SOCIAL IMPACT ASSESSMENT STUDY FINAL REPORT

LAND ACQUISITION FOR THE CONSTRUCTION OF OIL DEPOT &APPROACH ROAD FOR HPCL/BPCL AT VILLAGE IN DISTRICT

15th JANUARY 2019

Requiring Body SIA Unit

RAJAGIRI outREACH

HINDUSTAN PETROLEUM Rajagiri College of Social Sciences CORPORATION LTD. Rajagiri P.O, SOUTHZONE Pin: 683104

Phone no: 0484-2550785, 2911332

www.rajagiri.edu

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CONTENTS

CHAPTER 1 EXECUTIVE SUMMARY 1.1 Project and Public Purpose 1.2 Location 1.3 Size and Attributes of Land Acquisition 1.4 Alternatives Considered 1.5 Social Impacts 1.6. Mitigation Measures

CHAPTER 2 DETAILED PROJECT DESCRIPTION 2.1. Background of the Project including Developers background 2.2. Rationale for the Project 2.3. Details of Project –Size, Location, Production Targets, Costs and Risks 2.4. Examination of Alternatives 2.5. Phases of the Project Construction 2.6.Core Design Features and Size and Type of Facilities 2.7. Need for Ancillary Infrastructural Facilities 2.8.Work force requirements 2.9. Details of Studies Conducted Earlier 2.10 Applicable Legislations and Policies

CHAPTER 3 TEAM COMPOSITION, STUDY APPROACH AND METHODOLOGY 3.1 Details of the Study Team 3.2 Methodology and Tools Used 3.3 Sampling Methodology Used 3.4. Schedule of Consultations with Key Stakeholders 3.5. Limitation of the Study

CHAPTER 4 LAND ASSESSMENT 4.1 Entire area of impact under the influence of the project 4.2 Total Land Requirement for the Project 4.3 Present use of any Public Utilized land in the Vicinity of the Project Area

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4.4 Land Already Purchased, Alienated, Leased and Intended use for Each Plot of Land 4.5. Nature and Present Use of the Affected Land 4.6. Size of holding, Ownership Patterns and number of residential houses 4.7. Land Price and Recent Changes in Ownership

CHAPTER 5 ESTIMATION AND ENUMERATION

5.1 Directly Affected Families of the Project 5.2 Families of ST and other Traditional Forest Dwellers who have lost any of their Forest Rights 5.3 Families Which Depend on Common Property Resources which will be affected 5.4 Families which have been assigned land by the State Govt. or the Central Govt. 5.5 Families Which have been Residing on any land in the Urban areas for preceding 3 years or more prior to the acquisition 5.6 Families which have depended on the land being acquired as a primary source of livelihood for 3 years prior to the acquisition

CHAPTER 6 SOCIO-ECONOMIC AND CULTURAL PROFILE

6.1 Demographic Details of the Population in the Project Area 6.2 Income and Poverty Level of the Affected Family 6.3 Land Use and Livelihood 6.4 Vulnerable Groups 6.5 Local Economic Activities & Factors that Contribute to Local Livelihoods 6.6 Kinship Pattern,Social and Cultural Organization 6.7 Administrative / Political Organization/Community Based & Civil Society Organization 6.8 Regional Dynamics & Historical Change Process 6.9 Quality of the Living Environment

CHAPTER 7 SOCIAL IMPACT MANAGEMENT PLAN

7.1 Approaches to Mitigation 7.2 Measures to Avoid Mitigate and Compensate Impact

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7.3 Measures those are included in the terms of Rehabilitation and Resettlement 7.4 Measures that the Requiring Body has stated it will introduce in the project proposal 7.5 Alterations to project design and additional measures that may be required to address the extend and intensity of impacts across various groups as identified during SIA 7.6 Detailed Mitigation Plan

CHAPTER 8 SOCIAL IMPACT MANAGEMENT PLAN INSTITUTIONAL FRAMEWORK

8.1 Institutional Structures and Key Persons 8.2 Specify the Role of Non Governmental Organisation, if any 8.3 Indicate Capacities Required and Capacity Building Plan, Including Technical Assistance, if any 8.4. Timelines for each Activity

CHAPTER 9 SOCIAL IMPACT MANAGEMENT BUDGET AND FINANCING OF MITIGATION PLAN

9.1 Costs of all Resettlement and Rehabilitation Costs 9.2 Annual Budget and Plan of Action 9.3 Funding Sources with Break up

CHAPTER 10 SOCIAL IMPACT MANAGEMENT PLAN MONITORING AND EVALUATION

10.1 Key Monitoring and Evaluative Indicators 10.2. Reporting Mechanisms and Monitoring Roles 10.3. Plan for Independent Evaluation

CHAPTER 11 ANALYSIS OF COSTS AND BENEFITS AND RECOMMENDATION ON ACQUISITION

11.1 Analysis of Costs 11.2 Analysis of Benefits 11.3 Recommendation

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List of Tables

Table 1.3.1. Type of Land

Table 1.5.1. Possible Impacts of Project

Table 1.5..2. Impact on Productive Assets

Table 3.1.1. Details of the Study Team

Table 3.2.1 Concerns Raised in Public Hearing and Answer from the Requiring Body

Table 4.3.1. Location Features

Table 4.6.3. Duration of Ownership

Table 5.1.1. Opinion of the Affected Families about Land Acquisition

Table 6.1.1 Sex & Age wise Population

Table 6.1.2 Marital Status of the Adults Among Affected Population

Table 6.1.3. Educational Status of the Affected Population

Table 6.2.1. Monthly Income of the Affected Families

Table 6.2.2. Type of Ration Card

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CHAPTER 1

EXECUTIVE SUMMARY

1.1. Project and Public Purpose

The proposed project is to construct an Oil Depot and its Approach Road at in Payyanur village, Payyanur Municipality in for HPCL and BPCL. The number of vehicles is increasing day by day and hence the petrol and oil requirements are also mounting accordingly. Presently in , the facility for oil installation is available only in . There is no provision for expansion of storage & distribution facilities of the existing small depots at and Kannur and do not meet the revised / new Oil Industry Safety Directorate (OISD) norms. Hence HPCL is proposing to construct a new Petroleum Oil Installation in the Northern Kerala, as part of resettlement of the existing small depots as a Common User Facility.

In order to cater to the Petroleum Oil Lubricant requirements of Northern Kerala effectively, it is essential to have one more Oil Installation apart from Cochin, for each of the Oil Companies, so that tanker movement by road is avoided thereby reducing the risk of accidents and de-congestion of roads. Considering the presence of Naval Academy and proposed new developments in the region such as establishment of a new airport at , Cyber Park etc., will further enhance the requirement of POL in the region, the present project is expected to bring significant benefits to the northern region of the State as a whole.

1.2. Location

The proposed oil depot is located in the Division No: 23, of Payyanur Municipality falling in , in Kannur district, on the banks of river Perumba in

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Kandankali South. The proposed approach road will go through Division No. 24 and 25 of Payyanur Municipality

1.3. Size and Attributes of Land Acquisition

The proposed land is adjoining to the Railway line between Ezhimalaand Payyanur Railway Stations. 31.1619 hectors of land is proposed to be acquired to construct Oil depot which belongs to the Survey Nos. 526,530,532,533,534,535,536, 537,538,539,540, 541,542,543,544, 545, 546, 547, 548, 549, 551,553,554,555, 556, 558, 559,560, 561, and 594 for the Depot and 3.9 hectors of land belonging to the survey Nos. 404,405,407,408,416,418, 419, 420,489, 490, 491, 496, 500, 513, 514, 515 and 516 for approach road. A detailed list explaining the names of the land owners, survey numbers and approximate extent of acquisition is attached as annexure 09.

Table 1.3.1 : Type of Land

Type of land Number of Families Percentage Purayidam 17 7.6 Nilam 168 74.7 NilamNikarthuPurayidam 12 5.3 Information not available 28 12.4 Total 225 100

In total the land of 280 families will be acquired for the project; among them 225 families were surveyed by the SIA unit. The table 1.3.1 explains that out of 225 affected families studied , land of the 168 families is coming under the category of “Nilam” and 17 families are “Purayidam” 12 families are “NilamNikarthuPurayidam”, and the information was not received from the rest of the 28. 1.4 Alternatives considered As stated by the requiring body no other alternatives were considered because the proposed land is suitable for the project since it is adjoining to the railway track so that a siding can be constructed for product receipt through railway wagons. The

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land also falls outside the Municipal town limits of Payyanur with very little inhabitation. Besides, there is no large chunk of land is available in any of the northern districts of Kerala adjacent to railway track.

1.5 Social Impact

Due to the proposed project, 280 families will lose their land. Among the 225 families surveyed by the SIA unit, 2 families staying in the proposed depot site may lose their house fully, 12 families who reside in the land for approach road may fully/partially affected subjective to the alignment. During the survey, 145 families expressed that their livelihood may be affected due to the project. 68 families doing paddy cultivation occasionally in that land would also be affected. Lots of trees including more than 3000 trees have to be cut down for the project. 14 families revealed that this is their 2nd acquisition since they were displaced families of the land acquisition for Naval Academy.

The difficulties may be caused to the public during the construction time ie. health issues due to dust, hindering of their way etc. especially the way to the cremation place of Ezhava community to be considered as the impact of the project .

Table 1.5.1 : Possible Social Impacts of the Project Possible Impact of the project Number of families Loss of land 280 Loss of agriculture 198 Displacement 2 Fully/Partially affected residence for approach 12 road Loss of Livelihood 145 Loss of structures 1 cattle shed and 1 other shed in the

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proposed depot site will be affected. Structures like boundary wall, septic tank etc. may be affected in the proposed road site which is subjective to the structural alignment.

