CARGO MOTORS PRIVATE LIMITED

COMPREHENSIVE ENVIRONMENTAL IMPACT ASSESSMENT FOR PORT ,

ARABIAN SEA

Arabian Sea Valsad District

VALSAD DISTRICT

Port Location

CLARIFICATIONS TO EAC, MOEF&CC (Infra-2) ADDITIONAL INFORMATION September 2017

Submitted By

L&T Infrastructure Engineering Limited

C1121113

Clarifications to additional Information sought by MoEF&CC vide Minutes of the 21st Meeting of Expert Appraisal Committee (Infra-2) for Development of Nargol Port at Valsad District, Gujarat by M/s. Cargo Motors Pvt. Ltd. - Environmental and CRZ Clearance (IA/GJ/MIS/27560/2013; F. No. 11-4/2013-IA- III)

1 Submit declaration that no damage to mangroves will be done and free flow of the river will be maintained

CMPL Declaration on “there will be (i) No damage to Varoli River Mangroves and (ii) No hindrance to Varoli River existing water flow due to Construction and Operation Phase activities of Nargol Port” is enclosed as Annexure A.

2 Action Plan for Bio-shielding Apart from mangrove areas, Non-mangrove bio-shield along the coastal zone is popularly known as shelterbelts. Shelterbelts are strips of vegetation composed of trees and shrubs grown along the coasts to protect coastal areas from high velocity winds and also from devastations like the ones caused by Tsunami. They also serve the purpose of sand binders and prevent sand erosion. Shelterbelts are also promoted as a means of reducing wind speed and ameliorating the local microclimate. High wind speeds lead to physical damage to crops through abrasion, drying and wind throw. Well-placed and well-managed shelterbelts or bio-shields can therefore be used to increase agricultural productivity. Bio-shields can also serve as a source of livelihood to the local communities if designed with that of view. Choice and mix of species should be decided based on the height and depth of bio-shield required to make it effective at the proposed site. Properly raised bio-shields will also serve the purpose of sequestering carbon.

2.1 Broad Action Plan for Bio-shielding:  Initiation of Communication with Forest Department/PCCF  Identification of coastal belts/sites (degraded or new) around the proposed project site/EIA Study area or in the state of Gujarat in consultation with Forest Department/PCCF or community consultation along with the officials of the forest department/PCCF  Preparation of Base Maps/ Report of coastal sites based on the inputs from forest department/PCCF and community consultation highlighting the major biophysical condition  Exploring the status of the Plantation ( in the existing coastal belts/site)  Finalization of species to be used for shelterbelts or bio-shields or bio-walls along the coast in consultation with Forest Department/PCCF. The finalization of species can be done with the view to include coastal plant species of economic value to generate income to the local community who will be involved in the bio-shield movement  Both Technical and Financial assistance to Forest Department during Plantation along the finalised coastal belts and followed by the regular monitoring of the growth of plantation

2.2 Preliminary Works carried out Sofar:

2.2.1 Identification of Existing Coastal belt, Mangrove Area and other Forest Area in the Study Area:

Map showing the mangroves, various forest area, Forest area with coastal shelter belt (Plantations), other planation are present in the study area and also the Flora & Fauna Studies/ monitoring locations. l:\ports\2012\c1121113 - eia for nargol port\outputs\reports\ec clarifications\ec clarfication 22.09.2017\ec clarifications - alj - 22.09.2017.doc Page 1

2.2.2 Terrestrial Ecosystem/Flora Status in the Forest Area

2.2.2.1 Reserve Forests: (Bhilad, Katilpada, Sarai, Pali and Kannadipada)

Semi humid condition is present in the reserve forests. Mostly scrub and dry deciduous type of vegetation is seen in the forest blocks. In some places like Bhilad, there are plain lands and in the remaining parts the forests are present in the hilly and undulating terrain. Natural vegetation is mostly dominated with very common species which are found throughout the state. The habit wise dominant and commonly observed species are listed here.

According to the revised classification of Forest Types of (1962) by Champion and Seth, the forest types of this region are mainly characterized by Tropical Moist Deciduous Forest (Type 3B). l:\ports\2012\c1121113 - eia for nargol port\outputs\reports\ec clarifications\ec clarfication 22.09.2017\ec clarifications - alj - 22.09.2017.doc Page 2

 Trees: The most common tree species occurring are Acacia auriculiformis, Acacia nilotica, Terminalia sp., Azadirachta indica, Phoenix sylvestris and Tectona grandis.  Shrubs: The most common shrubs are Lantana camera, Hyptis suaveolens, Cassia auriculata, Calotropis procera, Prosopis juliflora, Acacia leucocephala and Catunaregam spinosa.  Herbs: The most common herbs are Tridax procumbens, Crotan bonplantianum, Tephrocia purpuria and Achyranthes aspera.  Climbers: The commonly seen climbers are Hemidesmus indicus, Pergularia daemia, Ipomoea pescaprae, Luffa cylindrica, Merremia, tridentata, Mucuna pruriens, Evolvulous alsinoides and Gloriosa superba.  Grasses: The common grass species are Chloris barbata, Cyperus castaneus, Cynodon dactylon and Impatiens balsamina.

Figure 2-1: Exploring reserve forests in southernmost part of study area

2.2.2.2 Coastal Shelter Belt

Most of the coastal belt is covered by only Casuarina plantations.

2.2.2.3 Mangrove Ecosystem

There are no mangrove forests or habitats found or recorded in the project area and also within the 2 Km of the project location. Within 5.0 Km radius from the Project Site near Navatalav and Umbergaon village, there are few pockets of thick mangroves extending up to a distance of 4 Km from the coast of the sea represented by Avicennia marina, Avicennia alba, Sonneratia apetala, Excoecaria agallocha and Rhizophora mucronata in and along the banks of the Varoli river, there are no mangrove forests within the buffer zone. Many of the Avicennia marina plants have attained a height of about 4.5 to 6.0 m while the Sonneratia apetala and Excoecaria agallocha plants were short but healthy.

Figure 2-2: Mangroves at Varoli River

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2.3 Way Forward

The detailed Action Plan for Bio-shielding will be finalised and submitted after consultation with the Forest Department/PCCF for the identified coastal sites and other sites if any suggested by Forest Department before commencement of Project.

3 Action Plan against GCZMA recommendations The action plan against GCZMA recommendations is enclosed as Annexure B.

4 Stage-I Forest Clearance for 4ha land

4.1 Summary on Status of Forest Clearance

Most of the facilities are planned on the reclaimed land. Total land requirement for Phase 1 and Phase 1A is about 175.5 Ha of which 171.5 Ha of land will be reclaimed land and 4.0 Ha will be onshore forest land. Survey nos. for the development of Logistic Support Building (LSB) is Survey No. 97 & 98 at village Nargol, which is classified under forest land.

Logistics Support Building (LSB) is an integral part of port and is imperative for security, control and operations of the port. LSB should be easily approachable from the existing state highways and as near to the Port as possible for efficient and optimized operation. The forest land at village Nargol (Survey No 97 & 98) is identified as a suitable location for LSB. This forest land is on the outskirts of the village and in the vicinity of the proposed port site.

This stretch of forest land is near the junction of Coastal State Highway (SH-6B) and the shamshanbhumi village road. It meets the requirements to effectively serve as a logistics /utility support for the port. The location also facilitates easy access to the existing highway network. As the development of Logistic Support Building (LSB) involves use of forest land for non-forest purposes (4 ha), necessary application have been submitted as per requirements.

 CMPL had submitted online application to forest department vide proposal no: FP/GJ/11386/2015 dated 28th April 2015 and demand letter along with Form A for the said Forest Clearance approval also on 02/06/2015  Land identified for swapping was submitted to DCF, Valsad South and it has not been accepted with following comments by the forest department:  Non forest land that CMPL offered is away from the existing forest area  Offered land is not suitable for compensatory forestation  Thereby, we have identified another suitable land as required by the forest department. The same is under consideration in the forest department

It is expected that the forest clearance for the LSB land (Only 4 ha) will take some more time.

4.2 Prevailing Office Memorandum and Request to Consider the Project for EC/CRZ Recommendation by EAC, MoEF&CC

As per following MoEF&CC Office Memorandums:

 No.J-11013/41/2006-IA.II(I) dated December 02, 2009  No.J-11013/41/2006-IA.II(I) dated September 09, 2011  No.J-1103/41/2006-IA.II(I) dated May 18, 2012

The proposal for environmental clearance shall not be linked with forest clearance even if it involves forestland and as these clearances are independent to each other and would in any case need to be obtained as applicable to such projects before starting any activity at site.

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At the stage of consideration of proposals for EC in respect of projects involving forestland, the project proponent would inform the respective EACs about the status of their application for forest clearance along with necessary supporting documents from the concerned Forest Authorities. It will clearly be informed to the EAC whether the application is at the State level or at the Central level. The EAC will take cognizance of the involvement of forestland and its status in terms of forest clearance and make their recommendations on the project on its merits. After the EAC has recommended the project for environmental clearance, it would be processed on file for obtaining decision of the Competent Authority for grant of environmental clearance. In the cases where the Competent Authority has approved the grant of environmental clearance, the proponent will be informed of the same and a time limit of 12 months, which may be extended in exceptional circumstances to 18 months, a decision on which will be taken by the Competent Authority, will be given to the proponent to submit the requisite stage-I forestry clearance. The formal environmental clearance will be issued only after the stage-I forestry clearance has been submitted by the proponent. All the above three mentioned office memorandums are attached as Appendix C, in light of the above MoEF&CC office memorandums, request EAC, MoEF&CC to consider the project for recommendation of Environmental/ CRZ Clearance.

5 Issues raised during public hearing and commitments made by the project proponent in the form of tabular chart with financial budget for complying with the commitments made The summary of issues rose during public hearing and commitments made by the project proponent in the form of table with financial budget for complying with the commitments made is given in Table 5-1 and Detailed point wise response to each of the issues raised during the Public Hearing and for written representations is enclosed as Annexure D. Table 5-1: Summary of Public Hearing Replies and Commitments made by Project Proponent along with Budget Financial Issues Proponent Replies/Commitment/Action Plan Commitment General Public Public Hearing was conducted strictly following the - not Aware procedure as per EIA Notification. Necessary about the documents for conducting PH were submitted to Project GPCB. The documents were made available in all the Development respective places for wide publicity. Executive Summaries in English and Gujarati are circulated in almost all the villages in study area and public announcement was also made. Impact on Former Principal Scientist & Head, Crustacean The budgetary estimate Fishing Fisheries division CMFRI, Kochi carried out Primary (Capital cost) for community Socio-economic surveys among the fishermen. Environmental Development of Nargol Port & associated activities Management up to will disturb the existing fishing activity of the area and Phase 1A is INR 645.30 Likely impacts are Restriction of Access to Sea; Crores. Deterioration of quality of marine This Includes environment/Affects biodiversity; Reduced fish catch/ Wastewater income; Forced Migration towards employment; Management, Air Displacement of households; Inadequate skills Pollution Control towards new changes / Cultural lag; Waste and measures, Marine life effluent discharge; Air and water quality deterioration; protection out of oil Loss of beach and landing centres; Loss of fishing spill, Other Pollution grounds; Changes in geomorphology of the Varoli Control measures, estuary/ mangroves; Conflicts. Construction Phase Impacts are carefully studied as a part of EIA Study Environmental

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Financial Issues Proponent Replies/Commitment/Action Plan Commitment and necessary mitigation measures were suggested in Monitoring, Green belt CEIA/EMP Report. Some of measures are Development etc.,  No R&R  No restriction to Sea; Awareness of the ongoing construction  Interactions with fishermen before commencement of construction  Proper Planning execution of offshore construction activities  Barges/Workboats will be provided Slop Tanks  To provide access, an approach trestle is planned with one span of the trestle will have clearance of 7m above HWL and 20m width for movement of fishing vessels. As suggested by GCZMA two Span has been considered with same features.  Educating the fishermen about orientation of approach channel and ships visits etc.,  Amicable resolving of conflicts  Berthing line and breakwater are planned b/w 13- 15m water depth. Fishing activities are observed beyond these depths  Varoli River mouth is 4.0 km and no open beach landing is observed; No impact on fish landing  At Many Places Fishing Harbour & Port Coexist Without Conflicts Land No land acquisition and hence no R&R is envisaged as The cost associated with Acquisition a part of the development of Nargol port. Only LSB is LSB forest land planned on a forest land of ~4.0 ha. conversion is being worked out which includes cost for swapping land also. Information of Details of railway are given as a part of CEIA report. Cost of the Railway link Railway are not Development of Rail corridor is being taken up as a development will be presented in separate project and as the development of rail line around INR 98.77 the report doesn’t attract EIA notification, necessary clearances Crores. from the relevant authorities such as Department of Railways etc., will be taken. Corporate CSR will be taken up and a separate budget for CSR The budget will be Social Initiatives shall be earmarked each year in compliance revised each financial Responsibility with the prevailing laws. year; however, the (CSR) capital budget earmarked for the CSR initiatives for Five year or as per company law for CSR is in the tune of INR 7, 00, 00,000/- (70 Million rupees). The CSR Budget shall be fixed for each financial year which will not lapse and will be transferred to the CSR Fund, which will accumulate Impact due to Necessary studies carried out covering both erosion Provision of 1.29 Crores Reclamation on and accretion. Erosion over a stretch 3.8 km (North) is made during Shoreline and accretion of 0.9 km (South) of proposed reclaimed Operation Phase for

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Financial Issues Proponent Replies/Commitment/Action Plan Commitment Changes area of port. No change in the morphology of Varoli Statutory compliance for River mouth which is located at ~4.0 km. Continuous environmental monitoring of shoreline with the help of high protection resolution satellite imageries during operation phase. (Environment Based on the monitoring results, appropriate Monitoring and others). techniques such as sand bypassing from accreting area to eroding area, as appropriate shall be carried out to maintain the stability of coast or Based on the monitoring results, the sand trap may be created where the high accretion is observed. Dredging of the area to be accreted/ sand trap shall be carried out regularly (as a part of maintenance dredging) and the material shall be used for maintaining the eroding coastal stretch, if observed. The quality of the dredged material was analysed in terms of its toxic metals and found no significant concentration of toxic metals. Mitigation measures will be carried out as a part of dredging contractors cost. Source of Water requirement of the proposed port will be Provision of 4.0 Crores Water sourced form Tokar river. The water availability is made to develop a details were obtained from WRD, which confirms the Water Supply System. availability of water. Impacts due to Proposed covered conveyer system, transfer points, Air Pollution Control Coal Handling shed type coal stockyard etc., dust suppression system, Measures cost will be wind barrier; trucks and railway wagons covered with around INR 585.63 tarpaulin; Silos arrangement; greenbelt development; Crores is considered. Adherence to Coal Handling Guidelines given by GPCB. Impacts of Ships/vessels calling at Nargol Port will not be - liquid cargo permitted to dump the wastes /bilge water during the washing berthing period. Also, Hold washing will not be permitted in the port complex and MARPOL regulations will be implemented Not clear with Consortium of CMPL & Amarillis (Israli company) - the owner of Ltd. has won the bid to develop Nargol port as per the the Project BOOT policy of GMB & GoG. CMPL is the lead promoter of the consortium and is responsible for taking all the necessary clearances for the project on behalf of consortium Employment Construction Phase: 1500-2000 personnel on direct The budget will be basis and around 5000 on indirect basis; Operational revised each financial phase: 200-300 people on direct and around 2500- year; however, the 3000 on indirect basis. As a part of CSR, it is proposed capital budget to provide skill development and training programs earmarked for the CSR for the local community. Vocational training has also initiatives for Five year been proposed to be provided in a professional or as per company law manner through partnership with Industrial Training for CSR is in the tune of Institutes. INR 7, 00, 00,000/- (70 Million rupees). The CSR Budget shall be fixed for each financial year which will not lapse and will be transferred to the CSR Fund, which will accumulate No information Disaster Management Plan including On-site and Off- Marine Life Protection on disaster due site Emergency Plan, Oil Spill Contingency Plan and out of Oil Spill (One l:\ports\2012\c1121113 - eia for nargol port\outputs\reports\ec clarifications\ec clarfication 22.09.2017\ec clarifications - alj - 22.09.2017.doc Page 7

Financial Issues Proponent Replies/Commitment/Action Plan Commitment to natural Management Plan for natural hazards such as tugboat with booms and hazards Cyclones/Floods, Tsunami, Earthquakes etc., have skimmer and dust been provided as a part of Draft CEIA exhausting equipment) – INR 10.13 Crores Change in Detailed Hydrodynamic studies were carried as a part The cost of the Approach Wave pattern of CEIA study and presented in the report. Various Structure/trestle will be due to layout options were studied for suitability and also about INR 465.80 development of considering future phases of development of port. Crores is considered as a port Effect of various layout options on the current pattern par to Project Cost in the study area was tested and layout Phase 1 and during Phase 1 and Phase 1 A was found to be causing the minimum further 9.27 Crore is variation in natural hydrodynamic condition and considered during Phase accordingly finalized (layout with trestle instead of 1 A also. approach bund to allow free flow of water in the leeward side of port)

6 Point wise reply to the complaint made by Conservation Action Trust The point wise reply to the complaint made by Conservation Action Trust is enclosed as Annexure E.

