key exclusion criteria and prescribes to the environmental guidelines for subproject selection. Will not involve the use or installation of The implementation of the subproject Construction hazardous materials including asbestos, Environmental Management Plan (C-EMP) ensures that PCBs, lead based paint. asbestos, mercury, PCBs and lead based paints will not be used in this project. This includes asbestos cement, gaskets, lead pipe and solder, fluorescent tubes etc. The contractor shall prepare Standard Operating Procedures (SOPs) for each material if potentially exposing workers to asbestos, PCB’s and lead. No new construction of landfills will be There is no proposal for a new landfill site. The municipal supported under this sector loan. solid waste shall be segregated at source into organic and inorganic waste. Organic waste shall be treated in the Micro Composting Center and for inorganic waste it shall be disposed through outsourcing carried out by the Tirunelveli Municipal Corporation No new electricity generation / electricity Electricity shall be provided by Tamil Nadu Electricity high voltage transmission line and Board (TNEB) distribution substations will be supported under this sector loan. Subprojects shall utilize water sources at Water supply will be provided by TWAD, which is a nodal sustainable levels of abstraction only agency for supplying water across Tamil Nadu. TWAD (i.e., without significant reductions in the follows all the necessary protocols to balance the water

Guidelines for Subproject Selection Remarks quantity or quality of the source overall), requirement for day to day activities of the communities. avoid polluted water sources, avoid water TWAD maintains the drinking water standard (IS 10500). use conflicts by not abstracting water that It also adopts various rainwater harvesting measures to is used for other purposes and ensure counterbalance the water usage and water recharge. A water quality provided complies with water source sustainability study is being undertaken by national drinking water standards at all TWAD which will be reincorporated in the IEE and EMP. times through regular monitoring. Subprojects should locate sewerage As per the requirement, the STP is located far from the treatment plants as far as possible from settlements and it will be fenced to prevent public entry. inhabited areas, ensure sewerage is SBR technology has been adopted in treating the sewage treated to national wastewater discharge to attain the national wastewater discharge standard. The standards, ensure no discharge of treated sewage water will be utilized for gardening, and wastewater occur where it could be a excess treated sewage water will be given to local body hazard to downstream users and include for watering trees and shrubs around Pallavarayan pond. measures for the safe disposal of sewage The generated STP sludge will be further treated using sludge. sludge digester to remove pathogens and it will be dried. Then the dried sludge shall be disposed at Ramaiyanpatti Sewage Treatment Plant (operated and maintained by Tirunelveli Municipal Corporation). II. Demolition works for all subprojects Demolition works at encroachments will: The EMP prepared for the demolition works shall be • exclude religious structures e.g., implemented to minimise impacts, with further details to chapels, temples, mosques, etc.; be addressed in the subproject specific Social Impact and if cannot exclude, then Assessment (SIA) / Resettlement Action Plan (RAP). replace or compensate for the Retaining of the Physical Cultural Resources (PCRs) or religious structures in shifting of the PCRs shall be based on public consultation consultation with the relevant and relevant government approvals including ASI and in stakeholders accordance with ADB SPS 2009. • involve clearance and fencing • avoid cutting of trees • avoid disturbance to PCRs • repair any structure that has been inadvertently damaged • fencing around the water body perimeter or along channel banks8 III. Regeneration works for all subprojects Regeneration works9 at cleared The final plan for regeneration of the water bodies will be encroachments will include at a minimum decided by the concerned ULBs with potential TNSCB • re-greening / re-vegetation of input. However, based on the activities required for water banks along water bodies / body regeneration works, an EMP has been prepared channels, and included in this IEE, which shall assist the ULBs in • clearing and preventing new minimising the impacts during regeneration works. The solid waste / sewage disposal in IEE and EMP will need to be updated once detailed water bodies / channels design is available and the relevant EMP will have to be adopted by the contractor. TNSCB will retain responsibility for clearing the site after demolition and fencing in coordination with relevant agencies. These impacts are covered under the EMP prepared for demolition works.

8 Fencing to ensure that re-encroachment of cleared spaces does not revert back to slums and is kept as green open space to realise ecological and public benefits from the cleared and restored waterways. 9 Regeneration works of the cleared encroachments will be undertaken such that it does not revert back to slums and is kept as green open space to realize ecological and public benefits from the cleared and restored waterways.

C. Purpose/ Objectives of IEE

10. ADB requires the consideration of environmental issues in all aspects of the Bank’s operations, and the requirements for environmental assessment are described in ADB’s Safeguard Policy Statement (SPS), 2009. The potential environmental impacts of the subproject have been assessed using ADB rapid environmental assessment checklist for Urban Development (Appendix 4). Then potential negative impacts were identified in relation to (i) pre-construction, construction and operation stages of the resettlement site, (ii) demolition of the structures in the encroachment sites and (iii) restoration of water bodies in the relocated sites. The results of the assessment shows that the subproject is unlikely to cause significant adverse impacts that are irreversible, diverse or unprecedented. Thus, this initial environmental examination (IEE) has been prepared in accordance with the EARF and ADB SPS, 2009 requirements for environment category B projects.

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

11. This IEE is based on the Detailed Project Report (DPR) prepared by Tamil Nadu Slum Clearance Board (TNSCB). The IEE is based mainly on field reconnaissance surveys and secondary sources of information. No baseline environmental monitoring was conducted to prepare the IEE. However, the environmental monitoring program developed as part of the Environmental Management Plan (EMP) will require the contractor to establish the baseline environmental conditions prior to commencement of civil works. The results of which will be reported in the final IEE as part of the revision of the baseline environmental section and as part of the ongoing environmental monitoring report. It will be the basis to ensure no environmental degradation will happen during subproject implementation. Stakeholder consultation is an integral part of the IEE, due to the ongoing COVID-19 pandemic, further planned stakeholders consultation have not been conducted. Therefore, there is a need to undertake further stakeholders consultations, when it is safe to do so.

D. Report Structure

12. This report contains the following 10 sections including the Executive Summary at the beginning of the report:

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

II. POLICIES, LEGAL AND INSTITUTIONAL FRAMEWORK

A. ADB Safeguard Policy Statement (2009)

13. ADB requires the consideration of environmental issues in all aspects of ADB’s operations, and the requirements for environmental assessment are described in ADB SPS, 2009. This states that ADB requires an environmental assessment of all ADB investments.

14. Screening and Categorization: The nature of the environmental assessment required for a project depends on the significance of its environmental impacts, which are related to the type and location of the project; the sensitivity, scale, nature and magnitude of its potential impacts; the availability of cost-effective mitigation measures. Projects are screened for their expected environmental impacts and are assigned to one of the following four categories.

(i) Category A. a proposed project is classified as category ‘A’ if it is likely to have significant adverse environmental impacts that are irreversible, diverse, or unprecedented. These impacts may affect an area larger than the sites or facilities subject to physical works. An Environmental Impact Assessment (EIA) is required. (ii) Category B. a proposed project is classified as category ‘B’ if its potentially adverse environmental impacts are less adverse than those of category ‘A’ projects. These impacts are site-specific, few of them are irreversible, and in most cases, mitigation measures can be designed more readily than for category ‘A’ projects. An Initial Environmental Examination (IEE) is required. (iii) Category C. a proposed project is classified as category ‘C’ if it is likely to have minimal or no adverse environmental impacts. No environmental assessment is required although environmental implications need to be reviewed. (iv) Category FI. a proposed project is classified as category ‘FI’ if it involves an investment of ADB funds to or through a Financial Intermediary (FI). An Environmental and Social Management System (ESMS) is required.

15. Analysis of Alternatives. The best fit option should be identified for the implementation of the project in terms of location, design, technology and/or components that would avoid, and, if avoidance is not possible, minimize adverse environmental impacts and risks.

16. Anticipated Adverse Impact Mitigation and Management. When the potentially significant adverse impacts and risks cannot be avoided or prevented, appropriate mitigation measures and management actions have to be identified so that the project / subprojects are designed, constructed, and operated in compliance with ADB SPS, 2009.

17. Environmental Management Plan (EMP): An EMP, which addresses the potential impacts and risks identified by the environmental assessment, shall be prepared. The level of detail and complexity of the EMP and the priority of the identified measures and actions will be commensurate with the project’s impact and risks.

18. Public Consultation. Carry out meaningful consultation with affected persons and facilitate their informed participation. Ensure women’s participation in consultation. Involve stakeholders, including affected persons and concerned NGOs, early in the project preparation process and ensure that their views and concerns are made known and understood by decision makers and taken into account.

19. Grievance Redress Mechanism (GRM). Establish a grievance redress mechanism (GRM) to receive and facilitate resolution of the affected person’s concerns and grievances regarding the project’s environmental performance.

20. Public Disclosure: ADB will post the safeguard documents on its website as well as disclose relevant information in an accessible manner in local communities:

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

B. National and State Laws

21. Environmental assessment. Government of India EIA Notification of 2006 (replacing the EIA Notification of 1994) sets out the requirement for Environmental Assessment in India. This states that Environmental Clearance is required for specified activities/projects, and this must be obtained before any construction work or land preparation (except land acquisition) may commence. Projects are categorized as ‘A’ or ‘B’ depending on the scale of the project and the nature of its impacts.

(i) Category A projects require Environmental Clearance from the central Ministry of Environment, Forests and Climate Change (MOEF&CC). The proponent is required to provide preliminary details of the project in the prescribed manner with all requisite details, after which an Expert Appraisal Committee (EAC) of the MoEF&CC prepares comprehensive Terms of Reference (ToR) for the EIA study. On completion of the study and review of the report by the SEAC, MoEF&CC considers the recommendation of the SEAC and provides the Environmental Clearance if appropriate. (ii) Category B projects require environmental clearance from the State Environment Impact Assessment Authority (SEIAA). The state-level EAC categorizes the project as either B1 (requiring EIA study) or B2 (no EIA study) and prepares ToR for B1 projects within 60 days. On completion of the study and review of the report by the SEAC, the SEIAA issues the Environmental Clearance based on the SEAC recommendation. The Notification also provides that any project or activity classified as category “B” will be treated as category “A” if it is located in whole or in part within 10 km from the boundary of protected areas, notified areas or interstate or international boundaries.

22. The proposed project involves construction of 2,124 dwelling units (including 876 dwelling units under ADB funding) at Reddiarpatti. As per the TNSCB norms, each unit shall have 400 sq.ft built-up area, other built-up area includes bus bay, visitor’s centre, community hall, anganwadi (child care centre), ration shop, livelihood centre, Sewage Treatment Plant (STP) thereby together the total built-up area would be 82,262.69 m2 ((including ADB financed housing and amenities 65,676.93 m2) which is less than the stipulated area (<1,50,000 m2) for the projects mandating EIA. Hence, the proposed project is classified as Category B2 and it does not warrant an EIA study. However, Environmental Clearance (EC) is required from the SEIAA.

Table 4: Environmental Regulatory Compliance (National and State Laws) Law Description Requirement Environmental Impact The Notification imposes restrictions As per the EIA notification, this Assessment Notification, and prohibitions on new projects or subproject is categorised as B2 2006 activities and also on the expansion and mandated Environmental or modernization of existing projects clearance from SEIAA is or activities based on their potential necessary. environmental impacts. ADB’s Safeguard Policy Categorization of project This project has been Statement 2009 components into A, B or C and “Categorized as B and developing required level of accordingly this IEE has been prepared “

Law Description Requirement environmental assessment for each component. Central Ground Water It provides for regulation and control Permission needs to be granted Authority, Notification, of ground water development and for the extraction of Groundwater 1997 management from Central Groundwater Board (CGWB) The Environment Emissions and discharges from the To comply with applicable notified Protection Act, 1986 facilities to be created or refurbished standards The Environment or augmented shall comply with the Protection Rules, 1986 notified standards Water (Prevention and Act was enacted to provide for the To obtain CtE and CtO for (i) hot Control of Pollution) Act prevention and control of water mix plant /batching plant; (ii) of 1974, Rules of 1975, pollution and the maintaining or construction (workers) camps and and amendments restoring of wholesomeness of (iii) proposed STP water. Control of water pollution is achieved through administering Compliance to conditions and conditions imposed in consent effluent disposal standards issued under to this Act. stipulated in CtE and CtO All pollution potential activities will require consent to establish (CtE) from Tamil Nadu Pollution Control Board (TNPCB) before starting implementation and consent to operate (CtO) before commissioning. Air (Prevention and The Act was enacted to achieve To obtain CtE and CtO for (i) Control of Pollution) Act, prevention, control and abatement diesel generators; (ii) hot mix units 1981, amended 1987 of air pollution activities by assigning / batching units; (iii) vehicles and its Rules, 1982. regulatory powers to CPCB and emitting air pollutants and (iv) SPCB’s for all such functions. construction camps.

Establishes ambient air quality Compliance to conditions and standards emissions standards stipulated in the CtE and CtO. Noise Pollution It provides for regulations to control To comply with the noise (Regulation and Control) ambient noise levels in public places standards. Rules, 2000 and further from sources such as industries/ amended construction works/ community events, etc. The Hazardous Wastes It provides for regulation and control Applicable for the subproject if it (Management, Handling of indiscriminate disposal of deals with generation/ handling/ and Transboundary Hazardous waste; and its sound storage/ processing of hazardous Movement) Rules, 2008 management to reduce risks to waste which should take environmental and human health cognizance of the provisions/schedules of these Rules and obtain authorization from the TNPCB. Municipal Solid Waste • Rules to manage municipal solid Solid waste generated at the Management Rules, waste generated; provides rules proposed facilities / construction 2016 for segregation, storage, camps / housing units shall be collection, processing and managed and disposed in disposal. accordance with the Municipal • MSW (Organic Compost), end Solid Waste Management Rules product quality as per the Fertilizer Control Order (FCO) The end product of the compost should be as per the FCO stipulated quality standard, to use it as a manure for agriculture purposes

Law Description Requirement Construction and Rules to manage construction and Construction and demolition Demolition Waste waste resulting from construction, waste generated due to civil works Management Rules, re-modelling, repair and demolition at subproject construction site 2016 of civil structure. Rules define and/or demolition of existing civil Construction and Demolition waste structures at encroached areas as comprising of building materials, shall be managed and disposed debris resulting from demolition / re- as per these Rules modelling or repairs The Ancient Monuments Provide guidance for carrying out Not applicable. The subproject and Archaeological Sites activities, including conservation, site is not close to any of the and Remains Act, 1958, construction and reuse in and archeological / protected and the rules, 1959 around the protected monuments. monuments Tamil Nadu State This Act is to protect groundwater Groundwater abstraction in any of Ground Water resources and provide safeguards the notified areas will be subject to (Development and against groundwater the provisions of this Act. Management) Act, 2003 overexploitation, and to ensure its planned development and management; notifies areas for development, regulation and control of groundwater; prohibits sinking of wells and groundwater transport in notified areas without prior permission of the designated authority; requires all wells to be registered Labor Laws The contractor shall not make Appendix 6 provides applicable employment decisions based upon labor laws including amendments personal characteristics unrelated to issued from time to time job requirements. applicable to establishments The contractor shall base the engaged in construction of civil employment relationship upon equal works, which will need to be opportunity and fair treatment, and followed by the subproject. shall not discriminate with respect to aspects of the employment relationship, including recruitment and hiring, compensation (including wages and benefits), working conditions and terms of employment or retirement, and discipline. The contractor shall provide equal wages and benefits to men and women for work of equal value or type. Minimum Wages Act, The employer is supposed to pay All construction / operation and 1948 not less than the minimum wages maintenance workers should be fixed by appropriate government paid not less than the stipulated agency as per the provisions of this wages under this Act. Act if the employment is a “scheduled employment” such as construction of Roads, Runways, and Buildings. Equal Remuneration The Act provides for payment of Act, 1979 equal wages for work of equal nature to male and female workers and for not making discrimination against genders. Inter-State Migrant Act is applicable to any The Contractor for subprojects is Workmen (Regulation of establishment that employs 5 or to register with the Labour Employment and more inter-state migrant workers Department in case of hiring of

Law Description Requirement Conditions of Service) through an intermediary (who has inter-state migrant workers. Act, 1979 recruited workers in one state for Adequate and appropriate employment at an establishment amenities and facilities to be situated in another state). provided to workers including housing, sanitation, portable water, medical aid, traveling expenses from home to work place, etc. Building and Other It regulates the employment and The subproject shall comply with Construction Workers conditions of service of building and the provisions of this Act. (Regulation of other construction workers and Employment and provides for their safety, health and Conditions of Service) welfare Act, 1996 Tamil Nadu State This Act is to protect groundwater Groundwater abstraction in any Ground Water resources and provide safeguards notified areas will be subject to the (Development and against groundwater provisions of this Act. Management) Act, 2003 overexploitation Tamil Nadu Minor Applicable for sand mining, All projects/activities being Mineral Concession quarrying and borrow areas implemented and/or funded under Rules, 1959 (corrected the sector loan shall take up to 31 March 2001) cognizance and comply with the provisions of this Act. Tamil Nadu Protection of An Act to provide measures for Cleaning of encroachments / Tanks and Eviction of checking the encroachment, regeneration works will have to be Encroachments Act, eviction of encroachment in tanks undertaken in line with this Act. 2007 which are under the control and management of Public Works Department, protection of such tanks and for matters incidental thereto. Tamil Nadu Building Regulates the employment and The subproject shall comply with and Other Construction conditions of service of building and the provisions of this Act. Workers’ (Regulation of other construction workers and to Employment and provide for their safety, health and Conditions of Service) welfare measures. Provides various Act, 1996 and Rules, benefits for registered workers. 2006 Source: MoEF&CC, TNPCB, Govt of Tamil Nadu.

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

Table 5: Clearances and Permissions Required by the PMU for Project Construction Sl.no Permission/ Competent Remarks Status Reference Clearances/ Authority Declaration 1. Environmental State As per the EIA notification, Obtained Appendix 5 Clearance as per Environment this subproject is the EIA notification Impact categorised as B2 and 2006 Assessment mandates Environmental Authority clearance from SEIAA is (SEIAA) necessary

Sl.no Permission/ Competent Remarks Status Reference Clearances/ Authority Declaration 2. Confirmation letter Revenue and Based on the disaster Obtained Appendix 1 from Taluk office on disaster information shared by the the flood situation management Tamil Nadu State Disaster in the department, Management Authority encroachment sites Tahsildhar, (TNSDMA), Palayamkottai Palayamkottai Taluk Office has issued the certificate confirming that the 9 encroachment sites have been identified for relocation are affected due to seasonal floods 3. Land Transfer Taluka office Land Transfer certificate Obtained Appendix 2 certificate Palayamkottai has been issued by the Taluka office Palayamkottai (for the government land with survey number 194/7) to the TNSCB for the construction of the resettlement residential units. 4. Land Use Office of the Reclassifying the Land Obtained Appendix 3 Classification Principle located in the S..No. 194/7 (Government Secretary of extent 90366 m2 Order) (Govt of Tamil (9.03.66 hectares) for the Nadu) Residential usage area 5. Confirmation letter TNEB, TNEB has accepted the Obtained Appendix 7 from the Tamil Tirunelveli request from TNSCB, Nadu Electricity accordingly site inspection Board (TNEB) has been carried out 6. Certificate Tahsildhar, Tahsildhar of Obtained Appendix 8 indicating the Palayamkottai Palayamkottai have Reddiarpatti issued a certificate resettlement site is indicating the Reddiarpatti not vulnerable for resettlement site is not flooding prone to flooding 7. Acceptance letter Tirunelveli TNSCB have received Obtained Appendix 9 for collection of Municipal acceptance letter from Municipal Solid Corporation Tirunelveli Municipal Waste Corporation provided with the following conditions. (i) It has been suggested to segregate MSW into organic and inorganic waste (ii) For organic waste it has been suggested to construct a “Micro Composting Center” in the resettlement site and the cost for the operation and maintenance has to be remitted to Tirunelveli Municipal

Sl.no Permission/ Competent Remarks Status Reference Clearances/ Authority Declaration Corporation, by TNSCB. (iii) For inorganic waste, the collection shall be outsourced by the Tirunelveli Municipal Corporation 8. Permission letter Palayamkottoai Consent has been given Obtained Appendix 10 for discharge of Panchayat for watering trees and treated sewage Union shrubs around Pallavarayan pond 9. Tamil Nadu Water TWAD TWAD has confirmed the Obtained Appendix 11 Supply and supply of water for 876 Drainage Board residential units proposed (TWAD) under ADB financing in acceptance/ the Reddiarpatti acknowledge for resettlement site. The the supply of water acknowledgement for the to Reddiarpatti same has been included resettlement site in the Appendix 11.

For remaining 1248 residential units (proposed to finance under TNSCB), TWAD has been requested to supply 1.486 MLD for which official communication has been submitted to TWAD from TNSCB. The acceptance / confirmation from TWAD is required prior to contract award.

Once detailed design for this associated activity is available a revised IEE and subsequent EMP for this activity should be submitted to ADB for concurrence prior to contract award for water supply construction by TWAD.

10. Confirmation for Tirunelveli Confirmation letter has Obtained Appendix 12 Collection and Municipal been issued by the disposal of Sludge Corporation Tirunelveli Municipal generated from Corporation for the STP installed at disposal of treated sludge Reddiarpatti at Ramaiyanpatti Sewage Resettlement site Treatment Plant (operated and maintained by Tirunelveli Municipal Corporation).

Sl.no Permission/ Competent Remarks Status Reference Clearances/ Authority Declaration 11. Source TWAD Study on the source Ongoing Appendix 21 sustainability study sustainability has been for supply of water conducted by TWAD to to the Reddiarpatti balance water demand resettlement site against water source availability. The study includes testing the water quality

24. Other Environmental Clearance conditions requirements. TNSCB will have to obtain approval for the STP design by an Independent approved third party or by an independent expert / reputed Academic institution for its adequacy and a report in this regard should be submitted to the SEIAA and incorporated into the IEE before contract award or commencement of construction.

25. Clearances/permissions to be obtained by the Contractor. Following table shows the list of clearances/permissions (but not limited to) required for project construction. The contractor should ascertain the requirements prior to start of the construction and obtain all necessary clearances/permission prior to start of construction.