Besides the above explained impacts, lots of trees have to be cut down for the implementation of the project. Table 1.5.2. Impact on Productive Assets Name of the tree Approximate Number Coconut tree 3402 Areca Palm 170 Plantains 57 Guava 12 Mahagani 42 Mango Tree 61 Tree 46 Anjili 4 Nutmeg Tree 12 Teak 6 Breadfruit Tree 5 Other Trees 7 Occasional Paddy cultivation 68 families

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Note: The above data is arrived as per the information provided by the respondents during the Survey. Supporting documents needto be verified during Land acquisition.

1.6. Mitigation Measures

The policy vide G.O.(Ms)No.448/2017/RD dated 29/12/2017 issued by Revenue(B) Department, for the rehabilitation and resettlement package for acquisition of land in the state in lieu of RFCT LARR Act 2013 will be applicable to the land acquisition for the construction of oil depot and approach road for HPCL/BPCL at Payyanur.

Project construction and implementation strictly followed by the mitigation and safety measures recommended by M/s.KITCO and the mandatory regulations of Oil Industry Safety Directorate

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CHAPTER 2 DETAILED PROJECT DESCRIPTION

2.1. Background of the Project

At present, northern districts of Kerala lacks the facility for oil installation and currently operates from Kochi or refineries. HPCL and BPCL have small depots at Kozhikode and Kannur respectively. There is no provision for expansion of storage and distribution facilities of the existing small depots at Kozhikode and Kannur and do not meet the revised / new Oil Industry Safety Directorate (OISD) norms. Hence HPCL is proposing to construct a new Petroleum Oil Installation in the northern Kerala, as part of resettlement of the existing small depots as a Common User Facility.In order to cater to the POL requirements of Northern Kerala effectively, it is essential to have one more Oil Installation apart from Cochin, for each of the Oil Companies, so that tanker movement by road is avoided thereby reducing the risk of accidents and de-congestion of roads.

The proposal is to establish a Greenfield Petroleum Oil and Lubricant (POL) terminal with a total storage capacity of 69490 KL to cater the fuel demand of the central and Northern Kerala districts.The storage terminal is proposed to facilitate the retail requirements of Motor spirit (MS), High Speed Diesel (HSD), Superior Kerosene Oil (SKO) and Aviation Turbine Fuel (ATF) of the districts of Northern and Central Kerala.The proposed depot at Payyanur, will mainly cater to the POL requirements of northern districts of Kasargod, Kannur, Kozhikode, , Wayanad and Mahi. Product receipt will be through Railway Tank Wagons either from Kochi or Mangalore Refineries.

The Government has accorded sanction for the project as per Order No. GO (RT) No. 591/2017RD dated 14/02/2017.

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2.2. Rationale for Project

Petroleum product movement either through Pipeline or through Railway Tank Wagons is always safer and economical option as compared to movement of bulk Oil through Tank Trucks by Road. Also the population and expansion of city took place near the existing depots of Kozhikode and Kannur and hence it is safer, to shift / re-locate the storage Depot away from City / Municipal limits. Thus the proposed project shall be considered as public purpose as per Section 2 of RFCT LARR Act.

2.3.Details of Project - size, Location, Production Targets,Cost and Risks

The proposed project is to construct an Oil Depot and its Approach Road at Kandankali in Payyanur village in Kannur district for HPCL and BPCL. POL terminal proposed to construct is with a total storage capacity of 69490 KL where the Class A and Class B petroleum products will be transported to the Terminal through railway wagons. The facility will have storage facilities for various products planned with refilling facility to the tank trucks to distribute further to the retail units.

The proposed approach road is to take off directly from -Payyanur Road, which is parallel to the Ezhimala-Payyanur railway line towards East having a length of 1.5 km. It will be a 30 m dedicated corridor with a provision for 7.5 m emergency exit Cost:

Total estimated cost of the project is Rs.250crores. Risks: Possible risk factors of the project is as follows: a. Environmental degradation b. Environment pollution

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c. Explosive nature of the product d. Health hazards

2.4. Examination of Alternatives

As stated by the requiring body no other alternatives were considered because the proposed land is suitable for the project since it is adjoining to the railway track so that a siding can be constructed for product receipt through railway wagons. The land also falls outside the Municipal town limits of Payyanur with very little inhabitation. Besides, there is no large chunk of land is available in any of the northern districts of Kerala adjacent to railway track.

2.5. Phases of the Project Construction

Phases of the Project Construction will be completed in two stages. The first will be the construction of Oil Depot and the next will be that of approach road and rail connectivity. The construction will be done as per the predesigned plan done by the HPCL/BPCL companies.

2.6. Core design Features and Size and Type of Facilities

The present proposal is to develop a dedicated facility for POL terminal with a total storage capacity of 69490 KL where the Class A and Class B petroleum products will be transported to the Terminal through railway wagons. The facility will have storage facilities for various products planned with refilling facility to the tank trucks to distribute further to the retail units. The terminal would have in built facilities for administration, truck-parking bays and fire-fighting facilities etc., which are integral part of the operation of such facilities.

It has been planned and its entire facilities will be designed as per OISD guidelines 244 integrating the essential facilities for following operations within the Terminal:

 Unloading of products from railway wagon through railway siding.

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 Storage of petroleum products in storage tanks fabricated as per international standards.

 Receipt of Ethanol through Tanker trucks

 Pump House Operations (PHO)

 Tanker Lorry Filling (TLF) operations

 Dispatch of above petroleum products through Tanker Trucks.

2.7. Need for Ancillary Infrastructural Facilities

Prima-facie, there is no need for any ancillary infrastructural facilities. However, due to the movement of Tanker Lorries, there will be requirements for up keeping and maintenance of the Tanker Lorries and eatery joints for the Tank Truck crew.

2.8. Work Force Requirements

The construction of the project shall be handled by officers already recruited for the Engineering and Projects Dept. and various execution works shall be finalized on the basis of tendering process as stipulated for the Public Sector Undertakings (PSUs). However, there will be indirect employment for construction under various works contracts.

In the operational phase, as the proposed new POL Depot is a resettlement of the existing Depots of Kozhikode & Kannur, the existing manpower would be relocated to the new location upon completion of the project. However, there will be lot many indirect employment opportunities for various contract workmen for operation and maintenance of the Installation.

2.9. Details of Studies Conducted Earlier

a) Site Selection Study by M/s Arya Consultants b) Topography Survey by M/s Secon Limited c) Cadastral Survey by M/s Secon India Limited

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d) Feasibility Study for Railway Siding by M/s RITES Ltd. e) Environment Impact Assessment Study by M/s KITCO Limited f) Hazardous Operations (HAZOP) Study by M/s KITCO Limited g) Risk Assessment Study by M/s KITCO Limited

The mitigation measures recommended by M/S KITCO Limited for the possible impacts of the project are attached as annexure.

2.10 ApplicableLegislations and Policies

The applicable laws on land acquisition, rehabilitation and resettlement for the construction of Oil Depot and its Approach Road at Kandankali in Payyanur village in Kannur district for HPCL and BPCL.

 The Right to Fair Compensation and Transparency in Land Acquisition, Rehabilitation and Resettlement Act, 2013  Government of Kerala – Revenue (B) Department -State Policy for Compensation and Transparency in Land Acquisition vide GO(P)NO.470/2015/RD dated 19/09/2015  Government of Kerala – Revenue (B) Department -State Policy for Rehabilitation and Resettlement Package for Land Acquisition in the State in lieu of RFCTLARR Act 2013 vide GO(MS)No.448/2017/RD dated 29/12/2017  Right to Information Act, 2005

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CHAPTER 3 TEAM COMPOSITION, STUDY APPROACH AND METHODOLOGY

As per the order G.O.(P)No.41/2018/RD dated 16/07/2018 & G.O.(P) No.71/2018/RD dated 05/11/2018 Government of Kerala appointed RAJAGIRI outREACH as the SIA Unit to study the Social Impact Assessment of the land acquisition for the construction of oil depot for HPCL/BPCL and its approach road in Payyanur of Kannur district.

The objective of Social Impact Assessment (SIA) is to enumerate affected land and structures, affected families and persons, to identify social impacts, and to prepare Social Impact Management Plan (SIMP). In order to capture data for the present exercise, both primary as well as secondary sources were systematically tapped. As a part of SIA, census socio-economic survey has been conducted by experienced members of SIA Unit in the proposed siteto list out the favourable and adverse impacts of the project.