7 Submit the set of following documents required as per para 4.2 (i) of CRZ Notification, 2011 S. No Details Remarks 1. Form-1 (Annexure-IV of the notification) Already Submitted and the same are submitted again along with this clarification. 2. Rapid EIA Report including marine and Not Applicable terrestrial component except for construction projects listed under 4(c) and (d) 3. Comprehensive EIA with cumulative studies Comprehensive EIA with cumulative for projects in the stretches classified as low studies for projects in the stretches and medium eroding by MoEF based on classified as low and medium eroding by scientific studies and in consultation with the MoEF&CC was submitted along with the State Governments and Union territory documents for CRZ/EC Clearance. Administration However, the same is being enclosed with this clarification. 4. Disaster Management Report, Risk The Disaster Management Report, Risk Assessment Report and Management Plan Assessment Report and Management Plan are part of the Comprehensive EIA (Section 7.3 and 7.2 of Chapter 7). 5. CRZ map indicating HTL and LTL The CRZ map indicating HTL and LTL demarcated by one of the authorized agency demarcated by one of the authorized (as indicated in para 2) in 1:4000 scale agency in 1:4000 Scale , CRZ map 6. Project layout superimposed on the above Covering 7 km radius, CRZ map map indicated at (e) above indicating CRZ- I, II, II and IV areas 7. The CRZ map normally covering 7km radius including Ecologically Sensitive area was around the project site submitted along with the documents for 8. The CRZ map indicating the CRZ-I, II, III and CRZ/EC Clearance. However, the same is IV areas including other notified ecologically being enclosed with this clarification sensitive areas 9. No Objection Certificate from the concerned No objection certificate is not applicable State Pollution Control Boards or Union as discharge of effluents/ Sewage and territory Pollution Control Committees for the the like are not involved in the project. projects involving discharge of effluents, solid wastes, sewage and the like.

l:\ports\2012\c1121113 - eia for nargol port\outputs\reports\ec clarifications\ec clarfication 22.09.2017\ec clarifications - alj - 22.09.2017.doc Page 8 Appendix A CMPL Declaration on No Damage to Mangroves and Free Flow of the River

Appendix B Action Plan on GCZMA Recommendations

Annexure B. Action Plan against GCZMA Recommendations S. Compliance/ Proponent GCZMA Specific Conditions No. Action Plan The provisions of CRZ The provisions of the CRZ Notification of 2011 shall be Notification 2011 (as amended) strictly adhered to by M/s CMPL. No activity in 1. will be strictly adhered. Layout contradiction to the provisions of the CRZ Notification as approved by GCZMA will be shall be carried out by M/s CMPL. followed. All the requisite permissions Necessary permissions from different departments/ will be obtained before 2. agencies under different laws/ acts shall be obtained before commencing the construction commencing any enabling activity for the proposed port. activity. In the existing layout, the approach trestle is planned in such a way that any one span of the trestle shall have minimum clearance of 7m above the High Water Level with 20m width for The CMPL shall ensure that adequate (at least two) passes movement of fishing vessels. way each of 20m width shall be provided with trestle for 3. safe movement of fishing boats with adequate draft and As suggested by GCZMA, the height. adequate (at least two) passes way each of 20m width shall be provided with trestle for safe movement of fishing boats with adequate draft and height during detailed engineering stage of the project. Noted and will be complied during both construction and operation phases of the project. The CMPL shall regularly monitor the shoreline and Provision of 1.29 Crores is made ensure that stability of the shore line shall be maintained 4. during Operation Phase for by way of taking adequate measure to control Statutory compliance for erosion/accretion, if any, due to proposed project. environmental protection (Environment Monitoring and others). No dredging, reclamation or any other project related Noted and will be complied on activities shall be carried out in the CRZ area categorized as starting and during construction CRZ I (A) and it shall have to be ensured that the activity. Declaration on “No 5. mangrove habitats and other ecologically important and damage to Varoli River significant areas, if any, in the region are not affected due Mangroves is given as to any of the project activities. Annexure A.

CMPL Declaration on “there will be (i) No damage to Varoli River The CMPL shall ensure that there shall be no damage to Mangroves and (ii) No the existing mangrove patches near the site and also ensure hindrance to Varoli River 6. the free flow of water should not be obstructed to avoid existing water flow due to damage to the mangrove. Construction and Operation Phase activities of Nargol Port” is enclosed as Annexure A. The CMPL shall not construct any storage facilities for The provisions of CRZ material / chemicals in the CRZ area except for those Notification 2011 (as amended) 7. permissible as per Annexure- II of the CRZ Notification, will be strictly adhered. Layout 2011. Also for other Hazardous chemicals, outside CRZ as approved by GCZMA will be l:\ports\2012\c1121113 - eia for nargol port\outputs\reports\ec clarifications\ec clarfication 22.09.2017\annexure b - gczma action plan.doc Page 1

S. Compliance/ Proponent GCZMA Specific Conditions No. Action Plan areas, the CMPL shall have to consult SDMA for Disaster followed. Also for other Management Plan. Hazardous chemicals, outside CRZ areas if any in future, the CMPL shall consult SDMA for Disaster Management Plan. All the recommendations and suggestions given by the L&T All the recommendations and Infrastructure Engineering Limited in their Environment suggestions given by the L&T 8. Impact Assessment reports for conservation / protection Infrastructure Engineering and betterment of environment shall be implemented Limited in their EIA report will strictly by M/s CMPL be implemented by CMPL. Noted and will be complied. The construction and operational activities shall be carried Reputed Institute/Organization out in such a way that there is no negative impact on will be appointed to provide the mangroves, if any, and other important coastal / marine 9. Environmental Management habitats. The construction activities shall be carried out Services (EMS) along with only under the guidance / supervision of the reputed NABL/MoEF&CC accredited institute / organization laboratories for monitoring. Proper care shall be taken to M/s CMPL shall strictly ensure that no creeks or rivers are 10. ensure that No creeks or rivers blocked due to any activity at proposed site. are blocked. The construction debris and any The construction debris and /or any other type of waste other waste will not be disposed shall not be disposed of into the sea, creek or in the CRZ of into the sea, creek or in the 11. areas. The debris shall be removed from the construction CRZ areas. The debris will be site immediately after the construction is over removed after construction is over. Construction labour will be located outside CRZ area and The construction camps shall be located outside the CRZ provided with the necessary area and the construction labour shall be provided with the amenities, including sanitation, 12. necessary amenities, including sanitation, water supply water supply and fuel and it will and fuel and it shall be ensured that the environmental be ensured environmental conditions are not deteriorated by the construction labours conditions are not deteriorated by construction labours. M/s CMPL shall prepare and regularly update their Local Oil Spill Contingency and Disaster Management Plan in consonance with the National Oil Spill and Disaster 13. Noted and will be submitted Contingency Plan and shall submit the same to this Department after having it vetted through the Indian Coast Guard M/s CMPL shall bear the cost of the external agency that may be appointed by this Department for supervision / 14. Noted and agreed. monitoring of proposed activities and the environmental impacts of the proposed activities The jetty and most of the approach would be supported on Approach mostly on Trestle is 15. piles allowing adequate flow of water without significant already Considered as a part of obstruction Project development plan. No ground water will be tapped The groundwater shall not be tapped within the CRZ areas within CRZ area. Water 16. by the CMPL to meet with the water requirements in any requirement will be met from case the identified source only. M/s CMPL shall take up massive greenbelt development Greenbelt as planned within activities in consultation with Forest Department / GEER Project Site will be initiated 17. Foundation / Gujarat Ecology Commission. A along with Construction comprehensive plan for this purpose has to be submitted to activities. CMPL will also the Forests and Environment Department. contribute to improve the green

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S. Compliance/ Proponent GCZMA Specific Conditions No. Action Plan cover of the state in consultation with Forest Department / GEER Foundation / Gujarat Ecology Commission within a period of Three years from the date of commencement of the project. Mangrove plantation in 100 ha. shall be carried out in Noted and preparation of Action consultation with the Gujarat Ecology Commission/ Forest Plan will be initiated on start of Department by M/s CMPL within a period of two years construction activity in 18. from the date of commencement of the project and an consultation with the Gujarat action plan in this regard shall be submitted to this Ecology Commission/ Forest Department along with satellite images and GPS readings Department. with Latitudes and Longitudes. Broad Action Plan for bio- Shielding development & Preliminary studies were carried out and the details are provided in reply to the query 2 of this The CMPL shall have to take up bio-shielding development clarification. The detailed programme as part of CSR in consultation with the Forests Action Plan for Bio-shielding 19. Department/PCCF and an action plan in this regard shall will be finalised and submitted have to be submitted to the MoEF&CC, GOI and this after consultation with the Department. Forest Department/PCCF for the identified coastal sites and other sites if any suggested by Forest Department before commencement of Project M/s CMPL shall have to contribute financially for taking Financial contribution will be up the Socio-economic upliftment activities in this region made in consultation with 20. in consultation with the Forests and Environment district authorities and Forest & Department and the District Collector / District Environment Department, GoG. Development Officer Separate budget will be earmarked for environmental A separate budget shall be earmarked for environmental management and socio- management and socio-economic activities including the economic activities including greenbelt / mangrove plantation and details thereof shall the greenbelt / mangrove 21. be furnished to this Department as well as the MoEF, plantation. The details of GOIThe details with respect to the expenditure from this expenditure shall be furnished budget head shall also be furnished along with the along with the compliance compliance report report upon starting the construction activity. A separate Environmental Management Cell with qualified personnel shall be created for environmental monitoring 22. Noted and will be complied. and management during construction and operational phases of the project Environmental Audit report indicating the changes, if any, with respect to the baseline environmental quality in the 23. coastal and marine environment shall be submitted every Noted and will be complied. year by M/s CMPL to this Department as well as to the MoEF&CC, GOI A six monthly report on compliance of the conditions mentioned in this letter shall have to be furnished by M/s 24. CMPL on a regular basis to this Department as well as to Noted and will be complied. the Ministry of Environment and Forests, Government of lndia 25. Any other condition that may be stipulated by this Noted. l:\ports\2012\c1121113 - eia for nargol port\outputs\reports\ec clarifications\ec clarfication 22.09.2017\annexure b - gczma action plan.doc Page 3

S. Compliance/ Proponent GCZMA Specific Conditions No. Action Plan Department, Ministry of Environment Forests, and Climate Change, Government of India from time to time for environmental protection / management purpose shall also have to be complied with by M/s CMPL

l:\ports\2012\c1121113 - eia for nargol port\outputs\reports\ec clarifications\ec clarfication 22.09.2017\annexure b - gczma action plan.doc Page 4 Appendix C MoEF&CC Office Memorandums Pertaining to Forest Clearance

NO. J-110 13/41/2006-IA.II(1) Government of India Ministry of Environment & Forests

Paryavaran Bhavan, C.G.O. Complex, Lodi Road, New Delhi-110003. Telefax: 24362434

Dated the gth September, 2011

OFFICE MEMORANDUM h.

Sub: Consideration of projects for grant of environment clearance under EIA Notification, 2006, which involve forestland - Procedure to be followed - further clarifications - Regarding.

Ministry of Environment & Forests had earlier issued an office memorandum vide no. J-11015/200/2008-IA.II(M)dated 31.3.2011 prescribing the procedure to be followed for consideration of projects for environmental clearance, which involve forestland.

2. Based on the experience gained in implementation of the instructions contained in the above referred O.M. and taking into consideration the inputs / feedback received from various stakeholders as also in light of the judgment of the Hon'ble Supreme Court dated 6.7.201 1 in the IA No. 1868, 2091, 2225-2227, 2380, 2568 & 2937 in W.P. No. 202 of 1995 - T.N. Godavarman Thirumulpad Vs. UOI 8 Ors in Lafarge Mining / Forest case, the matter has been further considered.

3. Now, therefore, in partial amendment of the above referred O.M. dated 31.3.2011, it has been decided that the following procedure shall be adopted for consideration of projects for environmental clearance, which involve forestland:

(i) At the stage of consideration of proposals for TOR in respect of the projects involving forestland, the project proponents would submit a credible proof in support of the fact that they have already submitted their application to the concerned Competent Authority for diversion of the forestland involved in the project.

(ii) At the stage of consideration of proposals for EC in respect of projects involving forestland, the project proponent would inform the respective EACs about the status of their application for forestry clearance along with necessary supporting documents from the concerned Forest Authorities. It will clearly be informed to the EAC whether the application is at the State level or at the Central level. The .EAC will take cognizance of the involvement of forestland and its status in terms of forestry clearance and make their recommendations on the project on its merits. After the EAC has recommended the project for environmental clearance, it would be processed on file for obtaining decision of the Competent Authority for grant of environmental clearance. In the cases where the Competent Authority has approved the grant of environmental clearance, the proponent will be informed of the same and a time limit of 12 months, which may be extended in exceptional circumstances to 18 months, a decision on which will be taken by the Competent Authority, will be given to the proponent to submit the requisite stage-I forestry clearance. The formal environmental clearance will be issued only after the stage-I forestry clearance has been submitted by the proponent.

(iii) In the eventuality that the stage-I forestry clearance is not submitted by the proponent within the prescribed time limit mentioned at para (ii) above, the proposal for environmental clearance will stand rejected and the entire process of obtaining environmental clearance will have to be initiated de-novo as per the procedure prescribed under EIA Notification, 2006.

4. The requirement of information / data / documents for such projects as specified in office memorandum no. J-11013/41/2006-IA.II(1) dated 26.4.20 11 will, however, continue to be completely followed .

This issues with the approval of the Competent Authority.

(Dr. S.K. Aggarwal) Director

1. All the Officers of IA Division 2. Chairpersons / Member Secretaries of all the SEIAAs/SEACs 3. Chairman, CPCB 4. Chairpersons / Member Secretaries of all SPCBs / UTPCCs

Copy to:-

1. PS to MEF 2. PPS to Secretary (E&F) 3. PPS to SS(JMM) 4. Advisor (NB) 5. Website, MoEF 6. Guard File No. J-11013/41/2006-IA.II(I) Government of India Ministry of Environment. Forests Paryavaran Bhavan, ,, e.G.D. Complex, Lodi Road, New Delhi-ll0003. Telefax: 24362434 ,. Dated the 18th May, 2012

Office Memorandum

Sub: Consideration of projects for grant of environment clearance . under EIA Notification, 2006, which involve forestland - procedure to be followed - Further Clarifications - Regarding.

In continuation to this Ministry's Office Memorandum of even no. dated 9th September, 2011 regarding the above mentioned subject, the matter has been further considered and examined in the Ministry. Accordingly, para 3(iii) of the above referred D.M. is substituted by the following:

"(iii) In the eventuality that the stage-I forestry clearance is not submitted by the project proponent within the prescribed time limit mentioned at para (ii) above, as and when the stage-I forestry clearance is submitted thereafter, such projects would be referred to EAC for having a relook on the proposal on case by case basis depending on the environmental merits of the project and the site. In such a situation the EAC may either reiterate its earlier recommendations or decide on the need for its reappraisal, as the case may be. In the eventuality, a reappraisal is asked for, the Committee will simultaneously decide on the requirement of documents / information for reappraisal as also the need for a fresh public hearing."

This issues with the approval of the Competent Authority.

~~(Dr.S.K~ Director To

1. All the Officers of IA Division 2. Chairpersons / Member Secretaries of all the SEIAAs/SEACs 3. Chairman, CPCB 4. Chairpersons / Member Secretaries of all SPCBs / UTPCCs

Copy to:-

1. PS to MEF 2. PPS to Secretary (E&F) 3. PPS to JS(RG) 4. Website, MoEF 5. Guard File Appendix D Public Hearing Replies with Financial Budget

Annexure D. Public Hearing Replies / Commitments made by Project Proponent

Sr. Name and The points represented Replies/ Commitment by CMPL Financial Commitment by CMPL No. Village Gram Sabha meeting was organized by the 1. Jayeshbhai Gajanandabhai people of Nargol and other nearby villages to discuss the proposed port and 34 issues was Responses to Mr. Ramanbhai Patkar MLA Baria, Nargol queries/concerns are presented in Sr. No 18 of this decided and out of 17 major issues were Sarpanch, document. separated and submitted it to MLA Ramanbhai - Nargol Patkar. Mr. Baria requested him to represent these issues on behalf of the public, during the public hearing. Honorable Collector said that we will go only after hearing everyone. Everyone keep silence. He informed that the people today here are in 2. Magan Dakale Type of Project: Development of All Weather Multi- difficulty. We are living here since British age. Purpose Green filed Port at Nargol. The details of - (Head of This land is of Government/CRZ. For this the Project and its impacts are studied and the Draft Kinara Bachao public hearing 2000 - 4000 people were Comprehensive EIA report was prepared along with Samiti ) estimated but about 10000 people have come. necessary maps and Submitted to GPCB for Public Even without transportation, they have walked Hearing. GPCB organised the Public Hearing near 20-20 kms. People are not explained about Microwave Tower, Nargol –Daman Road, Tadgam on 13.01.2016. The details of public hearing were what is happening. Everybody including advertised 30 days before in Indian Express people and Sarpanch are confused. On our (English) and Divya Baskar (Gujarati) and Sandesh representation to Honorable Collector, he has (Gujarati) newspapers. heard us. And hope to solve our questions. The Complete documents are made available in the 1200 houses are dwelling and what will following Places. happen to these houses, it is not mentioned in . The District Collector Office, Valsad 600 pages report. And Fishermen’s livelihood . District Development Office, Valsad depends on fishing business but these houses . District Industry Center, Valsad are not in their name. When fisherman’s sell . Taluk Development office, their house they don’t do any documentation. . Regional Office, GPCB, Sarigam Only panch decides. Fishermen are doing . The Chief Conservator of Forest, MoEF, Bhopal. fishing of 146 crores. And crore rupees of income is generated. We all are not poor. We The Executive Summary of Draft EIA in both have not taken any money from the English and Gujarati Languages are made available government nor have we asked for any jobs. almost all the study area villages which briefs the project development. In addition, all the documents l:\ports\2012\c1121113 - eia for nargol port\outputs\reports\ec clarifications\ec clarfication 22.09.2017\annexure d - issue raised during ph.doc Page 1

Sr. Name and The points represented Replies/ Commitment by CMPL Financial Commitment by CMPL No. Village were made available in GPCB website by GPCB. Our farmers earn their income from farming. Alphanso of Valsad is produce here in our place. No Fishing Habitations are located in the area

proposed for Nargol Port. Nearest Fishing village is If you disturb the sea then the impacts due to located at about 1.9 km from the project site. No waves cannot be prevented. The houses and R&R for the development of Port facilities. Most of

farms will also be destructed. How the port the Port facilities will be developed on the reclaimed would be built? land and hence no acquisition of agricultural/ farming land.