Table 6: Clearances and Permissions Required by the Contractor for Project Construction Sl.no Construction Statutory Statute under which Implementation Supervision Activity Authority Clearance is Required 1. Tree Cutting District Clearances from the Project Project Revenue authorities as per the Implementation Management Department Tamil Nadu Timber Division (PID) Unit (PMU) Transit Rules, 1968 or latest. 2. Batching plants, Tamil Nadu Consent to establish and Contractor PID Crushers and Pollution Control consent to operate under Hot mix plants Board (TNPCB) Air Act, 1981 3. Discharges from TNPCB Consent to establish and Contractor PID Construction consent to operate under activities Water Act, 1974 4. Storage, TNPCB Hazardous Wastes Contractor PID handling and (Management and transport of Handling) Rules. 1989 hazardous Manufacturing, Storage materials and Import of Hazardous Chemicals Rules, 1989 5. Sand mining, Department of Contractor to obtain Contractor PID quarries and Geology and material from the existing borrow areas mining, government licensed Government of mines/quarries; Tamil Nadu Contractor will require prior approval of PID for obtaining material from a particular source. PID to review and approve only existing licensed mines 6. Groundwater Public Works Tamil Nadu Groundwater Contractor PID extraction Department Development and Management Act 2000

Sl.no Construction Statutory Statute under which Implementation Supervision Activity Authority Clearance is Required 7. Disposal of TNPCB Construction and Contractor PID Construction Demolition (C & D) Waste and Demolition Management Rules, 2016 waste Source: MoEF&CC, CPCB, Govt of Tamil Nadu.

C. Applicable International Standards and Best Practices

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

27. The following IFC (World Bank Group) EHS and WHO Guidelines will be adopted in the EMP for the subprojects such as:

(i) WHO Guidelines on Air Emissions and Ambient Air Quality, Noise Management, Wastewater and Ambient Water Quality, (ii) Guidelines for Construction and Decommissioning (2007) (iii) Guidelines for Hazardous Material Management and Waste Management (iv) Good Practice Note: Asbestos: Occupational and Community Health Issues, May 2009 (v) Guidance Note on Workers Accommodation: Processes and Standards, August 200610 (vi) Guidelines on Occupational Health and Safety and Community Health and Safety (2007)

28. Comparison of national emissions standards and International Standards / Best Practices are provided in Table 7, Table 8 and Table 9. Due to different measuring conditions, the emission values are not directly comparable. However, IFC Guidelines / WHO standards are stricter than the national standards if converted to comparable values. The relevant standards applicable to this subproject is identified in the column “applicable per ADB SPS”.

10 IFC Guidance Note: Workers Accommodation

Table 7: National Ambient Air Quality Standards and WHO Guidelines WHO Air Quality Guidelines National (µg/m3) Ambient Air Global Applicable Per Quality Update Second ADB SPS Parameter Location a Standards b 2005 c Edition 2000 d (µg/m3) e Particulate Industrial 60 (Annual) 20 (Annual) - 20 (Annual) Matter Residential, Rural PM10 and Other Areas 100 (24-hr) 50 (24-hr) 50 (24-hr) (µg/m3) Sensitive Area 60 (Annual) 20 (Annual) - 20 (Annual) 100 (24-hr) 50 (24-hr) 50 (24-hr) Particulate Industrial 40 (Annual) 10 (Annual) - 10 (Annual) Matter Residential, Rural PM2.5 and Other Areas 60 (24-hr) 25 (24-hr) 25 (24-hr) (µg/m3) Sensitive Area 40 (Annual) 10 (Annual) 10 (Annual) 60 (24-hr) 25 (24-hr) 25 (24-hr) Sulfur Industrial 50 (Annual) 20 (24-hr) - 50 (Annual) Dioxide Residential, Rural 20 (24-hr) SO2 and Other Areas 80 (24-hr) 500 (10-min) 500 (10-min) (µg/m3) Sensitive Area 20 (Annual) 20 (24-hr) - 20 (Annual) 80 (24-hr) 500 (10-min) 20 (24-hr) 500 (10-min) Nitrogen Industrial 40 (Annual) 40 (Annual) - 40 (Annual) Dioxide Residential, Rural 80 (24-hr) NO2 and Other Areas 80 (24-hr) 200 (1-hr) 200 (1-hr) (µg/m3) Sensitive Area 30 (Annual) 40 (Annual) - 30 (Annual) 80 (24-hr) 200 (1-hr) 80 (24-hr) 200 (1-hr) Carbon Industrial 2,000 (8-hr) - 10,000 (8-hr) 2,000 (8-hr) Monoxide Residential, Rural 4,000 (1-hr) 4,000 (1-hr) CO and Other Areas 100,000 (15-min) 100,000 (15-min) (µg/m3) Sensitive Area 2,000 (8-hr) - 10,000 (8-hr) 2,000 (8-hr) 4,000 (1-hr) 100,000 (15-min) 4,000 (1-hr) 100,000 (15-min) Ozone Industrial 100 (8-hr) 100 (8-hr) - 100 (8-hr) (O3) Residential, Rural (µg/m3) and Other Areas 180 (1-hr) 180 (1-hr) Sensitive Area 100 (8-hr) 100 (8-hr) - 100 (8-hr) 180 (1-hr) 180 (1-hr) Lead (Pb) Industrial, 0.5 (Annual) - 0.5 (Annual) 0.5 (Annual) (µg/m3) Residential, Rural and Other Areas 1.0 (24-hr) 1.0 (24-hr) Sensitive Area 0.5 (Annual) - 0.5 (Annual) 0.5 (Annual) 1.0 (24-hr) 1.0 (24-hr) Ammonia Industrial 100 (Annual) - 100 (Annual) (NH3) Residential, Rural and 400 (24-hr) 400 (24-hr) (µg/m3) Other Areas Sensitive Area 100 (Annual) - - 100 (Annual) 400 (24-hr) 400 (24-hr) Benzene Industrial 5 (Annual) - - 5 (Annual) (C6H6) Residential, Rural (µg/m3) and Other Areas Sensitive Area 5 (Annual) - - 5 (Annual) Benzo(o) Industrial 1 (Annual) - - 1 (Annual) Pyrene Residential, Rural (BaP) and Other Areas

WHO Air Quality Guidelines National (µg/m3) Ambient Air Global Applicable Per Quality Update Second ADB SPS Parameter Location a Standards b 2005 c Edition 2000 d (µg/m3) e (ng/m3) Sensitive Area 1 (Annual) - - 1 (Annual) Arsenic Industrial 6 (Annual) - - 6 (Annual) (As) Residential, Rural (ng/m3) and Other Areas Sensitive Area 60 (Annual) - - 60 (Annual) Nickel (Ni) Industrial 20 (Annual) - - 20 (Annual) (ng/m3) Residential, Rural and Other Areas Sensitive Area 20 (Annual) - - 20 (Annual) a Sensitive area refers to Ecologically sensitive areas notified by the India Central Government b http://cpcb.nic.in/uploads/National_Ambient_Air_Quality_Standards.pdf c WHO Air quality guidelines for particulate matter, ozone, nitrogen dioxide and sulfur dioxide. Global update 2005. WHO. 2006. d Air Quality Guidelines for Europe Second Edition. WHO 2000. e As per ADB SPS, the government shall achieve whichever of the ambient air quality standards is more stringent. If less stringent levels or measures are appropriate in view of specific project circumstances, the executing agency of the government will provide full and detailed justification for any proposed alternatives that are consistent with the requirements presented in ADB SPS.

Table 8: National Noise Standards and WHO Guidelines WHO Guidelines Value Noise Level For Noise Levels Measured Applicable Per Standards a Out of Doors b ADB SPS c Receptor/ (dBA) (One Hour LAeq in dBA) (dBA) Source Day Night 07:00 – 22:00 22:00 – 07:00 Day time Night time Industrial area 75 70 70 70 70 70 Commercial area 65 55 65 55 Residential Area 55 45 55 45 55 45 Silent Zone 50 40 50 40 a Noise Pollution (Regulation and Control) Rules, 2002 as amended up to 2010 (http://cpcb.nic.in/displaypdf.php?id=Tm9pc2UtU3RhbmRhcmRzL25vaXNlX3J1bGVzXzIwMDAucGRm) b Guidelines for Community Noise. WHO. 1999. c As per ADB SPS, the project proponent shall achieve whichever of the ambient air quality standards is more stringent. If less stringent levels or measures are appropriate in view of specific project circumstances, the project proponent will provide full and detailed justification for any proposed alternatives that are consistent with the requirements presented in ADB SPS, 2009.

Table 9: National Drinking Water Quality Standards and WHO Guidelines National Standards for Drinking Water a, b WHO Guidelines Max. for Drinking Concentration Water Quality, Applicable Per Group Parameter Unit Limit 4th Edition, 2011c ADB SPS d, e Physical Turbidity NTU 1 (5) - 1 (5) pH 6.5 – 8.5 None 6.5 – 8.5 Color Hazen Units 5 (15) None 5 (15) Taste and Agreeable - Agreeable Odor TDS mg/l 500 (2,000) - 500 (2,000) Iron mg/l 0.3 - 0.3 Manganese mg/l 0.1 (0.3) - 0.1 (0.3) Arsenic mg/l 0.01 (0.05) 0.01 0.01 Cadmium mg/l 0.003 0.003 0.003 Chromium mg/l 0.05 0.05 0.05 Cyanide mg/l 0.05 None 0.05

National Standards for Drinking Water a, b WHO Guidelines Max. for Drinking Concentration Water Quality, Applicable Per Group Parameter Unit Limit 4th Edition, 2011c ADB SPS d, e Fluoride mg/l 1 (1.5) 1.5 1 (1.5) Lead mg/l 0.01 0.01 0.01 Ammonia mg/l 0.5 none established 0.5 Chemical Chloride mg/l 250 (1,000) none established 250 (1,000) Barium mg/l 0.7 None 0.7 Sulphate mg/l 200 (400) None 200 (400) Nitrate mg/l 45 50 45 Copper mg/l 0.05 (1.5) 2 0.05 (1.5) Total mg/l 200 (600) - 200 (600) Hardness Calcium mg/l 75 (200) - 75 (200) Zinc mg/l 5 (15) none established 5 (15) Mercury mg/l 0.001 0.006 0.001 Aluminum mg/l 0.1 (0.3) none established 0.1 (0.3) Anionic mg/l 0.2 (1.0) None 0.2 (1.0) Detergents Phenolic mg/l 0.001(0.002) None 0.001(0.002) Compounds Residual mg/l 0.2 5 0.2 Chlorine Microbial E-coli MPN/100ml Must not be Must not be Must not be detectable in any detectable in any detectable in any indicator Total Coliform MPN/100ml 100 ml sample 100 ml sample 100 ml Sample a http://cgwb.gov.in/Documents/WQ-standards.pdf. b Bureau of India Standard 10500: 2012 (Indian Standard, Drinking Water — Specification (Second Revision). c Health-based guideline values. d As per ADB SPS, the government shall achieve whichever of the drinking quality standards is more stringent. If less stringent levels or measures are appropriate in view of specific project circumstances, the executing agency of the government will provide full and detailed justification for any proposed alternatives that are consistent with the requirements presented in ADB SPS, 2009. e Figures in parenthesis are maximum limits allowed in the absence of alternate source.

29. Effluent Discharge Standards for Sewage Treatment Plants set by Central Pollution Control Board, Ministry of Environment, Forests and Climate Change, Government of India, Dated 15th April 2015 are provided in Appendix 14 of the EARF. The standards for composting as manure is given in the following table.

Table 10: Standards for Sludge Reuse as Manure

30. The Guidelines for Reuse of STP effluent and sludge are provided in Appendix 16 of the EARF.

31. The Central Pollution Control Board notifications and guidelines for operation of DG sets (that may be used for supporting services) are available at: https://cpcb.nic.in/genset- notifications/

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

(i) Freedom of association and the effective recognition of the right to collective bargaining (ii) Elimination of all forms of forced or compulsory labor (iii) Effective abolition of child labor (iv) Elimination of discrimination in respect of employment and occupation.

D. International Treaties/Conventions/Declarations on Environment Management

33. India is a signatory to the following international treaties/ conventions/ declarations on environment, social, safety and occupational issues that are relevant for the subproject. The list of international agreements is provided in Table 11.

Table 11: International Treaties/ Conventions/ Declarations on Environment Sl. International Treaties/ Conventions/ Description no Declarations 1. United Nations Conference on the To coordinate global efforts to promote sustainability Human Environment - Stockholm 1972 and safeguard the natural environment 2. Convention on International Trade in Its aim is to ensure that international trade in Endangered Species of Wild Fauna specimen of wild animals and plants does not and Flora (CITES), 1975 threaten their survival 3. Ramsar Convention, 1971, 1975 The Convention on Wetlands is the intergovernmental treaty that provides the framework for the conservation and wise use of wetlands and their resources 4. The Basel Convention on the Control The Convention aims to protect human health and of Transboundary Movements of the environment against the adverse effects Hazardous Wastes, 1989 resulting from the generation, transboundary movements and management of hazardous wastes and other wastes 5. Strategic Approach to International SAICM is an international non-binding policy Chemicals Management (SAICM) framework to support efforts to achieve the Johannesburg Plan of Implementation (WSSD) goal for chemicals, notably “achieve by 2020 that chemicals are used & produced in ways that lead to the minimization of adverse effects on human health & the environment” 6. United Nations Conference on The conference had three objectives (Agenda – 21, Environment and Development Rio Declaration and Millennium Development (UNCED), 1992, 2002 Goals), to secure renewed political commitment for sustainable development, to assess the progress and implementation gaps in meeting previous commitments, and to address new and emerging challenges 7. United Nations Framework Convention It operationalizes the United Nations Framework on Climate Change (UNFCCC), 1992 Convention on Climate Change by committing • Kyoto Protocol, 1997 industrialized countries to limit and reduce greenhouse gases (GHG) emissions in accordance with agreed individual targets 8. The Vienna Convention, 1985 It sets binding progressive phase out obligations for • Montreal Protocol on Ozone developed and developing countries for all the major depleting substances, 1992 ozone depleting substances, including chlorofluorocarbons (CFCs), halons and less damaging transitional chemicals such as hydrochlorofluorocarbons (HCFCs) 9. Convention on Biological Diversity, It is an international treaty governing the movement 1992 of living modified organism (LMO) resulting from • Cartagena Protocol on Biosafety, modern biotechnology from one country to another Ratified on 17th January, 2003 10. Convention to Combat Desertification, It is the only binding international agreement linking 1996 environment and development to sustainable soil management 11. Rotterdam Convention on Prior It is a multilateral treaty to promote shared Informed Consent Procedure for responsibilities in relation to importation of certain Hazardous Chemicals in hazardous chemicals International Trade, 2002

Sl. International Treaties/ Conventions/ Description no Declarations 12. Stockholm Convention on Persistent It aims to eliminate or restrict the production and use Organic Pollutants (POPs), 2001 of Persistent Organic Pollutants (POPs)

III. DESCRIPTION OF THE PROJECT

A. Subproject Overview

34. The subproject will be in implemented in Reddiarpatti Village, Palayamkottai Taluk of Tirunelveli District where TNSCB has identified 9 encroachment sites located around 9 tanks/ponds that are vulnerable to flooding. Based on the land availability (preferably government land) in Palayamkottai Taluk, TNSCB has identified Reddiarpatti (8°40'30.13"N, 77°44'56.68"E) in Palayamkottai Taluk as a resettlement site. Coordinates of the 9 encroachment sites are presented in Table 2 in Chapter 1.

35. Figure 3 shows the map of the locations of 9 encroachment sites chosen for relocation, and location of the resettlement site at Reddiarpatti. Area within 10 km radius of the resettlement site is also shown in the map. There are no environmental sensitive areas including protected areas, eco sensitive zones or ecologically sensitive areas notified by the MoEF&CC located within 10 km radius of the resettlement site.

Figure 3: Relocation sites within 10 km radius from Reddiarpatti

36. The selection of sites is based on the following ADB EARF screening criteria.

(i) Key Exclusion Criteria. Reddiarpatti resettlement site, 9 encroachment sites and 9 water bodies (proposed for regeneration) are not falling under the exclusion criteria as suggested in the EARF.

(a) None of the subproject activities (construction, demolition and regeneration) are falling under the Environmental category “A” (b) The subproject areas are not located within the 10km radius national park, sanctuary, wetland, mangrove reserve, biodiversity hotspot, reserve or protected forest area and CRZ zone. (c) The subproject is not falling under the ADB Prohibited Investment Activities List (ADB SPS, 2009, Appendix 5)

(d) The subproject is not highly complex and sensitive11 (e) The subproject activities do not affect the PCRs e.g., local heritage sites / archaeological sites,12 places of worship, etc., (f) The subproject is not located near electricity substations, high voltage transmission lines, underground cables, solid waste dumping yards, Oil /Gas pipelines, Coastal Regulatory Zone hazard line and/or polluting (heavy emissions / noisy) industrial activities (g) Subproject sites are in flood prone areas, areas with a history of flooding.

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

(a) The encroachment sites chosen for relocation are vulnerable for flooding and occupied by the slum dwellers. (b) The resettlement site proposed at Reddiarpatti will host 2124 dwelling units (including 876 dwellings units proposed under ADB financing) for the 807 HH to be evicted from the 9 encroachment sites, which is sufficient to accommodate project beneficiaries / resettled households and community members in line with housing space and design ratio considerations. (c) New site should be within one-hour travel time on public transport from existing settlement sites / encroachments). The resettlement site at Reddiarpatti meets this criterion. Figure 1 in Chapter 1 shows that the resettlement site is located within 10 km from the sites chosen for relocation and they are well connected by roads. Hence the travel time will be less than 1 hour. (d) New site should be within a 2.5 km radius of public amenities or be within prescribed social infrastructure access norms. The resettlement site at Reddiarpatti meets this criterion. The existing public amenities around the resettlement site have been depicted in Error! Reference source not found. in Chapter 1. (e) The subproject is designed to have 10% OSR and 15% green belt area. (f) New site should provide comprehensive infrastructure and supporting services, generate new optimally sited open spaces of adequate size, and community spaces including space for training and community enterprise. (g) Reddiarpatti resettlement site is in conformation to the land use classification, relevant development control regulations and DTCP approved master plan. (h) No new construction of Landfills, electricity generation/ electricity high voltage transmission line and distribution substations are proposed under this subproject. (i) Water source sustainability is maintained through supply of water by TWAD and the quality of the water is as per the IS 10500 (drinking water standard), (j) 1.8 MLD capacity Sewage Treatment Plant is proposed to treat the sewage generated from the Reddiarpatti resettlement site, the treated

11 Projects that ADB deems as highly risky or contentious or involve serious and multidimensional and generally interrelated potential social and/or environmental impacts. 12 ASI clarification is requested for the ancient wall like structure located near to the encroachment site. Based on the recommendations/ suggestions care shall be taken to preserve the wall from damages.

water shall be utilised for gardening, rainwater harvesting, and excess treated water shall be given to the Tirunelveli Municipal Corporation. The sludge generated in the STP shall be further digested to remove the pathogens and the dried sludge will be treated along with the organic waste in the Micro Composting Center (k) Demolition works at 9 encroachment sites will: • exclude religious structures e.g., chapels, temples, mosques, etc. • Involve clearance and fencing around the water body / canal banks13 • avoid cutting of trees • avoid disturbance to PCRs (l) Regeneration works at cleared encroachments includes: • re-greening / re-vegetation along water body / canal banks • clearing and preventing new solid waste / sewage disposal in water bodies / channels

37. The scope of this subproject covers (i) construction, operation and maintenance of 2,124 residential units (including 876 ADB funded dwelling units and 1,248 Government of Tamil Nadu funded dwelling units) and associated facilities at the resettlement site at Reddiarpatti; (ii) demolition of 807 structures located in 9 encroachment sites have been identified for relocation to Reddiarpatti; and (iii) restoration of 9 water bodies, which were encroached by the people needs to be relocated.

B. Proposed Subproject Interventions at the Resettlement Site.

38. Salient features of the resettlement site are presented in Table 12. Photograph of the resettlement site is presented as Figure 4.

Table 12: Salient Features of the Reddiarpatti Resettlement Site Features Description Plinth Area 78,544.42 m2 Built-up Area 85,729.72 m2 Total Housing/ 2,124 (including 876 ADB funded dwelling units and 1,248 Government of Residential Units Tamil Nadu funded dwelling units) Total Occupancy 10,620 persons Administration area The proposed relocation site falls in Reddiarpatti Village, Palayamkottai Taluk of Tirunelveli District Topography The site is located on the hill lock having a gentle slope towards northern direction Road Connectivity It is well connected to NH 7 and located at a distance of 4.5 km from the Tirunelveli city bus terminus Site nearby It abuts private land on one side and is adjacent to an existing TNSCB settlement and upcoming (under construction) TNSCB settlement for about 450 families14 Distance from All the encroachment sites proposed for relocation to this new site are located resettlement site to at a distance of 9 to 10 km (refer Error! Reference source not found.), encroachment sites Environmental No sensitive natural or environmental sensitive receptors are in close sensitivity proximity to the proposed relocation site. The nearest residential units are located at distance of 250m from the site

13 Fencing to ensure that re-encroachment of cleared spaces does not and to derive public benefits from the cleared and restored waterways. 14 The presence of the TNSCB settlements near the project site is also included in the project scope for environmental assessment.

Features Description Electricity TNEB have confirmed to provide electricity to the Reddiarpatti resettlement site for which approximately 10 to 15 transformers will be provided within the resettlement site. Health facilities Primary health care center is located at a distance of 2.5 km Water supply 1279.28KLD of water (as per IS 10500 drinking water standard) will be supplied by the Tamil Nadu Water Supply and Drainage (TWAD). Wastewater 1.8 MLD STP will be constructed within the resettlement site for treating treatment wastewater (grey water and black water) generated from the resettlement site. It is proposed to have Sequencing Batch Reactors (SBR) for treating wastewater. SBR is a variant of Activated Sludge Process (ASP) technology and is essentially a batch treatment through the combination of primary settling, aeration, secondary settling and decanting the treated sewage in a series of sequences. The treated wastewater quality will meet the requirement of the CPCB wastewater discharge standard. The treated water will be utilised for flushing, landscaping purposes and for groundwater recharge. The remaining excess treated water shall be used for watering trees and shrubs around Pallavarayan pond. Solid waste Tirunelveli Municipal Corporation have requested TNSCB to construct 3 MT management capacity Micro Compost Center within the resettlement site to treat the organic waste generated from the resettlement site. For inorganic waste disposal it will be outsourced by the Tirunelveli Municipal Corporation. Treated Sewage Palayamkottoai Panchayat Union has given consent for watering trees and Discharge shrubs around Pallavarayan pond by using the treated sewage generated from the STP located at Reddiarpatti Resettlement site. STP sludge It is proposed to have a sludge digester tank (anaerobic sludge digestion) in management the STP to digest the sludge into dry sludge for further disposal. The treated sludge shall be stored in the sludge drying bed and when it reaches its full capacity, it shall be collected and disposed at Ramaiyanpatti Sewage Treatment Plant (Operated and maintained by Tirunelveli Municipal Corporation).