3.1. Details of the Study Team

The study team is headed by the Project Director, who is the Chairperson of SIA Unit. A team of 9 members having experience in conducting Social Impact Assessment Study and Socio Economic Surveys were assigned for field level data collection, monitoring of data collection and co-ordination of the study. Representatives from Revenue Department supported the investigators to identify the affected families. Details of the study team are mentioning in the table below:

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Table 3.1.1. Details of the Study Team

Sl.No Name Qualification and Experience Designation MSW 30 years in Meena Kuruvilla 1. Chairperson development

sector MA, DSS, 26 years in 2 Maria Tency.V.S Documentation Officer development sector DSS, 23 years in 3 Ranjith K U Research Associate – SIA development Unit sector 23 years in 4. Biju C.P BA – Research Associate development sector 20 years experience 5. Ligi.V.E. MSW in development Research Associate sector MSW 2 Years experience 6. Tony Babu Research Associate in development

sector MSW 4 years experience 7 Mithun Mathew Research Associate in development sector MSW 2 Years experience 8 Gigin.P.S Research Associate in development sector MBA 9 Years experience 9. Salim.P. in development sector

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3.2 Methodology and Tools Used

FIGURE 3.2.1 APPROACH AND METHODOLOGY FOR SIA Phase-I

PRE-SURVEY ACTIVITIES AND SURVEY OFPAFspaPAFsPLIMENTATION SYSTEM

 Discussion with officials of concerned departments  Pretest of the questionnaire

 Training the Field Staff  One to one household interviews  Public consultation

Phase-II

POST SURVEY ACTIVITIES &REPORT PREPARATION

 Data tabulation and analysis plan  Organizing Public Hearing  Data coding and entry  Consultation on SIA findings with  Finalization of SIA report affected people, civil societies structure  Sharing of concerns by  Analysis of survey results stakeholders  Preparation of draft SIA report  Review & comments from concerned officials  Incorporation of comments and submission of the final SIA report

Before preparing the Draft SIA study report the study team acquired maximum information about the project with the support of requiring body. The team visited the affected area many times and studied the socio-economic background of the

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affected families. Various impacts of land acquisition were assessed in detail. Legal framework for land acquisition and compensation as per RFCTLARR Act 2013 were also studied.Various steps taken for the study are as follows:  Study of relevant documents, reports and project alignment drawing.  Site visits and information dissemination about the project  Socio-economic survey and enumeration of affected properties  Analysis of socio-economic survey data  Community/Public Consultation (Public Hearing)

Public Hearing: As per Form Form 5 of Rule 14 (1) of the Kerala Right to Fair Compenstion and Transperancy in Land Acquisition Rehabilitation and Resettlement Rules 2015, a public/community consultation (Public Hearing) was held on 12thDecember 2018 in Kairali Auditorium at Payyanur in which the affected families, officials from the requiring body, Land acquisition office and SIA unit were participated. Besides them, the Chairman of the Payyanur Minicipality and the general public were took part in it. During the public hearing, the affected families and the general public have raised concern/anxieties related to the land acquisition and about the proposed project.

The public hearing session has recorded with video streaming. The concerns/anxieties/queries raised by the participants were given to the requiring body in writing and it were answered by them. The details are given in the below given table. Table 3.2.1.:Concerns Raised in the Public Hearing and Answer from the Requiring Body:

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Name of the participant Questions/requirements Answer from the concerned authority NarayaniVellacheri She would like to know the width of the proposed Width of the approach Road shall be 20 M approach road and rail and width for Siding track shall be about 10 M. N.P.Surendran Requested to acquire his remaining land too Land is proposed to be acquired as per the requirement of Infrastructure and facilities planned and green belt areas. T.K. Beena& T.K. Gouri Requested for a good compensation for the acquired land Compensation shall be finalized as per the Thekkekottarathil and demanded the acquisition of the remaining land too. prevailing Rules of RFCT LARR Act 2013, and Since their land was first acquired for Ezhimala Naval as per Govt. guidelines. Academy, it is a second acquisition Kamalakshy.E.V Requested for a good compensation and demanded the acquisition of the remaining land too P.P. Kunjamina She is a widow and staying with her children in the affected Rehabilitation & Compensation shall be as Punchakkad land. Her house will lose due to the project. She requested per the prevalent Rules of Govt. of Kerala and a safe rehabilitation and sufficient compensation RFCTLARR Act. 2013 Indira Requested to get sufficient compensation for her land and a In case any opportunity for indirect job for a family member according to his/her qualification employment arises, preference would be given to the project affected people (PAPs), as per their qualifications and skill sets. However, Company cannot guarantee any job. N.K.Chandran, Narankulangara House, A part of the land from survey No.594/4 will be acquired. Wherever found feasible and required, Echilamvayal He has given a complaint against the partial acquisition. Company shall try to acquire the maximum Kandoth Requested to acquire the remaining land too since that will extent of land possible, leaving the be unused after acquisition. mandatory CRZ notified areas. Mohanan.K.P, Punchakkad Requested for sufficient compensation for his land and Compensation shall be finalized as per the Payyanur house acquired for the project prevailing Rules of RFCT LARR Act 2013, and as per Govt. guidelines. MaadakkaKunjikannanvelichappadan According to the first survey their full land included, but Wherever found feasible and required, Madakka house the second survey their land partially included. They Company shall try to acquire the maximum Kandankali cannot use the remaining land after acquisition. So extent of land possible, leaving the & requested to acquire their whole land mandatory CRZ notified areas. It is not VellacheryChandran possible to acquire land from

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Madakka House They also suggested to acquire the land from the Punchakkaddam onwards, as our Kandamkali Punchakkad Dam onwards otherwise the project may requirement is limited to about 85-90 acres cause difficulty to the people. only. No difficulty to the people is envisaged. Ajitha, Nalini, Sathi, Purushu, Kannan, Their expired mother Yashodha owns 50 cents land in the The land, if it falls under the project Satheesan& Ramachandran project area. Requested to acquire the whole land for the identified area of 85 acres, and based on legal project heir certificate, Corporation would be willing to acquire the whole land. They also suggested to acquire the land from the Punchakkad Dam onwards otherwise the project may It is not possible to acquire land from cause difficulty to the people. Punchakkad dam onwards, as our requirement is limited to about 85-90 acres only. No difficulty to the people is envisaged. MottammaniUnnikrishnan Ready to give land if provided with sufficient compensation Compensation shall be finalized as per the Kandankali prevailing Rules of RFCT LARR Act 2013, and as per Govt. guidelines. CheruvattilSantha She requested to get a land and house if the land will Rehabilitation and compensation as per the Punchakkad acquire for the proposed project. RFCT LARR Act shall be paid as per Govt. guidelines. Santha.C.V. Requested to acquire the whole land owned by The land, if it falls under the project PachaAmbuKomath and MayilvalappilKunjanga identified area of 85 acres, Company is proposing to acquire the whole land.

P.Krishnan, Requested to acquire the remaining land too ie. 33 cent in &P.Padmanabhan,Payyanur survey No.595/2 Wherever found feasible and required, Company shall try to acquire the maximum Ravikumar.O.K. Half of his property is acquired. Requested to acquire his extent of land possible, leaving aside the CRZ Ramanthali remaining land lays beside the river notified area. Vadakkumbad.P.O. C.Chandran 20 cents will remains from his 1 acre land after acquisition. Compensation shall be finalized as per the Chommambi House Requested to acquire the whole land and provide sufficient prevailing Rules of RFCT LARR Act 2013, and Punchakkat compensation. He was displaced due to the acquisition for as per Govt. guidelines. Payyannu Ezhimala academy. So this is a second acquisition ParathyManikkam& Demands sufficient compensation Compensation shall be finalized as per the ParathyNarayani prevailing Rules of RFCT LARR Act 2013, and

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KankokaranAmbu Demands right compensation for his land. He depends as per Govt. guidelines. Akshya upon the income from the land as coconut and other yields. Kandankali So his livelihood will lose. No other land to give for his heirs. Requested for a job for a member of his family N.V.Narayani Sufficient compensation require for her affected land and house in survey no.519/4 Enavalappil Kamalakshy Requested to acquire her whole land in survey no.530/20 Wherever found feasible and required, provided with sufficient compensation Company shall try to acquire the maximum Savitha.V.P 50 cents of land will be acquired from survey No.534 extent of land possible, leaving aside the CRZ owned by VadakkepurayilSavitha, BeericheryPavithran. notified area. Since they cannot use the remaining land , requested to Compensation shall be finalized as per the acquire fully provided with good compensation prevailing Rules of RFCT LARR Act 2013, and Damodaran.P. His land belongs to survey Nos 220/136, 561/101,342/10, as per Govt. guidelines. Kandankali 342(3,5), 563(13,3) and 561 (102,5). His land will partially affected and requested to acquire the whole land provided with sufficient compensation K.K.Vijayan, Punchakkad Half of his land will be acquired and requested to acquire the remaining land Sibin Stanley, Punchakkad He wants to get clarity on the acquisition of his land and Depending upon his Survey No. & actual site Near R.C.Church, Payyanur house, whether it is fully or partially acquired. locations, we will come to know, if the land can be acquired partly or fully. Suresh Babu, KripaNivas The family comprises of his wife, 2 daughters and himself In general, people reside nearer to the Oil Railway Gate, Punchakkad are staying near the railway gate. A corner of his land will Storage Depots all across the country and be affected due to the project. Whether the company can there is no danger. Area meant for approach ensure the safety of his house and stay after the road shall be segregated and fenced. construction of the road. He requested to rehabilitate his However, Company cannot undertake to family to another suitable place. ensure safety and stay of the personnel. Rehabilitation shall be as per the Extent Rules and RFCT LARR Act 2013. Shaduly.C.K, MuhammedYaseen He requested to avoid the acquisition of his house newly If feasible and possible, we shall endeavor to House, Kotty, Payyanur constructed. He has been started staying in the house since avoid acquisition of constructed and 8 months. He has to pay the debt related to house habilitated houses. However, in case we have construction. No other land owned by him to acquire, suitable compensation as per the RFCT LARR Act 2013 shall be payable by the

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Company.