Necessary study was already made to analyze the shoreline changes due to Nargol Port development covering both erosion and accretion aspects as a part of CEIA and it was observed that erosion takes

place over a stretch of 3.8 km towards north of proposed reclaimed area of port and 0.9 km of accretion towards south of proposed reclaimed area of port. The average rate of erosion is 4m/year adjacent to the north of proposed reclaimed area and accretion at rate of 1.4m/year adjacent to the south of proposed reclaimed area. The rate of accretion and erosion has reducing trend alongshore on either side of the proposed reclaimed area of port. Appropriate mitigation measures were suggested in the CEIA report to protect the shoreline. They are, Provision of 1.29 Crores is made during Operation . Continuous monitoring of shoreline with Phase for Statutory compliance for environmental the help of high resolution satellite protection (Environment Monitoring and others). imageries during operation phase . Based on the monitoring results, appropriate techniques such as sand bypassing from accreting area to eroding area, as appropriate shall be carried out to maintain the stability of coast

. Based on the monitoring results, the sand trap may be created where the high accretion is observed . Dredging of the area to be accreted/ sand

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Sr. Name and The points represented Replies/ Commitment by CMPL Financial Commitment by CMPL No. Village trap shall be carried out regularly (as a part of maintenance dredging) and the material shall be used for maintaining the eroding coastal stretch, if observed. The excess/unusable material shall be disposed at the identified offshore disposal location

During this project 600 acres land will be All port back up facilities of Phase 1 and Phase 1 A reclaimed for the development of port. Without development have been proposed on reclaimed land acquiring land no port can be developed. (behind berthing Line and in inter tidal area) as Leave it to make fool to the peoples. For suggested by Gujarat Maritime Board (GMB) through reclaiming 1 acre of land 10 crore is required. their bid document. Only the Logistic Support Building (LSB) is planned on a forest land of about 7000 crores will be required for developing 4.0 Ha. Necessary application for diversion of forest 700 acres of land. They are making us fool. land to non-forest purpose (development of LSB) is This port development is not possible in 5000 already submitted and the same is being scrutinized crores. This project cost is 4000 crores. We at the Deputy Conservator of Forest (DCF), Valsad have to see whether Rs.4000 crores they have Forest Office. No land acquisition and hence no R&R or not, if they have agency of Tata Motors only is envisaged as a part of the development of Nargol so from where will Cargo Motors collect port. money? Israel company is having 25% stake. The land to be reclaimed is about 171.5 Ha (~ 424 It is not written if this company is going to give Acres) Only. Reclamation will be carried out by using money. We won’t let a foreign company to dredged materials only. The Project cost estimate is come here. We are living happily. No objection provided in the CEIA based on the Detailed Project report of Nargol Port considering the use of dredged if there is no help. material for reclamation.

The consortium of CMPL & Amarillis (Israli company) Ltd. has won the bid to develop Nargol port as per the BOOT policy of GMB & GoG. The consortium has fulfilled all the technical & financial criteria set by

GMB & GoG during the pre-qualification stage of the Nargol port bid. As per the joint bidding agreement CMPL is the lead promoter of the consortium and is responsible for taking all the necessary clearances for the project on behalf of consortium. As per the l:\ports\2012\c1121113 - eia for nargol port\outputs\reports\ec clarifications\ec clarfication 22.09.2017\annexure d - issue raised during ph.doc Page 3

Sr. Name and The points represented Replies/ Commitment by CMPL Financial Commitment by CMPL No. Village requirement of GMB, after taking the EC & financial closure of the project, a SPV shall be formed for signing the concession agreement with GMB & GoG

The details of railway lines for the proposed project No information given whether railway will are given in Section 2.3.2, 2.7.22 and 7.5.7 of Draft come from Bhilad or Sanjan. If railway comes CEIA Report. Development of Rail corridor is being who will give the land to railway? There is no taken up as a separate project and As the information. development of rail line doesn’t attract EIA notification, necessary clearances from the relevant If port does not come doesn’t matter atleast do authorities such as Department of Railways etc., will not steal what we have. be carried out.

Our Umbergam is Holyland of Parshuram and 3. Mahesh Primary Socio-economic surveys among the The following financial commitment given by PP for Parshottam no one dies hungry here. Our village peoples fishermen were carried out by Former Principal the Environmental Management: Patel, Nargol carry out fishing activity for their livelihood; if Scientist & Head, Crustacean Fisheries division  Greenbelt development – INR 2 Crores CMFRI, Kochi. The findings of the study are provided (Teacher) steamer comes because of port our fisherman  Wastewater Management (Sewage Treatment will die hungry. How to go 25km away from in the Section 4.8 of DCEIA report. The impact on Plant & Drainage & Sewerage system/Storm sea shore and will survive. Under any fishing and mitigations measures are provided in Water System) – INR 30 Crores circumstances we will not allow the port to Section 5.9.1.2 and 7.6.1.3 of DCEIA report. Port development will be on intertidal area and berthing Air Pollution Control (Dust Sweeper, Installation come. Our Narendra Modi Sir talks about  line and breakwater in between 13 m to 15 m water of sprinkler system, Covered system for Coal carbon credit and other side here our depth. Majority of the fishing activity in the study area Storage, Wind barriers, Dust environment is snatched then we will sacrifice is observed beyond these depths. our life and I will be the first one. We will not Suppression/Water sprinkling during

allow coming port. Construction Phase, Conveyor Belt System The summary of the Fisheries study is given below. with Hood, Conveyor Belt System in stackyard, The Nargol Port will be constructed mostly on the Wagon loading system & Wagon loading reclaimed land. The construction activities which are hopper-1500 T capacity) – INR 585.63 Crores essential for the development of Ports and Harbours  Other Pollution Control Measures (Oil Water such as dredging, reclamation, breakwaters, berths, Separator, Settling pond at Coal Stockyard, installation of handling equipments, back up area development for storage and for other facilities and etc.) – INR 9.0 Crores creation of access, etc., will be carried out. These  Marine Life Protection out of Oil Spill (One

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Sr. Name and The points represented Replies/ Commitment by CMPL Financial Commitment by CMPL No. Village activities will disturb the existing fishing activity of the tugboat with booms and skimmer and dust area. The following are the concerns/impacts likely to exhausting equipment) – INR 10.13 Crores arise due to development of Nargol Port . Restriction of Access to Sea  Environmental Monitoring during Construction . Deterioration of quality of marine Phase (Both marine & terrestrial environment) environment/Affects biodiversity – INR 4.54 Crores . Reduced fish catch/ income  EMC Running Expenditure – 0.15 Crores/year . Forced Migration towards employment  Greenbelt Maintenance – INR 0.2 Crores/year . Displacement of house holds . Inadequate skills towards new changes /  Maintenance of Dust Sweepers – INR 0.3 Cultural lag Crores/year . Waste and effluent discharge  Maintenance of Air Pollution Control Measures . Air and water quality deterioration – INR 0.2 Crores/year . Loss of beach and landing centres . Loss of fishing grounds  Dust Suppression/ Water Sprinkling – INR 0.05 . Changes in geomorphology of the Varoli Crores/year estuary/ mangroves  Statutory Compliance for Environment . Conflicts Protection (Environmental Monitoring) – INR The above aspects were carefully studied and 1.29 Crores/year following mitigation measures were suggested: . No Resettlement & Rehabilitation for Port development . No restriction to Sea will be ensured by putting up signboards at the place of construction activities in order to make fishermen aware of the ongoing activities and necessary marker buoys will be installed . Interactions will be initiated with the fishing community before commencement of construction works . Proper Planning execution of offshore construction activities to ensure completion of the construction as per schedule . Ensure that slop tanks will be provided to barges/ workboats for collection of liquid/ solid waste during construction Phase

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Sr. Name and The points represented Replies/ Commitment by CMPL Financial Commitment by CMPL No. Village . Multiday fishing gillnetters and trawlers who may not be able to use their traditional fishing routes to go to the distant fishing grounds in Saurashtra and Kutch region. To provide the access, an approach trestle is planned in such a way that any one span of the trestle shall have minimum clearance of 7 m above the High Water Level with 20 m width for movement of fishing vessels. . Educating the fishermen about the orientation of approach channel and ships visits etc., . Regular interactions will be initiated with the fishing community . Conflicts, if any, with fishing community will be amicably resolved in all cases. . Port development will be on intertidal area and berthing line and breakwater in between 13 m to 15 m water depth. Majority of the fishing activity in the study area is observed beyond these depths. . Port developmental area is about 4.0 km north of river Varoli mouth. No open beach landing is observed in the area proposed for development. No impact on fish landing. . Most of the area fishing harbour and port co-exist without any conflicts . Mathematical Model Studies carried out to analyse the impact due to dredging and reclamation and dumping activities. The results reveals that the turbidity/ suspended sediment concentration increase will reach ambient conditions within shorter duration

. The results from the planform shoreline evolution model indicates that the l:\ports\2012\c1121113 - eia for nargol port\outputs\reports\ec clarifications\ec clarfication 22.09.2017\annexure d - issue raised during ph.doc Page 6

Sr. Name and The points represented Replies/ Commitment by CMPL Financial Commitment by CMPL No. Village accretion on the south side if the port will not extend beyond 1km and will not have any impact on the Varoli River mouth which is located about 4.0 km from the proposed development. In addition, the analysis of Hydrodynamic result with and without the proposed development revels that there will not be any changes in the hydrodynamic near the river mouth due to the construction of port. Similarly, it is found that the proposed structures will not alter the wave pattern near the river mouth. Hence, it can be concluded that the development of port will not have any influence on the existing morphological process near the river mouth and hence mangroves will not be affected. . Dredging would result in removal of benthic communities associated with bottom sediments. During dredging sessile forms will be removed along with sediments and mobile species tend to move away and are likely to increase species diversity in areas adjoining the site. Further, it is observed that due to movement of mobile species and transfer of nutrients during dredging activity, there will be an increase in species diversity and density in areas adjoining the dredging operation. All the construction phase impacts are short term in nature and will cease on completion of construction. . Air and Water Pollution control measures such as Covered stockyard, covered conveyors, Dust Suppression system, Wind Barrier, Covered trucks, STP, Oil water Separators, Settling ponds etc., are proposed. All the emissions and l:\ports\2012\c1121113 - eia for nargol port\outputs\reports\ec clarifications\ec clarfication 22.09.2017\annexure d - issue raised during ph.doc Page 7

Sr. Name and The points represented Replies/ Commitment by CMPL Financial Commitment by CMPL No. Village discharges shall meet the prevailing standards. Here at sea shore two type of farming takes No Fishing landing observed in the area 4. Mukeshbhai The following financial commitment given by PP for Machi place. One on seashore and other in sea. This proposed for Nargol Port. Nearest landing is the Environmental Management: sea shore is known as Golden Fisheries. Fish observed at River Varoli mouth which is located at (President-  Greenbelt development – INR 2 Crores here are very costly. If port comes then about 4.0 km away from the Project site. Port Macchi Samaj)  Wastewater Management (Sewage Treatment industry will come. Its waste water will be development will be on intertidal area and berthing Plant & Drainage & Sewerage system/Storm discharged into sea. Fish does not lay eggs in line and breakwater in between 13 m to 15 m water Water System) – INR 30 Crores deep clean water. Fish uses seashore to lays depth. Majority of the fishing activity in the study area Air Pollution Control (Dust Sweeper, Installation egg. If port comes the shore will be destroyed is observed beyond these depths. Most of the area  and hence fishes will also be destroyed. Flora- fishing harbour and port co-exist without any of sprinkler system, Covered system for Coal fauna and farming will be destroyed. conflicts. Storage, Wind barriers, Dust Suppression/Water sprinkling during No Wastewater discharge in to the sea will be Construction Phase, Conveyor Belt System ensured. The following are the measures proposed. with Hood, Conveyor Belt System in stackyard, . Ensure that slop tanks will be provided to Wagon loading system & Wagon loading barges/ workboats for collection of liquid/ hopper-1500 T capacity) – INR 585.63 Crores solid waste  Other Pollution Control Measures (Oil Water . Ships are prohibited from discharging wastewater, bilge, oil wastes, etc. into the Separator, Settling pond at Coal Stockyard, near-shore as well as harbour waters. etc.) – INR 9.0 Crores . Ships would also comply with the  Marine Life Protection out of Oil Spill (One MARPOL convention. tugboat with booms and skimmer and dust . As a mitigation measure for spillages an exhausting equipment) – INR 10.13 Crores Oil spill contingency plan prepared and will be implemented.  Environmental Monitoring during Construction . Provision of waste reception facility Phase (Both marine & terrestrial environment) during emergency – INR 4.54 Crores . In case of any cargo spillage during  EMC Running Expenditure – 0.15 Crores/year transfer from/to ships, it will be attempted to recover the spills. Oil spill control  Greenbelt Maintenance – INR 0.2 Crores/year equipment such as booms / barriers will  Maintenance of Dust Sweepers – INR 0.3 be provided for containment and Crores/year skimmers will be provided for recovery.  Maintenance of Air Pollution Control Measures Response time for shutting down the – INR 0.2 Crores/year fuelling, containment and recovery will be quicker  Dust Suppression/ Water Sprinkling – INR 0.05 l:\ports\2012\c1121113 - eia for nargol port\outputs\reports\ec clarifications\ec clarfication 22.09.2017\annexure d - issue raised during ph.doc Page 8

Sr. Name and The points represented Replies/ Commitment by CMPL Financial Commitment by CMPL No. Village . STP to treat the sewage generated in the Crores/year premises. Treated wastewater from STP  Statutory Compliance for Environment will be used for irrigating the greenbelt . Oily Water Separators Protection (Environmental Monitoring) – INR . Settling Pond at Coal Stockyard 1.29 Crores/year . Storm Water Drainage System . Ballast Water Management as suggested in CEIA will be followed. Other impacts and mitigation measures on fishing is discussed in query Sr. No 3. 5. Rakesh Rai People in Umargam are very calm and Kamala Shankar understanding. These people are not opposing Public Hearing Location: As per EIA Notification development but we do not want development Sarigam 2006 (as amended), the Public Hearing has to be which destroys environment. A year ago well conducted at the site or in its close proximity. water was used to drink and we have grown up (Member of Considering the access and other factors, GPCB but now we have to purchase water for Rs. 20. Sarigam organized the Public Hearing near Micro Wave That is we have to drink RO water. Tadgam Panchayat) Tower, Nargol – Daman Road, Tadgam. Tadgam where there is no population, public hearing is village boundary is at about 2.7 km from the Project arranged which is suspicious. site. The details of the Project and its impacts are studied and the Draft Comprehensive EIA report was prepared along with necessary maps and Information available on website and on net is Submitted to GPCB for Public Hearing. The details put up by Gujarat Maritime Board or Cargo of public hearing were advertised 30 days before in Motors. It is of 500 pages. This information and Indian Express (English) and Divya Baskar given audio visual is difficult for people to (Gujarati) and Sandesh (Gujarati) newspapers. understand. Even graduate person like me from English medium of University is not The Complete documents are made available in the able to understand then what will this village following Places. people understand. Then the people of this . The District Collector Office, Valsad region are not able to understand. Gujarat . District Development Office, Valsad Maritime Board officer and from Honorable . District Industry Center, Valsad Collector side should provide information that . Taluk Development office, Umargam can be clearly understood. There should be . Regional Office, GPCB, Sarigam gramsabha of only one issue all over from Dehri . The Chief Conservator of Forest, MoEF, to kalai of Umargam Taluka in which Gujarat Bhopal. Maritime Board Officer and Representative of Also the Executive Summary of Draft EIA in both Honorable Collector and Representative of English and Gujarati Languages are made available Cargo Motor comes, explain clearly in Gujarati l:\ports\2012\c1121113 - eia for nargol port\outputs\reports\ec clarifications\ec clarfication 22.09.2017\annexure d - issue raised during ph.doc Page 9

Sr. Name and The points represented Replies/ Commitment by CMPL Financial Commitment by CMPL No. Village visual. If people do not understand then what almost all the study area villages. In addition, all the

will they represent? This public hearing should documents were made available in GPCB website be cancelled in interest of justice. How much by GPCB. land will be required? What compensation will

be given to affected people? What will be done for land acquisition? Such information is not During Public Hearing held on 13.01.2016, Then the mentioned. There is no information related to representatives of M/s. Cargo Motors Pvt. Ltd, road and railway line. Showing dreams to presented Gujarati Audio visual Presentation with people of becoming millionaire but information information of proposed planning, environmental regarding above is not given in EIA. management system, project’s technical information, the proposed preventive steps, impact

on the environment and industry’s proposed activities regarding Corporate Social Responsibility (CSR). The public hearing was conducted as per

EIA Notification 2006 (as amended).