Figure 4: Photograph of the Resettlement Site

39. The actual requirement for the TNSCB is 876 residential units (refer Table 2), however, as a buffer to accommodate more families under unavoidable circumstances few more residential units has been proposed. This project is planned to construct in two phases. Phase

1 will have G+3 Structures (15 Blocks) and it will be constructed under the state fund. Phase 2 will have G+3 structure for three blocks (B, C and D) which will be funded under the ADB and G+7 for one block, which will be funded under the state fund. Each block will have unique floor plan. Careful planning has been adopted in line with the rules and regulation of the TNSCB. The total land area is estimated to be 8.99 ha (22.21 acres). The split up for land use is given in the following table. The total built-up area proposed under ADB financed housing project is 65,676.93 m2 (including amenities). The proposed master plan for Reddiarpatti site is shown in the

40. Figure 6: Proposed Sewer Line (ADB Portion) 41. .

Table 13: Plinth Area Details of Proposed Residential Units at the Resettlement Site Block No. of Units No. of No. of Total No. Plinth Area Total Plinth Sl.no Phase Type per Floor Floors Blocks of Units per Unit (m2) Area (m2) 1 Phase 1 Q 4 4 15 480 37.16 17,566.50 2 B 8 4 8 256 35.71 9,141.76 3 C 14 4 10 560 36.67 20,535.20 Phase 2 4 D 15 4 1 60 36.78 2,206.80 5 E 16 8 6 768 37.96 29,222.64 Total 40 2124 184.28 78,672.90 Source: TNSCB Layout Drawing for Reddiarpatti Subproject (highlighted blocks are funded by ADB)

Figure 5: Master Plan of the Reddiarpatti (Resettlement Area)

Figure 6: Proposed Sewer Line (ADB Portion)

Figure 7: Proposed Water Supply Line (ADB Portion)

Figure 8: Proposed Storm Water Drain (ADB Portion)

Figure 9: Proposed Green Belt Area

Table 14: Overall Built-up Area Details of the Buildings at the Resettlement Site Sl.no Description Built-up Area (m2) 1 Residential Buildings 78,544.42 2 Other Amenities 2.1 Ration Shop 149.10 2.2 ICDs 258.90 2.3 Commercial Shop 244.90 2.4 Community Hall 1126.00 2.5 V.Center 7.53 2.6 Market 191.10 2.7 Livelihood Center 306.40 2.8 Middle school 1221.00 2.9 Health Sub Centre 87.72 Subtotal 3,592.65 Grand Total 85,729.72

Table 15: Built-up Area Details for ADB Portion Sl.no Description Built-up Area (m2) 1 Residential Buildings 31,883.76 2 Other Amenities 2.1 Ration Shop 151.09 2.2 ICDS 207.12 2.3 Commercial Shop 323.54 2.4 Community Hall 569.72 2.5 V.Center 58.74 2.6 Market 136.21 2.7 Livelihood Center 375.27 2.8 Health Sub Centre 87.72 Subtotal 1,909.41 Grand Total 33,664.69 Source: As per DPR, TNSCB

Table 16: Site Infrastructure Details Sl.no Infrastructure Facilities ADB Portion/ Non ADB Portion/ Section Section 1. Sewer Line (m) 4683 200 2. Water Supply Pipeline (m) 9644 470 3. Storm Water Drain (m) 1383 280 4. Green Belt (m2) 8815.45 5018.00 5. STP (m2) 1260.04 NA 6. Micro Composting (m2) 706.28 NA 7. Internal Road (m2) 3891 4600 8. Streetlights (nos) Lumpsum 60 9. Rainwater Harvesting (Nos) 19 NA 10. Rainwater Harvesting Trench (m) 1125 828 11. Paver block (m2) 8133 2808 Source: TNSCB

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

Table 17: Subproject Interventions at the Resettlement Site Subproject Subproject Interventions Construction and operation of • Main Entry 2,124 residential units (including • Bus Bay 876 residential units funded by • Visitors Centre ADB) and supporting services • Open Market • Community Hall • Convenience Store • Anganwadi • Ration Shop • Fruit Orchard • Community Farming • Hilltop Walk • Hill Walking Path • Discovery Zone • Demonstration Farm • Approach roads and internal roads • Livelihood Centre • Play Park • Outdoor Gym • Surface Parking • Driveway • Sewage Treatment Plant • Rainwater Harvesting Structures • Health Sub Centre • Solar Power streetlights • Solid Waste Management • Micro composting plant Source: TNSCB Layout Drawing for Reddiarpatti Subproject

43. Power Requirement. The power requirement during the project construction will be met through power generators (ranging between 5kW to 200 kW). The generators having emission under control certificates will be permitted in the construction site. The power requirement during operation is estimated to be 2,294 kW and it will be sourced from the nearby TNEB grid (refer to Appendix 7 for Acknowledgement from TNEB for the supply of electricity to the resettlement site) which will be distributed through the transformers located within the premises with an end user connection voltage of 240V. Street lights will be solar powered, providing an energy saving of approximately 6 kW.

Table 18: Overall Power Requirement at the Resettlement Site Sl.no Particulars Unit kW 1 Residential Use No of residential units proposed 2,124 Power required per residential unit (Assuming 1 kW per 1 2,124 residential unit) 2 Pump Room No of Pump Rooms 3 Power requirement for the Pump Room (Assuming 6 kW per 18 Pump Room) 3 STP Assuming power consumption by STP is in the range between 96 95kW to 100kW 4 Streetlight Proposed Street lights 120 Power required for the Street Lights [Assuming 50 W per Street 6 Lamp]

Sl.no Particulars Unit kW 5 Micro Composting Center Power required for shredder, conveyer belt and indoor lighting 50 system Total Power Requirement 2294

Table 19: Power Requirement at the Resettlement Site (ADB Portion) Sl.no Particulars Unit kW Residential Use No of residential units proposed 876 1 Power required per residential unit (Assuming 1 kW per 1 876 residential unit) Pump Room No of Pump Rooms 4 2 Power requirement for the Pump Room (Assuming 6 kW per 24 Pump Room) STP 3 Assuming power consumption by STP is in the range between 95 100 kW to 100 kW 4 Streetlight Proposed Street lights 120 Power required for the Street Lights [Assuming 50 W per Street 6 Lamp] Total Power Requirement 1,006 Source: TNSCB.

44. In the event of power outages, an onsite Diesel Generator (DG Set) of 80 KVA, 415V, 3 Phase, 50 Hz @ 1500 RPM will be used to support STP operation. Stack height of 2 m shall be maintained for 80 KVA DG Set as per TNPCB norms, the height of the stack should be 2 m from the height of the building (height of the building +2 m). The DG set shall be fitted with acoustic enclosures.

45. Water Requirement and Supply. The total water requirement during construction is estimated to be 100L/Day, the source of water for construction shall be arranged by the Contractor through the ULB or the TWAD. The water requirement during operation is estimated to be 1.8MLD (including ADB and Non ADB residential units), which shall be supplied by the TWAD and relevant calculations can be found in Table 20 (Refer Appendix 11 for the commitment letter issued by the TWAD for the supply of water). The water will be sourced from River Tamirabarani at Thirumalaikolundupuram, which is located at a distance of 24 km from the Reddiarpatti resettlement site.

46. The wastewater generation from the project is estimated to be about 1.8MLD (including ADB and Non ADB dwelling units), which will be treated in a proposed Sewage Treatment Plant (STP)15 with a capacity of 1.8MLD. A portion of treated wastewater will be reused for flushing (520.72 KLD) and gardening (303.15 KLD), remaining treated water (967.15 KLD) will be used for watering trees and shrubs around Pallavarayan pond. The assumptions for estimating the water requirement is given in the following table.

Table 20: Water Requirement at the Resettlement Site No. of Total Occupancy S. No. Project Components Units Occupancy Rate @ (Nos.) 1 Residential unit 2124 5 person per unit 10620.0

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

No. of Total Occupancy S. No. Project Components Units Occupancy Rate @ (Nos.) 2 Floating Population 10% of the total 1062.0 residential population 3 Community Hall 2 200 per unit 400.0 4 Anganwadi 5 40 person per unit 200.0 5 Staff and Visitors 10% of the total 20.0 population 6 School 11 40 persons per unit 450.0 7 Staff and Visitors 10% of the total 45.0 population 8 Ration Shop 3 5 person per unit 15.0

9 Convenience Store 25 2 persons per unit 50.0 10 Livelihood center 1 75 person per unit 75.0 11 Health care center 1 5 person per unit 5.0 12 Visitors & Maintenance 10 to 15% from 30.0 Staff Convenience store, Livelihood center, Health care center etc Total Occupancy 12972.0 As per the National Commission on Integrated Water Resources 12972*100 = Development (NCIWRD) norms rural area shall be provided with 75 to 150 12,97,200 Litres Litre Per Capita Per Day (LPCD) have been recommended for the year 2025 (1297.2 KLD) and 2050. For this subproject 100 LPCD has been proposed. Hence the estimated water requirement is 1.3 MLD (1.29 MLD). Green area Development/ landscaping Area for Green area development (13,833 m2) × 3.5 lts/ m2 48,415.5 (KLD) 48.42 (MLD) Rounded 50.0 (MLD) Source: Conceptual Plan, TNSCB.

47. The water supply for domestic purposes (1279.28 KLD) shall be provided by TWAD Board. For the wastewater generated from the resettlement site a 1.8MLD capacity STP with SBR technology has been proposed. The SBR will have two reactors for treating wastewater. The STP process flow chart and SBR structure is given in Figure 11. Nearly 303.15 KLD of treated water will be used for green belt area/ landscaping purposes. From the remaining 1496.47 KLD, nearly 35% of the treated water (after ultra-filtration) will be recycled for flushing and gardening purposes with the remaining 65% will be used for watering trees and shrubs around Pallavarayan pond.

Figure 10: STP Process Flow Diagram and SBR Structure – Water Balance for Reddiarpatti Resettlement Site

48. Rainwater Harvesting (RWH) Structures. As per the Government of Tamil Nadu requirements, amendments made to Section 215 (a) of the Tamil Nadu District Municipalities Act, 1920 and Building Rules 1973, have made it mandatory to provide Rainwater Harvesting (RWH) structures in all new buildings. In view of this, at the Reddiarpatti resettlement site, TNSCB have designed 19 RWH structures/pits and 1125 m2 of rainwater harvesting trenches. The following sections will detail the assumptions and estimations that underpin the design.

Figure 11: Rainwater Harvesting Structure

(i) Rainwater volume estimation (a) As per the secondary information (refer Chapter 4 Description of the Environment) the project district receives annual rainfall of 1050.60 mm (b) The rainfall intensity has been estimated to be 2.87 mm / day (c) The total built-up area is worked out to be 69870.72 m2

(d) Assuming the coefficient of runoff (c) to be 0.90 for concrete surface area, it is expected that Q = c.i.a = 0.90 x 2.87 x 69870.72 = 178.98 m3/day

49. Based on the estimated rainwater volume, 19 RWH structures / pits and 1125 m of rainwater trenches are proposed. The design specifications for the RWH are as follows:

(ii) Rainwater Harvesting Structure. It is proposed to construct 19 RWH structure/pits with a diameter of 1.2m (clear) and height of 2.40m. Each residential block will be connected to the RWH structure/pit. The total volume of rainwater that can be collected by a RWH structure/ pit is estimated to be 2.71 m3, hence 19 RWH structures/ pits will collect 51.54 m3 of rainwater. The structure of the RWH is shown in the Figure 11. (iii) Rainwater Harvesting Trenches. The resettlement site will be provided with 1125 m of rainwater harvesting trenches along the perimeter of the site. The trench will be 1 m wide by 1.5 m deep filled with pebbles. The volume of rainwater that can be collected in the trench is estimated to be 1687.50 m3. (iv) Paver block all-around the buildings. It is proposed to provide paver blocks for the walkway, parking area and surrounding the buildings above a filling of 45cm. The gaps between the paver block will not be sealed, which will allow the rainwater to percolate further into the ground. The total area of the paver block is estimated to be 8133 m2. The volume of rainwater that can be collected by this system is estimated to be 3659.85 m3.

Table 21: Estimated Rainwater Sl.no Infrastructure Quantity Volume of rainwater that can be Collected 1. Rainwater Harvesting Structures/Pits 19 nos 51.57 m3 2. Rainwater Harvesting Trenches 1125 m 1687.50 m3 3. Paver block all-around the buildings 8133 m2 3659.85 m3 Total 5398.89 m3 = 54 Lakh Litres Source: TNSCB

50. Green area development/ landscaping. It is proposed to have landscaping in an area of around 13,833.03 m2 for the whole project site, however for the ADB portion, the green area has been estimated as 8815.45 m2, which constitutes 10.28% of the total area. The allocated green space is indicated in the Figure 9. It is estimated that 303.15 KLD of water is required for landscaping purposes which shall be met through usage of the treated water.

Table 22: Green Area Details Sl. No Green Belt Details m2 1 Green Belt - 1 924.22 2 Green Belt - 2 431.14 3 Green Belt - 3 819.67 4 Green Belt - 4 749.87 5 Green Belt - 5 340.15 6 Green Belt - 6 71.64 7 Green Belt - 7 785.18 8 Green Belt - 8 743.46 9 Green Belt - 9 3,001.00 10 Green Belt - 10 585.93 11 Green Belt - 11 628.23 12 Green Belt - 12 382.11 13 Green Belt - 13 900.57 14 Green Belt - 14 742.62 15 Green Belt - 15 455.28

Sl. No Green Belt Details m2 16 Green Belt - 16 2,172.00 17 Green Belt - 17 99.96 Total 13,833.03

51. Solid Waste Management. Wastes generated from the households will be segregated into bio-degradable waste and non-biodegradable waste at the source itself (by the occupants) in separate bins. It is estimated that 450 kg of MSW will be generated from the resettlement site. For handling the MSW, Tirunelveli Municipal Corporation have requested TNSCB to construct 3 MT capacity Micro Composting Center within the resettlement site and the same should be handed over to the Tirunelveli Municipal Corporation. It is also requested to remit the processing and maintenance charges of the proposed Micro Compost Center under the head of solid waste management Service User Charges (SUC). For inorganic waste disposal it will be outsourced to the Tirunelveli Municipal Corporation. It is also estimated to generate 495 kg of sludge waste (from ADB funded dwelling units and Non ADB dwelling units) per day from the STP. This sludge is considered a hazardous waste without treatment. Hence a sludge digester with a digestion tank will be provided in the STP. This will treat the sludge into a dry form, which will be pathogen free. A sludge drying bed with an area of 189 m2 has been earmarked for drying and storage of treated sludge. The treated sludge from the STP will be stored in the sludge drying bed to its maximum capacity, once the capacity is saturated, the sludge will be treated along with the organic waste in the Micro Composting Center. The treated sludge shall be as per compost quality standard given in the Solid waste management rules 2006 (schedule II A, standards for composting). The Table 23 illustrates the quantity of solid waste likely to be generated during the operation phase.

Figure 12: Layout for Micro Composting Center

Figure 13: Enlarged View of the STP location and Micro Composting Centre

Table 23: Solid Waste Generation at the Resettlement Site Sl.no Solid water Occupancy Per capita Total Solid Total Bio Total Non- generation load Generation waste Degradable Bio sources (kg/day) generation Waste (kg/day) Degradable (kg/day) Waste (kg/day) 1 Residential 10620 0.6 6,372 3,823.2 2,548.8 Units 2 Staff and 1062 0.2 212.3 127.4 84.9 visitors 3 STP Sludge - - 495 495 0 Total (kg/day) 7,079.3 4,445.6 2,633.7 Source: Conceptual Plan

52. Approach Road. The approach road has been designed for 4.5m wide (intermediate lane) which shall have earthen drain on either sides. It is proposed to have WBM as sub base material. The given cross section is typical to a rural road configuration and it is not suitable for heavy vehicle movement. However, for internal roads it is proposed to have 12m wide road with storm water drain provision along with hard shoulders (1.5m), which shall act as a platform for pedestrians.

Figure 14: Typical Cross section for Approach Road and Internal Roads

53. The proposed unit plan and details with respect to the blocks and other amenities are detailed in the master plan presented in Figure 5.

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

54. The following table depicts the proposed interventions for the encroachment sites and the water bodies.

Table 24: Subproject Interventions Sl.no Subproject Subproject Interventions 1 Demolishing structures • Demolition of 807 structures in the 9 encroachment in the encroachment sites site (prone to flooding) • Providing fencing to prevent further encroachment 2 Water body restoration • Clearance and fencing • Restoration of water bodies, which were encroached • Deepening of the ponds/ tanks to restore the water storage capacity • Restoring the catchment area • Provision for public parks/ recreation areas as per the community’s requirement • Avenue plantation/ landscaping

D. Existing Condition of the Encroachment Sites Identified for Relocation

55. Out of 9 encroachment sites (old settlement sites) identified for relocation, a random survey has been conducted at 4 of the sites identified for relocation namely (i) Karupanthurai (at the banks of the Thamirabarani River), (ii) West Kokarakulam (at the banks of the Thamirabarani River), (iii) Elanthakulum and (iv) Pillaikulam by the ADB team. For the remaining 5 relocation sites (v) Meenachipuram, (vi) Mela Veeragavapuram, (vii) Kurundhudaiyarpuram, (viii) Vellakoil and (ix) Vettuvankulam), the TNSCB have conducted surveys. Coordinates of the encroachment sites are provided in Table 2 in Chapter 1. The observations from the 9 encroachment sites are discussed in the below section.

Table 25: Existing Condition of the Encroachment Sites Identified for Relocation Sl.no Location Observations 1 • Dwelling units situated along the banks of the River Thamirabarani • Area faced severe floods in years 1989,1992 and 2015 • Drinking water is supplied through Corporation • Encroachers are not having patta • SWM is maintained by the corporation • Street light facility is provided

Karupanthurai (Encroachment site proposed • Common toilets has been provided; for Relocation) however open defecation is common • Residents do not have patta • Livelihood opportunities available in nearby areas • The nearest Eco sensitive location (Vallanadu Black Buck Wildlife sanctuary) is located at a distance of 20km • The resettlement site (Reddiarpatti) is located at a distance of 7km 2 • Dwelling units are located in the Elanthai Kulam periphery area • Residents do not have patta • Approximately 15m has been encroached in the Elanthai Kulam for the linear section and more than 200m encroached in the nonlinear (front area) section • Concrete structures have been built on the lake-bed after filling

• Religious structures constructed (church / temple) • Situated at a distance of 4.5 km from the proposed relocation site • Drinking water is supplied through corporation; some of the dwelling units are having their own bore well facility • Street light facility is provided • SWM maintained by the corporation. • Common public toilets has been provided; however, open defecation is common • Household wastewater directly discharges into the pond / tank (kulam) • Place of worship on the bund of the pond • The nearest Eco sensitive location (Vallanadu Black Buck Wildlife sanctuary) is located at a distance of 15.25km • The resettlement site (Reddiarpatti) is located at a distance of 4.2km

Elanthai Kulam

Sl.no Location Observations 3 • Dwelling units situated along the banks of the River Thamirabarani • Area faced severe floods in years 1989,1992 and 2015 • Drinking water is supplied through Corporation • Encroachers are not having patta • SWM is maintained by the corporation • Street light facility is provided • Common toilets has been provided; however open defecation is common • Residents do not have patta • Livelihood opportunities available in nearby areas • The nearest Eco sensitive location (Vallanadu Black Buck Wildlife sanctuary) is located at a distance of 19.2km • The resettlement site (Reddiarpatti) is located at a distance of 6.7km

West Kokarakulam (at the banks of the Thamirabarani River) 4 • Dwelling units are located in the Pillaikulam periphery area • Residents do not have patta • Drinking water is supplied through bore well provided with a pump house • SWM is maintained by the Corporation • Some dwelling units have toilet facilities, however these discharge directly into the pond/ tank (kulam).

• Most the dwelling units G+1 ‘pucca’ / concrete structures • Street light facility is provided • Pillaikulam is located at a distance of 13 km from the proposed relocation site • The nearest Eco sensitive location (Vallanadu Black Buck Wildlife sanctuary) is located at a distance of 12.1km • The resettlement site (Reddiarpatti) Pillaikulam is located at a distance of 6.1km 5 • This encroachment site is located on the bank of the River Tamirabarani • It is observed that filling has been done in the water body for extending the encroachment • Street light facility is provided • Solid Waste Management is an issue (not maintained properly).

Sl.no Location Observations • Common public toilets has been provided; however, open defecation is common • Street light facility is provided • Area is prone to flooding • Residents do not have patta • The resettlement site (Reddiarpatti) is located at a distance of 7.2 km • The nearest Eco sensitive location (Vallanadu Black Buck Wildlife sanctuary) is located at a distance of Meenachipuram 18.5km 6 • Dwelling units are located in the embankment of a PWD Pond • Encroachers have filled the water body to extend their land area • Street light facility is provided • Solid Waste Management is an issue (not maintained properly). • Common public toilets have been provided; however, open defecation is common Mela Veeraragavapuram • Most the dwelling units G+1 ‘pucca’ / concrete structures • Residents do not have patta • The resettlement site (Reddiarpatti) is located at a distance of 8.15 km • The nearest Eco sensitive location (Vallanadu Black Buck Wildlife sanctuary) is located at a distance of 17.3km 7 • This encroachment site located on the bank of the River Tamirabarani • It is observed that filling has been done in the water body for extending the encroachment • Street light facility is provided • Drinking water is supplied through bore well provided with a pump house • Solid Waste Management is an issue (not maintained properly). Kurunthudaiyarpuram • Common public toilets has been provided; however, open defecation is common • Most the dwelling units G+1 ‘pucca’ / concrete structures • Residents do not have patta • The resettlement site (Reddiarpatti) is located at a distance of 6.9 km • The nearest Eco sensitive location (Vallanadu Black Buck Wildlife sanctuary) is located at a distance of 18.3km

Sl.no Location Observations 8 • This encroachment site located at a distance of 300m from the River Tamirabarani • Street light facility is provided • Drinking water is supplied through Corporation • Solid Waste Management is an issue (not maintained properly). • Common public toilets have been provided; however, open defecation is common • Residents do not have patta Vellakoil • The resettlement site (Reddiarpatti) is located at a distance of 8.0 km • The nearest Eco sensitive location (Vallanadu Black Buck Wildlife sanctuary) is located at a distance of 15.6km 9 • Dwelling units are located in the embankment of a PWD Pond • Street light facility is provided • Drinking water is supplied through Corporation • Solid Waste Management is an issue (not maintained properly). • Common public toilets has been provided; however, open defecation is common • Residents do not have patta • The resettlement site (Reddiarpatti)

Vettuvankulam is located at a distance of 6.12 km • The nearest Eco sensitive location (Vallanadu Black Buck Wildlife sanctuary) is located at a distance of 14.4km

56. Demolition Works. The 9 encroachment sites having 807 dwelling units identified for relocation shall be demolished manually. Prior to the demolishing activities, the sites/ locations for disposal of the demolished waste shall be identified by the Tirunelveli Municipal Corporation, who will be assisted by the PID (TNSCB). The encroached sites shall be fenced and a monitoring mechanism will be in place to prevent further encroachment. Further revision in the estimated dwelling units at the encroachment sites or change in the approach toward the demolishing activities should be reflected in the IEE and accordingly the EMP also has to be revised.