Fousiya She is not willing to acquire her land for the construction of If her land is falling outside our alignment, road. She is staying near to the proposed area. required area, it is NOT proposed to be acquired. E.P.V.Narayanan/Dhakshayani Half of his land will be acquired and requested to acquire Wherever found feasible and required, Kandankali the remaining land provided with sufficient compensation. Company shall try to acquire the maximum Their land under the survey numbers of 528/5, 560/6, extent of land possible, leaving aside the CRZ 545/5, 560/70, 540/4, 544/1. notified area. ChenothKarinthappallivalappil Abdul He own 92 cents land in survey No.541, 530/6, 530/4. A Salam part of his land will be acquired. Requested to acquire the whole land provided with good compensation. He is a Compensation shall be finalized as per the cancer patient. prevailing Rules of RFCT LARR Act 2013, and K.Shekharan, PM-XXIII/448 Requested to consider the road frontage and the income as per Govt. guidelines. Thaloth from his land as coconut for the compensation. He also owns 1.5acre land (coconut farm) consists of well, pond and cattle shed behind the land of Mr.Madakkavijayan and the way to his house lays in the acquired land. Requested to not hinder the way to his house due to acquisition. The land under the survey numbers of 537/1, 539/16, 536/2A, 536/2B, 536/2C, 536/CD, 541/1. SukumaranKochodan, Sreelakam Till courtyard of both the families will be acquired for road Punchakkat, Survey No:491/7,8,9,10 and rail. Since they find difficulty to stay in their house after the construction of road and rail, requested to acquire Payas Dominic, Survey No:491/3,4 their whole property provided with sufficient Punchakkat compensation. Suresh Babu, Kripanivas All could understand they will be displaced for the project. During further proceedings, LA team / Kandankali But they are not yet intimated about the rehabilitation plan District administration would convey the as stated in the LAAR Act 2013. They are not ready to give rehabilitation & compensation plan as stated EramangalamKannan up his property for the project in the RFCT LARR Act 2013. Company is Punchakatt bound to follow the Rules and regulations of

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Padmini.T, Punchakatt the Act. And Govt. guidelines.

Satheesh.T, Eramangalam Punchakatt Khadeeja.K.K, Punchakatt

Ratheesh.T., S/o.E.Kannan Survey No:418/7 Miziriya.P.Pulukkal House Punchakatt Subaidha.M.K.P., Building No:392 The family is displaced for the Ezhimala Naval Academy Project. Again displacing for the Oil depot. She is not yet intimated about the rehabilitation plan as stated in the EramangalamShyamala LAAR Act 2013. She is not ready to give up his property for Nandanam House, Punchakkatt the project Ganeshan.T.P. Land acquisition will affect his livelihood. He don’t know Suitable rehabilitation & compensation as per Thazhathepurayil any other job other than agriculture. Requested to avoid RFCT LARR Act 2013 shall be paid to the Punchakatt his land from acquisition. Their traditional occupation is affected people. Alternate opportunities of agriculture. It is the only livelihood of them. The project livelihood shall be generated once the Depot will also cause some environmental issues. is constructed and become operational. There will not be any environmental issues due to the project. KaiparathKarunakaran Survey No.of his affected land is 538/1. He is willing to In case any opportunity for indirect S/o.PothekkaraKunjikannanNambiyar, give his land and requires a permanent job for his son employment arises, preference would be “Sreepadham”, Kaiprath House, (graduate+accountant course) in the company along with given to the project affected people (PAPs), Kandankali compensation as per their qualifications and skill sets. However, Company cannot guarantee any job. Prasad Melath He explains that the cemetery of SC belongs to the project Cemetery area is not proposed to be Karumkadavu area cannot use after the project implementation. He also acquired. Cemetery can continue even after Punchakkad understood that the project will cause environment the project implementation and suitable problems to the community. passage/ access shall be provided to the Cemetery area. No environment problems

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are envisaged, due to presence of Oil Storage Depot nearby.

Unnikrishnan Requesting that the entire property be taken as the Wherever found feasible and required, remaining land cannot be used. Company shall try to acquire the maximum extent of land possible, leaving aside the CRZ notified area.

Savithri Requests that a fair compensation be given as it is the Compensation shall be finalized as per the livelihood of the people that is being lost. prevailing Rules of RFCT LARR Act 2013, and as per Govt. guidelines. Prasad He opined that the 10000-30000 land value of the recent sale in the last three years should not be taken into account for calculating the value of the land under acquisition as during those land sales it was the need of the seller that the land should be sold and thus the land is not sold for the actual price but a lower price. here since it the governments need to acquire the land a better compensation should be given.

He wished to know how the compensation is being calculated when it is the house of the people and their toil of their entire life is at stake.

He also wished to highlight that the people who are to lose their land for the project are not against the project but rather only demanding a fair compensation. Akbar A proper fair compensation should be given.(this family had already been displaced 30 years ago for the Indian Navy)

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Suresh Acquire the entire land as it is lying unused and Wherever found feasible and required, Company shall try to acquire the maximum inaccessible. extent of land possible, leaving aside the CRZ notified area.

Sukumaran Wants to know what measures are taken for the safety of There will not be any private land between the people who land lay between the rail and the road Rail and road corridors and the entire combined width of about 30 M would be acquired. GangadharanNambiyar Precautions should be taken to prevent oil spills and other All the Safety measures and equipment as per problems from rising. the Oil Industry Safety Directorate (OISD) He commented that nothing regarding the environmental Standards shall be provided, and all impact of the project is mentioned in the study. precautions shall be taken/ ensured so as to He stated that the project can be supported if the prevent Oil spills and associated problems. government can ensure the safety of the locals. Balan During further proceedings, LA team / District administration would convey the Requested to disclose the details of the rehabilitation rehabilitation & compensation plan as stated package. in the RFCT LARR Act. Company is bound to

follow the Rules and regulations of the Act. And Govt. guidelines. O.V.Rajan They are doing agricultural jobs in the affected land. Their Suitable Rehabilitation/ compensation would livelihood will lose due to the project. So requested to give be made to the affected people as per the ParathyRaveendran up the project. RFCT LARR Act 2013 and Govt. guidelines.

ParathyPrakashan The Project is in line with the larger interests of the State and would be beneficial to the Husain K P, Safiya V P State of Kerala and its development.

Krishnan Nambiyar He has no problem in giving his land. He suggested that As and when any indirect employment jobs in the upcoming project be given to the locals also so opportunity arises, preference would be that they are benefitted. given to the locals. However, Company He opined that should any problems arise the government cannot guarantee permanent employment. should take responsibility and show initiative in solving

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the problems. As per RFCTLARR Act 2013 copy of the SIA He further said that a copy of the SIA report should be report will be available in Payyanur made available to the affected families Municipality, Village office, District Collectorate and in Land acquisition office which can be accessible to the affected families and for the general public. The report will be also published in the website of SIA unit and District Administration (Reply from SIA unit) Anilkumar.K.V He is staying near the project area. He could understand People who are staying near the project area, PuthukkadKoman House that people cannot continue to reside there as the after but not affected due to acquisition, can Payyanur effect of the project. So he requested to avoid the project to continue to stay there. There are many places save the field and river in our country, where public continues to reside near the Oil Depots. P.P.Sarada She stated that his panchayat is declared as the Company assures that there will not be any Vice President environment impact area of this project. It is an island disturbance / damage to the Kavai river. ValiyaparambuGramapanchayat situated beside the kavai river. The project is proposed to There is no bund proposed to be constructed be construct in the joining point of Ramapuram and on the river. There will not be any Perumba rivers and Environment Impact Assessment contamination nor will there be any Report published by the company states that the project disturbance to the livelihood. There are many site is in the high and low tide area. Kavai river which is Oil storage depots constructed adjoining the the only resource centre of the panchayat. The project will river and Irumpanam Terminal is one such contaminate the river and they have prior experienced that example in Kerala state. the contamination of Kavai river affected the livelihood related to river. Once they constructed a bund in this river caused contamination of river and health issues to the people. She requested to withdraw the project which is unsuitable for the society and environment Appukuttan Presently there is a narrow road from the joining point of The purpose of the approach road is to Kavil the 30 m proposed approach road to the National High provide access from Depot to one of the Payyanur way. The concern on the width of those roads were major roads of the town, and the same can be expressed by the Panchayath Presidents during the public the part of the proposed project. Widening of hearing of EIA. 1 km proposed approach road will not the town road is beyond the purview of the enough for the project implementation. So the present SIA project. If need be, this can be taken up with

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is incomplete without including the land needed to extend the Municipality/ Govt. However, it is the approach road estimated that the existing roads would be sufficient to handle additional Oil tankers required for the Depot operations. Rashid MKP He stated his anxiety on the height of the approach road There will not be substantial increase in the Punchakkad which may cause difficulty to the nearby families. And the height of the approach road, which may cause proposed road’s area is the only way from Kanam to difficulty to nearby families. The approach Punchakadschool and that may be affected. He requires a road to the Punchakad school will not be clear remedies for it and also requested to change the affected, as there is proposal to of land project to other non residing area. acquisition near / leading to school. K.Jayaraj, UDF Chairman He requested to give up the project considering the public During the recent Public Hearing, as part of PayyanurMandalam committee opposition and safety Social Impact Assessment study, it was noted that there is no public opposition to the project and all the land owners willingly came forward to sell their land. There are no apparent Safety concerns as well, as Corp. shall ensure all necessary steps to maintain Safety & environment. Director, SEEK The persons engaged with agriculture, cattle rearing, As we understand from the Public, there is no Payyanur fishing etc. will lose their job. And their number will be much cultivation done in the proposed area more than the number of employment stated in the EIA and most of the land is lying idle. Almost all report the land owners are willing to sell their land, and suitable compensation / rehabilitation as Cremation places of 5 community, cemetery of Muslim and per the RFCT LARR Act shall be paid to the cemetery of Christian are in the project area. Whether affected people, and hence there should not these will be relocated for the project. Otherwise what will be any issue. be the solution for hindering the way to there. None of the Cemeteries are proposed to be He would also like to know the rehabilitation plan for those acquired for the project and will continue as families who are facing second acquisition it is. Necessary passage/ access shall be provided, in case required. EIA report states that 2 ponds used by the community in the project area and recommended that access to this pond It may be noted that no pond is proposed to if denied facility must be provided in co-ordination with be acquired for the project. Ponds shall be

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Kerala Water Authority. Was it discussed with KWA and outside our boundary wall and will have what will be the further steps for it access to the people.