All port back up facilities of Phase 1 and Phase 1 A development have been proposed on reclaimed land (behind berthing Line and in inter tidal area) as

suggested by Gujarat Maritime Board (GMB) through their bid document. The land to be reclaimed is about 171.5 Ha. Only the Logistic Support Building (LSB) is

planned on a forest land of about 4.0 Ha. Necessary application for diversion of forest land to non-forest purpose (development of LSB) is already submitted

and the same is being scrutinized at the Deputy Conservator of Forest (DCF), Valsad Forest Office.

No land acquisition and hence no R&R is envisaged as a part of the development of Nargol port.

The details of railway lines for the proposed project

are given in Section 2.3.2, 2.7.22 and 7.5.7 of Draft CEIA Report. Development of Rail corridor is being taken up as a separate project and As the

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Sr. Name and The points represented Replies/ Commitment by CMPL Financial Commitment by CMPL No. Village authorities such as Department of Railways etc., will

be carried out.

The proposed Nargol port marine facilities such as breakwaters are about 6.1 km away from the shoreline. Detailed Hydrodynamic studies were

carried as a part of CEIA study and presented in the If port is built at 12.5 nautical miles and report. The following are the observations made from reclamation is done, thereafter the impact of the study:

high tide water from Dehri to Kalai is not mentioned. Sir, you and GPCB do not convey . Current in the region is mainly tide driven. opinion for this upcoming port and let the voice Effect of wind on current was found of our people reach to Government. This negligible. Direction of currents is towards company talks about CSR activity but even big north during flood tide and reverses during companies in Sarigam are also not paying ebb tide. A maximum current speed of 1.6 taxes. Pass the peoples voice to Gandhinagar m/s was observed at 10m contour off and Delhi (MoEF) Nargol coast during flood of spring tide and is in the order of 1.2 m/s during ebb. Periodic wetting and drying of seabed can be seen for up to a distance of around 1km from coast.. . However, restricting the flow completely in the leeward side of port may lead to stagnation of water in this area and can cause high current speed in the seaside of port and across the channel. This in turn may cause changes in shoreline of nearby area. Thus an alternate approach was adapted by providing trestle instead of The cost of the Approach Structure/trestle will be approach bund to allow free flow of about INR 465.80 Crores is considered as a par to water in the leeward side of port. Project Cost during Phase 1 and further 9.27 Crore Moreover, the alignment of breakwater was is considered during Phase 1 A also. also optimized to minimise the variations in hydrodynamic conditions in the surrounding. Various layout options were studied for suitability and also considering l:\ports\2012\c1121113 - eia for nargol port\outputs\reports\ec clarifications\ec clarfication 22.09.2017\annexure d - issue raised during ph.doc Page 11

Sr. Name and The points represented Replies/ Commitment by CMPL Financial Commitment by CMPL No. Village future phases of development of port.

Effect of various layout options on the current pattern in the study area was tested and layout Phase 1 and Phase 1 A was found to be causing the minimum variation in natural hydrodynamic condition and accordingly finalized.

As a part of Corporate Social Responsibility (CSR), CMPL has proposed to take up activities in the following areas for improving the way of living of people of surrounding villages. All of the project as identified by the Nargol Port under its CSR plan shall The capital budget earmarked for the CSR be developed and implemented in a time bound initiatives for 5 years is in the tune of INR manner by a public charitable trust named 7,00,00,000/- (INR 70 Million). The CSR Budget ―YASHPAL NANDA FOUNDATION established by shall be fixed for each financial year which will not M/s Cargo Motors Private Limited. lapse and will be transferred to the CSR Fund, which will accumulate.

. Education . Health Care . Sustainable Development . Infrastructure Development All the details are provided in the CEIA report. A separate budget for CSR Initiatives shall be earmarked each year in compliance with the prevailing laws. The budget will be revisited each financial year; however, the capital budget earmarked for the CSR initiatives for Five year or as per company law for CSR is in the tune of INR 7, 00, 00,000/- (70 Million rupees) The CSR Budget shall be fixed for each financial year which will not lapse and will be transferred to the CSR Fund, which will accumulate. In order to ensure effective implementation of the CSR programs undertaken, a monitoring mechanism shall be put in place by the Port EHS & CSR Cell.

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Sr. Name and The points represented Replies/ Commitment by CMPL Financial Commitment by CMPL No. Village

Honorable Collector said that till now five peoples has been represented. All other peoples are for their representations so for representation come directly and say name. We are not going to take any decision. All the questions raised are being recorded and your guidance/ suggestions / representation will be sent to Govt. of India through GPCB. Nargol Port facilities development mostly planned The payment for the compensatory afforestation in Rajeshbhai V. Everyone likes developments but why this 6. on the reclaimed land and no land acquisition is ~4ha area shall be made as per the compensatory Keni people have come we should know. Even for involved. Hence No R&R. As mentioned in the afforestation scheme of the Gujarat forest construction of road gramsabha permission is Maroli. Draft CEIA report, about 4 Ha of Forest land is department. required then why this mega project without proposed for LSB purpose. Necessary application (Gram Panchayat gramsabha permission? In gramsabha villagers for diversion of forest land to non-forest purpose were asking question that what is information of Sarpanch) (development of LSB) is already submitted and the this port? So previously I wrote letter to same is being scrutinized at the Deputy Honorable Collector and in reply we got Conservator of Forest (DCF), Valsad Forest Office. collector office letter that there is no information Necessary procedure will be followed. of port. Our youngster going to Sarigam and

Umargam asking for job are not given Public Hearing was conducted as per the employment. In most of the company’s people procedures stipulated in the EIA Notification 2006 from outside are working then what is the (as amended). assurance that how many locals will be

employed in this project. The fishermen sell

their fish for 10 rupees to run their home. Our During the construction phase of the project there Ramanbhai is favorite leader. We request will be large-scale employment generation in the Honourable Ramanbhai Patkar to give justice form of skilled and semiskilled laborers and and represent to Government. technical staff. It is likely to provide an employment for 1500-2000 personnel on direct basis and around 5000 on indirect basis.

During operational phase, the port is likely to generate employment of 200-300 people on direct and around 2500-3000 on indirect basis.

Preference shall be given to locals based on the skill set.

As a part of CSR, In Sustainable Livelihood CSR cost is given above in Point no. 5. following programs have been proposed for providing livelihood in a locally appropriate and environmentally sustainable manner . Formation of Self Help l:\ports\2012\c1121113 - eia for nargol port\outputs\reports\ec clarifications\ec clarfication 22.09.2017\annexure d - issue raised during ph.doc Page 13

Sr. Name and The points represented Replies/ Commitment by CMPL Financial Commitment by CMPL No. Village . Groups for women empowerment . Vocational training . Agriculture development and better farmer focus . Watershed development . Partnership with Industrial Training Institutes

7. Vinay According to EIA report we requested Collector Public Hearing was conducted by GPCB as per the Gulabchand that EIA report is of 600 Pages so organize procedure stipulated in the EIA Notification 2006 (as Seth, public hearing after 2 months period but it is amended). organized within month. EIA report is Phansa incomplete and misleading. After making central government committee of expert of this subject The Comprehensive EIA/Studies have been carried again EIA report must be made. out for the development of Nargol Port. All the impacts associated with construction and operation

phases on all the environmental (Terrestrial/ Marine) and social parameters have been studied and appropriate mitigation measures were proposed for

sustainable development.

Total Land required for the proposed project is 147.5 In first phase no land is required but how many ha for Phase 1 & 175.5 ha for Phase 1A for which

phases are there and then after no information ToR was approved by MoEF. is given how much land will be acquired. No R&R for the development of Port facilities. Most of the Port facilities will be developed on the reclaimed

land and hence no acquisition of agricultural/ farming

land. Only LSB will be developed in the forest land where which mainly Casuarinas and Eucalyptus trees are observed. Necessary application has been filed with department of Forest.

As directed by GMB no land shall be acquired for No information regarding other port in nearby Initial development of port facilities at Nargol. Hence, region is there. About Boisar, Hajira, Pipavav the proposed port development will be developed port at what capacity are they running there is mostly on reclaimed land except port administration no information about it. If other ports are studied facilities such as LSB complex. For the construction then I feel they are running at low capacity. So of LSB, afforest land has been identified with survey l:\ports\2012\c1121113 - eia for nargol port\outputs\reports\ec clarifications\ec clarfication 22.09.2017\annexure d - issue raised during ph.doc Page 14

Sr. Name and The points represented Replies/ Commitment by CMPL Financial Commitment by CMPL No. Village there is no need for this port. On page number 4 numbers 97 & 98 at village Nargol. proposed Delhi- Mumbai corridor is mentioned Hence no rehabilitation of people will be needed for but Delhi-Mumbai is dedicated freight corridors Phase 1 and Phase 1A development of this port. In is not mentioned. In addition there are no case of future expansion of the port, details regarding studies done on this. If compared with other phases and land required will be intimated to public ports of New Delhi Mumbai Corridor then through EIA study and PH. As of now only Phase 1 economically not feasible. That is why Nargol and 1A are planned or which no R&R is involved. Port is not required. In the latest traffic study carried out by PWC in

2013, all the competing ports & their existing & upcoming handling capacity has been accounted for. As per the traffic report, even after the planned

capacity expansion at these competing ports, there is good traffic potential at Nargol port. A summary of the detailed traffic study is given as Section 2.4 of Draft CEIA report. Delhi – Mumbai Freight Corridors On page no. 13 rail is going to acquire land are considered in the Traffic Management Study inside 12 km, this information is not mentioned and presented in the CEIA report. In Chapter 7

which is the land of farmers. Their acquisition in this EIA report is not been discussed. Railway line is not included in the EIA report. What about the land that will be acquired for rail The details of railway lines for the proposed project corridor? What about compensation to farmer? are given in Section 2.3.2, 2.7.22 and 7.5.7 of There are no details regarding land requirement Draft CEIA Report. Development of Rail corridor is for railway. Umargam has been declared as a being taken up as a separate project and As the

Schedule area under the Schedule-V of development of rail line doesn’t attract EIA Constitution. Umbergam has got many notification, necessary clearances from the important rights. And no discussion has been relevant authorities such as Department of done about these rights. After gramsabha Railways etc., will be carried out. Also all the resolution further development work is requisite procedures will be adhered by CMPL. recommended. That is why project is recommended to be cancelled.

On page no 5.16 water which has to be obtained, it will be used from bore well and hence in our region we will have water Proposed Nargol port water requirement is estimated problems. It will also pollute ground water and at 2.3 MLD up to Phase 1 A which will be sourced . Utilities & Services (Water Supply System) – INR 4 Crores l:\ports\2012\c1121113 - eia for nargol port\outputs\reports\ec clarifications\ec clarfication 22.09.2017\annexure d - issue raised during ph.doc Page 15

Sr. Name and The points represented Replies/ Commitment by CMPL Financial Commitment by CMPL No. Village no solution for this is mentioned in the report. from Tokar River and through Authorized Local . Maintenance of Utilities & Services – INR Water Suppliers. The availability details at River 0.35 Crores/year Tokar were obtained from Water Resource . Wastewater Management (Sewage Department (WRD) and presented in Section Treatment Plant & Drainage & Sewerage 2.7.23.1 which confirms that Net/Excess available system/Storm Water System) – INR 30 water is 74.75 MLD. Thereby there will be adequate Crores water available for port operations without impacting . Other Pollution Control Measures (Oil the water needs of other users. CMPL will apply to Water Separator, Settling pond at Coal GoG for the water requirement. It is not envisaged to Stockyard, etc.) – INR 9.0 Crores draw groundwater to avoid impact to local groundwater resources. A dedicated water supply . Marine Life Protection out of Oil Spill (One

system will be developed by the port. Also, treated tugboat with booms and skimmer and dust wastewater will be reused. Also, the impacts exhausting equipment) – INR 10.13 Crores associated with the contamination/pollution of . Maintenance of dust bins – INR 0.04 groundwater have been studied in Draft CEIA and Crores

appropriate mitigation measures have been suggested such as STP, Oil water Separator, Settling Ponds, Storm water management System, reclamation methods, Solid waste Management etc.

The Comprehensive EIA/Studies have been carried out for the development of Nargol Port. All the According to EIA report page number 7.54, impacts associated with construction and operation there will be direct employment of 200-300 phases on all the environmental (Terrestrial/ Marine) people and indirectly 2500 to 3000 people will and social parameters have been studied and be employed. So for this there is no need to appropriate mitigation measures were proposed for waste money and destroy environment. This sustainable development. region is naturally rich and there is only need of The benefits of the port project are given below farming, fisheries and animal husbandry . Probable increase in the infrastructure business. The generations will keep on getting resources due to the project in the region this wealth. If fishery businesses will be by the way of additional/improved developed then more 200-300 will get transport, communication, health facilities, employment. EIA report is incomplete, false and drinking water facilities, sanitation and misleading. Hence the EIA report and port hygiene facilities and other basic facilities should be cancelled. will be created l:\ports\2012\c1121113 - eia for nargol port\outputs\reports\ec clarifications\ec clarfication 22.09.2017\annexure d - issue raised during ph.doc Page 16

Sr. Name and The points represented Replies/ Commitment by CMPL Financial Commitment by CMPL No. Village . Due to proposed project, surrounding villages and region would get maximum benefits such as upcoming of industries and its allied ancillary units, direct and indirect employment, skill development activities to the employable youth in the region, better quality of educational and medical facilities to the local people, proposed project thus will also cater to the growing demand-supply gap of physical and social infrastructure etc., . Improved socio-economic conditions which focused primarily on work force requirements, acquisition of supplies, and increase in industrial activity . Quality of life in the region is likely to improve due to the creation of jobs for the local people so that the dependency changes and there will be more than one earning member in the family, which will provide economical freedom and would facilitate a higher standard of living with better facilities . As a part of the Corporate Social Responsibility (CSR) initiatives, it is envisaged to create better and quality Sanitation, Medical & Education facilities, etc. . Improvement in the trading, marketing as well as value addition of local products. . The proposed project shall further act as a catalyst to industrialization and urbanization of the region . Overall economic growth of Valsad District and Gujarat State GPCB has conducted the public hearing at 8. Yatin Bhandari The Public Hearing was conducted as per EIA th (Ex. Sarpanch Tadgam. Today the date is 13 which is a Notification 2006 (as amended), by GPCB. black date for Tadgam village. In the same of Nargol) l:\ports\2012\c1121113 - eia for nargol port\outputs\reports\ec clarifications\ec clarfication 22.09.2017\annexure d - issue raised during ph.doc Page 17

Sr. Name and The points represented Replies/ Commitment by CMPL Financial Commitment by CMPL No. Village

village the polluted water was discharged from G.I.D.C. Sarigam. Due to this ample amount of ecosystem was destroyed. As a Sarpanch, Total Land required for the proposed project is 147.5 ha for Phase 1 & 175.5 ha for Phase II. approached the High Court and filed a petition,

fought and won and now filtered water is released into the sea. Forest land of Nargol is As directed by GMB no land shall be acquired for under our people conservation. And without Initial development of port facilities at Nargol. The payment for the compensatory afforestation in our consent it is being given to others. I have Hence, the proposed port development will be ~4ha area shall be made as per the compensatory objection as a Chairman of Van Shakari developed mostly on reclaimed land except port afforestation scheme of the Gujarat forest Mandali. This port will lead to development of LSB complex. For the construction of LSB, a forest department. . the country but this development will be at the land has been identified with survey numbers 97 & 98 at village Nargol. Hence no rehabilitation of cost of Nargol, Vankas, Saronda, Tumb, people will be needed for Phase 1 and Phase 1A Tadgam, Umargam, etc. which will adversely development of this port. . Necessary application for affect on environment. Friends although we diversion of forest land to non-forest purpose are uneducated but we are quite clever. And (development of LSB) is already submitted and the our objection is on this. Our objection is on same is being scrutinized at the Deputy Conservator acquisition of the Survey no. 97/98. of Forest (DCF), Valsad Forest Office. Also all the requisite procedures will be adhered by CMPL.