57. Regeneration Works. The water bodies located within the 9 encroachment sites and its catchment area, which was encroached shall be regenerated and restored. In addition, the inlet to the water body shall be cleared of obstructions and deepening of the water body shall be done. Based on the assessment, enhancement measures like provision of walkway, recreation area, public park area, and children play area shall be explored to make the water body usable to the public. The enhancement measures shall be identified based on the public consultations.

58. Climate Resilience Measures. A study on the Climate Change Risk and Vulnerability Assessment (CRVA) for the IRSHUPSP has been conducted for Climate Risks, Climate Adaptation and Climate Finance. As per the study the resettlement site (Reddiarpatti) does

46 not have physical constraints such as flooding, wildfire and tropical cyclones. This is due to the resettlement site being located away from major rivers and as the site is a dry open area, located on a hilllock with little or no vegetation. As per the proposed layout, the Reddiarpatti resettlement site is designed to have more open space and includes: green space (15.80% of total area) and community farming, fruit orchard and recreation areas (e.g. Outdoor gym, Play Park etc.). The suggested adaptation measures or mitigation measures are as follows:

(i) Water Supply (a) Level of consumption of water may be lowered further using more water efficient appliances, taps, and showerheads; (b) Use drought-tolerant plants to reduce the need for watering the landscaping, increasing water efficiency; (c) Community-based messaging/campaigns to promote water efficiency; (d) To use swales and ponds on parts of the site for effective rainwater harvesting; and (e) To incorporate natural drainage channels and lakes into storm water management plan. (ii) Provision of green space, community farming, livestock (a) Explore improved shading opportunities for community recreation areas, market and milk booth (iii) Roads and pavement areas (a) Reduce area of impermeable surfaces to minimise run-off. (b) Use of pavement materials to ensure resilience to extreme temperatures. (c) Use of permeable materials that provide additional cooling benefits.

E. Project Proposal for the Relocated Sites

59. Project Implementation Schedule. The construction period for the Blocks B, C and D (funded by ADB) Reddiarpatti resettlement site is expected to take 17 to 24 months, which will be followed by 5 years of maintenance period. The expected construction schedule can be seen in Figure 8. For demolition works the scheduled time period will be 6 months and for water body regeneration works the scheduled timeframe varies with respect to the type of proposal (water body beautification, embankment strengthening, restoring the catchment area etc.), from the Tirunelveli Municipal Corporation. However, based on standard routine activities for water body regeneration works it is expected to take between 6 months to 12 months.

Figure 15: Construction Schedule Bar Chart

IV. DESCRIPTION OF THE ENVIRONMENT (BASELINE DATA)

A. Area of Impact

60. The primary areas of impact are (i) sites for proposed project components; (ii) main routes/intersections which will be traversed by construction vehicles; and (iii) quarries and borrow pits as sources of construction materials. The secondary areas of impact are: (i) other than the delineated primary impact area; and (ii) area surrounding the new resettlement site (Reddiarpatti).

B. Methodology used for Environment Baseline Study

61. Data collection and stakeholder consultations. Data for this study has been primarily collected through comprehensive literature survey, discussion with TNSCB, and field visits to the proposed subproject sites. The literature survey has broadly covered the following:

(i) Project details, reports, maps and other documents prepared by TNSCB; (ii) Discussions with technical experts of the ADB team, TNSCB, and other relevant government agencies; (iii) Secondary data from project reports and published articles; and (iv) Literature on land use, soil, geology, hydrology, climate, socioeconomic profiles, and other planning documents collected from government agencies and websites.

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

C. Physical Environment

a) Location, Area and Connectivity

63. Reddiarpatti is located in Palayamkottai Block of Tirunelveli district16 in Tamil Nadu. The geo coordinates of Reddiarpatti is 8°40'30.13"N, 77°44'56.68"E. It is positioned in a semi urban area of Tirunelveli district of Tamil Nadu, it is one of the 47 villages of Palayamkottai Block of Tirunelveli district. The resettlement site is located at a distance 12.5 km from the Tirunelvel Town. The site is located on a hill lock, on the Southern direction, National Highways 44 traverses through the resettlement site at a distance of 600 m. There is no development or settlements in the Eastern direction. However, towards the Northern direction and the Western direction, considerable number of settlements are observed in the Thirumal nagar (500 m from the resettlement site) and Mahilchi Nagar (1km from the resettlement site) respectively.

64. All the sites chosen for relocation are located within 10 km from the resettlement site at Reddiarpatti. Coordinates of the encroachment sites are given in Table 2 in Chapter 1. Total area of the resettlement site (as per FMB) is 90,366 m2 (9.03 ha). The land is owned by Government of Tamil Nadu. None of the construction sites, including Reddiarpatti resettlement

16 Tirunelveli is the sixth largest city in Tamil Nadu after Chennai, Madurai, Coimbatore, Trichy and Salem. Geographically, it is located at 8°43′41.82″N 77°41′43.94″E. Tirunelveli City Municipal Corporation was constituted in 1994 and for administrative purposes, municipal area has been divided in to four zones namely: Tirunelveli, Thachanallur, Palayamkottai, and Melapalayam. The administrative area of Tirunelveli City Corporation is 108.65 km2, population according to 2011 census was 473,637. The project area (Reddiarpatti) comes under the Tirunelveli zone.

49 site and all 9 encroachment sites, are located near or in the vicinity of the Archaeological Survey of India (ASI) identified monuments or heritage buildings.

Figure 16: Reddiarpatti (Project area) Location

65. The project area is well connected by the presence of National Highways 44 (Kashmir to Kanyakumari Road), which is one of the longest highways in India. Other interior roads also connect the resettlement site with the rest of the Tirunelveli towns.

b) Topography, Soils and Geology

66. The resettlement site in Reddiarpatti is located in a small hillock. The maximum elevation is at 84m AMSL and the lowest is 74m AMSL. There is a gentle slope towards the northern direction. As can be seen in Figure 17, it is clearly evident that there is a slope on either side from the site. Hence, cut and fill is unavoidable. The slope extends toward the Tamirabarani River in the east.

Figure 17: Elevation profile for the Resettlement site at Reddiarpatti

67. In Tirunelveli, the soil type has been classified into: i) Deep Red soil; ii) Red Sandy Soil; iii) Black Cotton Soil; iv) Saline Coastal Alluvium; and v) River Alluvium. In the resettlement area, the soil type is Deep Red soil, which is suitable for cultivating coconut and palmyrah trees.

68. As per the study conducted by the Central Groundwater Board (CGWB), Tirunelveli district has a wide variety of geological formations ranging from Precambrian to recent period. The rock types within the district can be broadly classified into (i) Charnokite group of rocks; (ii) Gneissic group of rocks; (iii) Shell limestone, (iv) Tuffaceous kankar and (v) Tertiary kankar. Project area has predominant zone of quartzite beds and associated crystalline limestone and

50 calc gneisses with intercalated layers and bands of pyroxene granulite’s within the quartzite beds.

c) Climate and Rainfall

69. Tirunelveli experiences a tropical climate. The maximum temperature is 39.4°C in the month of May and minimum is 21.7°C in the month of January. From the middle of February, the temperature increases gradually. The weather is quite hot in the month of April to June. Sometimes reaches 42.5°C. With the onset of the southwest monsoon by beginning of June, there is some drop-in temperature. The period from November to January is the coolest part of the year.

70. There are two principle monsoon seasons: southwest (June to August/Sept) and northeast monsoons (October to January). Tirunelveli receives an annual average rainfall of 845.1 mm. The average rain fall in the district is 845.1 mm, most of which is received during the northeast monsoon. Much higher rainfall, above 1000 mm per year, is received in the district that are close to Western Ghats.

Figure 18: Annual Rainfall Distribution in the Reddiarpatti (Project Area)

Table 26: Rainfall information for Tirunelveli District Year South West North-East Winter Hot Total % Deviation Monsoon Monsoon Season Weather from Normal Season (+ or – or =) from Normal Normal Actual Normal Actual Normal Actual Normal Actual Normal Actual 2011-12 142.4 107.7 467.2 639.9 69.3 70.7 166.2 100.7 845.1 919 8.75 2012-13 142.2 36.9 467.2 515.8 69.3 98.9 166.2 169.7 844.9 821.3 -2.8 2013-14 142.4 237 467.2 412.8 69.3 70.4 166.2 314.1 845.1 1034 22.39 2014-15 142.4 118.8 467.2 847.5 69.3 19.5 166.2 317.9 845.1 1304 54.27 2015-16 142.4 158.8 467.2 1051 69.3 6.8 166.2 111.1 845.1 1333 58 2016-17 142.4 77.32 467.2 178.8 69.3 42 166.2 84.96 845.1 383.1 -54.67 2017-18 142.4 212.6 467.2 665.5 69.3 25.8 166.2 84.96 845.1 988.9 17.01 Source: Department of Economics and Statistics, Chennai

71. Winds are generally light to moderate in strength. The wind direction is predominantly towards North and West in the mornings and South and East in the evenings. Between May and September winds are mainly north westerly or westerly and from October to February winds are mainly north easterly or easterly. During the months of April and May, the weather is often cloudy for many days until thunderstorms occur. In the southwest and northwest monsoon seasons, the sky is heavily clouded or overcast.

72. Humidity is the highest during the period of October-December and found to be the highest in the month of November with 98% humidity and the minimum occurs in May at 29%. The relative humidity in general, during the year, is between 56.6% and 72.9% in the district, except during the northeast monsoon season, when it is over 74.3%.

d) Seismicity

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

Figure 19: Seismic Map for Reddiarpatti Project Area

e) Land Use

74. The landuse pattern of the project area (Reddiarpatti) has been assessed through the Bhuvan17 Map. The project is falling under the urban built-up which is surrounded by the barren area and scrub forest. Majority of the land use belongs to built-up, which is followed by agriculture and forest area. The 9 encroachment sites are located in urban built-up area (within Tirunelveli Municipal Corporation limit). TNSCB have constructed some residential apartments near the Reddiarpati project area, which is located at a distance of 50 m.

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

Figure 20: Land Use Pattern (Google earth image and Bhuvan Land Use map) of the Subproject Area

f) Drainage System

75. Thamarabarani, Nambiar, Chittar and Karamaniar are the important rivers draining the Tirunelveli district, which originates from the Western Ghats and runs across the gentle slopes of the mid lands and confluence in Bay of Bengal. Out of five rivers, River Tamirabarani18 is located in the eastern direction and it is 7km from the Reddiarpatti site. It acts as the main drainage point in the project area. As discussed in the topography section, the slope from the site is towards the River Tamirabarani, which is the main source of irrigation as well as provides drinking water facilities to the settlements in the Tirunelveli district. In the encroachment sites, due to the presence of the structures (dwelling units), the catchment area of the water bodies has been affected.

18 Tamirabarani is a perennial river; originating from Agastyarkoodam peak in the Western Ghats above Papanasam in Ambasamudram Taluk and flows through Tirunelveli and Tuticorin districts of Tamil Nadu and drains in Gulf of Mannar.

g) Surface Water

76. Elandhakulam is the nearest surface water body located in the northern side at a distance of 6 km from the project site and River Tamirabarani is located in the eastern side at a distance of 7km. The project area lies within the watershed expanse of the Tamirabarani River Basin. The water from the River Tamirabarani is treated and supplied to the settlements in the Tirunelveli District, similarly, in near future, the water supply to the Reddiarpatti (project area) shall be arranged from the same river source.

77. Water quality of surface water bodies is classified by Central Pollution Control Board into five (A, B, C, D and E, see Table 27) quality classes according to their quality suitability for designated best use. Water quality monitoring of River Tamirabarani is conducted regularly by TNPCB and samples are collected regularly from 12 sampling points. According to the water quality data collected for the period 2014 to 2015, the river water quality is classified as “B”. Annual average value of pH of water ranges between 6.2 and 7.7, Biochemical oxygen Demand (BOD) ranges between 2.0 and 5.0 mg/l. At Authoor and Eral the TDS concentration was recorded high (878 mg/l and 347 mg/l respectively). The presence of Coliforms was observed in all the samples, indicating the contamination due to the sewage inlet into the river. None of these monitoring stations are located near to the project area. The closest monitoring station to the project site is Kokirakulam, which is located at distance of 6.8 km. These are located far up stream or far down stream of the Tirunelveli City. In comparison with the WHO water quality standard, except Manganese all other water quality parameters are within the stipulated limits.

Table 27: Central Pollution Control Board

Table 28: Tamirabarani River Water Quality (annual average values), 2014-2015 Sl. No. Parameters Units Cheranm Kokira Murapa Thiruvidai Amba Authoor Eral Kallidai ADB SPS devi kulam nadu marudur samudram Kurichi EARF 1 DO mg/l 6 6 7 7 7 7 7 7 - 2 BOD at 27°C mg/l 3 3 2 3 5 3 2 3 - 3 COD mg/l 33.33 38.67 28.67 33.33 29.33 41.33 29.33 32.67 -

4 pH 6.4 6.5 6.8 7.7 7.7 7.2 7 6.2 6.5 to 8.5 5 EC mhos/ 110 144 220 80 65 1281 473 74 - cm 6 Ca++ mg/l 26.58 32.25 67.0 16.17 12.08 117.7 92.25 14.75 75 7 Mg2+ mg/l 9.0 12.0 31.0 6.58 5.75 115.3 46.67 7.08 0.1 8 Na+ mg/l 8.33 10.25 13.17 5.83 4.86 106.30 24.83 5.25 - 9 K+ mg/l 1.5 2.1 2.6 1.3 1.3 10.8 4.7 1.3 - 3- 10 PO4 mg/l 0.12 0.13 0.07 0.09 0.14 0.09 0.08 0.13 - 11 NO3- mg/l 0.19 0.35 2.16 0.24 0.11 0.45 0.24 0.2 45 2+ 12 SO4 mg/l 11.69 14.67 14.43 9.23 6.97 52 18.7 9.06 200 13 Cl- mg/l 15.46 17.63 25.08 12.97 10.72 367.9 41.67 11.55 250 14 F- mg/l 0.01 0.01 0.01 0.01 0.01 0.01 0.01 0.01 1 15 Total Alkalinity mg/l 37.92 45.13 83.5 25.42 18.00 142.0 119.5 23.92 - 16 TDS mg/l 80.5 105.5 158.17 59.17 49.5 878.0 347.17 55.5 500 17 Turbidity NTU 6.75 6.0 4.75 5.0 4.5 5.83 6.0 5.0 1 18 Total Coliform MPN/ 56.0 82.0 45.0 45.0 46.0 62.0 60.0 52.0 Must not be 100 ml detectable in any 100 ml sample BOD = biochemical oxygen demand, COD = chemical oxygen demand, DO = dissolved oxygen, mg/l = milligram per liter, ml = milliliter, MPN = most probable number, NTU = Nephelometric Turbidity Unit, pH = potential of hydrogen, TDS = total dissolved solids. Source: Tamil Nadu Pollution Control Board.

h) Groundwater

78. Tirunelveli district is underlined by both porous and fissured formations. The important aquifer systems in the district are created by Weathered and fractured hard rock formations of Archaean age and Porous sedimentary formations ranging in age from Tertiary and Recent. The porous formations are found as small patch in the south-eastern part of the district. The porous sedimentary river alluvium is found along the river courses and the thickness of alluvium is restricted to 5-6 m.

79. As per the Central Groundwater Board (CGWB) study, the thickness of weathered zone in the Tirunelveli district is up to 30 meter below ground level (mbgl). The groundwater exploration in the district downs to a depth of 200 mbgl by CGWB has revealed that in the western part of the district potential fractures are encountered beyond 100 mbgl while in the rest of the area, potential fractures are restricted to 100 mbgl. The well yield is in the range of 63 to 270 litres per minute. The depth to water level in the district varies between 1.19 to 13.35 mbgl during pre-monsoon; depth to water level varies between 0.18 to 7.97 mbgl during post monsoon. The seasonal fluctuation shows a fall in water level, which ranges from -0.12 to - 2.14 mbgl, and rise in water level, which ranges from 0.33 to 11.24 mbgl.

80. As per the information collected from the National Remote Sensing Centre (BHUVAN), Reddiarpatti is falling under the ground water scarce area. It is depicted in the following Error! Reference source not found.. As an enhancement measure rainwater harvesting structures are proposed at each building blocks as well as in surface water drains.

Figure 21: Groundwater Prospects for Reddiarpatti Subproject Area

81. Groundwater quality in Tirunelveli town is good, in general it is colorless, odorless and slightly alkaline in nature. Following table presents the groundwater quality data from the wells located in four localities of the town. Absence of coliforms indicates the water is free from sewage/ wastewater contamination. All the physico-chemical parameters are within the drinking water standards specified by Bureau of Indian Standards (BIS) and WHO water quality standard.

Table 29: Groundwater Quality in Tirunelveli, 2014 Sl.no Parameters Units BIS standard Sankarnagar Vannar Rajagopalapuram IOB pettai Colony 1 Total hardness mg/l 300-600 220 52 310 328 2 pH 6.5 - 8.5 7.68 8.14 7.05 7.56 3 EC  - 789 135 1042 980 4 Ca++ mg/l 75-200 50 12 88 85 5 Mg2+ mg/l 30 - 100 23 5 22 28 6 Na+ mg/l 200 75 7 88 75 7 K+ mg/l - 15 2 19 13 3- 8 PO4 mg/l - 0.21 0.02 0.27 0.16 9 NO3- mg/l 45-100 3 0 6 6 2- 10 SO4 mg/l 200-400 41 4 44 26 11 CL- mg/l 250 90 14 140 146 12 F- mg/l 0.1 – 1.5 0.8 0.1 0.1 0 13 Total Alkalinity mg/l - 232 42 280 240 14 TDS mg/l 500-2000 536 95 708 667

i) Ambient Air Quality and Noise levels

82. Regular monitoring for ambient air quality and noise levels are not conducted by the TNPCB in Tirunelveli. Following data shows the random monitoring conducted for 24 hours by TNCPB/CPCB to record air quality and noise level in 2019. The data shows the oxides of sulphur and nitrogen in the ambient air is well below the ambient air quality standards, however, particular matter (PM10) is above the standard level in Tirunelveli town. Dry weather conditions coupled with poor road surface and traffic contribute to the high particulate matter in ambient air. In comparison with WHO air quality standard, the PM10 concentration recorded at Tirunelveli Town is relatively high, however other AAQ parameters are well within the limits.

Table 30: Ambient Air Quality in Tirunelveli AAQ WHO Locations Sl.no Parameters Standard standard Tirunelveli Town Pettai 1 Particulate Matter (PM10) 65 45 50 60 2 Particulate Matter (PM2.5) 15 12 25 100 3 Oxides of sulphur (SOx) 13 9 20 80 4 Oxides of Nitrogen (NOx) 21 15 80 80 Source: TNPCB/ Air Quality

83. Regular ambient noise level monitoring conducted by the Tamil Nadu Pollution Control Board indicate that ambient noise levels are much higher than the notified noise standards and World Bank Group’s Environmental, Health and Safety Noise Level Guidelines in residential and commercial zones.

Table 31: Ambient Noise Levels in Tirunelveli Sl.no Location Leq Day Time Leq Night Time 1 Tirunelveli Town (Residential) 61.8 57.9 2 Pettai (commercial) 56.8 54.3 Noise quality Standard Residential 55.0 45.0 (CPCB) Commercial 65.0 55.0 WHO Standards for Industrial 70.0 70.0 Noise Residential 55.0 45.0 Source: TNPCB/ Ambient Noise Levels

D. Biological Environment

84. Tirunelveli is an urban area surrounded by land that was converted from agricultural use many years ago. There is no remaining natural habitat in the town. The flora is limited to artificially planted trees and shrubs and the fauna comprises of domesticated animals (cows, goats, pigs and chickens), plus other species are able to live close to man (urban birds and rodents). River Tamirabarani, which flows through the town, is an important part of its ecosystem and it is 7km from Reddiarpatti. River Tamirabarani, has high seasonal fluctuations inflows, with very high flow during monsoon to or linear flow/ no flow during summers.

85. As per the IBAT study (refer Appendix 15), the Vellanadu Blackbuck Wildlife Sanctuary is located at a distance of 10 km from the Reddiarpatti resettlement site, however as per the Google Earth as well as the forest maps, it is located at a distance of 15.4km. Another wildlife sanctuary (Koonthankulam BirdSanctuary), is located at a distance of 20 km from the Reddiarpatti resettlement site. Considering the forest department information, it shall be concluded that there are no protected areas, eco sensitive zones or ecologically sensitive areas notified by MoEF&CC within a radius of 10 km from the Reddiarpatti resettlement site.

86. As per the MoEF&CC guideline for Eco Sensitive Zone, there are no sensitive areas like forest or protected areas located at a radius of 10 km surrounding from the Reddiarpatti (project area). Vallanadu Blackbuck Wildlife Sanctuary is the nearest to the Reddiarpatti project area, which is located at a distance of 15.4 km. Which is followed by Koonthankulam Bird Sanctuary, which is located at a distance of nearly 20 km.

87. Vallanadu Blackbusk Wildlife Sanctuary. The Vallanadu Blackbuck Sanctuary is an isolated hillock with scrub forest in Thoothukudi Revenue District situated on eastern side of Tirunelveli – Tuticorin highway. The Vallanadu Wildlife Sanctuary is a protected area by the Tamil Nadu Forest Department. It is created for the protection of blackbuck antelope and it is spread over an area of 16.41 km2. Thorny hardwood and xerophytes (Dalbergia horrida (see Dalbergia), Dichrostachys cinerea, Vachellia horrida, Acacia planifrons, Albizia amara, Zizyphus sp. and a few Azadirachta indica, Dodonia viscosa[clarification needed], Carissa carandas, Pterolobium hexapetalum, Euphorbia, Acalypha fruticosa and Ocimum tenuiflorum) are predominantly observed in this sanctuary. Apart from the xerophytes, some of the common trees observed are jackfruit, betel nut palm, Jamun and Mangoes. The dominating faunal species are Blackbuck (Antilope cervicapra), Spotted deer (Axis axis), Macaque monkey (Macaca mulatta), Jungle cat (Felis chaus), common monkey (Macaca sinica), Wild cat (Felis silvestris), Mongoose (Herpestes edwardsi), Black naped hare (Lepus nigricollis), Scaly anteater (Manis crassicaudata), Viper snake (Crotalus horridus) and Rat snake (Ptyas mucosa).

Figure 22: Location of Vallanadu Blackbuck Wildlife Sanctuary

88. Koonthankulam Bird Sanctuary: It is located 35 km (by road) away from Tirunelveli in Tirunelveli Thisaianvilai Road comprising of Koonthankulam and Kadankulam. It is declared as a sanctuary in 1994 and it is spread over an area of 1.29 km2. Migratory birds start coming by December end and fly away to their northern homes by June or July after they lay eggs, hatch them and the young ones grow old enough to fly with the older ones. The migratory birds includes Bar-headed goose (Anser indicus), Common sandpiper (Actitis hypoleucos), Common teal (nas crecca), Coot (Fulica atra), Green sandpiper (Tringa ochropus), Greater flamingo (Phoenicopterus roseus), Northern pintail (Anas acuta) and White stork (Ciconia ciconia).