What will be the solution to mitigate the fear of isolation, There will be lot of indirect employment loss of livelihood, security threat and risk of hazard of 13 opportunities arising out of set up of an Oil families residing there since the project will be sand Depot and these families can be benefitted. wiched them between the river and storage facility There shall be no security threat / risk of hazard as all necessary precautions shall be taken by the Company. There are many Oil Depots in the country & Kerala state where public inhabitation is close to the Depot, for many years, without any problem. K.V. Surendran, Chairman, Proposed site lies at the adjoining area of two rivers It may be noted that mandatory CRZ notified Kavvaikayal-Wetland system of bordered by mangrove forest coming under CRZ. Two areas near Mangroves &Kavvayi river are not Northern Kerala Protection-Action rivers drains at Kavvayi river just 1 km away from the site. going to be acquired. During the Public Committee Valiyaparambupanchayath is fully depending on the river Hearing, it is noted that all the landowners for livelihood. All the 16 panchayaths are closely related are happy to sell their lands, as very little with Kavvayi river. The proposed site is a highly ecological farming is carried out these days. Suitable sensitive zone and water logged area. The tidal action in compensation & Rehabilitation as per RFCT the lake affects a wide area in Kannur and Kasargod LARR Act 2013 shall be made. The entire district. The proposed site is a farm land. The POL storage operational areas inside the Depot shall be will destroy the livelihood and valuable resources of a large concreted and hence there is no chance of Oil number of people in the 16 Panchayaths. As the oil spills on seepage into the sand/ ground. The the sandy soil can spread to the whole backwater proposed project will not disturb the eco- ecosystem and adversely affect aquatic life. system of the surrounding areas, nor it will disturb the mangroves or the adjoining Many mid land laterite hills have to be destroyed to raise rivers. the low lying wetland upto 3 metres for project Filling inside the proposed depot area shall construction which cause flood and drought in the area. not be more than 1.5 M and not 3 M. There Digging bore wells to pump a huge amount of water for the will not be any flooding in the area nor any project will deplete the drinking water availability and drought, due to setting up of Oil Depot. Water cause ingression of salt water into existing wells in a large shall be taken from the adjoining river in case area. of any emergency, but bore-wells will not be dug. Water for drinking purpose shall be

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Apart from houses, there are several schools, educational sourced from Payyanur Municipality. institutions, places of worships, cultural institutions in the vicinity of the project area. Transportation of fuel in oil The movement of Oil tankers will not pass tankers by road to 334 outlets in all the 7 districts of North within the Payyanur Municipal limits and Kerala from this single facility will create traffic problems shall be diverted to other peripheral roads. on the already congested roads in and around the Movement of Tankers shall also not create PayyanurMunicipality. any new traffic problems in Payyanur.

Temple festivals in the vicinity using crackers will not be There is no in the close proximity of the possible anymore as fire near the oil facility will be Depot and bursting of crackers during extremely dangerous. festivals will not be any issue, as all the temples are located more than 1 km away, There are about 5 cremation grounds of different and there is no danger. communities adjacent to the project site. These cannot be relocated as suitable lands are not available and the people None of the cremation grounds are not are sentimentally attached to the cremation sites of their proposed to be acquired. There will not be ancestors. The EIA was prepared without taking into any disturbance to this activity due setting up consideration of any of these factors of Oil Depot.

Environmental clearance cannot be obtained for the New State Committee has already been set- project as the State Committee’s term has expired up and EC shall be obtained shortly, before the land is acquired.

As the proposed site is not ecologically, socially and There is no alternate large chunk of land culturally not suitable for the project he requested to find (about 80-90 acrs) anywhere in the northern an alternative site. Whether alternate place was considered Kerala adjoining the Railway track. We have for the project as said in LAAR Act seen other places also but find this place as the best option. He could understand that the area of land proposed to be acquired is more than the land required. Hence this land It is proposed to take only that much land acquisition is against the LAAR Act which is actually required for the Depot, leaving the mandatory green belt area, which Considering all the afore said he requested to withdraw is about 30%. No additional area shall be the project from the proposed site. acquired.

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All points above have been justified and suitable remedial measures shall be taken, & in the larger interest of State and Nation, this project cannot be withdrawn.

The families requested to include their property in acquisition

Name of the participant Questions/requirements Answer from the concerned authority DamodaranKaana The family resides in the road side of the project area. Own There should be no problem in continuing to stay Kaana House, Punchakatt 4.5 cents of land and a small house. Expressed anxiety on along the road side. Even now, most of our continue their stay after the implementation of the project. houses are along the road. Hence requesting to acquire their land provided with Compensation shall be finalized as per the adequate compensation prevailing Rules of RFCT LARR Act 2013, and as per Govt. guidelines. P.V.Karthiyani, A displaced family of the land acquisition for Naval academy. Wherever found feasible and required, Company MullakkottThaleth, Kandankali Now staying in Thalothvayal. Requested to include her land shall try to acquire the maximum extent of land in survey No.595/2, 595/1 for present acquisition possible, as per the requirement, leaving aside Antony Maniyan (Babu) He has already given an application to include his land (16 the CRZ notified area. Estate- ares) in survey No,525/101-23 to the special Tahsildar. (Maniyan House) Requested to consider that application Compensation shall be finalized as per the KizhakkeKandankali prevailing Rules of RFCT LARR Act 2013, and as AkkarakkaranRameshan Resides within 100 meter in the area. Ready to give his land per Govt. guidelines, and Corporation shall abide Punchakkatt for project. Requires sufficient compensation and job for a by the above. family member

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U.N.Ramla She is not staying in the affected area but have property there RamanthaliVadakkumpad and would like to know whether her property is included in acquisition. She is ready to give the land if provided with good compensation KuttampeedikayilMuhammedK Ready to give his land in survey Nos:420/5,2,3&6 if provided unji with good compensation Vanaja.K.v, Saantha.K.V., Requested to include their land survey No.515/10, 518/3 in Kamala.K.V and Vimala.K.V acquisition D/O. ParathipalerivalappilKunjamb u ChalenSundaran Requested to include his land survey No.534/12 in acquisition P.Thampan Requested to include his land survey no. 54/3,539/17 & 55/24 in acquisition K.P.Mohammed Requested to include his land survey no. 420/5,2,3,&6 in acquisition M.Kallyani, Muttil House Requested to include his land survey no.594/2, 595/2, 593/1 Punchakatt in acquisition K.K.Sahida, MohzaManzil Requested to include her house in the approach road area in Kandankali gate acquisition O.Lakshmi, Madavalappil Requested to include her land in acquisition East Kandankali ThandayiLakshmanan Requested to include his land survey no.539/9,566/12, 539/14 in acquisition after the remittance of land tax E.P. Poomani, The access to his land may be denied after the If the land is falling outside our required / D/o.palorachindan, implementation of the project. Hence requested to include his earmarked area, we cannot acquire this land. Edadanputhiyaveedu land in acquisition. There will access to all the lands adjoining the Kandankali Depot, subsequently.

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Anitha.V.V. Requested to include the land survey No. 541/1 in Rajani.V.V acquisition

SajithaVadakkeveettil The property adjoining to the affected land is the sole income There will be access provided to the adjoining W/o.EttammalKunjhikrishnan source of the applicant. Only access to the said property is land which are not part of the acquisition. Muttil House, Punchakkad through a mud road and the applicant apprehend that the Implementation of this project will in no way Payyanur, implementation of the above said project will diminish the diminish the value of the property and would Survey No. 531/1 value and utility of the said property and further reduce his also generate other livelihood opportunities. ChunnambiBharathan income. Hence requested to take appropriate measures Muttil House, Punchakkad either for making accessible motorable way or to take over Survey No:528/7,529/2 the entire property by giving compensation. EttammalKunjhikrishnan Muttil House, Punchakkad Survey Nos: 595/1,2&3 MuttilSarojini W/o.ChunnambiBharathan Muttil House, Punchakkad Survey No:594/1, 595/1, 529/1, 529/2 Prasad.C&Meenakshy.C The land acquisition should include the land from Dam to It is not possible to acquire the land beyond what Mullakkod House, Kandankali Chankoori bridge is actually required for the construction of new Depot and its approach road. Thungapriya.C.Kombatt The property bought to start a resort. Since the nearby land If the land mentioned is falling within our Survey No: is acquired for the project they cannot start the resort. Hence required / earmarked area of 85 acres, it will be 593/1,593/8,593/9,593/3,593 requested to include these land in the acquisition definitely acquired. If the said land is falling /10,593/11,538/8, beyond, what is required, we may not acquire. 538/6,538/9, 538/7, However, resort can also be constructed 538/4,538/5,538/10,538,3, adjoining an Oil Depot, safely. 548/19,593/2,593/12,593/13, 593/4, 546/2,51/16b (total 1418.79 cents

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ParathySahadevan Requested to acquire their land too for the project ParathyPrakashan Survey No: 534/9, 536/12 M.Krishnan Requested to include 532/2 owned by MottamaniManikyam

K. Balan, 560/6 Requested to include the land survey No. 560/6 in acquisition

MottammaniDevaki Requested to include the land in acquisition

Kamalakshy.K. Her land is at Thalothvayal. Since the adding of railway lines There will not be any danger to the public, due to the entry to her land may be difficult. She is willing to give the project. Compensation shall be as per the her land for the project if provided with compensation RFCT LARR Act 203. ensuring no danger to the public due to the project E.Kunjikrishnan, Muttil House, Copies of the petitions sent to the Chief Minister and the Wherever found feasible and required, Company Punchakkad, Minister of Ports &Archeology were given to SIA unit. They shall try to acquire the maximum extent of land explained that the project was 1st considered 125 acres of possible, as per the requirement, leaving aside M.Prabhakaran, land and then it changed to 75 acres. These families’ property the CRZ notified area. We find this area of 50 K.Padmanabhan& Abdul Salam belongs to the 1st alignment. They can not even sale their acres (125-75) is CRZ notified area, where no property after the implementation of the project. Hence construction is allowed and hence not being requesting to acquire their land too for the project considered for acquisition.