It was shown on projector under CSR that As a part of Corporate Social Responsibility (CSR),

work on new lake and work of school of Tumb, CMPL has proposed to take up activities in the CSR cost is given above in Point no. 5. Saronda is done and Rs.25 lakhs is spent. But following areas for improving the way of living of people of surrounding villages. All of the project as if we observe the work in the mentioned identified by the Nargol Port under its CSR plan villages then no work has been done. CSR shall be developed and implemented in a time activity should be carried out along with the bound manner by a public charitable trust named Sarpanch. Development is talking about ―YASHPAL NANDA FOUNDATION‖ established money but it is false. If initially making such big by M/s Cargo Motors Private Limited. fools then what will happen afterwards? There is no complete information provided for the . Education port and that’s why we oppose the Public . Health Care hearing of GPCB. And has to be declared as . Sustainable Development l:\ports\2012\c1121113 - eia for nargol port\outputs\reports\ec clarifications\ec clarfication 22.09.2017\annexure d - issue raised during ph.doc Page 18

Sr. Name and The points represented Replies/ Commitment by CMPL Financial Commitment by CMPL No. Village . Infrastructure Development cancelled. If CSR activity is not carried out along with the villagers then we will not allow All the details are provided in the CEIA report. any survey. A separate budget for CSR Initiatives shall be

earmarked each year in compliance with the prevailing laws. The budget will be revisited each financial year; however, the capital budget earmarked for the CSR initiatives for Five year or as per company law for CSR is in the tune of INR 7, 00, 00,000/- (70 Million rupees) The CSR Budget shall be fixed for each financial year which will not lapse and will be transferred to the CSR Fund, which will accumulate. In order to ensure effective implementation of the CSR programs undertaken, a monitoring mechanism shall be put in place by the Port EHS & CSR Cell.

He said that we request the Collector that our 9. Ashok Thakur Primary Socio-economic surveys among the opposition is for the port not for the public fishermen were carried out by Former Principal (Kinara Bachao hearing. The port should be cancelled. 600 Samiti) page EIA report has been made. Has Regional Scientist & Head, Crustacean Fisheries division Officer read it completely? There is no CMFRI, Kochi. The findings of the study are information about the livelihood of fishermen in provided in the Section 4.8 of DCEIA report. The it. There is no mention of rehabilitation of impact on fishing and mitigations measures are fishermen. provided in Section 5.9.1.2 and 7.6.1.3 of DCEIA report. Port development will be on intertidal area and berthing line and breakwater in between 13 m

to 15 m water depth. Majority of the fishing activity in the study area is observed beyond these depths. Also as reported through the primary surveys, the

fishing grounds are also beyond this area. In addition, all the mitigation measures as suggested

in the DCEIA will be followed for various activities.

The impacts and mitigation measures for fisheries has also provided in the reply to Public Hearing

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Sr. Name and The points represented Replies/ Commitment by CMPL Financial Commitment by CMPL No. Village Query No: 3.

There will not be any hindrance to the fishing activity in the region. In the initial stages of Phase1 As per information on page no. 5.1 there will and 1A there will be no land acquisition hence be reclamation activity which will cause there will be no rehabilitation.

coastal erosion. Kalai, Nargol, Phansa, Tadgam, etc. will be immersed in sea. Necessary study was already made to analyze the shoreline changes due to Nargol Port development

covering both erosion and accretion aspects as a part of CEIA and , it was observed that erosion takes place over a stretch 3.8 km towards north of

proposed reclaimed area of port and 0.9 km of accretion towards south of proposed reclaimed area of port. The average rate of erosion is 4m/year adjacent to the north of proposed reclaimed area and

accretion at rate of 1.4m/year adjacent to the south of proposed reclaimed area. The rate of accretion and erosion has reducing trend alongshore on either side

of the proposed reclaimed area of port. Appropriate mitigation measures were suggested in the CEIA report to protect the shoreline. They are, . Continuous monitoring of shoreline with

the help of high resolution satellite imageries during operation phase . Based on the monitoring results,

appropriate techniques such as sand bypassing from accreting area to eroding area, as appropriate shall be carried out to maintain the stability of coast

. Based on the monitoring results, the sand trap may be created where the high accretion is observed No information is given: how much land will be . Dredging of the area to be accreted/ sand acquired for railways? How much trap shall be carried out regularly (as a compensation will be provided? etc. is not part of maintenance dredging) and the mentioned. No farmer is willing to give land. material shall be used for maintaining the

eroding coastal stretch, if observed. The

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Sr. Name and The points represented Replies/ Commitment by CMPL Financial Commitment by CMPL No. Village excess/unusable material shall be In the last 150 years in this place no disposed at the identified offshore disposal location thunderstorm has occurred and no Koli and fisherman houses are neither relocated nor destroyed. So due to this development there is Development of Rail corridor is being taken up as no information provided of hurricane and a separate project and As the development of rail storms. If thunderstorm strikes the surrounding line doesn’t attract EIA notification, necessary farms will be destroyed. clearances from the relevant authorities such as Department of Railways etc., will be carried out. On page no. 17 it is mentioned that more than 2 crore ton of coal will be unloaded in the Disaster Management Plan including On-site and proposed port but no information is mentioned Off-site Emergency Plan, Oil Spill Contingency in EIA regarding the particulate matter of coal Plan and Management Plan for natural hazards which will spread over miles. And farming will such as Cyclones/Floods, Tsunami, Earthquakes be totally destroyed. In EIA 450 acres and etc., have been provided as a part of Draft CEIA. 6.1km deep dredging will be done frequently, there will be storms in this region and due to Fugitive emissions from coal heaps and other this mangoes and chickoos farms will be  Greenbelt development – INR 2 Crores areas will be prevented by providing Longitudinal  Air Pollution Control (Dust Sweeper, Installation destroyed. Covered shed type coal stockyard; Ultrasonic dust suppression system‘ at ship unloaders, transfer of sprinkler system, Covered system for Coal points, stockyard, loading system etc., 1.5 km long Storage, Wind barriers, Dust wind barrier; transportation through covered Suppression/Water sprinkling during conveyors from coal berth to the stockyard; Construction Phase, Conveyor Belt System covered transfer points; Wagon loader for train loading and silos arrangement for truck loading; with Hood, Conveyor Belt System in stackyard, Trucks before leaving the loading area shall be Wagon loading system & Wagon loading covered with tarpaulin and also the railway hopper-1500 T capacity) – INR 585.63 Crores wagons; Trucks Tyres and areas susceptible for  Environmental Monitoring during Construction coal dust before leaving premises shall be Phase (Both marine & terrestrial environment) cleansed washed to remove coal particles; greenbelt development around the coal stockyard – INR 4.54 Crores and above all adherence to the coal handling  EMC Running Expenditure – 0.15 Crores/year guidelines given by GPCB. All these measures are  Greenbelt Maintenance – INR 0.2 Crores/year provided in the Draft CEIA report.  Maintenance of Air Pollution Control Measures No information is mentioned what will be the – INR 0.2 Crores/year

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Sr. Name and The points represented Replies/ Commitment by CMPL Financial Commitment by CMPL No. Village effect on ground water due to reclamation and Air quality modeling studies has been carried out  Dust Suppression/ Water Sprinkling – INR 0.05 dredging of the sea and, we are also strictly considering all the possible sources of emissions Crores/year opposing for that. We all are opposing the and it was observed that predicted ground level  Statutory Compliance for Environment port. concentrations and resultant concentrations are Protection (Environmental Monitoring) – INR well with in the National Ambient Air Quality Standards (NAAQS) at all the receptors/villages 1.29 Crores/year considered.

The quality of the dredged material was analysed in terms of its toxic metals and found no significant concentration of toxic metals. The area proposed to be reclaimed during Phase 1 is in intertidal zone which is saline in nature. The slope of project site is towards the sea and chances of intruding sea water into groundwater to be negligible. In addition, the area behind the berthing line is proposed to be reclaimed during Phase 1 A. Hence, no significant impacts are anticipated due to land reclamation on ground/ or nearby surface water. However as suggested in CEIA, the ground water quality monitoring will be carried out in and around the villages. Honorable Collector said that this public hearing is for Nargol Port. Then let us discuss only about it. Represent your objection, why these questions? Is Mr. Patel going to give permission for the port? This public hearing is only to record your guidance / suggestion. GV Patel said that all your issues will be taken on record properly. According to EIA report this port will be 10. Shaileshbhai The area to be reclaimed (171.5 Ha) is intertidal The cost associated with the mitigation measures Hodiwala constructed by reclaiming inside the sea at 6 zone in Phase 1 and behind the berth during are provided in Query no. 3. kms. Therefore 371 hectare of area will be Phase 1A. The proposed area for reclamation is (Deputy reclaimed in Nargol coastal area. So plants devoid of any vegetation, and any major Sarpanch, endanger/endemic flora and fauna species are not Nargol) and living ecosystem will be destroyed. observed or reported. The dredged material will be used for reclamation which is non-hazardous in Macchi Samaj- President nature. However, the intertidal benthos in the reclamation area will be impacted due to reclamation. As mitigations measures,

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Sr. Name and The points represented Replies/ Commitment by CMPL Financial Commitment by CMPL No. Village Reclamation area will be restricted as per

development plan. No Spillage of dredged material in other areas will be ensured. While reclaiming the inter tidal area, bunds will be provided with a suitable overflow facilities so that only clear water will be returned to the sea. From Umargam to Kalai Phansa etc in this

region there are 600-700 small mechanized boats. In one boat 6-7 people are there. So everyday 10,000-15,000 fisherman get their Primary Socio-economic surveys among the livelihood. Hence because of port fishermen were carried out by Former Principal

development fishermen will be at loss. The Scientist & Head, Crustacean Fisheries division port mentions to give employment to 200 CMFRI, Kochi. The findings of the study are people. In this region fishes like Dado, Ghol, provided in the Section 4.8 of DCEIA report. The impact on fishing and mitigations measures are Pomfret, Lobster are exported and provided in Section 5.9.1.2 and 7.6.1.3 of DCEIA government gets profit. Due to port the shore report. Port development will be on intertidal area will get washed away, waves will rise. and berthing line and breakwater in between 13 m Because of this our livelihood will be to 15 m water depth. Majority of the fishing activity destroyed. There is possibility that villages will in the study area is observed beyond these

be submerged under coastal water and there depths. Also as reported through the primary will be loss to village. We oppose the port. surveys, the fishing grounds are also beyond this area. In addition, all the mitigation measures as suggested in the DCEIA will be followed for various activities.

The impacts and mitigation measures for fisheries has also provided in the reply to Public Hearing Query No: 3. There will not be any hindrance to the fishing activity in the region. In the initial stages of Phase1 and 1A there will be no land acquisition hence there will be no rehabilitation.

Necessary study was already made to analyze the shoreline changes due to Nargol Port development

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Sr. Name and The points represented Replies/ Commitment by CMPL Financial Commitment by CMPL No. Village covering both erosion and accretion aspects as a

part of CEIA and , it was observed that erosion takes place over a stretch 3.8 km towards north of proposed reclaimed area of port and 0.9 km of accretion towards south of proposed reclaimed area of port. The average rate of erosion is 4m/year adjacent to the north of proposed reclaimed area and accretion at rate of 1.4m/year adjacent to the south of proposed reclaimed area. The rate of accretion and erosion has reducing trend alongshore on either side of the proposed reclaimed area of port. Appropriate mitigation measures were suggested in the CEIA report to protect the shoreline. They are, . Continuous monitoring of shoreline with the help of high resolution satellite Provision of 1.29 Crores is made during Operation imageries during operation phase Phase for Statutory compliance for environmental . Based on the monitoring results, protection (Environment Monitoring and others). appropriate techniques such as sand bypassing from accreting area to eroding area, as appropriate shall be carried out to maintain the stability of coast . Based on the monitoring results, the sand trap may be created where the high accretion is observed . Dredging of the area to be accreted/ sand trap shall be carried out regularly (as a part of maintenance dredging) and the material shall be used for maintaining the eroding coastal stretch, if observed. The excess/unusable material shall be disposed at the identified offshore disposal location

Detailed Hydrodynamic studies were carried as a

part of CEIA study and presented in the report. The following are the observations made from the study:

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Sr. Name and The points represented Replies/ Commitment by CMPL Financial Commitment by CMPL No. Village . Current in the region is mainly tide driven.

Effect of wind on current was found negligible. Direction of currents is towards north during flood tide and reverses during ebb tide. A maximum current speed of 1.6 m/s was observed at 10m contour off Nargol coast during flood of spring tide and is in the order of 1.2 m/s during ebb. Periodic wetting and drying of seabed can be seen for up to a distance of around 1km from coast. . However, restricting the flow completely in the leeward side of port may lead to stagnation of water in this area and can cause high current speed in the seaside of port and across the The cost of the Approach Structure/trestle will be channel. This in turn may cause changes in about INR 465.80 Crores is considered as a par to shoreline of nearby area. Thus an alternate Project Cost during Phase 1 and further 9.27 Crore approach was adapted by providing trestle is considered during Phase 1 A also. instead of approach bund to allow free flow of water in the leeward side of port. Moreover, the alignment of breakwater was also optimized to minimise the variations in hydrodynamic conditions in the surrounding. Various layout options were studied for suitability and also considering future phases of development of port. Effect of various layout options on the current pattern in the study area was tested and layout Phase 1 and Phase 1 A was found to be causing the minimum variation in natural hydrodynamic condition and accordingly finalized. Honorable Collector said that the suggestion given by Shaileshbhai is good. There are many people for representation and it will take 2-3 days. I request that many points have been repeated. Now do not repeat and represent new issues so that everyone gets chance. 11 Jayprakash Here the area is having fertile land/farms. The proposed Nargol Port project shall further act as Bhandari Horticulture crops are grown. Rice like crops is a catalyst to industrialization and urbanization of the taken here and we earn our livelihood on it. region. The Comprehensive EIA/Studies have been (Ex. Sarpanch- Development of GIDC is going on in Umargam carried out for the development of Nargol Port. All Nargol) then why development of port? Nargol tourism, the impacts associated with construction and greenery and agricultural land of the region will operation phases on all the environmental l:\ports\2012\c1121113 - eia for nargol port\outputs\reports\ec clarifications\ec clarfication 22.09.2017\annexure d - issue raised during ph.doc Page 25

Sr. Name and The points represented Replies/ Commitment by CMPL Financial Commitment by CMPL No. Village be destroyed. In Gujarat one of the highest (Terrestrial/ Marine) and social parameters have density of trees district and that too it is the been studied and appropriate mitigation measures most in my Umargam taluka. The kings of fruit were proposed for sustainable development. alphanso, chickoo etc fruits are produced in Ports are major gateway for the flow of any goods in plenty. And maximum income is generated. Due and out of a country. In the latest traffic study to port Alphanso mangoes of Valsad will be carried out by PWC in 2013, all the competing ports destroyed and production of chikoo will come to and their existing and upcoming cargo handling an end. Due to port 16km of sea will be capacity has been accounted for. As per the traffic destroyed. And the breeding area of jhinga, report, even after the planned capacity expansion at paaplet and bumbla etc will destroy. Farmers on these ports, there is good traffic potential at Nargol agricultural land and fisherman at sea cost build Port. The traffic forecast summary provided by Price houses. Fishermen will be without houses. Water Coopers (PWC) is given in Section 2.4 of Farming land of farmers will be acquired for DCEIA report. roads and rail then farmers will be without farm. And the details about land acquisition for No land shall be acquired for Phase 1 and Phase railway line are not provided and for tat social 1A development of port facilities at Nargol.The survey study has not been done. Therefore we proposed port will be developed mostly on have objection against this port. reclaimed land except port LSB complex. For the construction of LSB, afforest land has been identified with survey numbers 97 & 98 at village Nargol. Hence no rehabilitation of people will be needed for Phase 1 and Phase 1A development of this port. .

No Fishing landing observed in the area proposed for Nargol Port. Nearest landing is observed at River Varoli mouth which is located at about 4.0 km away from the Project site. As the port is located far away from sea and also there is no land acquisition for the port there will not be any impact on the houses of fishermen as well as the farm land.