Figure 23: Location of Koonthankulam Wildlife Sanctuary

E. Social Environment

a) Demographic Profile

89. All the 9 encroachments are located within the Tirunelveli Municipal Corporation. It covers an area of 108.65 km². As of 2011 India census, Tirunelveli Municipal Corporation has a population of 473,637 of which 233,659 are male while 239,978 are female. Population of Children with an age of 0-6 is 46,624 which is 9.84 % of total population. Female Sex Ratio is 1027 against the state average of 996. Moreover, the Child Sex Ratio is around 951 compared to Tamil Nadu state average of 943. Literacy rate is 90.39 %, which is higher than the state average of 80.09 %. The male literacy rate is around 94.75 % while female literacy rate is 86.18 %. The growth rate of urban agglomeration19 is 20.22%.

90. According to Census 2011, Reddiarpatti's population is 5,166. Out of this, 2,629 are males while females make up 2,537. This village has 577 children in the age bracket of 0-6 years among them 298 are boys and 279 are girls. Literacy rates in Reddiarpatti village is 77%. 3,983 out of a total of 5166 population are literate. Among males the literacy rate is 81% as 2,154 males out of total 2,629 are literate while female literacy rate is 72% as 1,829 out of total 2,537 females are educated in this Village. The negative side is that illiteracy rate of Reddiarpatti village is 22%. Here 1,183 out of total 5,166 people are illiterate. Male illiteracy rate is 18% as 475 males out of total 2,629 are uneducated. In females the illiteracy rate is 27% and 708 out of total 2,537 females are illiterate in this village. In Reddiarpatti village out of total population, 2083 are engaged in work activities. 78.54 % of workers describe their work as Main Work (Employment or Earning more than 6 Months) while 21.46 % are involved in Marginal activity providing livelihood for less than 6 months. Of 2083 workers engaged in Main Work, 64 are cultivators (owner or co-owner) while 116 are agricultural labourer.

b) Socio-Economic Features

91. The economy of Tirunelveli district is chiefly agro based, given its vast agricultural hinterland. It is also rich in mineral resources like limestone, garnet sand etc. that contribute to the region’s economy. Small Industrial Development Corporation (SIDCO) has developed an Industrial estate in the Pettai area on the northern part of the city. The city has the distinction of having the first spinning mill established under co-operative movement at Pettai in 1958. Tamilnadu Sugar Corporation limited has established a factory at Tirunelveli. Due to limestone deposits, there are cement factories in the vicinity of the city.

92. There are 25 medium and major industries such as Cement, Cotton yarn, Sugar, Rice bran oil, Printing papers and flour Mill etc. Beedi rolling, safety matches making, mat weaving and processing and manufacturing of palm fibre and articles from Palm trees and hand loom weaving of textiles are the main household industries that are found in the city and its adjoining hinterland. Some of the famous products from Tirunelveli area include: Korai mats from Pathamadi, Kallidaikurichi Pappads, Karukurichi mud pots.

93. The river and the centuries old irrigation system associated with it, have made Tirunelveli district, a major ‘rice bowl’ of Tamil Nadu. The primary crops grown in the region are paddy and cotton; people are also engaged in the cultivation of spices and condiments (like cumbu, ragi) groundnut, pulses, gingelly, coconut, chilies, and indigo. The most common tree is the Palmyra palm, a raw material in cottage industries.

19 An urban agglomeration is a continuous urban spread constituting a town and its adjoining outgrowths (OGs), or two or more physically contiguous towns together with or without outgrowths of such towns.

Table 32: MSME Industrial Units in Tirunelveli City – Zone wise Sl.no Zones Number of Micro, Small and Medium Scale Establishment Units 1 Thatchanallur Zone 37 2 Palayamkottai Zone 66 3 Melapalayam Zone 31 4 Tirunelveli Zone 60 Total 194 Source: MSME, Tirunelveli District

c) Infrastructure

94. Water Supply. The main source of water supply for Tirunelveli Corporation is from River Tamirabarani. About 55 MLD of treated water is supplied to the city with per capita supply of 116 lpcd from 11 head works, covering 55 wards. A new water supply scheme by proposing Ariyanayagipuram Anicut across River Tamirabarani has been designed to meet the growing demand of the Tirunelveli Municipal Corporation area that envisages supply of 135 LPCD.

95. Sewerage. Tirunelveli town and the junction (area around the railway station) of the corporation area has had an underground drainage system installed since 1989. The corporation is divided into 4 Administrative zones. The sewage generated from each zone is collected through a network of street sewers to a collection well. The sewage collected in each zone is pumped to the sewage treatment plant constructed at Ramaiyanpattai of capacity 24.20 MLD. The treated effluent is let into the open channel and utilized for Agriculture. The total length of sewer line is 187.27 km with 7,924 manholes. The total number of house service connections is 22,226. The Underground sewerage System (UGSS) is proposed and the work is in progress near the project site.

96. Solid Waste Management. Sanitation in the Tirunelveli Municipal Corporation is effectively operated by 17 sanitary units. About 100 metric tonnes of solid waste is collected from the city daily by door-to-door collection. The per capita waste generation is about 350 gram per day and total generation is around 180 tons per day.

97. Transportation. The project site is well connected by road, rail and air ways. The proposed project is located nearer to Varanasi to Kanyakumari highway road (NH-7). Palayam Kottai Railway Station is station is located at 4.41 km, NW direction from the project site. Reddiarpatti bus stand is 0.94 km from the project site. The closest airport to the city is the Thoothukkudi airport (28 km), located at Vaagaikulam in Thoothukkudi district.

98. Hospitals. There are many government and private hospitals and small clinics that are available in the Reddiarpatti. Few of them are Arogya Vanam Health Centre, Savera Dental Care, JK Hospital and Primary Health Center are located less than a kilometre from the resettlement site.

99. Education Institutions. Reddiarpatti is a school cluster in Palayamkottai Rural block of Tirunelveli district, the project area has about 20 schools. This cluster includes private and government schools. Some of the well-known schools includes Good Shepherd School, Rose Mary Matric. Higher. Secondary. School, Sri Jayendra Swamigal Silver Jubilee School, Apple Kids International Pre School, High School for the Blind, Pushpalata British International School, A.U.P.E.T. Chinmaya Vidyalaya, Adithya Vidhya Niketan School and Sringeri Sarada Vidyalaya Matriculation Higher Secondary School (nearest to the resettlement site located at a distance of 2.5km).

d) Cultural and Heritage sites

100. Tirunelveli has many Temples, Nellaiappar Temple being the most prominent and it is located at a distance of 11.5 km (aerial distance) from the Reddiarpatti resettlement site. The nearest encroachment site is Meenachipuram which is located at a distance of 2 km (aerial distance). However, it is not an ASI protected monument. There are seven monuments protected by the ASI out of which 4 comes under the national monuments and the remaining 3 comes under state protected monuments. The following table depicts the monument importance and distance from the Reddiarpatti site.

Table 33: Information on the Archaeological Monuments Sl.no Protected Monument Location Distance from Reddiarpatti ( km) National Monuments 1 Bhaktavatsala Temple Cheranmahadevi 20.20 2 Valisvara Temple Tiruvalisvaram 25.20 3 Two rock cut temples with inscriptions in Thirumalapuram 46.60 Varunachimalai 4 Ancient Site Kunnathur 8.80 State Protected Monuments 5 Poola Udaiyar Inscription and Bed Pandian 53.20 kudiyiruppu 6 Iranyan kudiyiruppu Nanguneri 22.45 7 Tiruneelakandar Temple Pananjadi 15.60 Source: ASI

101. It is evident from the given information, that none of the ASI sites are in the near vicinity to the Reddiarpatti. Hence, implementation of the project will not have any impact.

Figure 24: National Monuments surrounding the Project Area

V. ANALYSIS OF ALTERNATIVES

102. During project preparation, comprising of screening and design preparation, various alternatives were identified and analysed to help in decision making.

A. With and Without project alternatives

103. The “With” project scenario has positive beneficial impacts on the encroachers living conditions. It will remove encroachments on existing waterways helping to improve the environment and also relocate vulnerable people into areas which are not flood prone and into appropriate housing helping to reduce their risk to disaster and improve their livelihood opportunities. In comparison, the “Without” project scenario can lead to further deterioration of the living conditions and quality of life of the present encroachers while adversely impacting the surrounding environmental conditions. Other factors like infrastructure development, and other project benefits were also taken into consideration in analysing the with and without project scenarios.

B. With Project Scenario.

104. The proposed Reddiarpatti resettlement site project shall have 2,124 residential units, which will accommodate encroachers from 9 encroachment sites who are at heightened risk of natural hazards due to their encroachment of existing waterways or water bodies. A number of resettlement sites were investigated with the ultimate location being determined due to its locational advantages and government ownership of land. Tirunelveli town/city is located at a distance of 7 to 8.5km, which is accessible via State highways and National highways. There are a number of schools, hospitals and other commercial establishments located in the vicinity that can also be accessed. The resettlement site is designed to have all the essential amenities which includes:

(i) Water supply and road network (ii) Grand Boulevard (iii) Electricity (iv) Landscaping/ green area with ample OSR (v) Sewage treatment plant and Municipal solid waste management (vi) Children play area (vii) Convenience shop (viii) Ration shop (ix) Anganwadi (x) Community Hall (xi) Livelihood Center and Library (xii) Health Sub Centre (xiii) Market (xiv) Bus Bay (xv) Visitors Centre (xvi) Community Farming (xvii) Hill Walking Path (xviii) Storm water drains (xix) Outdoor Gym (xx) Rainwater Harvesting Structures (xxi) Solar Power streetlights

105. Subproject benefits. The proposed STP will treat the wastewater generated from the resettlement sites and has been designed to recycle the treated water for flushing and gardening purposes, which will reduce the actual water demand and have beneficial impacts on the environment (through recycling and reuse). Solar powered streetlights have been

63 proposed within the resettlement sites, which will marginally reduce the use of TNEB power supply. Internal roads have been designed with storm water drains that will prevent flooding/ ponding of water within the resettlement site. It is proposed to have rainwater harvesting pits/ structures surrounding the residential blocks as well as in common areas to tap the rainwater to increase the groundwater recharge potential. It is planned to have native floral species in the green area/ landscaping areas. 5 years of periodic operation and maintenance has been proposed.

106. A graduation program shall be conducted for the relocated people to improve self- sustainability and to access to better economic opportunities that will help to improve living standards. This subproject also aims to improve the gender balance and women empowerment by assisting the women in the family, women headed households and elderly people through skill development training programs (under the Tamil Nadu Skill Development Corporation).

C. Without Project Scenario

107. As per the field visits undertaken as part of due diligence, some of the problems associated with encroachers are as follows

(i) substandard housing and lack of hygiene; (ii) significant health risks (due to mosquito breeding and spread of vector borne diseases); (iii) They lack basic facilities like road, electricity and drinking water (iv) The illegal nature of housing makes encroachers susceptible to extortion (v) They are more prone to disasters like urban floods

108. Key Social issues. It is evident from the site visits, that none of the encroachment sites are provided with a household connection to water supply as a common water tap is provided for the entire community of slum dwellers at a distance of 500 m to 1 km (min distance). This is a difficult situation especially for women. All the encroachment sites do not have basic infrastructure facilities as those that are available are too far for people or are poorly designed and in unhygienic conditions. The quality of life is observed to be below average, as most of them are working as daily labours. The dwelling structures do not have strength to withstand climate hazards (including heavy rain, wind and increase in temperature). The approach roads are too narrow and are without streetlights, which is not safe for the night time road users especially women.

109. Key Environmental issues. The catchment area of the water bodies has been encroached and as a result the natural drains are closed with the water bodies in a dilapidated condition. Some of the water body area has been covered by wild thorny bushes and contains solid waste from the encroachers and the general public. Proper toilet facilities are not available and untreated sewage water is discharged into the water body which deteriorates water quality and indirectly causes ground water contamination.

D. Alternate Technology Adopted for STP

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

(i) DEWATS. Design uses physical and biological treatment mechanisms such as sedimentation, floatation, aerobic and anaerobic treatment to treat domestic

wastewater. DEWATS is designed to be affordable, low maintenance, use local materials. The Typical DEWATS will have four components for treatment (a) Settler, (b) Anaerobic Baffled Reactor, (c) Anaerobic filter and (d) Planted Gravel Filter. Though it has advantages in treating the waste with high efficiency, due to the land constraints for TNSCB in the resettlement sites, this system may not be feasible, because it requires more space, periodic maintenance and expensive.

Table 34: DWATS Salient Features Sl. DWATS Advantages Disadvantages no Components 1 Settler simple, durable, underground need regular de-sludging 2 Anaerobic simple, durable, little permanent required large space Baffled Reactor space, high treatment efficiency 3 Anaerobic filter simple, durable, underground, high costly, filter blockage treatment efficiency 4 Planted Gravel high efficiency, no nuisance, no need permanent space, requited Filter wastewater on ground intensive maintenance with expertise, relatively costly

(ii) SBR Technology. SBR aeration system is similar to an Activated Sludge Process (ASP). The major difference is that this SBR uses one tank for all the treatment steps, rather than using different equipment for each step. As the term “sequencing” suggests, SBR uses time, rather than space, to accomplish its wastewater treatment purposes.

The advantages of using SBR include its: • ability to adapt to different volumes of influent; • work with automated controls; and • requiring less space than a system using multiple tanks

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

E. Alternative Approaches to the Resettlement site design

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

Table 35: Alternative Approach in Building Plan CATEGORY Traditional TNSCB Building Proposed TNSCB Building Plan (ADB Plan funded) URBAN DESIGN Overall Focus Cost efficiency, number of Quality of life, people centric designs that are units future ready (without compromising on cost and number of units) Site Approach Design assumes site to be an Integrated, sustainable design solutions independent plot of land, often with minimal connection (spatial and programmatic) with the surrounding context Environmental Minimal solutions created to Providing environmentally sensitive design Sustainability respond to the context and solutions to ensure minimum carbon footprint, environmental sustainability while creating a healthy and comfortable living environment

CATEGORY Traditional TNSCB Building Proposed TNSCB Building Plan (ADB Plan funded) Inclusive Inadequate consideration of Creating design strategies that focus on Design different user groups. vulnerable groups within the community such as children, differently abled, the aged, youth and women Spatial and Hierarchy of spaces absent Creating a hierarchy of open and community Circulation thereby making the open spaces with appropriate density to support Hierarchy spaces monotonous diverse forms of social interactions Vehicular movement typically Promoting pedestrian circulation and networks prioritized; vehicular circulation over vehicular circulation in order to create paths also intersect with safe spaces for all users; creating safe pedestrian paths creating interactions unsafe environments for the residents Open Space Design approach typically Spatial design that focuses on the design of Design treats open spaces as "left shared public spaces to nurture harmony of over spaces" rather than collective action integrating them cohesively. Landscape Inadequate focus on Open spaces that integrate native, Design landscape design natural landscapes that are didactic, productive as well as recreational in their functions Walkability Lack of walkable spaces Promoting Walkability- nodes typically within 3m, 5m and 7m walking radii Block Standardised block patterns Enhancing a sense of identity and belonging Arrangements does not create unique identity through block design to the communities Closely placed blocks to Design allows for greater distance between optimize efficiency reduces blocks where possible and avoids the situation privacy where the longer side of blocks face one another Blocks are designed close to Designing blocks that are perceivable for the each other with less focus on human scale the human scale Eyes on the Design has leftover/ narrow Designing neighborhoods such that they avoid Street alleyways/ spaces which are redundant areas away from sight which are poorly maintained and end up prone to poor maintenance and blight; being blighted unsafe regions activating spaces between buildings and of the community adding value through artwork and other design solutions Promoting Inadequate attention to open Creating programmatic interventions in open Physical and space programming that spaces that enable physical and mental Mental Well promotes physical and mental recreation for different age groups Being well being Cater to the physical and emotional needs of different groups of people in the design of spaces Visual Quality Minimal visual quality features Emphasizing visual quality of spaces through incorporated in the design the introduction of nodes, elevation design etc to name a few BLOCK DESIGN Block Buildings are oriented without Building orientations to be responsive to the Orientation critical consideration of site site conditions/ context, with a focus on features, daylight and wind improved interior thermal comfort paths Façade Design Minimal intervention on facade Enhancing the external appearance of design and almost restricted to buildings through innovative façade design, the same style across all sites with a focus on optimizing O&M costs

CATEGORY Traditional TNSCB Building Proposed TNSCB Building Plan (ADB Plan funded) Openings Buildings are designed with Visualising and designing blocks as a product minimal openings creating of solids and voids to create spaces for dark and long corridors and interaction and enhance the quality of the un-aesthetic built form; lack of common spaces adoption of passive surveillance Block Length Blocks accommodate large Incorporating limited housing units within each number of units creating long block to ensure shorter corridors that help with and dark corridors way finding Building Repetitive blocks that create a Creating modulated block forms with varying Heights sense of monotony heights to add to the character of the community while adding vibrancy UNIT DESIGN Efficiency Units are maximised to have Carpet area maximised to create a healthy maximum efficiency living environment Space Minimal spaces are designed Addition of ante space and balconies to create Segregation within the units without better circulation and segregation of activities segregation of spaces in spaces Creating multi-functional spaces to enhance better usage of spaces while not compromising on the sizes Storage Areas Minimal storage facilities are Creating multiple storage facilities within the provided within the units unit for residents to store their personal belongings

F. Outcome based on the Analysis

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

Table 36: Outcome of the Analysis of Alternatives Sl.no Infrastructure facilities and other amenities With Project Without Project 1. Well-structured Residential Building ✓  2. Electricity ✓  3. Water supply ✓  4. Approach Road ✓  5. Convenience shop ✓ ✓ 6. Ration shop ✓ ✓ 7. Anganwadi ✓  8. Milk booth ✓ ✓ 9. Community Hall ✓  10. Livelihood Center and Library ✓  11. Health Sub Centre ✓ ✓ 12. Streetlights ✓  13. Sewage Treatment Plant ✓  14. Solid waste management ✓ 

VI. ANTICIPATED ENVIRONMENTAL IMPACTS AND MITIGATION MEASURES

113. This chapter on the anticipated environmental impacts and mitigation measures is based on the preliminary detailed design for the Reddiarpatti resettlement site and proposed demolition works and water body regeneration works are based on the consultations had with TNSCB officials. The given information will have to be updated/ revised once the detailed designs are finalized for resettlement site and plans for demolition at the encroachment sites and water body regeneration works are completed.

114. Screening of potential environmental impacts is categorized into four categories considering project phases: location impacts and design impacts (pre-construction phase), construction phase impacts and operations and maintenance phase impacts:

(i) Location impacts. Impacts associated with site selection, including impacts on environment and resettlement or livelihood related impacts on communities (ii) Design impacts. Impacts arising from project design, including the technology used, scale of operations etc. (iii) Construction impacts. Impacts resulting from construction activities including site clearance, earthworks, civil works, etc. (iv) O&M impacts. Impacts associated with the operation and maintenance of the infrastructure built in the project.

115. The proposal envisages construction of (i) residential units (large scale construction activity provided with essential amenities), (ii) demolishing activity (for the identified 9 encroachment sites (old settlement sites), which are chosen for relocation), (iii) restoration of water bodies (at 9 relocated locations) and (iv) Operation and maintenance (O&M). The construction of residential units along with supporting urban infrastructure and services at Reddiarpatti and demolishing works at the encroachment sites identified for relocations are located in the adjoining area of the existing buildings and hence this would result in environmental impacts typical to the construction activities. The land identified for construction of residential units at Reddiarpatti belongs to the TNSCB and hence it is free from any encumbrances.

116. The sites identified for demolition (encroachment sites for relocation) are located within the settlement area. Gaining free access and movement of workers, vehicles and other construction related machinery would be an issue that will be addressed by obtaining requisite permissions, consultations with affected stakeholders and public information dissemination before commencement of demolition works on site. Identity cards and vehicle permits shall be provided by the Contractor for all such movement to and from the construction site. A Traffic Management Plan (TMP) should be prepared by the Contractor in consultation with PIDs and affected stakeholders.

117. Other impacts related to construction activities such as generation of dust and noise, removal of construction debris and demolition wastes etc. are envisaged which shall be minimized and addressed by adopting safe engineering practices and appropriate methodology for demolishing works and water body restoration works. Caution will be exercised in planning for safe construction and operations phase to minimize disturbance to the adjoining existing activities. Provision for water for construction will be made through municipal water supply or through mobile water tankers.

118. Land Acquisition and Resettlement. As indicated earlier, the land proposed (8.99 ha) for construction of residential units and associated services belongs to the TNSCB,20 similarly the encroachment areas (proposed for demolition) are owned by the Tirunelveli Municipal

20 90,366 m2 of land is required for the ADB financed portion of the resettlement site.

Corporation and hence land acquisition is not envisaged. As per the Resettlement Framework (RF), the proposed categorisation for this subproject is Category “A”, for involuntary resettlement (IR) as it results in physical or economical displacement for 807 Households (HH).

119. Design Considerations to Avoid Environmental Impacts The following are design considerations to avoid environmental impacts:

(i) Incorporation of adequate drainage provisions (ii) Provision for adequate cross ventilation (iii) Adoption of design compatible with the natural environment and suitable selection of materials to enhance the aesthetic appeal and to blend with the natural surroundings. (iv) Straight lines and simple geometry in the proposed landscape and architectural features. (v) Natural tree species in the proposed landscape (vi) A separate area has been designated (away from the residential blocks) in the layout plan for managing municipal solid waste generated in the resettlement site (vii) Ensure water demand can be met sustainably and reused wherever possible. The STP and treated water is proposed to be utilised for flushing and gardening purposes by reducing the water demand.

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

A. Assessment of Environmental Impacts

121. Determination of Area of Influence. The primary impact areas are (i) sites for proposed project components; (ii) main routes/intersections which will be traversed by construction vehicles; and (iii) quarries and borrow pits as sources of construction materials. The secondary impact areas are: (i) Other than the delineated primary impact area; and (ii) areas surrounding the Reddiarpatti site in terms of over-all environmental and socioeconomic improvement.

122. In the case of this subproject the components will involve straight forward construction and operation, and impacts will be mainly localized, short in duration and expected during construction and operation period.

B. Pre-construction Impacts and Mitigation Measures

123. Consents, permits, clearances, no objection certificate (NOC), etc. Necessary consents/NOC as per Table 5, Table 6, para 23 and 24 will be required to be obtained during pre-construction phase and before any civil works commence. A copy of Consent/Permission/Clearance/ NoC should be included in the monitoring reports and submitted to the PID and PMU. Failure in obtaining the same will result in delay of work and may lead to stoppage of works.