T.P.Krishnan, C.Govindan Copy of the petition sent to BPCL &HPCL requesting to As this land between the river and the proposed C.Meenakshy, P.Govindan Nair include their 10 acre land in acquisition was given to SIA unit. depot is basically the CRZ notified area, where no C.Thressia, C.Thampai According to the present alignment their land lays between construction is allowed and hence Company C.Sasikumar, A.Surendran the river and compound wall of the depo. So the land will cannot acquire it. Already an area of about 30% K.Pushpa, C.Syamala remain useless. They demand the total amount of 12 ares of of the Depot land is being left unutilized as green V.Kunjikrishnan, K.V.Ashokan the land. belt. Rajan.T.P. After the implementation of the project his agricultural land Once the Oil Depot is constructed and made Thazhathepurayil lays East side of the affected land will be useless. So his operational, indirect & alternate means of Punchakad livelihood will lose. So requested to include 534/12 (01832 livelihood would be generated. ar), 534/9 (0.0284 ar), 534/9(0.0100ar) in acquisition. Also requested to include his house and plot in survey no,525/1B People can also continue to stay in the adjoining if the nearby house are acquired. land, as there will not be any threat / safety

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Pradeepan The people may find difficulty to reside in the land lays west hazard owing to the Depot operations. Counsillor side of the project area besides the river which is not taken Payyannoor Municipality over by the company. Suggested to allocate it for Municipality to make an environment friendly park During the public hearing some of the land owners requested to add their houses and land in acquisition ie approximately 12 acres west side of the proposed land between the river and west side of the project site.

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Society for Environmental , an organization in Edat in Kannur district has given a petition to the District Collector about the public hearing and submission of draft report. Considering this the SIA unit conducted a hearing on 12th January 2018 with the organization in which Mr. Padmanabhanan.T.P., Director and one member of the organization attended. Their views shared related to the land acquisition and projects are mentioning below: 1. Land acquisition for the project is beyond the limit of “bare minimum” as insisted by the Act. 2. The draft report is not given clarity on whether any alternative has considered. 3. The proposed 30 m. width approach road will reach to the main road having width of 7 m. that will bring traffic congestion while reaching National Highway 4. The proposed approach road will cause isolation of the 6 crematoriums and st.Mary’s L.P. School situated in Kandankali. Besides the project will hinder the traditional activities of Kandankali temple. 5. Since the project area is an agricultural land including paddy field what will be the alternative solution to regenerate to safe guard food security of the particular place 6. What will be alternative drinking water solution in lieu of the affected public using 2 ponds. 7. The proposed project site lies at the adjoining area of two rivers bordered by mangrove forest coming under CRZ and these rivers drains at Kavvay river just 1 k.m away from the site. If there is any contamination in river water due to the project that may affect the livelihood of the people in Valiyaparamb Panchayath and also may cause health hazard to the neighbouring community.

3.3. Sampling Methodology used:

The study has conducted through socio-economic survey of the affected families. Before the household Socio Economic Survey, visits have been done to identify the properties that were likely to be affected by the project with the support of Revenue Departmentstaffand alignment drawing. An interview schedule was prepared on the basis of the preliminary site visit and it was pre-tested. The survey was conducted through door-to-door personal interviews of the affected land owners staying in the project area and in the nearby area. Besides the SIA unit representatives met the affected families and interviewed them at Kandankli Library with prior notification in the local News paper. The details of affected families, possession of legal documents

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(if any, towards the claim of property),data related to social profile, occupation, source of income, family expenditure, self employment activities, employment pattern were collected through this interview. Most part of the interview schedule has been pre-coded except those reflecting the opinion and views of PAFs, which have been left open-ended.

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3.4. Schedule of Activities and Consultations with Key Stakeholders

16.07.2018 - Government of Kerala, entrusted RAJAGIRI outREACH to conduct the SIA study 16.07.2018 & 05.11.2018 - Publication of 4 (1) notification August 2018- Preliminary visit to the affected area and discussion with LA officer Sept. &Nov.2018 - Data Collection 26.11.2018 - Notification for public hearing 12.12.2018 - Public hearing& Draft Report submission 12.1.2019 -Hearing of the President of Society for Environmental Education 15.01.2019 - Final Report submission

3.5. Limitation of the Study:

As Per the information from the office of Land Acquisition, land properties of 28o families are required to be acquired. However, there were no concrete information to contact affected parties directly or indirectly. Since the geographic area is big and number of residence in the region is less, SIA unit has given notices in the regional edition of leading newspaper and also facilitated wide broadcast through other channels to encourage affected parties to take part in the survey. Apart from the door to door survey, special venue had been arranged for the affected parties who don’t live in the region. Despite these efforts, SIA unit couldn’t contact 55 affected parties and must consider it as limitation of this study.

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CHAPTER 4 LAND ASSESSMENT

The proposed site is located about 2 kilometers from Payyanur Town. The plot proposed for oil depot is bordering the bank of Perumba River along the Southern and Eastern side. The railway line between Payyanur and Ezhimala runs along the entire northern boundary of theplot. Western boundary is demarcated by a small creek (thodu) extending in the North-South direction up to railway line.

It can be approached from Ezhimala - Payyanur road by taking a diversion at Punnakadavu Bridge, via Punchakkad - Kurumkadavu Road. Nearest railway station is Ezhimala situated at around 1.3 km southeast of the proposed plot boundary and is located around approximately 2.4 km North-West.

As per the present layout, proposed approach road is to take off directly from Ezhimala-Payyanur Road, which is parallel to the Ezhimala-Payyanur railway line towards East having a length of 1.5 km. It will be a 30 m dedicated corridor with a provision for 7.5 m emergency exit.

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4.1 Entire Area of Impact under the Influence of the Project

In total, 280 families will be directly affected because of the project since they are losing their land and property. Most of these families are staying far away from the project area. SIA unit could find out and surveyed only 225 families among them. 2 families staying in the proposed depot area will be displaced from there. The residence of the 12 families may be fully/partially affected for the construction of approach road subjective to the alignment. Out of the 225 families studied for the Social Impact Assessment, 145 families expressed that their livelihood will lose due to the project. During the Public Hearing 14 families shared that they are the families who were already displaced for Ezhimala Naval Academy and this is a second acquisition for them.

Indirect Impacts The difficulties may be caused to the public during the construction time ie. health issues due to dust, hindering of their way etc. to be considered as the impact of the project and should be mitigated accordingly.

The families residing near to the affected property, whose land is not acquired, shared their anxiety due to implementation of the project. So their concern also to be addressed.

4.2. Total Land required for the project 31.1619 hectors of land requires for the construction of the Oil Depot and 3.9 hectors of land requires for the approach road. The proposed land belongs to Payyanur Municipality in Kannur district.

4.3. Present Use of any Public, Utilised land in the Vicinity of the project Area. The proposed land is adjoining to the railway line. There is public road (untarred road) near to the property which leads to the crematorium of SC caste people lays

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there. crematorium of Ezhava caste people is also near to the project area. The following table gives a picture on the features located and its distance from the project area. Table No: 4.3.1. Location Features Sl.No. Distance Features 1 Within 500 m of the Facility Payyanur – Ezhimala / Along the proposed road Railway line, Perumba River, alignment within 100 m Crematorium, Anganwadi, Puchakkad, Anganwadi, Kandankali, St. Mary’s Church and Orphanage and St. Mary’s LP.UP School 2 Within 1 km Railway Bridge, St Mary’s LPUP School Punchakkad 3 Within 2 km Food Corporation of India (FCI) Godown, Ezhimala Railway station, Thiruvillamkunnu Siva Temple, Kunnaru Mookambika Temple, Thiruvillamkunnu Bus stop, Lourd Matha Church, Puthiya- Puzhakkara Bridge, Govt:higher Secondary School,Kandankali, Primary Health Centre Kandankali,

4.4. Land Already Purchased No land is purchased, alienated, leased or acquired already in the area for the requirement of the proposed project.

4.5. Nature and Present use of the Affected Land: The following diagram depicts the type of the acquired land. Out of the total land area of the respondent families, 74.7% of land comes under the category of “Nilam” 7.6% and 5.3% of the land are graded as “Purayidam” and “NilamNikathupurayidam” respectively. The information was not received from 12.4% of the families.