Details of the relevant details of roads and railway lines for the proposed project and roads to be widened are given in Section 7.5 of Draft CEIA Report. Development of Rail corridor is being taken l:\ports\2012\c1121113 - eia for nargol port\outputs\reports\ec clarifications\ec clarfication 22.09.2017\annexure d - issue raised during ph.doc Page 26

Sr. Name and The points represented Replies/ Commitment by CMPL Financial Commitment by CMPL No. Village up as a separate project. As the development of rail line doesn’t attract EIA notification, necessary clearances from the relevant authorities such as Department of Railways etc., will be carried out. 12 Keki Mistry, I was Captain at sea. Parsis have stayed for  Greenbelt development – INR 2 Crores 1086 years in Sanjan/ Udwada.  Air Pollution Control (Dust Sweeper, Installation Captain, Nargol of sprinkler system, Covered system for Coal Storage, Wind barriers, Dust We do not have any information about port Type of Project: Development of All Weather Multi- Suppression/Water sprinkling during being developed. We haven’t spread our hand Purpose Green filed Port at Nargol. The details of in front of anybody. Gurdeep Singh took Construction Phase, Conveyor Belt System the Project and its impacts are studied and the Draft permission from Anjuman but who is Gurdeep with Hood, Conveyor Belt System in stackyard, Comprehensive EIA report was prepared along with Singh, we don’t remember. He does not have necessary maps and Submitted to GPCB for Public Wagon loading system & Wagon loading experience of Port operation. Railway will come Hearing. The Complete documents are made hopper-1500 T capacity) – INR 585.63 Crores adjacent to my house. If the port is developed available in the following Places. here, Agiyaree and temple would be washed  Environmental Monitoring during Construction . The District Collector Office, Valsad away. Phase (Both marine & terrestrial environment) . District Development Office, Valsad – INR 4.54 Crores . District Industry Center, Valsad . Taluk Development office, Umargam  EMC Running Expenditure – 0.15 Crores/year

. Regional Office, GPCB, Sarigam  Greenbelt Maintenance – INR 0.2 Crores/year . The Chief Conservator of Forest, MoEF,  Maintenance of Air Pollution Control Measures Bhopal. – INR 0.2 Crores/year Also the Executive Summary of Draft EIA in both  Dust Suppression/ Water Sprinkling – INR 0.05

English and Gujarati Languages are made Crores/year available almost all the study area villages.  Statutory Compliance for Environment Protection (Environmental Monitoring) – INR Necessary impacts related to reclamation for the 1.29 Crores/year development of proposed Nargol port is provided If sea is reclaimed then from where will it come in Section 5.2.1.4 of Draft CEIA report and back? appropriate mitigation measures were also suggested for sustainable development Primary Socio-economic surveys among the fishermen were carried out by Former Principal Scientist & Head, Crustacean Fisheries division What will happen to these people if they lose CMFRI, Kochi. The findings of the study are

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Sr. Name and The points represented Replies/ Commitment by CMPL Financial Commitment by CMPL No. Village their farming land and fisheries? Why you want provided in the Section 4.8 of DCEIA report. The to spoil Nargol beach? impact on fishing and mitigations measures are provided in Section 5.9.1.2 and 7.6.1.3 of DCEIA

report. Port development will be on intertidal area and berthing line and breakwater in between 13 m to 15 m water depth. Majority of the fishing activity in the study area is observed beyond these depths. Also as reported through the primary surveys, the fishing grounds are also beyond this area. In addition, all the mitigation measures as suggested in the DCEIA will be followed for various activities.

The impacts and mitigation measures for fisheries has also provided in the reply to Public Hearing Query No: 3. There will not be any hindrance to the fishing activity in the region. In the initial stages of Phase1 and 1A there will be no land acquisition hence there will be no rehabilitation.

Necessary study was already made to analyze the shoreline changes due to Nargol Port development covering both erosion and accretion aspects as a part of CEIA and , it was observed that erosion takes place over a stretch 3.8 km towards north of proposed reclaimed area of port and 0.9 km of accretion towards south of proposed reclaimed area of port. The average rate of erosion is 4m/year adjacent to the north of proposed reclaimed area and accretion at rate of 1.4m/year adjacent to the south of proposed reclaimed area. The rate of accretion and erosion has reducing trend alongshore on either side of the proposed reclaimed area of port. Appropriate mitigation measures were suggested in the CEIA report to protect the shoreline. They are,

. Continuous monitoring of shoreline with l:\ports\2012\c1121113 - eia for nargol port\outputs\reports\ec clarifications\ec clarfication 22.09.2017\annexure d - issue raised during ph.doc Page 28

Sr. Name and The points represented Replies/ Commitment by CMPL Financial Commitment by CMPL No. Village the help of high resolution satellite

imageries during operation phase . Based on the monitoring results, appropriate techniques such as sand bypassing from accreting area to eroding area, as appropriate shall be carried out to maintain the stability of coast . Based on the monitoring results, the sand trap may be created where the high accretion is observed . Dredging of the area to be accreted/ sand trap shall be carried out regularly (as a part of maintenance dredging) and the material shall be used for maintaining the eroding coastal stretch, if observed. The excess/unusable material shall be disposed at the identified offshore disposal location

State-of-the-art facilities shall be provided for coal handling in the proposed Nargol port. Fugitive emissions from coal heaps and other areas will be prevented by providing Longitudinal Covered shed type coal stockyard; Ultrasonic dust suppression system‘ at ship unloaders, transfer points, stockyard, loading system etc., 1.5 km long wind barrier; transportation through covered Cargo Motors will make coal stack yard in 64 conveyors from coal berth to the stockyard; acres, due to which people will suffer from TB. covered transfer points; Wagon loader for train Had come to measure wind velocity in village to loading and silos arrangement for truck loading; install windmill over house. You all come to my Trucks before leaving the loading area shall be house. My house will complete 100 years in covered with tarpaulin and also the railway 2016. On 17th January 2010 of Mint paper in wagons; Trucks Tyres and areas susceptible for Mumbai in it, agreement is done between Israeli coal dust before leaving premises shall be port and Cargo Motors. I have obtained a 45 cleansed washed to remove coal particles; pages project report in private from L&T. Now greenbelt development around the coal stockyard the report is 26 pages. and above all adherence to the coal handling guidelines given by GPCB. All these measures l:\ports\2012\c1121113 - eia for nargol port\outputs\reports\ec clarifications\ec clarfication 22.09.2017\annexure d - issue raised during ph.doc Page 29

Sr. Name and The points represented Replies/ Commitment by CMPL Financial Commitment by CMPL No. Village are provided in the Draft CEIA report. Fire

hazard during Coal handling is mentioned in the Now in Sarigam quarry is hill now. From it EIA report and mitigation measures were stones will be removed for the reclamation in proposed. Swivelling Type Nozzles will be sea then our religious places in Udwada and installed to cover entire stockpile to suppress the Sajan will be washed away. Once reclaimed auto ignition of coal and ensure the workers then from where from where will you get back safety. Nozzles will be installed on pipes at sea. Shri. Ramabhai Patkar (MLA) told that if different levels from ground. the port comes people will be millionaires and

billionaires. But in other areas of West Bengal, Punjab and Gujarat price of land is about 2 Air quality modeling studies has been carried out crores and bought flats, car and now on they considering all the possible sources of emissions have nothing. Farming has stopped. At present and it was observed that predicted ground level they are working as a peon and watchman for concentrations and resultant concentrations are rupees 10,000 to 15,000. BDR will make 64 well with in the National Ambient Air Quality hectare coal stockyard. I request people here; Standards (NAAQS) at all the receptors/villages there is a coal stack yard of 3MMTPA at Shiveri considered. and Wadala. There is a hospital built nearby but

only for TB patients. Sulphur Dioxide and Methane gas will be produced from coal. Methane gas which will be generated is not Reclamation will be carried out by using dredged mentioned. Which is inflammable. It can catch fire anytime and is harmful to humans. Recently materials. Other construction materials will be there was news that not even one bed is vacant sourced from approved quarries as identified in the CEIA report. in Shiveri. Today including patients, Doctors, and worker are living in compound and worker / No Crude oil is proposed to be handled at Nargol doctor are dying. If this port comes tankers of Port. 3lakh ton will come and crude pump will also come which will produce hydrogen sulphide gas and if there will be leakage in pump then gas will spreading Nargol , Daman, Dahanu village and it will immediately affect people. My aunt’s son resides in Hazira, and now he is scared to go out and if port comes my Nargol will turn evil. So that is why we oppose this port. 13 M.S. H. Shaikh M.S.Shaikh tried to raise points. - (NGO, Olpad, ) l:\ports\2012\c1121113 - eia for nargol port\outputs\reports\ec clarifications\ec clarfication 22.09.2017\annexure d - issue raised during ph.doc Page 30

Sr. Name and The points represented Replies/ Commitment by CMPL Financial Commitment by CMPL No. Village Honorable Collector informed him that only affected locals can make oral representation. That is why you cannot give oral representation. But you can give your representation in writing. 14 Mukeshbhai He is our representative for Nargol, Umargam, - - Macchi (Nargol) Maroli. Lot of information of about port. Out of 365 he lives with us 120 days. Hence we request to allow MSH Sheikh to make representation. Honorable Collector informed that we are going as per Government Rules and Regulations. Local people will orally represent and outside people will represent in writing 15 Krushnakanth Honorable Collector cannot say no to anybody - Chauhan to represent in public hearing. I want to speak a Mr. M.S.H. Shaikh has presented his (Baroda) little on hearing and EIA. For hearing and EIA concerns/queries. Replies to the queries/concerns there is verdict of Honorable Delhi High Court. of Mr. M.S.H. Shaikh are given in Sr. No: 28. In 2010 there is order against writ petition no 9313-2009 was issued. In which, on page no 8 and 9, it talks about EIA notification guidelines. It is about public hearing and Environment hearing. According to the court, notification does not say about it and does not prohibit. People not staying near project can also participate in public hearing and can give their suggestions. You are head so you can decide. In addition he showed copy of high court order and insisted that outside person be allowed to represent. Honorable collector informed that it is mentioned in notification only affected people can make oral representation, whereas people from outside can give it in writing. 16 Sanjeev Bariya We file our opposition against the port. - - (Resident of coastal area) Honorable Collector said that we have noted this. 17 M. S. H. Sheikh, If the EIA notification and 600 pages of report The details of the Project and its impacts are The cost associated with the mitigation measures Surat put in English on website, when it is going to studied and the Draft Comprehensive EIA report are provided in Query no. 3. affect livelihood of the 30,000 people doing was prepared along with necessary maps and

fishing and 30,000 people will become Submitted to GPCB for Public Hearing. GPCB unemployed themselves then how will they organised the Public Hearing near Microwave l:\ports\2012\c1121113 - eia for nargol port\outputs\reports\ec clarifications\ec clarfication 22.09.2017\annexure d - issue raised during ph.doc Page 31

Sr. Name and The points represented Replies/ Commitment by CMPL Financial Commitment by CMPL No. Village understand the 600 page report put up in Tower, Nargol –Daman Road, Tadgam on English. If we are doing anything wrong let us 13.01.2016. The details of public hearing were know. If I legally translate each and every word advertised 30 days before in Indian Express of English into pure Gujarati and can explain (English) and Divya Baskar (Gujarati) and Sandesh fishermen then what wrong have I done? (Gujarati) newspapers. Environment is field of Science. Only pages will The Complete documents are made available in the be kept in EIA report. In Ministry only minutes following Places. will be scrutinized. For such kind of reports a . The District Collector Office, Valsad committee is formed in Ministry and 50 projects . District Development Office, Valsad are scrutinized and each project gets only one . District Industry Center, Valsad minute. The process of permission for thirty . Taluk Development office, Umargam thousand people will be given in one minute in . Regional Office, GPCB, Sarigam New Delhi. Till now the company has not give . The Chief Conservator of Forest, MoEF, single answer. Which is incomplete justice Bhopal. procedure? Also the Executive Summary of Draft EIA in both English and Gujarati Languages are made available almost all the study area villages. In addition, all the documents were made available in GPCB website by GPCB.

Mr. M.S.H Sheikh has thanked for the Fisheries study carried out as a part of CEIA which can be referred from the query S.No: 28.

Primary Socio-economic surveys among the fishermen were carried out by Former Principal Scientist & Head, Crustacean Fisheries division CMFRI, Kochi. The findings of the study are provided in the Section 4.8 of DCEIA report. The impact on fishing and mitigations measures are provided in Section 5.9.1.2 and 7.6.1.3 of DCEIA report. Port development will be on intertidal area and berthing line and breakwater in between 13 m to 15 m water depth. Majority of the fishing activity in the study area is observed beyond these depths. Also as reported through the primary l:\ports\2012\c1121113 - eia for nargol port\outputs\reports\ec clarifications\ec clarfication 22.09.2017\annexure d - issue raised during ph.doc Page 32

Sr. Name and The points represented Replies/ Commitment by CMPL Financial Commitment by CMPL No. Village surveys, the fishing grounds are also beyond this area. In addition, all the mitigation measures as suggested in the DCEIA will be followed for various activities.

The impacts and mitigation measures for fisheries has also provided in the reply to Public Hearing Query No: 3. Honorable Collector said that the hearing is not yet complete, so how can you say this is incomplete justice procedure. There has been an in-depth study conducted on the 18 Raman Patkar I have been asked to represent on behalf of The cost associated with the mitigation measures impact on fishermen and the environment, which Fisherman and Sarpanch We have to see are provided in Query no. 3. (MLA) has been mentioned in our Draft CEIA. The whether the Environment NOC has to be or not Comprehensive EIA/Studies have been carried out given to this port. Fishermen having pending for the development of Nargol Port. All the impacts question There is no information given on associated with construction and operation phases impact on fisherman and Environment in coastal on all the environmental (Terrestrial/ Marine) and villages by upcoming port. social parameters have been studied and I have visited the Kochi, Kerala coast in the past appropriate mitigation measures were proposed for where fishermen were living on the coastline sustainable development. and I did not observe any loss to fishermen. In Bombay fishermen need to go inside for fishing. Primary Socio-economic surveys among the Fishing, while 4000 boats from fishermen were carried out by Former Principal goes out to Porbunder, Veraval, Mangrol. In Scientist & Head, Crustacean Fisheries division past I have written to Chief Minister for saving CMFRI, Kochi. The findings of the study are houses on shore in Veraval coast. There is no provided in the Section 4.8 of DCEIA report. The mention of how much effect will occur on the impact on fishing and mitigations measures are environment due to port development. There is provided in Section 5.9.1.2 and 7.6.1.3 of DCEIA no problem with the report. I don’t have any report. Port development will be on intertidal area information about upcoming port. Where there and berthing line and breakwater in between 13 m is matter of Govt. of India, MLA will only be to 15 m water depth. Majority of the fishing activity besides you. As a MLA if there is any loss to in the study area is observed beyond these depths. people then I will surely be with the public. And Also as reported through the primary surveys, the gave thanks. fishing grounds are also beyond this area. The approach trestle is planned in such a way that any one span of the trestle shall have minimum clearance of 7 m above the High Water Level with 20 m width for movement of fishing vessels. No

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Sr. Name and The points represented Replies/ Commitment by CMPL Financial Commitment by CMPL No. Village restriction to Sea will be ensured by putting up signboards at the place of construction activities in order to make fishermen aware of the ongoing activities and necessary marker buoys will be installed. In addition, all the mitigation measures as suggested in the DCEIA will be followed for various activities. The impacts and mitigation measures for fisheries has also provided in the reply to Public Hearing Query No: 3. As most of the proposed Phase 1 and Phase 1 A will be developed on the reclaimed land located ion intertidal area and in sea (Behind the berthing line), No Resettlement and Rehabilitation issues are envisaged.