124. Mitigation measures. The following measures will be conducted during the detailed design phase prior to construction for the resettlement site, demolition and regeneration works:

(i) Obtain all necessary consents, permits, clearance, NOCs, etc. prior to start of civil works. (ii) Acknowledge in writing and provide report on compliance of all obtained consents, permits, clearance, NOCs, etc. (iii) Include in detailed design drawings and documents all conditions (e.g., the

location of the STP should be away from the settlement area and the treated water should meet the discharge standards as per the TNPCB) and provisions if necessary (iv) The demolished materials from the 9 encroachment sites should be recycled to the maximum extent possible (3R concept should be adopted). (v) For asbestos material disposal, an appropriate inventory has to be carried out and proposed management measures implemented before any demolition activity occurs by the Asbestos Expert/ Environmental Specialist in the encroachment sites. Care should be taken in disposal of the asbestos materials (used as roofing materials) as per the relevant protocols/ hazardous waste management rules 2016 (refer to the EMP for Asbestos material management). (vi) In compliance to the Noise Standards, the proposed construction activities should be implemented in a controlled manner, the dB(A) levels for residential area (day time noise level 55 dB(A) and night time noise level 45 dB(A)) should be maintained. (vii) Pre-construction environmental monitoring as indicated in Table 42 will be conducted by the Contractor under the supervision of the PID. The outcome of the analysis shall be referred as baseline information for key environs (Air, Water and Noise). (viii) Conduct consultation with the local communities and provide detail in the language that is understandable to the local community regarding project activities and the anticipated impacts as part of the project information dissemination (prior to the start of the construction and demolition activity).

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

(i) Identify and include locations and operators of these utilities in the DPR to prevent unnecessary disruption of services during the construction phase. (ii) Require contractors to prepare a contingency plan to include actions to be done in case of unintentional interruption of services. (iii) Require contractor to obtain from the PIDs the list of affected utilities and operators; (iv) If relocations are necessary, contractors along with PIDs will coordinate with the providers/line agencies to relocate the utility. (v) Consult with the local communities if there is a need for interruption of services (especially during the demolition activities)

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

(i) Ensure the ADB SPS 2009 requirements are met while dealing with physical cultural resources (ii) Continually consult Archaeological Survey of India and/or State Department of Archaeology to obtain an expert assessment of the archaeological potential of the site. (iii) Consider alternatives if the site is found to be of medium or high risk. (iv) Include state and local archaeological, cultural and historical authorities, and interest groups in consultation forums as project stakeholders so that their expertise can be made available. (v) Develop a chance find protocol for use by the construction contractors in conducting any excavation work, to ensure that any chance finds are

recognized and measures are taken to ensure they are protected and conserved, this must include stopping work if any suspected cultural heritage item is found.

127. Site selection of construction work camps, stockpile areas, storage areas, and disposal areas. Priority is to locate these near the project location. However, if it is deemed necessary to locate elsewhere, sites to be considered will not promote instability and result in destruction of property, vegetation, irrigation, and drinking water supply systems. Residential areas will not be considered for setting up construction camps to protect the human environment (i.e., to curb accident risks, health risks due to air and water pollution and dust, noise, and to prevent social conflicts, shortages of amenities, and crime). Extreme care will be taken to avoid disposals near forest areas or in water bodies.

128. Site selection of sources of materials. Significant quantities of bricks, coarse aggregate and fine aggregate will be required for construction works (including the construction works in the resettlement site as well as water body regeneration works). The contractor should procure these materials only from the quarries permitted/licensed by Department of Geology and Mining. The contractor should, to the maximum extent possible, procure material from existing quarries, and creation of new quarry areas should be avoided as far as possible. If new quarries are required then the contractor will be responsible for obtaining all permissions and clearances, including environmental clearance for mining. The contractor should factor in the time required for obtaining clearances including conduct of EIA if required under the law. It will be the construction contractor’s responsibility to verify the suitability and legal status of all material sources and to obtain the approval of Department of Geology and Mining and local revenue administration, as required.

129. Erosion control. Most of the impacts will occur due to excavation and earth movements during construction phase. Prior to commencement of civil works, the contractor will be required to:

(i) Develop an erosion control and re-vegetation plan to minimize soil loss and reduce sedimentation. (ii) Minimize the potential for erosion by balancing cuts and fills to the extent feasible. (iii) Identify and avoid areas with unstable slopes and local factors that can cause slope instability (groundwater conditions, precipitation, seismic activity, slope angles, and geologic structure). (iv) Minimize the amount of land disturbed as much as possible. Use existing roads, disturbed areas, and borrow pits and quarries when possible. Minimize vegetation removal. Stage construction to limit the exposed area at any one time.

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

(i) Plan transportation routes so that heavy vehicles do not use narrow local roads, except in the immediate vicinity of delivery sites. (ii) Schedule transport and hauling activities during non-peak hours. (iii) Locate entry and exit points in areas where there is low potential for traffic congestion. (iv) Keep the site free from all unnecessary obstructions. (v) Drive vehicles in a considerate manner.

C. Construction Impacts and Mitigation Measures

131. The impacts during the proposed construction works are standard and site-specific to the construction activities and are not expected to be significant. The Environmental Management Plans (EMP’s) specifies the necessary mitigation measures to be strictly followed by the Contractors and supervised by the PIDs. Key impacts during construction are envisaged on the following aspects (i) transportation of materials, (ii) dust generation, air and noise pollution from construction activities, (iii) sourcing of water for construction activities, (iv) handling of construction materials at site and, (v) adoption of safety measures during construction. However, the prepared EMPs (refer to chapter VIII) should be updated as construction EMPs based on the site conditions by the contractor under the supervision of the PIDs.

132. Construction Schedule and Method. As per the detailed design, construction activities in the resettlement site is expected to take 24 months (tentatively), demolition activities in the 9 encroachment sites shall take 6 months and the 9 water bodies regeneration works is expected to take 6 to 12 months for completion. The proposed interventions for the resettlement site will be constructed manually with minimum use of machinery and equipment and with necessary safety precautions, for example, barricades around demolition sites, restricting pedestrian and vehicular movements. Noise from demolition works should not exceed the noise standards as set by CPCB. Any damage to surrounding buildings will require work to be stopped immediately and rectified before work can recommence. The materials from the demolishing works will be reused to the maximum extent possible. Materials will be brought to site by trucks and will be stored on unused areas within the project site. The working hours will be 8 hours daily. Night works will be avoided except on an emergency basis or due to high day-time traffic as per prevailing conditions at the time of construction. This shall be further considered by the PID but only in consultation with the local communities.

133. There is sufficient space for a staging area, construction equipment, and stockpiling of materials. However, the Contractor will need to remove all construction and demolition wastes on a daily basis.

134. Erosion Hazards. The resettlement site at Reddiarpatti is located in a small hill lock and hence the risk of erosion is high. For the demolishing works, the encroachment sites are located in the built-up area and therefore the risk of erosion is low. However, the Contractor will require to:

(i) Save topsoil removed during excavation and use to reclaim disturbed areas, as soon as it is possible to do so. (ii) Use dust abatement such as water spraying to minimize windblown erosion. (iii) Provide temporary stabilization of disturbed/excavated areas that are not active under construction. (iv) Apply erosion controls (e.g., silt traps) along the drainage leading to the water drains. (v) Maintain vegetative cover within unused land to prevent erosion and periodically monitor the area to assess erosion. (vi) Clean and maintain catch basins, drainage ditches and culverts regularly. (vii) Conduct routine site inspection to assess the effectiveness and the maintenance requirements for erosion and sediment control systems.

135. Impact due to cut and fill. For construction activities levelling the ground is very much essential and looking at the existing topography, it is anticipated to perform cut and fill operation. While performing the cut and fill, the Contractor will be required to:

(i) The Contractor should perform construction activities in various stages

especially at the time of drilling the piles, which may disturb the surrounding area due to vibration. (ii) The Contractor should check the soil stability and to avoid highly erodible soils (if any) and also the slope stability. (iii) Appropriate compaction has to be conducted in arresting the loose soil, which may lead to erosion (iv) The use of chemical stabilizers shall be explored

136. Impacts on Water Quality. There are no surface water sources near the Reddiarpatti resettlement site, however, all the demolition sites are located surrounding the water body. Therefore, impacts on water quality for the demolishing work site is high. Hence, the Contractors will be required to:

(i) The project sites (including the resettlement site and the water body regeneration sites) are in a water scarce area where the use of groundwater is prohibited for construction purposes, hence the contractor should arrange for water, which shall be either purchased from the ULB or the TWAD. The agreement and / or MoU has to be shared with the PID. For any other arrangements for the source of water, the evidence of the same has to be furnished to the PID. (ii) Schedule civil works during non-monsoon season, to the maximum extent possible. (iii) Ensure drainages within the construction zones are kept free of obstructions. (iv) Keep loose soil material and stockpiles out of drains and flow-lines. (v) Avoid stockpiling of excavated and construction materials (sand, gravel, cement, etc.) unless covered by tarpaulins or plastic sheets. (vi) Conduct periodic Environmental Monitoring to check the water quality as indicated in the Table 42. (vii) Use silt trap for the surface runoff to prevent sediments entering into the nearby irrigation tank/ water bodies. (viii) Re-use/utilize, to maximum extent possible, excavated materials. (ix) Dispose any residuals at identified disposal site (PID will identify approved sites). (x) Dispose waste oil and lubricants generated as per provisions of Hazardous Waste (Management and Handling) Rules, 1989.

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

(i) Conduct regular water spraying on earth piles, trenches and sand piles. (ii) Conduct regular visual inspection in the construction zones to ensure that there are no excessive dust emissions. (iii) Spreading crushed gravel over backfilled surfaces if re-surfacing of disturbed areas cannot be done immediately. (iv) Maintain construction vehicles and obtain “Pollution Under Control” (PUC) certificate from Emission Testing Centres (authorised by TNPCB). (v) Obtain CtE and CtO for batching plants, crushers, diesel generators, etc., if is to be used in the project from TNPCB. (vi) Conduct periodical environmental monitoring for ambient air as per schedule given in EMP (Table 42).

138. Noise and Vibration Impacts. With exemption to piling works, most of the construction activities (including construction and demolishing works) shall be done manually with minimum use of machinery and equipment and with necessary safety precautions, for example, barricades around demolition sites, restricting pedestrian and vehicular movements. Noise from demolition works should not exceed the noise standards as set by CPCB. Any damage to surrounding buildings will require work to be stopped immediately and rectified before work can recommence Hence the chances for significant noise and vibration impacts are not envisaged. For the piling operation, Piling Rig will be used, it will generate noise and vibration to the surrounding, however, it is temporary and since there are scattered habitations (the nearest settlement is located at a distance of 250 m), the anticipated noise and vibration impacts shall be minimal. Nevertheless the Contractors will be required to:

(i) Plan activities in consultation with the PID’s so that activities with the greatest potential to generate noise are conducted during periods of the day which will result in least disturbance. (ii) Minimize noise from construction equipment by using vehicle silencers and fitting jackhammers with noise-reducing mufflers. (iii) Create awareness among drivers not to use horns unless it is necessary to warn other road users or animals of the vehicle’s approach. (iv) Shut off idling equipment. (v) Night time construction activities should be avoided and no piling works shall occur at night, and only be considered on an emergency basis or due to high day-time traffic as per prevailing conditions at the time of construction (vi) Follow day time ambient noise levels as per Noise Pollution (Regulation and Control) Rules and conduct periodical environmental monitoring for ambient noise as per schedules given in EMP Table 42 (vii) Ensure vehicles comply with Government of India noise limits for vehicles. Pollution Under Control (PUC) should be available for every construction equipment and vehicles.

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

(i) Conduct site induction and environmental awareness. (ii) Limit activities within the work area. (iii) Do not remove or harm existing vegetation except those required under proposed contract (iv) Strictly instruct workers not to cut trees for fuel wood. (v) Replant trees in the area using minimum ratio of 10 trees for every 1 tree cut, if any. Replacement species must be approved by District Forest Department.

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

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

disposal. Include in waste management plan designated/approved disposal areas. (iii) Coordinate with Municipal Authorities/ ULB’s for beneficial use of demolished materials or immediately dispose to designated areas. (iv) Recover used oil and lubricants and reuse; or remove from the sites. (v) Avoid stockpiling and remove immediately all demolished materials, excess construction materials, and solid waste (removed concrete, wood, packaging materials, empty containers, oils, lubricants, and other similar items). (vi) Prohibit disposal of any material or wastes (including human waste) into drainage, nallah, or watercourse. (vii) Any waste that contains asbestos, or is contaminated with asbestos, must be double-bagged, labelled and placed in a covered, locked skip. This includes asbestos sheets, asbestos pipeline, asbestos cement etc. Care should be taken in the handling and disposal of the asbestos materials as per the relevant protocols/ hazardous waste management rules 2016 and the EMP (refer EMP for Asbestos material management).

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

(i) Disallow worker exposure to noise level greater than 85 dB(A) for a duration of more than 8 hours per day without hearing protection. The use of hearing protection shall be enforced actively. (ii) Develop a comprehensive site-specific health and safety (H&S) plan. The overall objective is to provide guidance to Contractor on establishing a management strategy and applying practices that are intended to eliminate, or reduce, fatalities, injuries and illnesses for workers performing activities and tasks associated with the project. (iii) Include in H&S plan measures such as: (i) type of hazards during excavation works; (ii) corresponding personal protective equipment for each identified hazard; (iii) H&S training for all site personnel; (iv) procedures to be followed for all site activities; and (v) documentation of work-related accidents. (iv) The working hours will be 8 hours daily. Night works should be avoided, however, it may be considered on an emergency basis or due to high day-time traffic as per prevailing conditions at the time of construction. During such requirements, appropriate consultation with the local communities will be conducted. However, due to the close location of existing residential buildings to the resettlement site, piling works will be prohibited at night. (v) Provide H&S orientation training to all new workers to ensure that they are appraised of the rules of work at the site, personal protective protection, and preventing injury to fellow workers. (vi) Ensure that first aid kit is available at site and it should be easily accessible for all workers in terms of emergency. (vii) Provide medical insurance coverage for workers. (viii) Secure construction zone from unauthorized intrusion and accident risks through provision of barriers, guards and warning signs. (ix) Ensure the core labour standards are adopted (i). Universal and indivisible human rights, (ii) Freedom from forced labour (iii) Freedom from child labour (iv) Freedom from discrimination at work (x) Provide adequate supply of potable drinking water. (xi) Provide clean eating areas where workers are not exposed to hazardous or

noxious substances. (xii) Provide visitor orientation if visitors to the site can gain access to areas where hazardous conditions or substances may be present. Ensure also that visitor/s do not enter hazard areas unescorted. (xiii) Ensure the visibility of workers through their use of high visibility vests when working in or walking through heavy equipment operating areas. (xiv) Ensure moving equipment is outfitted with audible back-up alarms. (xv) Mark and provide sign boards in the construction zone, and areas for storage and disposal. Signage shall be in accordance with international standards and be well known to, and easily understood by workers, visitors, and the general public as appropriate. (xvi) Prior to any demolition activity an asbestos walk-over by an Asbestos specialist will be required to mark any potential asbestos waste and a demolition and handling protocol will be developed. Demolition activity undertaken in these areas will require appropriate PPE to be worn. Any waste that contains asbestos, or is contaminated with asbestos, must be double-bagged, labelled and placed in a covered, locked skip. This includes asbestos sheets, asbestos pipeline, asbestos cement etc. Exposure to asbestos causes Asbestosis (chronic lung disease), hence care should be taken in disposal of the asbestos materials as per the relevant protocols/ hazardous waste management rules 2016 (refer to the EMP for Asbestos material management) (xvii) COVID-19. WHO has declared COVID-19 as a pandemic which has affected entire world including India. In view of the prevailing COVID-19 pandemic, the Contractors and workers would need to take additional measures to avoid the spread of the disease and shall follow various guidelines/guidance notes issued by the national/state government, WHO, ILO, World Bank/IFC from time to time. As described in these guidelines, the Contractors shall undertake a COVID risk assessment of project area and prepare a COVID Response and Management Plan (C-R&MP) and submit to TNSCB and PID for approval. A brief guidance on “To Do” List prepared from these documents is provided in Appendix 16.

142. Impact on Associated Infrastructure facilities. The estimated water demand of 0.67 MLD of water for 876 residential units (funded by ADB) and 1.486 MLD of water for 1248 residential units (funded by TNSCB under state fund) shall be supplied by the TWAD. The water will be sourced from River Tamirabarani at Thirumalaikolundupuram, which is located at a distance of 15 km from the Reddiarpatti Resettlement Site. It is arranged through gravity for which pipeline shall be laid for a distance of 24 km. The pipeline laying activities shall have direct air and noise impacts to the public. Being an associated activity to this subproject, once detailed design information is available, the PID environmental specialist shall prepare the EMP in accordance with ADB SPS with assistance from the PMU environmental specialist. Accordingly, this IEE and EMPs will need to be revised and submitted to ADB for concurrence. The prepared EMP will need to be adopted by the contractor, who undertakes the pipeline laying works. This EMP shall be monitored and reported by both TWAD and PID. The key observations should be reflected in the quarterly project progress reports and quarterly safeguard reports to ADB.

D. Post-Construction Impacts and Mitigation Measures

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

(i) Backfill any excavation and trenches, preferably with excess excavation material generated during the construction phase. (ii) Use removed topsoil to reclaim disturbed areas.

(iii) Re-establish the original grade and drainage pattern to the extent practicable. (iv) Stabilize all areas of disturbed vegetation using weed-free native shrubs, grasses, and trees. (v) Restore staging areas and temporary work areas. (vi) Remove all tools, equipment, barricades, signs, surplus materials, debris, and rubbish. Demolish buildings/structures not required for O&M. Dispose in designated disposal sites. (vii) Request in writing from PIDs that construction zones have been restored. (viii) Solid waste (debris, excavated soils, etc.) from the demolishing sites and restoration of water body site should be disposed by the contractor as per the guidance of the Environmental specialist of PIDs.

144. Operation and maintenance activities. The PID’s in support from the service providers will operate and maintain the infrastructure facilities in the Rediyarpatti resettlement site and Tirunelveli Municipal Corporation shall maintain the restored/ rejuvenated water bodies. The maintenance activities at Rediyarpatti (residential units) includes:

(i) Rain water Harvesting Pit management. (a) Regular inspection and cleaning of catchment, gutters, filters and tanks reduce the likelihood of contamination. (b) Water from other sources should not be mixed with that in the tank. (c) TNSCB will carry out routine management of the RWH pits (ii) Management of the STP (a) For initial 5 years, the construction contractor shall maintain and operate the STP. Thereafter a separate Contractor shall be engaged for operation and maintenance of STP. During the operation, the STP will be operated by a skilled operator, who will be required to wear all the essential PPE’s (including but not limited to gloves, masks, safety shoes and safety eyewear) to safeguard themselves from any hazards likely occurring from the STP. (b) TNSCB will carry out regular inspection of the STP to prevent any impacts, including pollution of ground water and nearby water courses. (c) The sludge generated from the STP shall be further treated in the sludge digester tank (anaerobic sludge digestion) in the STP to digest the sludge into dry sludge. The treated sludge shall be stored in the sludge drying bed, which is proposed in an area of 189 m2 and when it reaches its maximum capacity it will be disposed off in the Ramaiyanpatti Sewage Treatment Plant (Operated and maintained by Tirunelveli Municipal Corporation).The treated sludge shall be as per compost quality standard given in the Solid waste management rules 2006 (schedule II A, standards for composting) for which the O&M contractor/ service provider shall perform scheduled monitoring as suggested by the Environmental specialist from PID. (iii) Maintenance of sanitation facilities, solid waste collection and regular maintenance of constructed amenities. TNSCB will carry out maintenance of the sewer system (including the pipeline, collection system etc.), carry out the regular collection of wastes, and will also ensure that: (a) Sanitation facilities do not result in pollution of groundwater (b) Sanitary facilities do not interfere with other utilities and block access to buildings, causing nuisance to neighbouring areas. (c) Municipal Solid Waste will be segregated as organic waste and inorganic waste. Both organic and inorganic waste shall be collected by the Tirunelveli Municipal Corporation, organic waste will be composted in the Micro Composting Center and will be used a manure. The inorganic waste disposal will be outsourced by the Tirunelveli Municipal

Corporation (d) No spillage will happen during the transfer of waste and all wastes will be transported to a designated solid waste treatment site. (e) Staff collecting the municipal solid waste will be provided with necessary PPE’s (including gloves, masks and boots) (iv) Fire fighting equipment’s including the fire extinguisher and sand buckets has to be regularly maintained. Fire extinguishers have to be regularly checked for the expiry date and has to be refilled or replaced as required prior to the expiry date. Any wet sand (if any) in the bucket should be replaced with dry sand (v) Management of the Micro Composting Center (a) Odour is a major concern in composting but the inoculants eliminate or reduce the odour to the barest minimum. The vegetation buffer around the project site is another mitigation factor that will reduce the spread of odour. (b) Noise generation will be limited to the equipment (shredder, conveyor belt etc) to be used in the Composting Center and to move materials around. The level of noise will be insignificant but personnel at the noisy end of the operation will be mandated to wear earmuffs. (c) The operation of the compost facility is not expected to significantly affect the surface and ground water quality. The floor of the compost pads will be concretized to reduce permeability. All employees will be trained properly on good operational practices, plant safety procedures and good housekeeping. All employees will also be provided PPEs (high visibility clothing, hard hats gloves, masks, ear protection and boots) and trained on how to appropriately use them during operations of the composting center. (d) It is expected that composting may indeed encourage some form of animal and birds activities (attracted by the rodents, snakes, cats, dogs and scavenging birds), which shall be prevented through construction of boundary wall with appropriate covering. (e) The aesthetics of the resettlement site shall not be affected by the micro composting center as it located at the end in the resettlement area and public access will be prohibited. (vi) Other amenities including Landscaping, children play area and streetlights shall be handed over to Palayakottai Panchayat Union for maintenance and operation.

VII. INFORMATION DISCLOSURE, CONSULTATION AND PARTICIPATION

A. Consultation and Participation

145. The active participation of stakeholders including local community, NGOs/CMROs, etc., in all stages of project preparation and implementation is essential for successful implementation of the project. It will ensure that the subprojects are designed, constructed, and operated with utmost consideration to local needs, ensures community acceptance, and will bring maximum benefits to the people. Public consultation and information disclosure is a must as per the ADB Safeguard Policy Statement (2009).

146. Most of the main stakeholders have already been identified and consulted during preparation of this IEE, and any others that are identified during project implementation will be brought into the process in the future. Primary stakeholders of the subproject include vulnerable communities/ residents, surrounding residents, sensitive receptors at the resettlement site (including hospitals and schools) shopkeepers and petty shop business people living along the water bodies, government and utility agencies responsible for provision of various services in project area, community representatives, TNSCB and ADB.