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Type of Land

Total

Information not available

Nilam Nikarthu Purayidam

Nilam

Purayidam

0 50 100 150 200 250

Percentage Number of Families

Present Use of the affected Land Open land Residence 4% 8%

Agriculture 88%

The above diagram shows that the present use of the affected land. Out of the 225 affected families studied 88% are using it for agriculture and among them 68 families are doing paddy cultivation irregularly in the affected land. 7.6% are using for residence and 4.4% are open land.

4.6. Size of Holding, Ownership Patterns and Number of Residential Houses Names and approximate extend of the land proposed to be acquired received from the Special Tahsildar(LA) office is given as annexure 09. Out of the total 225 families

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studied, 136 families (60,4%) were owned the property from their ancestors as hereditary and 89 families (39.6%) were purchased it. Table 4.6.3 Duration of Ownership Period of ownership Number of families Percentage Below 3 years 3 1.3 3 to 10 years 100 44.4 11 to 25 years 40 17.8 26 to 40 years 32 14.2 41-50 years 16 7.1 51 and above 8 3.6 Information not revealed 50 22.2 Total 225 100

The above table shows the years of owning the property by the affected families. 3 families have been possessed the property since 3 years. 8 families own the property for more than 51 years. 16 families comes under the period of 41-50 years and 26 to 40 years for 32 families. 100 and 40 families fall under the period of 3 to 10 years and 11 to 25 years respectively.

4.7. Land Price and Recent Changes in Ownership As per the information given by the respondents, no transactions had been taken place in the affected properties for the last three years except 3 families who possess the land recently. As per the information received from the respondents the market price of land as per the recent transactions in the locality was between Rs.10000 and 30000 for wet land and Rs.1.5 to 2 lakhs for dry land

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CHAPTER 5 ESTIMATION AND ENUMERATION

This chapter comprises of the details of the families that are directly and indirectly affected by the project.

5.1 DirectlyAffected Families of the Project There are 280 families who are being affected because of the land acquisition for the construction of Oil depot for BPCL/HPCL and approach road. These 280 families are the directly affected families of the project as they are losing their land and property. Most of these families reside far away from the project area. The SIA unit could find out and surveyed only 225 families. Table 5.1.1. Opinion of the Affected Families about Land Acquisition

Opinion Number of Percentage Families Better compensation and job for a family 8 3.6 member along with compensation Better compensation 184 81.8 Not willing to give the land 12 5.3 Not Responded 21 9.3 Total 225 100

Out of the total 225 families surveyed 192 families (85%) are willing to confer their land for the project. Among them 8 families demanded job for a family member and compensation and 184 families demanded better compensation equivalent to buy another land and property. 12 families are not willing to give their land and 21 families were not responded to this question.

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5.2. Family of Scheduled Tribes and other Traditional Forest Dwellers who have lost any of their Forest Rights

Nil

5.3. Families which depend on common property Resources which will be affected due to land acquisition for their livelihood

Nil

5.4. Families which have been assigned land by the State Government or the Central Government Under any of its Schemes and Such land is under acquisition

Nil

5.5. Families which have been Residing on any land in the Urban Areas for Preceding three years of more prior to the acquisition of land

Not Applicable

5.6. Families which have depended on the land being acquired as a primary source of livelihood for three years prior to the acquisition

Out of the 225 families studied, 145 families (64.4%) were shared that they are depending on the land as their primary source of livelihood. Besides, the people who are working on field as agricultural labours may lose their job and 5 among them were given their concerns by writing to the SIA unit.

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CHAPTER 6

SOCIO-ECONOMIC AND CULTURAL PROFILE

6.1.Demographic Details of the Population in the Project affected area:

Out of the 225 affected families identified during the survey, only 17 families are residing in the project affected area. Demographic details of the 225 project affected families studied are analyzing below:

Table 6.1.1: Sex & Age wise Population

Age Male Female Total Below 5 26 19 45 6-18 62 75 137 19-30 92 77 169 31-45 127 111 238 46-59 95 27 122 60 and above 95 106 201 Total 497 415 912

The above table depicts that there are 912 ie. 497 male and 415 female population reside in the affected 225 families. Among them, 45 are infants below 5 years, 137 are under the age group of 6-18 and 169 comes under the age group of 19-30. There are 238 pupil comes under the age group of 31-45 and 122 in 46-59. 201 pupil included in the project affected people are elderly ie in the age group of 60 and above.

Table 6.1.2:Marital Status of the Adults among affected population:

Marital Status Male Female Total Married 270 276 546 Unmarried 101 56 157 Divorced/Separated 1 4 5 Widow/widower 5 46 51

Table 6.1.2. Shows that 5 divorced/separated, 5 widowers and 46 widows are included in the project affected people

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Table 6.1.3. Educational Status of the affected population:

Educational Status Male Female Total Illiterate 3 11 14 Up to 4th class 46 49 95 5th to 10th 180 178 358 Higher Secondary 53 42 95 Degree /Professional diploma 88 110 198 Post Graduation 28 27 55

Educational status of the project affected people are depicted in the Table 6.1.3. There are 14 illiterate adult members included in the affected population. 95 members have completed/pursuing upto 4th standard and 358 have completed/ pursuing in classes from 5th to 10th. 95 people have completed or pursing in Higher secondary educationand 198 people have either completed or pursing degree course /professional diploma. 55 members of the affected families are pursuing/completed post graduation.

6.2. Income and Poverty Level

Out of the total affected population of 912 , only 242 are earning members and 670 (73.5%) are dependants.

Table 6.2.1: Monthly Income of the affected families

Income Number of families Percentage Below 5000 24 10.7 5001 to 15000 61 27.1 15001 to 30000 69 30.7 30001 to 50000 19 8.4 50001 to 70000 7 3.2 70001 to 90000 8 3.6 90001 to 1 lakh 2 0.8 Above 1 lakh 2 0.8 Information not revealed 33 14.7 Total 225 100

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The above table reveals 24 affected families earn only below 5000 rupees per month. 61 families shared that as they are earning between Rs,5001 to 15000. 69 families are getting between Rs.15001 to 30000, 19 families are earning Rs.30001 to 50000, 7 families are earning Rs.50001to 70000, 8 families earning Rs.70001 to 90000 and 2 families are earning Rs.90001 to 100000. Only 2 affected families shared that they are earning above one lakh rupees per month. 33 families did not reveal the said information.

Based on the classification by Public Distribution System the affected families possess the ration cards as explained in the table below:

Table 6.2.2. Type of Ration Card

Colour of Ration card Number of Percentage families White 49 21.8 Blue 78 34.7 Pink 55 24.4 Yellow 5 2.2 Information not revealed 38 16.9 Total 225 100

6.3. Land Use and Livelihood:

Out of the 225 affected families studied, 88% of them are being used their land for agriculture and among them, 68 families are engaged in paddy cultivation irregularly in the affected land. 7.6% are using as residential land and 4.4% are open land. 145 families (64.4%) were shared that they are depending on the affected land as their primary source of livelihood. Besides, there are people who are working in the land as agricultural labours.

6.4.Vulnerable Groups:

182 children, 201 elderly people, 5 divorced/separated, 5 widowers and 46 widows of the affected people should consider as vulnerable people.

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6.5. Local Economic Activities & Factors that Contribute to local Livelihoods:

Except the agricultural activities no other economic activities are conducting in the project area.

6.6. Kinship Pattern, Social and Cultural Organisation:

Only 17 families are residing in the affected area ie. 2 families in the proposed depot site and 15 families in approach road site; which are nuclear families. No social and cultural organization exist in the project area but there are cultural clubs in the 23rd division of Payyanur Municipality in which the project area belongs.

6.7. Administrative/Political/Community Based and civil Society Organisation:

The project area belongs to division 23 of Payyanur Municipality. The proposed approach road goes through 24 and 25 divisions of Payyanur Municipality. Community based or civil society organisations are not there in the project area.

6.8. Regional Dynamics and Historical Change Process:

Kandankali, the project area is a village belongs to Payyanur Municipality. The project area is a less populated area. No changes or developments have been undertaken in the project area since the last 25 years as shared by the respondents.

6.9. Quality of the living environment

The people in the area have no easy access to their necessities, they depend Payyanur town for the same.

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CHAPTER 7

SOCIAL IMPACT MANAGEMENT PLAN

7.1 Approaches to Mitigation

 The Rehabilitation and Resettlement package as per the Policy issued by Revenue(B) Department, Government of Kerala vide G.O.(Ms)No.448/2017/RD dated 29/12/2017 for the rehabilitation and resettlement package for land acquisition in the state in lieu of RFCTLARR Act 2013 shall be provided to the affected land owners.  Ensure the precautions and safety measures are taken to avoid environmental hazards that may cause due to the project and the same has to be properly informed and guaranteed to the public including the neighbouring Panchayats.

 Make the necessary arrangements for smooth entry and exit to the public and private utility/institutions such as crematorium, schools etc.