The details of the Project and its impacts are studied and the Draft Comprehensive EIA report was prepared along with necessary maps and Submitted to GPCB for Public Hearing. GPCB organised the Public Hearing near Microwave Tower, Nargol –Daman Road, Tadgam on 13.01.2016. The details of public hearing were advertised 30 days before in Indian Express (English) and Divya Baskar (Gujarati) and Sandesh (Gujarati) newspapers. The Complete documents are made available in the following Places. . The District Collector Office, Valsad . District Development Office, Valsad . District Industry Center, Valsad . Taluk Development office, Umargam . Regional Office, GPCB, Sarigam . The Chief Conservator of Forest, MoEF, Bhopal. Also the Executive Summary of Draft EIA in both l:\ports\2012\c1121113 - eia for nargol port\outputs\reports\ec clarifications\ec clarfication 22.09.2017\annexure d - issue raised during ph.doc Page 34

Sr. Name and The points represented Replies/ Commitment by CMPL Financial Commitment by CMPL No. Village English and Gujarati Languages are made available almost all the study area villages. In addition, all the documents were made available in GPCB website by GPCB. 19 Pharlok Gowadia The land to be acquired for roads which is 23 No land acquisition is there for the development of The budgetary estimate (Capital cost) for acre land belongs to our trust. Out of 10 acres proposed Nargol port facilities. Based on the Environmental Management up to Phase 1A is INR (Residential of of this land, income is generated by coconuts detailed studies conducted it was concluded that 645.30 Crores. Nargol) and other crops. Our trust and Agyari depends existing roads with proper traffic management will This Includes Wastewater Management, Air on this income. Government is demanding 10 be sufficient to cater Phase 1 and 1A port traffic. No Pollution Control measures, Marine life protection acres from this land for road; I have come to Dedicated road corridor will be developed during out of oil spill, Other Pollution Control measures, oppose it. If the land is taken, our income will Phase 1 and Phase 1 A. Construction Phase Environmental Monitoring, stop then what will happen to our community? If Only the Rail line will be developed as a part of Green belt Development etc., the coast gets destroyed the question of Phase 1 and 1 A development and is being taken up drinking water will arise. Whole village will turn as a separate project. As the development of rail saline. Before 1200 years in Nargol, Ataf line doesn’t attract EIA notification, necessary Baheram Irashansha stayed for 600 hundred clearances from the relevant authorities such as years in Sanjan. Fishermen have been living in Department of Railways, etc., will be carried out. Nargol from the beginning. At that time the name of village was not known. Nargol name was given from Anargol (Pomegranate). We have been living here for 600 hundred years; Necessary shoreline changes studies were carried there is requirement of members of Parsi out as a part of CEIA and the mitigation measures community whereas you have come to take to protect the coast has been proposed, the details are addressed in the Replies to the query/concern land of our religion and trust. In one hand government promotes Parsi community Sr. No: 2. whereas on other hand you have come to The quality of the dredged material was analysed in acquire our trust land. An English medium terms of its toxic metals and found no significant school was opened in Nargol for the first time in concentration of toxic metals. The area proposed to 1908. 10 crore rupees has been given by be reclaimed during Phase 1 is in intertidal zone government to Udwada on the other hand want which is saline in nature. The slope of project site is to take land of Parsi for port. We want to help towards the sea and chances of intruding sea water Nargol. Therefore we strongly oppose it. into groundwater to be negligible. In addition, the area behind the berthing line is proposed to be reclaimed during Phase 1 A. Hence, no significant impacts are anticipated due to land reclamation on ground/ or nearby surface water. However as suggested in CEIA, the ground water quality monitoring will be carried out in and around the

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Sr. Name and The points represented Replies/ Commitment by CMPL Financial Commitment by CMPL No. Village villages. 00 Kanchanben Village people don’t have any information about Public Hearing was conducted by GPCB as per the the port you are going to build. So you provide procedure stipulated in the EIA Notification 2006 (as (Taluka true information about project and then organize amended). Umbergaon public hearing. Panchayat The details of the Project and its impacts are President) studied and the Draft Comprehensive EIA report was prepared along with necessary maps and Submitted to GPCB for Public Hearing. GPCB organised the Public Hearing near Microwave Tower, Nargol –Daman Road, Tadgam on 13.01.2016. The details of public hearing were advertised 30 days before in Indian Express (English) and Divya Baskar (Gujarati) and Sandesh (Gujarati) newspapers. The Complete documents are made available in the following Places. . The District Collector Office, Valsad . District Development Office, Valsad . District Industry Center, Valsad . Taluk Development office, Umargam . Regional Office, GPCB, Sarigam . The Chief Conservator of Forest, MoEF, Bhopal. Also the Executive Summary of Draft EIA in both English and Gujarati Languages are made available almost all the study area villages. In addition, all the documents were made available in GPCB website by GPCB. 02 Manvendra Many people came to India and did oppression Based on ’s Port Policy GMB - Kashyap and went. Gujarat has a coastline of 1600 km identified ten locations viz. Dholera, Vansi-Borsi, then why port only at Nargol? Shift the port at Hazira, Dahej,Mithivirdi, Simar, Positra, Rozi (Bedi) (Resident of other place. Develop other ports in Gujarat. We and Mundra as feasible for the development of new Nargol) do not need port at Nargol. Do something for ports, including one in Maroli, Valsad District. GMB development of fisheries wealth. Fishes are has identified the Maroli coastal stretch in Valsad for exported from here. Make a fishing port. development of an All Weather Port. In 1996, l:\ports\2012\c1121113 - eia for nargol port\outputs\reports\ec clarifications\ec clarfication 22.09.2017\annexure d - issue raised during ph.doc Page 36

Sr. Name and The points represented Replies/ Commitment by CMPL Financial Commitment by CMPL No. Village Develop farmers and animal husbandry. WAPCOS carried out a prefeasibility study to Provide employment to local people. There is ascertain the most desirable location for the Port; no need of any other port. We need tourism and near Maroli. The study considered the stretch near fishing port, we don’t need this port. There are Phansa, Saronda, and Umbergoan, near Nargol, four 20 year old jetties at Nargol Port which are apart from Maroli in Valsad District as alternative broken at present, there is need repair them. sites for development of an All Weather GIDC was established, people from outside Multipurpose Port. Based on the Analysis of came. People of cargo motors are sitting like Alternate Sites Nargol was found most suitable puppets. Not a single representative is considering Environmental, Technical and General discussing and nobody is speaking. Narendra Factors. This site with no mangroves and least Modi does chai pe charcha with one hundred social issues turns out to be most viable site. and twenty five thousand million people. Here

only fisheries port is required. Must carry out Chai pe charcha with people of Nargol. We do GMB awarded the "Letter of Intent" to Cargo Motors not want this Nargol Port. Private Limited (CMPL) along with Amaryllis Ltd - a subsidiary of Israel Port Development and Assets Company Limited (IPC) on August 30, 2012 to develop All weather Greenfield Multipurpose Port in Nargol on Build, Own, Operate and Transfer (BOOT) basis.

In the latest traffic study carried out by PWC in 2013, all the competing ports & their existing & upcoming handling capacity has been accounted for. As per the traffic report, even after the planned capacity expansion at these competing ports, there is good traffic potential at Nargol port. A summary of the detailed traffic study is given as Section 2.4 of Draft CEIA report. Honorable collector informed that your representations/objections will be sent to Government of India, Delhi through G.P.C.B., And decision for this port will be taken by Government of India. I or GPCB do not have authority to take decision about port after public hearing. Primary Socio-economic surveys among the 00 Dinesh Machhi We are doing business of fishing since 63 The cost associated with the mitigation measures fishermen were carried out by Former Principal years. Do not require filthiness. We get costly are provided in Query no. 3. (Resident of Scientist & Head, Crustacean Fisheries division fishes like paplet, boomla, golden fish, titana, Nargol) CMFRI, Kochi. The findings of the study are dado. This port will steal our fishery business. It provided in the Section 4.8 of DCEIA report. The will also raise a question on our livelihood. impact on fishing and mitigations measures are Because of that that we oppose this port.

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Sr. Name and The points represented Replies/ Commitment by CMPL Financial Commitment by CMPL No. Village provided in Section 5.9.1.2 and 7.6.1.3 of DCEIA We are hearing since last 17 years about report. Port development will be on intertidal area development of fishing port here, but till date no and berthing line and breakwater in between 13 m fishing port has come up. Not once but 17 times to 15 m water depth. Majority of the fishing activity we have said that we do not need a port. in the study area is observed beyond these depths. People are having power in democracy but not Also as reported through the primary surveys, the government. Our livelihood will be snatched fishing grounds are also beyond this area. The then intestine will strive (“Aatardi Kakadse”). approach trestle is planned in such a way that any And nothing good will happen in life. “Mit one span of the trestle shall have minimum Marenge Mar Jayenge Bandar Nahi Babane clearance of 7 m above the High Water Level with Denge” (We will die but we will not allow build a 20 m width for movement of fishing vessels. No port) “Humko Mita Sake woh Sarakar Mein Dum restriction to Sea will be ensured by putting up Nahi, Sarakar Humse Hain Hum Sarakar se signboards at the place of construction activities in Nahi” (Government has no power to destroy us, order to make fishermen aware of the ongoing Government is there because of us, not are we activities and necessary marker buoys will be for government.) “Hum Jhukenge Nahi, Bandar installed. In addition, all the mitigation measures as Hatake Rahenge.” (We will not steep, will suggested in the CEIA will be followed for various remove port) activities. The impacts and mitigation measures for fisheries has also provided in the reply to Public Hearing Query No: 3. 23 Magan Dakle We oppose the port. But, everyone present here - - (Kinara Bachao has a right to speak. Whosoever wants to Samiti) speak in support of the port can come here and speak. 24 Kosva Varazvan My native is Nargol, Honorable Collector you - - (Resident of are also District Magistrate then also you are Nargol) not allowing outside NGO advisor. We have already shown you the High Court order then also you have not allowed. This is contempt of Court. My son is a lawyer and I will convince him to file PIL and you Honorable collector will be punished.

25 Jayeshbhai Baria On 4/1/2016, in our gram Sabha we have - - (NargolSarpanch) unanimously decided that Mr. Shaikh

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Sr. Name and The points represented Replies/ Commitment by CMPL Financial Commitment by CMPL No. Village (Environmentalist) will represent for us in the public hearing. After representation by people Honorable Collector asked company This statement had been wrongly interpreted in the - representatives to reply to queries raised by people. Company representative Minutes of Meeting (MoM) released by GPCB, Mr. Tarang Fajalia (Senior Executive) , replied that total 171 Sarigam. It has been confirmed with the Public Hectare of Land will be reclaimed. 143.5 hectare will be in intertidal zone. Hearing video recording that statement given by the There will be no impact on the shore. In phase IA, Reclamation of 28 hectare representative of the Project Proponent is as will be done inside behind berth by using the whole dredging materials for follows. making containment bunds, so that soil doesn’t spread elsewhere. Only "Railway is not in relation of this public hearing existing road will be used, no new road is to be built. Care will be taken that for Nargol Port Project, necessary surveys are in no damage is caused to the environmental wealth due to the work. There is progress.” As you told about ToR, that railway is no proposed railway planned in Phase 1.When railway is required in phase mentioned in ToR. Here I am talking about ToR IA, it will be developed by taking necessary clearances from concerned Amendment, dated 14th August, 2015. And you department. There is mention of railway in TOR but representatives informed can see in point No. 4 that “Only the rail line will that ToR is amended and Rail connectivity is not mentioned in that. Honorable be developed in phase 1 and 1A development Collector requested company to reply in Gujarati to everybody. and associated studies are in progress. As the development of rail line doesn’t attract EIA notification, necessary clearances from the relevant authorities such as Department of Railways.” Letters have been submitted to the Collector, GPCB Gandhinagar and GPCB Sarigam requesting them to provide guidance for making corrections in the MoM of Public Hearing. The copies of the letters are given in Volume II (Public Hearing Document). 26 Manish Baria We request you sir, we don’t want to -- understand anything, hence we don’t need to (Resident of listen explanation of Cargo Motors Nargol) 27 Yatin Bhandari, Request was made to Honorable collector, as -- - Rakesh Rai& the EIA report is difficult for us and other village others people to understand. It is a request to allow Mr. M. S. Shaikh as our representative to make Nargol representation on behalf of us. Honorable collector informed that we have gathered here for you. We are meeting on auspicious day of Sankranti. Representation of all approximately 23 people has been done, everything is being recorded and we will not take any decision here. You have emotions that port is required or not required, we will send to Government of India through GPCB. I assume that all the l:\ports\2012\c1121113 - eia for nargol port\outputs\reports\ec clarifications\ec clarfication 22.09.2017\annexure d - issue raised during ph.doc Page 39

Sr. Name and The points represented Replies/ Commitment by CMPL Financial Commitment by CMPL No. Village aspects of local people are over. All and Sarpanchs have emotions to allow Mr. Shaikh to speak, but what new will Mr. Shaikh add? Sarpanch of Maroli informed that we are informing Mr. Shaikh to make representation because our fishermen families are illiterate. They are without education. Therefore they are not able to speak. I am literate, so I can speak. Therefore Mr. Shaikh will speak on behalf of all of us. Collector informed that I did not expect such a sharp representation by you, yet, giving respect to the feelings of 4000 people, Mr. Shaikh will speak for five minutes and then public hearing will end. All have feelings that government is for public. Public Hearing has almost ended, I am giving five minutes to Mr. Shaikh, say do you agree? After representation of Mr. M. S. Shaikh, public hearing will be declared as over. Logistic Support Building (LBS), sub-station, 28 M. S. H Shaikh, The company wants to acquire forest land for The following financial commitment given by PP for customs building, water reservoirs etc are planned NGO, Surat their office. In case land is required, first the Environmental Management: on onshore land. Considering various factors such government land and then private land should as resettlement & rehabilitation, CRZ area, common  Greenbelt development – INR 2 Crores be possessed and if not available then only property resources (CPR) etc, a forest land of 4ha  Wastewater Management (Sewage Treatment forest land should be used. It is mentioned in has been chosen. The same is provided in the your EIA report that there isn’t any government Plant & Drainage & Sewerage system/Storm Section 2.3.1, 5.2.1.1 and 7.6.1.1 of the CEIA or private land in Nargol. Water System) – INR 30 Crores report. Necessary application for diversion of forest Village has government and private land, then land to non-forest purpose (development of LSB) is  Air Pollution Control (Dust Sweeper, Installation why forest land is demanded? How has this already submitted and the same is being scrutinized of sprinkler system, Covered system for Coal application reached Gandhinagar without at the Deputy Conservator of Forest (DCF), Valsad Storage, Wind barriers, Dust resolution of Gram Sabha? Cargo Motors says Forest Office. All the necessary procedures will be Suppression/Water sprinkling during that this land doesn’t come in Scheduled area, adhered by CMPL. Construction Phase, Conveyor Belt System the same should be investigated. If GMB can show details of other ports such as Pipavav, with Hood, Conveyor Belt System in stackyard, In the latest traffic study carried out by PWC in Hajira, JNPT and others and also their Wagon loading system & Wagon loading 2013, all the competing ports & their existing & expansion details, the ports falling in 90km such upcoming handling capacity has been accounted hopper-1500 T capacity) – INR 585.63 Crores as Hazira and Adani port can also be shown. for. As per the traffic report, even after the planned  Other Pollution Control Measures (Oil Water GMB port also brings coal, one is being capacity expansion at these competing ports, there Separator, Settling pond at Coal Stockyard, developed of 300 hectares in Hazira, then why is good traffic potential at Nargol port. A summary of is Nargol Port is called? This port will be built in etc.) – INR 9.0 Crores the detailed traffic study is given as Section 2.4 of deep sea, therefore dredging will be required,  Marine Life Protection out of Oil Spill (One Draft CEIA report. and if it is done, water current will change and tugboat with booms and skimmer and dust fishing will come to an end. Due to erosion, sea exhausting equipment) – INR 10.13 Crores will have erosion and there is probability that The proposed Nargol port marine facilities such as Varoli river mouth may be blocked. The data  Environmental Monitoring during Construction breakwaters are about 6.1 km away from the given in EIA report are of only one year in fact, Phase (Both marine & terrestrial environment) shoreline. Detailed Hydrodynamic studies were data of 15 to 20 years should be given, which carried as a part of CEIA study and presented in the – INR 4.54 Crores are not provided. TOR has railway line but you report. The following are the observations made from  EMC Running Expenditure – 0.15 Crores/year have not given any information, regarding it. the study:  Greenbelt Maintenance – INR 0.2 Crores/year How will you do land acquisition, at market rate or government rate? The company  Maintenance of Dust Sweepers – INR 0.3 manufacturing motor cars is going to built port, . Current in the region is mainly tide driven. Crores/year indeed, the activity of making port should be Effect of wind on current was found l:\ports\2012\c1121113 - eia for nargol port\outputs\reports\ec clarifications\ec clarfication 22.09.2017\annexure d - issue raised during ph.doc Page 40

Sr. Name and The points represented Replies/ Commitment by CMPL Financial Commitment by CMPL No. Village given to an experienced company and Israel negligible. Direction of currents is towards  Maintenance of Air Pollution Control Measures Company associated with Cargo motors has north during flood tide and reverses during – INR 0.2 Crores/year also moved as per report I have received. In ebb tide. A maximum current speed of 1.6 past black dust from other ports such as Dahej, m/s was observed at 10m contour off  Dust Suppression/ Water Sprinkling – INR 0.05 used to spread, the same will also happen here Nargol coast during flood of spring tide and Crores/year in future.For Dahej, High Court case was filed. is in the order of 1.2 m/s during ebb.  Statutory Compliance for Environment Fisherman is opposing the port. So no banks Periodic wetting and drying of seabed can Protection (Environmental Monitoring) – INR are giving loan to Fisherman As per EIA report, be seen for up to a distance of around 1km 1.29 Crores/year 20 thousand fishermen are affected. The from coast.. boomla of this area are famous, which is However, restricting the flow completely in the exported in other countries. If coal dust is leeward side of port may lead to stagnation of water spread on boomla, due to sticky skin nature the in this area and can cause high current speed in the dust cannot be removed. And its export to other seaside of port and across the channel. This in turn countries will come to an end. 20 lakh MTPA may cause changes in shoreline of nearby area. dredging will be done and the sea area where Thus an alternate approach was adapted by dredging material will be disposed contains providing trestle instead of approach bund to rocks where large quantities of lobsters are allow free flow of water in the leeward side of present. The cavities will be filled so breeding port. Moreover, the alignment of breakwater was will not occur hence lobster will not get. .They also optimized to minimize the variations in will also be destroyed. In EIA report, you say hydrodynamic conditions in the surrounding. that there will be no waste water, but as per Various layout options were studied for suitability MARPOL act, when cargo chemicals arrive, and also considering future phases of development before filling other material in them wont you of port. Effect of various layout options on the need to wash the cargo? During handling of current pattern in the study area was tested and liquid cargo it is needed to be washed. There is layout Phase 1 and Phase 1 A was found to be no mention of treatment plant (ETP) for it. You causing the minimum variation in natural are responsible for liquid waste. Will activity of hydrodynamic condition and accordingly finalized. cargo washing by representative of company not be carried out? Instead of port, tourism from Daman to Umbergam Nargol should be Necessary study was already made to analyze the developed. The Jetty got broken 15 years shoreline changes due to Nargol Port development earlier. All other places jetty has came-up, only covering both erosion and accretion aspects as a Umargam is remaining. The government is not part of CEIA and , it was observed that erosion takes repairing it and they should also provide ice place over a stretch 3.8 km towards north of plants for fishermen. The fisheries survey proposed reclaimed area of port and 0.9 km of carried out in EIA is performed very well, for accretion towards south of proposed reclaimed area which I thank you. But, there isn’t any survey of of port. The average rate of erosion is 4m/year loss to fisherman due to port. As per EIA, 3 lakh adjacent to the north of proposed reclaimed area and ton Rubbles (Ruff stones) will be brought from accretion at rate of 1.4m/year adjacent to the south of l:\ports\2012\c1121113 - eia for nargol port\outputs\reports\ec clarifications\ec clarfication 22.09.2017\annexure d - issue raised during ph.doc Page 41