147. COVID-19 has prevented further planned consultations with affected people at the encroachment sites and around the resettlement site. Further formal consultations are expected to be held prior to construction and will be incorporated into the draft IEE.

B. Public Consultation

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

1. Consultation during Project Preparation

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

Table 37: Meetings/Discussions between various stake holders Sl.no Date Stakeholder Details Department 1 12th March Directorate of Consultation was conducted with Mr. Krishna Moorthy, 2019 Town and Country Deputy Director of Town and Country Planning. The Planning (DTCP) following key points were discussed • Various planning options in determining the landuse and its categorisation has been discussed in detail • The preparation of the landuse map across Tamil Nadu was explained to the ADB team 2 5th Tamil Nadu Consultation was conducted with Dr. S. Selvan, Chief December Pollution Control Environmental Engineer, TNPCB and 2020 Board (TNPCB) Mr.R.Ramasubbu Joint Chief Environmental Engineer. The followings are the key outcome of the meeting • Disposal of Construction and Demolition waste: Various policies and regulations adopted by the TNPCB has been discussed. It was informed that Permissions/ NoC from the TNPCB is required, if the construction and demolishing waste (C&D) is equal to or greater than 20 tons per day or 300 tons per project in a month.

Sl.no Date Stakeholder Details Department • Environmental clearance for the subprojects: TNPCB informed that based on the built-up area the project will be categorised as either A or B. It was also indicated that since the built-up is less than 150,000 m2, the Reddiarpatti subproject will be categorised as 8B, which requires an Environmental Clearance from the SEIAA. • Storage and handling of Hazardous materials: It was informed that a licence is not required for storing of Diesel, if the total quantity in possession does not exceed 2500 litres in non-bulk (i.e. drums) or 1000litres in a receptacle / tank (i.e. bulk) • Sewage Treatment Plant: TNPCB mandates the need for a STP in the resettlement site, it was informed that the project owner/ project proponent can choose any available technology for treating the wastewater, however the treated water quality parametera should met the stipulated limits prescribed by the CPCB. • Solid waste management: it was informed that all the corporations/ municipalities/ town panchayats are facilitated with appropriate waste collection, handling, transport and disposal system and hence it shall be managed by the ULB’s. However, the handling of waste should be as per the Municipal Solid Waste Management Rules, 2016 3 5th Adyar River Consultation was conducted with Dr. S. Viswanathan, December Restoration Trust Senior Environmental Scientist. The procedures/ 2020 methodology adopted in restoration of the Adyar River Estuary (Adyar Poonga) has been discussed in detail. • The resettlement issues in evacuating the encroachers from the estuary area and allocation of the resettlement sites for the project affected persons. • Compensation measures adopted including livelihood assistance, transportation allowances and other provisions are discussed in detail. • Restoration of the water body and its challenges. • Restoration of the mangroves in the estuary area. • Monitoring and reporting system for the biodiversity in the Adyar estuary area.

2. Consultations with the Affected Community

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

(i) Lack of basic facilities including water supply, street lights and proper approach roads; (ii) Flooding issues during monsoon season; some of the settlements located near Tamarabarani river have experienced severe flood during 1989, 1992 and 2015; (iii) Encroachers have resided at the same place for 30 years; (iv) Patta is not available for the encroachers; (v) Common toilets has been provided; however open defecation is a common issue (vi) Most residents work as daily labours and housemaid workers; (vii) Schools/ educational institutions, hospitals are located in accessible distances; (viii) Drinking water supply is provided by Tirunelveli Municipal Corporation; (ix) Some encroachers showed willingness to relocate, but some have shown their unwillingness for relocation

Figure 25: Snap Shots from the FGDs conducted at Water Body Encroachment sites

Elanthaikulam Karupanthurai

Pillaikulam Kokkirakulam

3. Consultation during construction

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

81 work sites, public information boards will also be provided to disseminate project related information.

C. Information Disclosure and Future Consultations

152. Executive summary of the IEE will be translated in Tamil and made available at the offices of TNSCB, PID’s and also displayed on their notice boards. Hard copies of the IEE will be accessible to citizens as a mean to disclose the document and at the same time creating wider public awareness. Electronic version of the IEE in English and Executive Summary in English and Tamil will be placed in the official website of the TNSCB after approval of the IEE by ADB. Stakeholders will also be made aware of grievance register and redress mechanism.

153. Public information campaigns to explain the project details to a wider population will be conducted. Public disclosure meetings will be conducted at key project stages to inform the public of the progress and future plans. Prior to start of construction, the PIDs will issue notification on the start date of implementation in the TNSCB website. Subproject information brochure/ pamphlets will be issued to the local communities for better understanding, the brochure/ pamphlets shall include the EMP cost. A board showing the details of the project will be displayed at the construction sites for the information of general public. Local communities will be continuously consulted regarding location of construction camps, access and hauling routes and other likely disturbances during construction.

VIII. GRIEVANCE REDRESS MECHANISM

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

(i) Review and document eligible complaints of project stakeholders; (ii) Proactively address grievances; (iii) Provide the complainants with notice of the decisions made; (iv) Prepare periodic reports to summarize: (a) the number and types of complaints received and resolved at all levels; (b) chosen actions and time required for resolution; and (c) final outcomes of the grievances; and (d) Make the reports available to ADB as part of the regular Safeguards Monitoring Reports. (v) Eligible complaints will include (a) those related to the project activities, (b) any of the service providers, (c) any person responsible for carrying out the project, (d) complaints on misuse of funds and other irregularities, and (e) grievances due to any safeguards, labor and gender issues.

155. The PIDs (Environment / Social Cell) will establish a common GRM acceptable to ADB at divisional levels for addressing any environment and/or social issues that arise due to subproject activity. The GRM will constitute a suitable systematic process to receive, evaluate and facilitate resolution of affected persons and other stakeholder’s complaints and grievances about subproject environmental (and social) safeguards performance. It will aim to provide a time-bound, trusted and transparent mechanism to voice and resolve issues and concerns associated with the subproject implementation.

156. Public awareness campaigns in the project area of influence will ensure that knowledge of the grievance redress procedures is generated. The PIDs (Environment / Social Cell) will conduct awareness campaigns to ensure that all affected persons and vulnerable households are made aware of grievance redress procedures, entitlements and anticipated environmental impacts.

157. Affected persons will have the flexibility of conveying grievances/suggestions by dropping grievance redress/suggestion forms in complaints/ suggestion boxes to be installed by the PIDs (Environment / Social Cell) or by writing in a complaint register in the PID office or by e-mail, or by registering complaints by post (as per the PMU’s existing grievance redress mechanism). Careful documentation of the name of the complainant, date of receipt of the complaint, address/ contact details of the person, location of the problem area, and how the problem was resolved will be undertaken. The PID (Environment / Social Cell) officers will have the overall responsibility for timely grievance redress on environmental and social safeguards issues and for registration of grievances, related disclosure, and communication with the aggrieved party. The proposed template of a grievance registration form is provided in Appendix 17. All the documents made available to the public will include information on the contact number, address and contact person for registering grievances, and will be disseminated throughout the project area of influence by the PIDs (Environment / Social Cell).

158. Proposed GRM.21 In case of grievances that are immediate and urgent in the perception of the complainant, the on-site Contractor/Animator/Community Officer / Assistant Engineer / Junior Engineer from PID (Environment / Social Cell) will provide the most easily, accessible or the first level of contact for the quick resolution of grievances. Contact phone numbers and names of the concerned staff and contractors, will be posted at all construction sites in visible locations.

(i) 1st level grievance: The on-site contractor/ Animator/ Community Officer/ Assistant or Junior Engineer of the PID will receive and record the complaint at the subproject site. Alternatively, the complaint can be registered by phone call, message, email, or on the TNSCB website. The complaint will be reviewed and the on-site contractor/ animator / Community Officer / Assistant or Junior Engineer of the PID will try to resolve the issue on-site in consultation with the aggrieved party. This will be done within 7 days of receipt of a complaint/ grievance. (ii) 2nd level grievance: All grievances that cannot be redressed within 7 days at the field level (on-site) will be brought to the notice of the Community Development Officer of the PID and the Environment Specialist of the Environment Cell in the PID. The PID Community Development Officer / Environmental Specialist of the Environmental Cell / PID Executive Engineer (PID Head) will resolve the grievance within 14 days of receipt of a complaint/ grievance with support of the PIU Superintending Engineer. (iii) 3rd level grievance: If the grievance is not resolved at PID Community Development Officer / Environmental Specialist/ Executive Engineer (PID Head) level, the grievance will be referred internally to Chief Community Development Officer / Environmental Consultant of PMU / the Chief Engineer of IRSHUPSP. The grievance at this level will be resolved within 21 days of its receipt. All resolutions shall be communicated to the aggrieved party / complainant(s).

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

21 Any IRSHUPSP specific grievance which comes in through TNSCBs existing system (refer to Section 3) will be routed back to the project specific GRM to level 1.

Figure 26: Grievance Redress Process

160. In the event that the established GRM is not in a position to resolve the issue, the affected persons can also use the ADB Accountability Mechanism by directly contacting (in writing) the complaint receiving officer at ADB headquarters or the ADB India Resident Mission. The complaint can be submitted in any of the official languages of ADB’s Developing Member Countries. The ADB Accountability Mechanism information will be included in the project information document to be distributed to the affected communities, as part of the project GRM.

161. Record-keeping. The PID will keep records of grievances received, including contact details of the complainant, the date the complaint was received, the nature of the grievance, agreed corrective actions and the date these were affected and the final outcome. The number of grievances recorded and resolved and the outcomes will be displayed/disclosed in the PID office, as well as reported in monitoring reports submitted to ADB on quarterly (during construction) and annual basis (during operation).

162. Periodic review and documentation of lessons learned. The PMU will periodically review the functioning of the GRM and record information on the effectiveness of the mechanism, especially on the program’s ability to prevent and address grievances.

163. Costs. All costs involved in resolving the complaints (meetings, consultations, communication and reporting/ information dissemination) will be borne by the PID.

164. Country legal procedure. An aggrieved person shall have access to the country's legal system at any stage, and accessing the country's legal system can run parallel to accessing the GRM and is not dependent on the negative outcome of the GRM.

165. ADB’s Accountability Mechanism. If the established GRM is not in a position to resolve the issue, the affected person also can use the ADB Accountability Mechanism through directly contacting (in writing) the Complaint Receiving Officer (CRO) at ADB headquarters or the ADB India Resident Mission. The complaint can be submitted in any of the official languages of ADB’s developing member countries. Before submitting a complaint to the Accountability Mechanism, it is recommended that affected people make a good faith effort to resolve their problems by working with the concerned ADB operations department (in this case, the resident mission). Only after doing that, and if they are still dissatisfied, they could approach the Accountability Mechanism. The ADB Accountability Mechanism

85 information will be included in the project-relevant information to be distributed to the affected communities, as part of the project GRM.

IX. ENVIRONMENTAL MANAGEMENT PLAN

A. Environmental Management Plan

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

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

167. The EMP will guide environmentally-sound practices at the time of construction and operation of the subprojects and ensure efficient lines of communication between TNSCB PMU, PIDs, and contractors. The EMPs will (i) ensure that the activities are undertaken in a responsible non-detrimental manner; (ii) provide a pro-active, feasible and practical working tool to enable the measurement and monitoring of environmental performance on site; (iii) guide and control the implementation of findings and recommendations of the environmental assessment conducted for the subproject; (iv) detail specific actions deemed necessary to assist in mitigating the environmental impact of the subproject; and (v) ensure that safety recommendations are complied with. The EMPs includes a monitoring program to measure the environmental condition and effectiveness of implementation of the mitigation measures. It will include observations on- and off-site, document checks, and interviews with workers and beneficiaries. The IEE and EMP will be included in the bid and contract documents to ensure compliance to the conditions set out in this document.

168. The contractor will be required to submit to PIDs, for review and approval, a Site Environmental Management Plan (SEMP) including (i) proposed sites/locations for construction work camps, storage areas, hauling roads, lay down areas, disposal areas for solid and hazardous wastes; (ii) specific mitigation measures following the approved EMP; and (iii) monitoring program as per EMP and (iv) prepare a COVID Response and Management Plan (C-R&MP). No works are allowed to commence prior to approval of SEMP.

169. A copy of the EMP and approved SEMP will be kept on site during the construction period at all times.

170. As per the prefeasibility report, the water supply is expected to be arranged through a 24km pipeline through pumping and detailed design is still underway. This is an associated activity to this subproject and once enough information is available, the PID environmental specialist shall prepare the EMP for this activity in accordance with ADB SPS with assistance from the PMU environmental specialist. Accordingly, this IEE and EMP will need to be revised and submitted to ADB for concurrence prior to appointment of the contractor by TWAD. The prepared EMP will need to be adopted by the contractor, who undertakes the pipeline laying works, and it shall be monitored and reported by both TWAD and PID. The key observations should be reflected in the quarterly safeguard reports to ADB.

171. For civil works, the contractor will be required to (i) carry out all the mitigation and monitoring measures set forth in the approved SEMP; and (ii) implement any corrective or preventative actions set out in environmental monitoring reports that the employer will prepare from time to time to monitor implementation of this IEE and SEMP. The contractor shall allocate adequate budget for compliance with these SEMP measures, requirements and actions.

172. The following table shows the potential environmental impacts, proposed mitigation measures and responsible agencies for implementation and monitoring.

Table 38: Environmental Management Plan for Construction Site - Reddiarpatti, Tirunelveli District Environmental Issues Mitigation Measures Indicators and Responsibility Responsibility Sl.no Targets for for Supervision implementation 1. Location Impacts 1.1 Location impacts pertain to siting • The siting of facilities will be in line with the • List of tree PID PMU of facilities for construction of new EARF and DTCP approved Master Plan. species buildings/ dwelling units at • The site allotted for the construction of new • Tree cutting Reddiarpatti, Tirunelveli District buildings / dwelling units at Reddiarpatti permit / belongs to Tamil Nadu Slum Clearance Board permission from • Clearing of wild vegetation’s (TNSCB). Hence there are no LA Issues the competent • Maintain slope for natural drain anticipated. authority • Excess earth disposal • The land is vacant and located in a hilly area • Identification of (78 m elevation) having gentle slope towards Disposal site for northern direction. Hence levelling operations disposing debris have to be conducted for the construction and excavated purpose. By doing so it is anticipated to soil generate excavated excess earth/ soil (cut and filling), which has to be disposed in an authorised/ identified landfill or disposal area. If the site is a new disposal area, then it has to be approved by the PID. • There are few trees identified in the project site, which has to be preserved through design considerations or it shall be transplanted to the designated landscaping area. 1.2 Lack of sufficient planning to • In accordance with the provisions in the sub- • DPR and designs PID PMU assure long term sustainability of project selection criteria, the sub-project Approved from the developments design shall include adequate provisions for competent ensuring effective maintenance and authority protection of the assets created so as to • Work plan ensure the long term sustainability of the prepared and sites. approved by PID • The designs will be worked out and implemented in accordance with the provisions.

Environmental Issues Mitigation Measures Indicators and Responsibility Responsibility Sl.no Targets for for Supervision implementation • No construction activity of any kind shall be taken up in the OSR area 1.3 Land acquisition (Socio economic • No additional land will be required, the • Revenue records PID PMU Impacts) proposed project at Reddiarpatti is designed to implement within the available 8.99 ha land area • Resettlement and/or land acquisition problems are not anticipated in the construction activities. • In case of any additional land acquisition, the compensation as per the Entitlement matrix given in the Resettlement Framework (RF) shall be adopted 1.4 Clearing of trees/ Removal of • All reasonable measures shall be undertaken • Tree count PID PMU vegetation to ensure that no native fauna is harmed or information and placed at risk during the course of the compensation clearing activities ratio • As per the proposed design, felling of trees is not envisaged at any stage of the project. However, under unavoidable conditions if any of the trees are required to be cut/ felled, then prior permission as per existing procedure from Forest department, ensuring appropriate compensation including compensatory plantation at 1:10 ratio as stipulated by the High Court of Madras (WP No 7811/2010 and MP No 1/2010 dated 25/06/2010). 2. Design and Pre-Construction Impacts 2.1 Increased storm water runoff from • Design of proposed building components will • Site drainage PID PMU alterations of the site’s natural enable efficient drainage of the sites and plan to be drainage patterns due to maintain natural drainage patterns. The siting prepared and excavation works in the of the project components, involving physical applied Reddiarpatti site, construction of construction shall be done to ensure no • Construction of Anganwadi, Community hall, drains to prevent

Environmental Issues Mitigation Measures Indicators and Responsibility Responsibility Sl.no Targets for for Supervision implementation Ration shop, addition of paved disruption of natural drainage patterns or water logging at surfaces and approach roads. flows into the nearby drain/nallah. site during rains • Construction activities (including excavation and trenching works) shall be restricted during the monsoon season. • The Contractor shall discuss with the PID to carryout necessary construction activities in the monsoon season by providing appropriate safety measures to the satisfaction of the PID. 2.2 Consents, permits, clearances, • All the necessary approvals/ permissions/ • General PID PMU NOCs, etc. clearances/ NoCs as given in the Conditions and Environmental Clearance (EC) for Specific Condition Reddiarpatti Resettlement Site should be as mentioned in obtained by the PID and verified by PMU the Environmental before start of the construction activities or as Clearance per the conditions given in the EC. This • Source includes STP design approval from a third sustainability party. study • The findings and recommendations from the • Consultation source sustainability study22 (performed by meeting outcomes TWAD) has to be completed and incorporated and records into the IEE prior to a contractor being appointed by TWAD. • . The study shall include water quality information as well. • Meaningful consultations with communities to keep them informed of anticipated activities and associated impacts 2.3 Water supply pipeline laying • The impacts of the water supply pipeline will • Revised IEE and PID and TWAD PMU activities shall have direct air and need to be assessed once enough EMP

22 The water source sustainability study should indicate the project shall utilize water sources at sustainable levels of abstraction only (i.e., without significant reductions in the quantity or quality of the source overall), avoid polluted water sources, avoid water use conflicts by not abstracting water that is used for other purposes and ensure water quality provided complies with national drinking water standards at all times through regular monitoring. This requires identification of all users of the water source and that the water source can be appropriately recharged. The water source sustainability study to be conducted should be incorporated into the relevant IEE and EMP.

Environmental Issues Mitigation Measures Indicators and Responsibility Responsibility Sl.no Targets for for Supervision implementation noise impacts to the public as well information is available and this IEE and EMP • Contractor as other construction impacts. should be revised and submitted to ADB for records concurrence prior to a contractor being appointed. • The contractor appointed for water supply will be required to adopt the EMP. 2.4 Selection of materials and • Designs to be worked out in such a manner • list of approved PID PMU construction technologies, if not that exposed steel and concrete structures quarry sites and carefully chosen, will adversely are avoided source of material impact the visual appeal of the • The design brief for all building components • List of trees/ buildings proposed will strictly conform to the TNSCB shrubs for requirements. landscaping • Any new landscaping elements will only utilize • List of materials to native species to protect local biodiversity be procured for construction works included in BOQ 2.5 Integration of energy efficiency • The detailed designs for the building • DPR and designs PID PMU and energy conservation components shall ensure that environmental approved from programs in design of building sustainability principles, including energy competent components efficiency, resource recycling, waste authority minimization etc. are integrated, and designs • Use of energy accordingly worked out. efficient and ISO • All the electrical and mechanical equipment’s certified used in the construction works shall be energy equipment in efficient and ISO certified as per BOQ construction provisions. works • PUC for all construction vehicles 2.6 Odour / smell from Sewage • The detailed design/ layout should have • DPR and designs PID PMU Treatment Plant (STP) and designated STP and the MSW areas, which approved from Municipal solid waste (MSW) should be located away from the settlement to competent collection area prevent the odour nuisance authority

Environmental Issues Mitigation Measures Indicators and Responsibility Responsibility Sl.no Targets for for Supervision implementation • MSW should be collected frequently • STP should be maintained 2.7 Noise pollution from the pumps • Pump house should be located away from the • Regular PID PMU used for lifting water to the OHT’s residential blocks and it should be acoustic maintenance is proof required • conducting frequent Noise monitoring 2.8 Sourcing of water for construction • Contractor shall purchase water from ULB or • Regular Contractor and PMU activities TWAD for the construction activities. The monitoring is PID agreement/ MoU has to be shared with the required PID. • Feedback from • Use of groundwater for construction purpose the local is prohibited. communities • Water demand during construction should be reduced by use of premixed concrete, curing agents and other best practices prevalent. • Tapping of surface water from river sources should not affect the downstream water users (appropriate permission for the same from the TWAD/ PWD should be obtained) • Tapping of surface water from tanks/ ponds should be in consultation with the local communities and the same records should be submitted to the PID and PMU. • For any other arrangements for the source of water, the evidence for the same has to be furnished to the PID 2.9 Installation of Diesel Generators • As per the CPCB norms, place the Diesel • Standards Contractor and PMU Generators (DG’s) in an acoustic enclosure prescribed by the PID or other sound insulation CPCB

Environmental Issues Mitigation Measures Indicators and Responsibility Responsibility Sl.no Targets for for Supervision implementation • Place the DG’s at least 100 m from the • conducting nearest new building for housing frequent noise • Low Sulphur Diesel shall be used for monitoring operating diesel generator • Ensure DG sets comply with the noise standards prescribed by the CPCB 3. Pre-Construction activities by Contractor 3.1 Submission of updated EMP / • Appoint Environment, Health and Safety Unsatisfactory Contractor and PMU SEMP; EMP implementation and Supervisor to ensure EMP implementation compliance with PID reporting • Submission of updated EMP/ SEMP prior to EMP starting of work, • Timely submission of monthly monitoring Contractor reports including documentary evidence on consultation EMP implementation such as photographs records and consultation records. • SEMP documents shall include information about site restoration, noise and dust control, wastewater management, spills response, community and site health and safety, traffic control, tree cutting, construction of labour camps, storage areas, hauling roads, regulatory permissions, disposal areas for solid and hazardous wastes, sensitive features like schools and hospitals • Provide project-related information to stakeholders, communities and/or affected people before and during construction works including at least 7 days prior to the start of works and again at least 1 day prior to works through issuing a pamphlet booklet to affected persons. 3.2 Consents, permits, clearances, • Obtain all necessary consents, permits, All the project Contractor and PMU NOCs, etc. clearance, NOCs, etc. prior to the award of related clearances PID civil works. should be obtained as indicated in the

Environmental Issues Mitigation Measures Indicators and Responsibility Responsibility Sl.no Targets for for Supervision implementation • Ensure that all necessary approvals for Table 5, Table 6, construction to be obtained by the contractor para 53 and 54 are in place before the start of construction • Acknowledge in writing and provide a report on compliance of all obtained consents, permits, clearance, NOCs, etc. 3.3 Sources of construction materials • Maximize the re-use of earth-cut materials, Contractor to Contractor and PMU (Impact on natural land contours, spoils, and construction & demolition debris / prepare a list of PID vegetation, disturbance to natural wastes approved quarry drainage patterns, water logging, • Specify materials that are recycled, have sites and sources of and water pollution.) recycled content or are from sustainable materials with the sources approval of PID • Obtain construction materials only from before any government-approved quarries with prior construction approval of PID commences • PID to review, and ensure that proposed quarry sources have all necessary clearances/ permissions in place prior to approval • Contractor to submit to PID the documentation every month with the details of the material obtained from each source (quarry/ borrow pit) • Avoid the creation of new borrow areas, quarries, etc., for the project; if unavoidable, contractor to obtain all clearances and permissions as required under law, including Environmental Clearance (EC) prior to approval by PID 3.4 Construction Camps – Location, • The construction camps will be located at • Location of Contractor and PMU Selection, Design and Layout 500m away from settlements and water construction camp PID bodies. The construction camps including approved by PID separate female and male sanitation facilities, • Construction shelter, canteen, first aid, health care, day camp having all the basic

Environmental Issues Mitigation Measures Indicators and Responsibility Responsibility Sl.no Targets for for Supervision implementation crèche facilities must be adequately drained, amenities with and must not be subject to periodic flooding. proper sanitary • The camps must be located such that the conditions drainage from and through the camps will not drainage and risk any domestic or public water supply. watery supply • All sites must be graded, ditched and rendered free from depressions such that water may get stagnant and cause a nuisance. • The contractor shall provide the dispenser for the disposal of Sanitary Napkins • MSW and domestic sewage generated from the construction camp should be disposed on day to day basis. The collection of waste and sewage shall be done by the Tirunelveli Municipal Corporation for which the contractor should get approval from the corporation accordingly with the assistance from the PID. • Potable water (as per IS 10500 standard) to the labours/ construction workers should be provided by the Contractor • Comply with the ban on one time use and throwaway plastics under Tamil Nadu Government Order • First Aid Room shall be provided in the project site during the entire construction and operation phases of the project 3.5 Stockpiling of materials • Storage of construction material confined to • Location of Contractor and PMU work sites in a way to ensure that there is no construction camp PID obstruction to natural drainage pattern, approved by PID efficient drainage is maintained • Approved • Stockpiles to be covered to reduce dust materials generation management plan.