 Arrange alternative facilities for the 2 affected ponds (Water Source) being used by the community.  Reconsider the request of affected parties to acquire the remaining land in the affected area  Redress grievances raised by the families whose residences are likely to be isolated by the implementation of the project.  Comply rules and regulations for the developmental activities in wetlands, Mangroves, agriculture fields including paddy etc.  Already displaced families for Naval Academy should be treated with priority  Re install livelihood opportunities for the affected families or consider deserving family members for the possible job opportunities in the project

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7.2 Measures to avoid mitigate and compensate impact Consider the suggestions given in 7.1. 7.3. Measures those are included in the terms of Rehabilitation and Resettlement The Rehabilitation and Resettlement package as per the Policy issued by Revenue(B) Department, Government of Kerala vide G.O.(Ms)No.448/2017/RD dated 29/12/2017 for the rehabilitation and resettlement package for land acquisition in the state in lieu of RFCTLARR Act 2013

7.4. Mitigation Measures Stated by the Requiring Body

Some of the social impact mitigation measures proposed to be taken by the requiring body are listed below.

a) Resettlement & Rehabilitation will be provided as per Right to Fair Compensation & Transparency in Land Acquisition, Resettlement and Rehabilitation, 2013. b) Compensatory plantation will be done for the developed area by twice the number of trees, which will have to be cleared during the construction phase. c) Green belt area would be developed within the proposed site in vacant / unused areas. d) Appropriate measures will be provided for preventing interruption to existing socio-economic activities in and around the surroundings. e) Effluent generated from the facility, if any, during the operational phase and due to any accident, will be taken into Effluent Treatment Plant (ETP), with Oil water separator, which will ensure NIL discharge from the premises. f) Storm Water Drains shall be provided within the premises to ensure no water logging

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g) Impervious layers of concreting would be undertaking in the Tank storage areas and the loading / unloading areas, so that there is no seepage of Oil into the ground, in case of any leakage/ spillage. h) Rainwater harvesting would be provided. Water generated from the harvesting shall be utilized for landscaping and fire water replenishment. i) Solar Panels would be provided as alternate energy source for day-to day operations. j) Provision for proper parking arrangement and traffic management plan shall be in place for smooth flow of vehicles and to help abate noise pollution due to vehicular traffic.

The requiring body also stated that all the measures to ensure that there is no disturbance to the surrounding eco-system shall be ensured apart from the mandatory regulations as stipulated in the Oil Industry Safety Directorate (OISD) shall be implemented.

7.5. Alterations to Project Design and Additional Measures that May be Required to Address the Extent and Intensity of Impacts Across Various Groups as Identified during the SIA Process:

Out of the total 225 families, 69% opined that the project may cause hazard to the neighbouring people and suggested to take sufficient mitigation measures. The families reside in the neighbourhood area of the project site expressed their anxiety about the hazardous nature of the product and they have given an application to the SIA unit requesting to acquire their land too for the project. Besides Thaloth Vayal protection committee, President and vice president of Valiyaparambu GramaPanchayat have also shared their anxiety on the environmental impact of the project. The proposed project site lies at the adjoining area of two rivers bordered by mangrove forest coming under CRZ and these rivers drains at Kavvay river just 1 k.m away from the site. If there is any contamination in river water due to the project that may affect the livelihood of the people in Valiyaparamb Panchayath and also may cause health hazard to the neighbouring community. So the mitigation

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measures must be taken properly and the people have to be properly informed about it.

7.6. Detailed Mitigation Plan

 The Rehabilitation and Resettlement package as per the Policy issued by Revenue(B) Department, Government of Kerala vide G.O.(Ms)No.448/2017/RD dated 29/12/2017 for the rehabilitation and resettlement package for land acquisition in the state in lieu of RFCTLARR Act 2013 shall be provided to the affected land owners.  Ensure the precautions and safety measures are taken to avoid environmental hazards that may cause due to the project and the same has to be properly informed and guaranteed to the public including the neighbouring Panchayats.

 Make the necessary arrangements for smooth entry and exit to the public and private utility/institutions such as crematorium, schools etc.

 Arrange alternative facilities for the 2 affected ponds (Water Source) being used by the community.  Reconsider the request of affected parties to acquire the remaining land in the affected area  Redress grievances raised by the families whose residences are likely to be isolated by the implementation of the project.  Comply rules and regulations for the developmental activities in wetlands, Mangroves, agriculture fields including paddy etc.  Already displaced families for Naval Academy should be treated with priority  Re install livelihood opportunities for the affected families or consider deserving family members for the possible job opportunities in the project

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CHAPTER 8 SOCIAL IMPACT MANAGEMENT PLAN INSTITUTIONAL FRAMEWORK 8.1 Institutional Structures and Key Persons

RTFCTLARR Act, 2013 defines the Administrator appointed by the State Government would be the person responsible for Preparation of Rehabilitation and Resettlement Scheme for affected families of Land Acquisition. Subject to the superintendence, directions and control of the appropriate Government and the Commissioner for Rehabilitation and Resettlement, the formulation, execution and monitoring of the Rehabilitation & Resettlement Scheme shall vest in the Administrator. In the proposed land acquisition for the construction of Oil Depot and approach road for HPCL/BPCL at Payyanur, the major mitigation measures from the acquisition can be handled by providing the appropriate compensation under the RFCTLARR Act, 2013.

As per G.O. (Ms) No.485/2015/RD, dated 23/09/2015, The Kerala State Policy for Compensation and Transparency in Land Acquisition, the District Level Fair Compensation, Resettlement and Resettlement Committee comprising :  District Collector, Administrator for resettlement and rehabilitation,  Land Acquisition officer,  Finance Officer,  Representatives of the requiring body to take financial decisions on its behalf,  Representatives of Local Self Government Institution will monitor the Rehabilitation Action Plan.

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8.2 Specify the Role of Non Governmental Organisation, if any Not applicable

8.3 Indicate Capacities Required and Capacity Building Plan, Including Technical Assistance, if any

Not applicable

8.4 Timelines for Each Activity

Timeline will be finalized as per the Kerala Right to Fair Compensation and Transparency in Land Acquisition, Rehabilatation and Resettlement Rules, 2015

CHAPTER 9

SOCIAL IMPACT MANAGEMENT BUDGET AND FINANCING OF MITIGATION PLAN

9.1. Costs of all Resettlement and Rehabilitation Costs The requiring body stated that necessary budget provision exists for meeting the cost of acquisition.

9.2. Annual budget and plan of action Not Applicable

9.3. Funding sources with breakup Not Applicable

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CHAPTER 10

SOCIAL IMPACT MANAGEMENT PLAN MONITORING

AND EVALUATION

10.1 Key Monitoring and Evaluative indicators  Fair compensation  Rehabilitation and Resettlement procedures  Mitigation of the concern and fear of the neighbouring people about the possibilities of environment and other issues due to the project

10.2. Reporting mechanisms and monitoring roles  Rehabilitation and Resettlement procedures as stated in the Kerala Right to Fair Compensation and Transparency in Land Acquisition, Rehabilitation and Resettlement Rules 2015  The measures proposed to be taken to mitigate the environment impact should be informed to the people through the Local Self Government and through the medias.

10.3 Plan of independent evaluation Not Applicable

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CHAPTER 11

ANALYSIS OF COSTS AND BENEFITS AND RECOMMENDATION ON ACQUISITION 11.1.Analysis of costs The proposed land acquisition for the construction of Oil Depot and approach road for HPCL/BPCL at Payyanur will affect 280 families losing their land. It will affect agricultural activities due the acquisition of cultivation land. Among the total 225 affected families studied, 88% of the families are using the same solely for agricultural purpose and among them 68 families (30.2%) are occasionally engaged in paddy cultivation. 144 families whose primary income source being agriculture are affected on their regular income. 12 families reside in the affected area may partly or fully affected their housing. A large number of trees including coconut trees shall be cut downfor the project implementation.

11.2.Analysis of benefits The proposed project of construction of Oil Depot and its Approach Road at Kandankali in Payyanur village in Kannur district for HPCL and BPCL is the resettlement of the existing small depots at Kozhikode and Kannur as a Common User Facility. There is no provision for expansion of storage & distribution facilities of the existing small depots at Kozhikode and Kannur and do not meet the revised / new Oil Industry Safety Directorate (OISD) norms. Presently in Kerala, the facility for oil installation is available only at Kochi. In order to cater to the POL requirements of Northern Kerala effectively, it is essential to have one more Oil Installation apart from Cochin. Petroleum product movement either through Pipeline or through Railway Tank Wagons is always safer and economical option as compared to movement of bulk Oil through Tank Trucks by Road. The proposed land is lying near to the railway so that a siding can be constructed for product receipt through railway wagons.So that tanker movement by road is avoided thereby reducing the risk of accidents and de- congestion of roads. .

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11.3. Recommendation  The proposed land acquisition is recommended based on the compensation and resettlement as per the Rehabilitation and Resettlement Policy issued by Revenue (B) Department, Government of Kerala vide G.O.(Ms)No.448/2017/RD dated 29/12/2017, for the rehabilitation and resettlement package for acquisition of land in the state in lieu of RFCTLARR Act 2013, considering all loss due to the land acquisition.

 Ensure the precautions and safety measures are taken to avoid environmental hazards including the contamination of river that may cause due to the project and the same has to be properly informed and guaranteed to the public including the neighbouring Panchayats.

 Make the necessary arrangements for smooth entry and exit to the public and private utility/institutions such as crematorium, schools etc.

 Arrange alternative facilities for the 2 affected ponds (Water Source) being used by the community.  Reconsider the request of affected parties to acquire the remaining land in the affected area  Redress grievances raised by the families whose residences are likely to be isolated by the implementation of the project.  Comply rules and regulations for the developmental activities in wetlands, Mangroves, agriculture fields including paddy etc.  Already displaced families for Naval Academy should be treated with priority  Re install livelihood opportunities for the affected families or consider deserving family members for the possible job opportunities in the project  It is also suggested to ensure the mitigation and safety measures recommended by M/S.KITCO and the mandatory regulations of Oil Industry Safety Directorate has been taken during the project construction and implementation period and the same has to be properly informed to the public.

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REFERENCES AND ANNEXURES

References

Enviornment Impact Assessment Report by KITCO Ltd.

Annexures falls in the appendix pages.

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