Environmental Issues Mitigation Measures Indicators and Responsibility Responsibility Sl.no Targets for for Supervision implementation • Develop and implement the Materials Management Plan (including warehouses / storage) 3.5 Establishment of baseline • Conduct documentation of location of Baseline Contractor and PMU environmental conditions prior to components, areas for construction zone environmental PID start of civil works (camps, staging, storage, stockpiling, etc.) profile including and surroundings (within direct impact ambient air, noise, zones), locations of environmental monitoring water quality as per Include photos and GPS coordinates the standards • The monitoring parameters and the frequency indicted in the of the monitoring should comply with the monitoring plan Environmental Monitoring Plan (Table 42) (Table 42) 3.6 Drinking water availability and • The contractor will be responsible for • Records of Contractor and PMU water arrangement arrangement of water in every workplace at drinking water PID suitable and easily accessible place for the supply to workers whole construction period. • Feedback from • Sufficient supply of cold potable water (as per workers IS 10500) to be provided and maintained. • If the drinking water is obtained from an intermittent public water supply then, storage tanks will be provided. 3.7 Identification of disposal sites • Location of disposal sites will be finalized by • Disposal site Contractor and PMU the Environmental Specialist of the PID and selected and PID he will confirm that disposal of the material approved by PID does not impact natural drainage courses or • Records of surface water bodies or low-lying areas and materials that no endangered / rare flora is impacted by disposed at such materials. disposal site • The disposal sites shall be identified in • Logbook consultation with the Tirunelveli Municipal maintained for Corporation debris disposal • Information on the disposal site should be included in the IEE (update/ revise it accordingly)

Environmental Issues Mitigation Measures Indicators and Responsibility Responsibility Sl.no Targets for for Supervision implementation 3.8 Shifting of Utilities • Identify and include locations and operators of • List showing Contractor and PMU these utilities in the detailed design utilities to be PID documents to prevent unnecessary disruption shifted of services during the construction phase. • Contingency plan • Require contractors to prepare a contingency for services plan to include actions to be done in case of disruption unintentional interruption of services. • Obtain from the PID the list of affected utilities and operators; • If relocation is necessary, Contractor will coordinate with the providers to relocate the utility and communicate the dates and duration in advance to affected communities / persons / businesses. 3.9 Social and Cultural Resources • No cultural properties or religious structures Chance find Contractor and PMU shall be removed or relocated without the protocol PID knowledge and written consent of the concerned parties or communities and local administration as the case may be. Sites for the relocation of these religious structures shall be identified following the choice of the community. • As far as possible, the architectural elements of the structure should be conserved/reflected/translated into the design of new structures following the wishes of the community • For any Chance find, consult Archaeological Survey of India (ASI) or Tamil Nadu Archaeology Department to obtain an expert assessment of the archaeological potential of the site. • Consider alternatives if the site is found to be of medium or high risk.

Environmental Issues Mitigation Measures Indicators and Responsibility Responsibility Sl.no Targets for for Supervision implementation • Include state and local archaeological, cultural and historical authorities, and interest groups in consultation forums as project stakeholders so that their expertise can be made available. • Develop a protocol for use by the construction contractors in conducting any excavation work, to ensure that any chance finds are recognized and measures are taken to ensure they are protected and conserved. 3.10 Circulation plan during • Prior to mobilization and commencement of • Site work plan Contractor and PMU construction in the densely site activities, contractor has to prepare site prepared by PID populated areas work plan approved by Engineer23 so that no contractor and works or activities shall interrupt safe passage approved by PID of local residents/ road users during • Traffic plan and construction stage, including development of records of road alternatives access routes, traffic regulations, signage’s signage etc., during construction • The sensitive receptors like residential settlements, schools and hospitals in the close proximity of the resettlement site have to be consulted to discuss the site work plan for their suggestions and feedback, accordingly the plan shall be modified. The Contractor with support of the PID will carry out dissemination of these information 3.11 Access • Traffic congestion near the entry and exit Temporary Traffic Contractor and PMU points from the roads adjoining the proposed management Plan PID project site must be avoided • Plan transportation routes (NH-7, Tirunelveli- Moolaikaraipatti Road etc.,) so that heavy vehicles do not use narrow local roads, except in the immediate vicinity of delivery sites.

23 Engineer refers to Project Implementation Division (PID)

Environmental Issues Mitigation Measures Indicators and Responsibility Responsibility Sl.no Targets for for Supervision implementation • Schedule transport and hauling activities during non-peak hours. • Locate entry and exit points in areas where there is low potential for traffic congestion. • Keep the site free from all unnecessary obstructions. • Drive vehicles in a considerate manner. 3.12 Occupational health and safety • Comply with IFC EHS Guidelines on Health and safety Contractor and PMU Occupational Health and Safety (H&S) plan PID • Develop comprehensive site-specific health and safety (H&S) plan. The overall objective is to provide guidance to Contractors on establishing a management strategy and applying practices that are intended to eliminate, or reduce, fatalities, injuries and illnesses for workers performing activities and tasks associated with the project. • Include in H&S plan measures such as: (i) type of hazards in the construction site; (ii) corresponding personal protective equipment for each identified hazard; (iii) H&S training for all site personnel (including labours); (iv) procedures to be followed for all site activities; and (v) Documentation of work-related accidents. • Provide medical insurance coverage for workers. • Contractor to nominate an on-site environment, health and safety officer. • Contractor shall undertake a COVID risk assessment of project area and prepare a COVID Response and Management Plan (C- R&MP) and submit to PID for approval

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Environmental Issues Mitigation Measures Indicators and Responsibility Responsibility Sl.no Targets for for Supervision implementation 3.13 Site clearance activities including • Commencements of site clearance activities Construction and Contractor and PMU delineation of construction areas shall be undertaken after permissions of PID workers camp sites PID to minimize environmental impacts. should be restored • All areas used for construction and camp as per the original activities shall be restored to their former situation conditions after project completion and no impact to the baseline environment indicators have been confirmed. 3.14 Excessive disturbance to • Meaningful consultations with communities to Community Health Contractor and PMU communities due to prolonged keep them informed of anticipated activities, and Safety PID construction in particular those that may result in disruption Plan with respect to area access, utilities, and noisy or dust-generating activities that are Contractor likely to result in significant disturbance consultation • Identify and adhere to strict construction records schedule • Liaise with schools that are in close proximity to construction sites on school examination periods and scale down construction activities and avoid noisy activities (including piling) during such periods • Alert communities and residents if night time construction work shall occur nearby (no night time construction within 500 m of the nearest household) and ensure safe alternative access is provided • Ensure communities are aware of Grievance Redress Mechanism (GRM) entry points • Create awareness of health & safety risks of transmittable diseases (HIV/AIDs / COVID- 19), child labor, bonded labor or forced labor • Develop and implement the Community Health and Safety Plan 4. Construction Impacts

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Environmental Issues Mitigation Measures Indicators and Responsibility Responsibility Sl.no Targets for for Supervision implementation 4.1 Improper stockpiling of • Adequate safety precautions will be ensured • Proper stockpiling Contractor and PMU construction materials cause during transportation of quarry material from of construction PID impacts starting from obstruction quarries to the construction site. materials of drainage, disturbance/ safety • Vehicles transporting material will be covered • vehicles hazard etc. to prevent spillage. transporting • Operations to be undertaken by the contractor construction as per the direction and satisfaction of materials covered Engineer. to prevent spillage 4.2 Impacts due to Batching Plant • Batching plant shall comply with the • Batching Plants Contractor and PMU operation requirements and specifications of the should be kept/ PID relevant current emission control legislation. stationed away • Batching plant shall be located within the from residential project construction area and as far as /settlements and possible from at least 300m in residential/settlements/commercial the downwind establishments at least300m in the direction from downwind direction. nearby sensitive • The Contractor shall submit a detailed layout receptors. plan for all such sites and seek prior approval of PID before entering into a formal agreement with a landowner for setting-up such sites. • Actions by PID against any non-compliance shall be borne by the Contractor at his own cost. • Arrangements to minimize dust pollution through the provision of windscreens, mist spray units, and dust encapsulation shall have to be provided at all such sites. • Specifications of batching plant shall comply with the requirements of the relevant current emission control legislation and Consent / NOC for such plant shall be submitted to the PID

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Environmental Issues Mitigation Measures Indicators and Responsibility Responsibility Sl.no Targets for for Supervision implementation • No such installation by the Contractor shall be allowed till all the required legal clearances are obtained from the competent authority and the same is submitted to the PID. 4.3 Quarry, borrow areas operations • If quarry, borrow areas are exclusively • list of approved Contractor and PMU opened for the project, the contractor shall quarry sites and PID ensure that they qualify all the legal conditions sources of to operate such areas. materials • Consent to Operate (CtO) for quarry sites • CtE and CtO have to take from Tamil Nadu Pollution certificated Control Board (TNPCB) and a copy of the obtained by same has to be kept in record and submitted contractors for to PID. quarry sites, • Contractor has to comply all the conditions batching plant and stipulated in Consent to Operate document. DG sets and • If contractor purchases the materials from submitted to PID other party he has to ensure that quarry has obtained the necessary clearance from Tamil Nadu Pollution Control Board (TNPCB) and should take a copy of it and submit in PID. 4.4 Stripping, stocking and • The topsoil from areas of cutting and areas to • Top soil Contractor and PMU preservation of top soil be permanently covered (proposed site preservation plan PID construction of building) will be stripped to a prepared and specified depth of 150mm, trans located and approved by PID stored in stockpiles. • Record of top soil • The stockpiles will be covered with gunny excavated, bags or tarpaulin. It will be ensured by the preserved and contractor that the topsoil will not be reutilized unnecessarily trafficked either before stripping or when in stockpiles. Such stockpiled topsoil will be returned to cover the disturbed area and cut slopes. 4.5 Soil and water pollution due to • Fuel and lubricant storage areas shall be • Proper storage of Contractor and PMU storage of fuels, lubricants, designed in such a way that oil may not fuel and PID contaminate soil or water. lubricants

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Environmental Issues Mitigation Measures Indicators and Responsibility Responsibility Sl.no Targets for for Supervision implementation construction vehicles and • The floor of storage area shall be protected • Impermeable construction wastes by impermeable membrane and covered by membrane used roof so that it is not affected by rain. in flooring of • Oil pumps should be used to take out the oil storage yard to from the container and no oil spillage shall prevent soil and take place. water pollution • All the construction waste should be • Construction disposed properly after end of the day so waste disposal that it may not create nuisance at site. records • Soil and water pollution parameters shall be • Waste monitored as per the monitoring plan. management plan • Dispose waste oil and lubricants that have been generated as per provisions of Hazardous Waste (Management and Handling) Rules, 1989. • Inspect all vehicles daily for fluid leaks before leaving the vehicle staging area, and repair any leaks before the vehicle resumes operation • Strictly prohibit open defecation by workers in nearby areas 4.6 Siltation of drains/ water bodies • Silt fencing to be provided at construction • Site fencing Contractor and PMU due to spillage of construction sites during rain period to prevent sediments • Numbers of Silt PID wastes from the construction site to enter into the traps constructed watercourses/ nearby settlements. The at site number of units of silt fencing to be installed • Proper drainage is to be decided by the Engineer. system provided • Haul roads on the site and approaches to the at site watercourse (or drains leading to • Regular cleaning watercourses) will be regularly cleaned to of drains during prevent the build-up of mud; areas of bare soil rain period will be kept to a practical minimum to reduce silt runoff.

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Environmental Issues Mitigation Measures Indicators and Responsibility Responsibility Sl.no Targets for for Supervision implementation • Extraneous construction wastes will be transported to the pre-identified disposal site for safe disposal. 4.7 Emission from Construction • The discharge standards promulgated under • PUC available for Contractor and PMU Vehicles, Equipment and the Environmental Protection Act will be all vehicles PID Machinery strictly adhered to. • maintenance • All vehicles, equipment and machinery used record of for construction will conform to the relevant construction Standard. vehicles and • All vehicles, equipment’s and machinery used equipment for construction will be regularly maintained to ensure that pollution emission levels comply with the relevant requirements. • All the construction vehicles shall have Pollution under Control (PUC) certificates to check air pollution. 4.8 Erosion Hazards The resettlement site is located in a small • Slope stability Contractor and PMU hillock and hence the risk of erosion is • Frequent PID anticipated. Hence the Contractor will require monitoring during to: the piling • Save topsoil removed during excavation and operation use to reclaim disturbed areas, as soon as it • Monitoring noise is possible to do so. and vibration • Use dust abatement such as water spraying to minimize windblown erosion. • Provide temporary stabilization of disturbed/excavated areas that are not active under construction. • Apply erosion controls (e.g., silt traps) along the drainage leading to the water drains. • Maintain vegetative cover within unused land to prevent erosion and periodically monitor the area to assess erosion. • Clean and maintain catch basins, drainage ditches and culverts regularly.

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Environmental Issues Mitigation Measures Indicators and Responsibility Responsibility Sl.no Targets for for Supervision implementation • Conduct routine site inspection to assess the effectiveness and the maintenance requirements for erosion and sediment control systems 4.9 Cut and fill (soil erosion and dust • . The Contractor should check the soil stability • Slope stability Contractor and PMU pollution) and to avoid highly erodible soils (if any) and PID also the slope stability. • Appropriate compaction will have to be conducted in arresting the loose soil that will occur during trenching and piling works, which may lead to erosion • The use of chemical stabilizers shall be explored under unforeseen situations where blasting may be required. The Contractor shall discuss with the PID to work out a plan accordingly to use chemical stabilizers to avoid blasting. • Appropriate PPEs (as per Material Safety Data Sheet (MSDS)) have to be provided by the contractor to the workers/ labours who are involved in the use of chemical stabilizers.

4.10 Pilling Operation (Noise and • The Contractor should perform construction • Frequent Contractor and PMU Vibration Impacts) activities in a phased manner especially monitoring during PID during drilling the piles, which may disturb the the piling surrounding area due to vibration operation Monitoring noise and vibration 4.10 Generation of Dust • The contractor will take every precaution to • records of Contractor and PMU reduce the levels of dust at construction sites housekeeping PID to the satisfaction of the Engineer. • records of water • All earth works to be protected / covered in a sprinkling at site manner acceptable to the satisfaction of the • vehicles carrying Engineer to minimize dust generation. excavated soil covered

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Environmental Issues Mitigation Measures Indicators and Responsibility Responsibility Sl.no Targets for for Supervision implementation • Clearance will be affected immediately by • AAQ parameters manual sweeping and removal of debris, or if (Particulate matter so directed by the Engineer, the road (PM10 & PM2.5), surfaces will be hosed or watered using SOx, NOx, CO) to necessary equipment. be monitored • Construction site shall regularly be wetted by (Table 42) sprinkling of water during dusty conditions especially during summer seasons and winds. • Ambient Air Quality monitoring has to be performed as per the Environmental Monitoring Program as indicated in the Table 42. 4.11 Noise from construction activities • The Contractor will ensure appropriate noise • maintenance Contractor and PMU and equipment monitoring is carried out continuously record of PID especially during piling works. construction • Prior to any heavy vehicles and equipment/machinery/piling works the equipment contractor should inform surrounding areas • exhaust silencers as well and it will be prohibited at night. working properly Specify the limit for noise for the piling works. • use of proper • Maintenance of vehicles, equipment and PPEs as work machinery will be regular and to the sites satisfaction of the Engineer, to keep noise • records of noise from these at a minimum. monitoring as per • All vehicles and equipment used for EMP (Table 42) construction will be fitted with exhaust silencers. During routine servicing operations, the effectiveness of exhaust silencers will be checked and if found to be defective will be replaced. • Noise limits for construction equipment used in this project (measured at one metre from the edge of the equipment in free field) such as compactors, rollers, front loaders,

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Environmental Issues Mitigation Measures Indicators and Responsibility Responsibility Sl.no Targets for for Supervision implementation concrete mixers, cranes (movable), vibrators and saws will not exceed 75 dB (A). • Notwithstanding any other conditions of contract, noise level from any item of plant(s) will comply with the noise standards specified by CPCB. • If specific noise complaints are received during construction, the Contractor may be required to implement one or more of the following noise mitigation measures, as directed by the Engineer: • Shut off idling equipment. • Reschedule construction operations to avoid periods of noise annoyance identified in the complaint. • Notify nearby residents whenever extremely noisy work will be occurring. • The Contractor shall provide necessary PPEs as per the direction of the environmental specialist (PID) • The Contractor shall adopt IS 5121-1969 (Indian standard Safety Code for Piling and Other Deep Foundation Works) to ensure safety is maintained during the piling operations • Ambient Noise levels has to be monitored as per the Environmental Monitoring Program 4.12 Impacts on flora and fauna • Strictly instruct workers not to cut trees for fuel • Baseline Contractor and PMU wood information of the PID • Do not harm existing vegetation in the area flora and fauna for except for those indicated in site plan the project area • Limit activities within the work area. • Strictly prohibit poaching of birds and animals in the vicinity of work sites

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Environmental Issues Mitigation Measures Indicators and Responsibility Responsibility Sl.no Targets for for Supervision implementation 4.13 Material Handling at Site • All workers employed on mixing asphaltic • use of proper Contractor and PMU material, cement, concrete etc., will be PPEs as work PID provided with protective footwear and sites protective goggles. Workers, who are • records of PPEs engaged in welding works, will be provided procured and with welder’s protective eye-shields. Workers issued for use engaged in stone breaking activities will be provided with protective goggles and clothing and will be seated at sufficiently safe intervals. 4.14 Disposal of Construction Waste • The waste generated will be reused in the • records of Contractor and PMU /Debris / Cut Material construction activities, either as a fill material excavated soil PID or otherwise, based on its suitability of reuse and to the maximum extent possible. • records of reuse • Safe disposal of the extraneous material will and disposal of be ensured in the pre-identified disposal excavated soil locations. In no case, any construction waste • disposal site will be disposed around the project locations identified and indiscriminately. approved • Burning of municipal solid waste or hazardous • AAQ parameters waste will be prohibited. (Particulate matter (PM10 & PM2.5), SOx, NOx, CO) to be monitored 4.15 Safety Measures During • Personal Protective Equipment (PPE) for • use of PPEs Contractor and PMU Construction workers on the project and adequate safety • records of PPEs PID measures for workers during handling of procured and materials at site will be taken up. issued for use • The contractor has to comply with all • compliance of all regulations regarding safe scaffolding, regulations ladders, working platforms, gangway, regarding stairwells, excavations, trenches and safe scaffolding, means of entry and egress. ladders and work • Appropriate safety measures have to be at height adopted for the construction during the night

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Environmental Issues Mitigation Measures Indicators and Responsibility Responsibility Sl.no Targets for for Supervision implementation time (Lux level shall be equivalent to a minimum of two 500 watt flood lights) 4.16 Risk caused by Force Majure • All reasonable precaution will be taken to • records of first aid Contractor and PMU prevent danger of the workers and the public facilities at site PID from fire, flood, drowning, etc. • records of safety • All necessary steps will be taken for prompt training to workers first aid treatment of all injuries likely to be sustained during the course of work. 4.17 Malaria Risk • The Contractor will, at his own expense, • records of use of Contractor and PMU conform to all anti-malarial instructions given mosquito PID to him by the Engineer; mosquito prevention prevention at site should be done measures at site • The frequency of the testing for malaria and work camps should be increased during the monsoon • anti-malaria season instructions to workers 4.18 Clearing of Construction Camps & • Contractor to prepare site restoration plans for • restoration plan Contractor and PMU Restoration approval by the Engineer. The plan is to be for site and work PID implemented by the contractor prior to camps prepared demobilization. • restoration of site • On completion of the works, all temporary and work camps structures will be cleared away, all rubbish as per plan should be removed, excreta or other disposal pits or trenches filled in and effectively sealed off and the site left clean and tidy, at the Contractor’s expense, to the entire satisfaction of the Engineer. 4.19 Influx of migrant • Local labourer’s to be given preference for • Health and safety Contractor and PMU workers job opportunities and each contractor should risks PID be bound by this commitment • Chances of • The Contractor has to adopt a Code of spread of sexually Conduct for the migrant labour to resolve any transmittable issues with locals diseases like • Ensure labour-related regulations are met AIDS • Water pollution

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Environmental Issues Mitigation Measures Indicators and Responsibility Responsibility Sl.no Targets for for Supervision implementation • In case of hiring outside labour, ensure that • Health & Safety their working conditions as well as camps Risks due to meet local regulations and the best practices Transmittable of the industry (refer to IFC Workers' diseases (HIV/AID Accommodation: Processes and Standards) and Covid-19) / awareness plan