Sr. Name and The points represented Replies/ Commitment by CMPL Financial Commitment by CMPL No. Village quarry and filled to save forest, but what about proposed reclaimed area. The rate of accretion and the destruction due to cavity of land made to erosion has reducing trend alongshore on either side obtain for this rubble? And what will be its of the proposed reclaimed area of port. Appropriate environment effects. There are so many ports mitigation measures were suggested in the CEIA such as Birla jetty, ONGC (OPAL) and LNT report to protect the shoreline. They are, jetty, shell terminal, etc. which are being . Continuous monitoring of shoreline with operated in spare capacity. We are thinking that the help of high resolution satellite destruction doesn’t happen in other area. imageries during operation phase Therefore, this Nargol port is economically not . Based on the monitoring results, viable and is not sustainable. Therefore, appropriate techniques such as sand permission should not be given to this port. bypassing from accreting area to eroding area, as appropriate shall be carried out to maintain the stability of coast . Based on the monitoring results, the sand trap may be created where the high accretion is observed . Dredging of the area to be accreted/ sand trap shall be carried out regularly (as a part of maintenance dredging) and the material shall be used for maintaining the eroding coastal stretch, if observed. The excess/unusable material shall be disposed at the identified offshore disposal location

The Comprehensive EIA/EMP Studies have been carried out as per the EIA Notification 2006 (as amended) for the development of Nargol Port. All the impacts associated with construction and operation phases on all the environmental (Terrestrial/ Marine) and social parameters have been studied and appropriate mitigation measures were proposed for sustainable development

Development of Rail corridor is being taken up as a separate project. As the development of rail line doesn’t attract EIA notification, necessary clearances from the relevant authorities such as Department of Railways etc., will be carried out. The l:\ports\2012\c1121113 - eia for nargol port\outputs\reports\ec clarifications\ec clarfication 22.09.2017\annexure d - issue raised during ph.doc Page 42

Sr. Name and The points represented Replies/ Commitment by CMPL Financial Commitment by CMPL No. Village same was communicated to MoEF&CC through updated Form 1 during ToR validity extension application and accordingly mentioned in the ToR validity extension letter (given as a part of Draft CEIA report).

The consortium of CMPL & Amarillis (Israli company) Ltd. has won the bid to develop Nargol port as per the BOOT policy of GMB & GoG. The consortium has fulfilled all the technical & financial criteria set by GMB & GoG during the pre- qualification stage of the Nargol port bid. As per the joint bidding agreement CMPL is the lead promoter of the consortium and is responsible for taking all the necessary clearances for the project on behalf of consortium. As per the requirement of GMB, after taking the EC & financial closure of the project, a SPV shall be formed for signing the concession agreement with GMB & GoG.

Fugitive emissions from coal heaps and other areas will be prevented by providing Longitudinal Covered shed type coal stockyard; Ultrasonic dust suppression system‘ at ship unloaders, transfer points, stockyard, loading system etc., 1.5 km long wind barrier; transportation through covered conveyors from coal berth to the stockyard; covered transfer points; Wagon loader for train loading and silos arrangement for truck loading; Trucks before leaving the loading area shall be covered with tarpaulin and also the railway wagons; Trucks Tyres and areas susceptible for coal dust before leaving premises shall be cleansed washed to remove coal particles; greenbelt development around the coal stockyard and above all adherence to the coal handling guidelines given by GPCB. All these measures are provided in the Draft CEIA report. l:\ports\2012\c1121113 - eia for nargol port\outputs\reports\ec clarifications\ec clarfication 22.09.2017\annexure d - issue raised during ph.doc Page 43

Sr. Name and The points represented Replies/ Commitment by CMPL Financial Commitment by CMPL No. Village

Based on the marine monitoring and NHO chart there are no rocky patches reported in the disposal area. However, Sed Bed Characteristics surveys shall be carried out before disposal. In addition the material to be dredged are Soft Clay/Silt, Stiff Clay, Sand/Gravel and Weathered Rock in nature. The details are given in Section 2.7.10 of CEIA report. There is no Hard Rock Blasting/Dredging is envisaged.

Ships/vessels calling at Nargol Port will not be permitted to dump the wastes /bilge water during the berthing period. Also, Hold washing will not be permitted in the port complex and MARPOL regulations will be implemented. However, during emergency, the reception facilities will be provided. The collected wastewater will be sent to the treatment plants within the port for treatment and the treated wastewater will be reused for the application of green belt. Or the bilge water will be collected by authorized waste recyclers and taken for further treatment. The relevant information about the bilge water is provided in Sections 2.7.24.3, 5.4.3.1 and 5.5.3.1 of Draft CEIA.

Breakwater Stones/ Construction materials will be sourced from approved quarries as identified in the CEIA report. 29 Shweta Bhatt Shweta Bhatt tried to represent. Writ-petition The written queries of Ms. Shweta Bhatt received - judgment has been shown to you. And public from GPCB were addressed and Submitted. (NGO, Mumbai) hearing can continue for two to three days, therefore we should be given chance to speak.

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Sr. Name and The points represented Replies/ Commitment by CMPL Financial Commitment by CMPL No. Village Honorable Collector sir informed her that only locals can represent orally. So, you cannot. If you want to then you can give it in writing. 30 Krishnakant Points of EIA report should be heard. In interest -- - Chauhan, Baroda of justice and environment, all points should be heard. Honorable Collector sir informed them that only locals can represent orally. So, you cannot. If you want to then you can give it in writing. 31 Yatin Sheth From this area, any one wants to speak in favor -- - of port, he can speak. Till now nobody has Phansa come, therefore we have strongly opposed the port. Primary Socio-economic surveys among the 32 Chairman Shree, Society has been registered in 1959 and is the The cost associated with the mitigation measures fishermen were carried out by Former Principal Fishermen oldest. Where the port is to be built, is fishing are provided in Query no. 3. Scientist & Head, Crustacean Fisheries division Society, ground. Ropes worth crore rupees are lying CMFRI, Kochi. The findings of the study are Umbergam there; a net are tied there and catches fishes. provided in the Section 4.8 of DCEIA report. The This is fishing zone. Fish of different kinds are impact on fishing and mitigations measures are exported from here, our fishermen run livelihood provided in Section 5.9.1.2 and 7.6.1.3 of DCEIA from it. We have strong opposition of port. report. Port development will be on intertidal area and berthing line and breakwater in between 13 m to 15 m water depth. Majority of the fishing activity in the study area is observed beyond these depths. Also as reported through the primary surveys, the fishing grounds are also beyond this area. The approach trestle is planned in such a way that any one span of the trestle shall have minimum clearance of 7 m above the High Water Level with 20 m width for movement of fishing vessels. No restriction to Sea will be ensured by putting up signboards at the place of construction activities in order to make fishermen aware of the ongoing activities and necessary marker buoys will be installed. In addition, all the mitigation measures as suggested in the CEIA will be followed for various activities. The impacts and mitigation measures for fisheries has also provided in the reply to Public Hearing Query No: 3. l:\ports\2012\c1121113 - eia for nargol port\outputs\reports\ec clarifications\ec clarfication 22.09.2017\annexure d - issue raised during ph.doc Page 45 Appendix E Replies to the Complaint made by Conservation Action Trust (CAT)

Annexure E. Replies to Conservation Action Trust S. No. CAT Comments CMPL Replies Replies to the mail dated Mon, August 21, 2107 at 4:15 PM We had earlier sent our submissions to you vide email dated 20.05.2016. Please find same in 1. - the mail trail CMPL has followed the requirement EIA Notification 2006 ( as amended) and CRZ Notification 2011 ( as amended) such as Form1 and ToR Approval from MoEF&CC, EIA preparation by Reputed accredited Consultant, Public Hearing, Coastal Zone Management Authority approval etc., The Comprehensive EIA/Studies have been carried out for the development of 2. At the outset, we request the authority to reject this proposal Nargol Port. Probable impacts associated with construction and operation phases on all the environmental (Terrestrial/ Marine) and social parameters have been studied and appropriate mitigation measures were proposed for sustainable development. Therefore, the request of Conservation Action Trust to reject the proposal not to be considered. Total land requirement for Phase 1 and Phase 1A development is about 175.5 Ha. It is proposed to develop most of the Port facilities of Phase 1 and Phase 1 A in the reclaimed land (behind berthing Line and in inter tidal area) as 3. This project will lead to reclamation of 171.5 hectares of the coastal area suggested by GMB. An area of 171.5 Ha of land requirement is estimated for Phase 1 and Phase 1 A development except for LSB Complex (4.0 Ha will be onshore forest land). The CEIA report is prepared for the Phase 1 and Phase 1A of Nargol Port The present proposal is only for Phase I and IA. The piecemealing of the project will lead to Development as per approved ToR. Future Phases or Master Plan 4. fragmentation of the existing ecosystem and will be detrimental to the environment. development stage or during expansion stage, separate application will be made and impacts will be studied in entirety. The proposed port activities are sufficiently away from the Varoli River 5. Furthermore, the project is proposed in the vicinity of the mangroves of the area mangroves and Mangroves in the study area. Impacts on mangroves are studied and details are provided in Section 5.5.1.2 of Chapter 5 CEIA Report. The conditions of the GCZMA vide dated 15.10.2016 clearly states that "4. No dredging, reclamation or any other project related activities shall be carried out in the CRZ area categorized as CRZ I (A) and it shall have to be ensured that the mangrove habitats Undertaking is being submitted along with the Clarifications on Additional and other ecologically important and significant areas, if any, in the region are not affected due 6. information sought by MoEF&CC during Minutes of the 21st Meeting of Expert to any of the project activities. Appraisal Committee (Infra-2). 5. The CMPL shall ensure that there shall be no damage to the existing mangrove patches near the site and also ensure the free flow of water should not be obstructed to avoid damage to the mangrove." l:\ports\2012\c1121113 - eia for nargol port\outputs\reports\ec clarifications\ec clarfication 22.09.2017\annexure e - replies to cat.doc Page 1

S. No. CAT Comments CMPL Replies In the event the proposal is granted clearance, we request the authority to direct the project proponent to give an undertaking with respect to the aforementioned conditions. CMPL has followed the requirement EIA Notification 2006 ( as amended) and CRZ Notification 2011 ( as amended) such as Form1 and ToR Approval from MoEF&CC, EIA preparation by Reputed accredited Consultant, Public Hearing, The GCZMA minutes clearly states that 'The Authority was further apprised that during public Coastal Zone Management Authority approval etc., hearing and technical committee visit, huge opposition was observed from the local people 7. against this project" The Comprehensive EIA/Studies have been carried out for the development of It is not clear that why despite such opposition the GCZMA has recommended the proposal. Nargol Port. Probable impacts associated with construction and operation phases on all the environmental (Terrestrial/ Marine) and social parameters have been studied and appropriate mitigation measures were proposed for sustainable development. The GCZMA minutes also state that "As per the CRZ maps prepared by the Institute of Remote Sensing, the proposed activities fall within CRZ-I(B), CRZ-III and CRZ-IV(A) category." No CRZ I(A) area is reported for the area proposed for Nargol Port 8. The project area however envisages reclamation of the mudflats and also roads and railways Development as per the CRZ map prepared by MoEF&CC Authorized agency in the mudflats. Mudflats are classified under CRZ I [A] as per the CRZ notification. Hence, the proposal should not be allowed. Total land requirement for Phase 1 and Phase 1A development is about 175.5 The proposal is of "initial development in Two Phases (Phase 1 and Phase 1A), development Ha. It is proposed to develop most of the Port facilities of Phase 1 and Phase of Breakwaters/Navigational requirements/ Dredging/ Reclamation / Backup area etc." 1 A in the reclaimed land (behind berthing Line and in inter tidal area) as As per the GCZMA minutes, there would be requirement of land of 143.5 hectares for suggested by GMB. An area of 171.5 Ha of land requirement is estimated for reclamation and onshore Forests Land of 4 hectares for Phase I and additional 28 hectares Phase 1 and Phase 1 A development except for LSB Complex (4.0 Ha will be 9. reclamation land for Phase-IA. Whereas other documents by the project proponent state that onshore forest land). the land requirement is of 17.5 hectares of which reclamation would be of 171.5 hectares. The project proponent may be asked to clarify about the actual reclamation area and to explain why As the development is proposed in Phases, about 143.5 Ha is proposed to be two separate figures are given, which is misleading. reclaimed during Phase 1 and addtional 28 ha is proposed to be reclaimed during Phase 1A. The Environment Appraisal Questionnaire / Comprehensive EIA report shows that the construction phase of the project is likely to provide an employment for 1500-2000 personnel on direct basis and around 5000 on indirect basis and during operational phase, the port is The direct employment will be on the basis of technical skills and CMPL likely to generate employment of 200- 300 people on direct and around 2500-3000 on indirect 10. recruitment policy whereas indirect employment will be based on requirement basis. of workers in supply of raw material, auxiliary and ancillary works. It is not clear if the employment would be for local and whether it would be of temporary or permanent in nature. The project proponent may please be directed to explain this. Map on page 133 of the Environment Appraisal Questionnaire / Comprehensive EIA report As per CRZ map prepared by MoEF&CC authorized agency, no mud Flats 11. shows the proposed rail through inter-tidal area which is mudflats. are reported. The intertidal area has been classified as CRZ I (B). The map of the eco-sensitive areas on page 135 of the Environment Appraisal Questionnaire / The HTL/LTL and CRZ Demarcation map given in Comprehensive EIA/ EMP 12. Comprehensive EIA report fails to show presence of mangroves in the area. clearly demarcates mangroves in the area as Figure FD0204. The HTL/LTL l:\ports\2012\c1121113 - eia for nargol port\outputs\reports\ec clarifications\ec clarfication 22.09.2017\annexure e - replies to cat.doc Page 2

S. No. CAT Comments CMPL Replies and CRZ Demarcation report along with the map is also uploaded on The project proponent in its EIA report also fails to mention the presence of mangroves under 13. MoEF&CC website and hard copy of the same is submitted as a part of the Ecologically sensitive areas. additional documents. Sand will be sourced from where the sandy material has been identified during the geotechnical survey. Based on the geotechnical investigation, required With regards to the reclamation, the EIA report mentions that "Use of Dredged materials and quantity of sand is available in south of the inner channel and some portions in over dredging for additional quantity and materials from land side such as Quarry overburden 14. north of channel between (-) 13.0 m CD to (-) 14.0 m CD contour. The same is from land" will be used given in Section 2.7.10 of Chapter 2 of Comprehensive EIA/EMP report. Also, The project proponent has failed to clarify from where it will source the sand. the details of the identified quarries and access route to the project site are given in Section 5.2.2.1 of Chapter 5 of CEIA/EMP report. Necessary study was already made to analyze the shoreline changes due to Nargol Port development covering both erosion and accretion aspects as a part of CEIA and it was observed that erosion takes place over a stretch of 3.8 km towards north of proposed reclaimed area of port and 0.9 km of accretion towards south of proposed reclaimed area of port. The average rate of erosion is 4m/year adjacent to the north of proposed reclaimed area and accretion at rate of 1.4m/year adjacent to the south of proposed reclaimed area. The rate of accretion and erosion has reducing trend alongshore on either side of the proposed reclaimed area of port. Appropriate mitigation measures were suggested in the CEIA report to protect the shoreline. They are, . Continuous monitoring of shoreline with the help of high resolution satellite imageries during operation phase . Based on the monitoring results, appropriate techniques such as The EIA report also mentions that it is proposed to make use of containment bunds /dikes, geo sand bypassing from accreting area to eroding area, as appropriate 15. bags, etc. I say that this will lead to alteration of the existing shoreline and change the existing shall be carried out to maintain the stability of coast HTL. Furthermore, the reclamation could eventually lead to flooding in the area. . Based on the monitoring results, the sand trap may be created where the high accretion is observed . Dredging of the area to be accreted/ sand trap shall be carried out regularly (as a part of maintenance dredging) and the material shall be used for maintaining the eroding coastal stretch, if observed. The excess/unusable material shall be disposed at the identified offshore disposal location The proposed Nargol port marine facilities such as breakwaters are about 6.1 km away from the shoreline. Detailed Hydrodynamic studies were carried as a part of CEIA study and presented in the report. The following are the observations made from the study: . Current in the region is mainly tide driven. Effect of wind on current was found negligible. Direction of currents is towards north during flood tide and reverses during ebb tide. A maximum current speed of

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S. No. CAT Comments CMPL Replies 1.6 m/s was observed at 10m contour off Nargol coast during flood of spring tide and is in the order of 1.2 m/s during ebb. Periodic wetting and drying of seabed can be seen for up to a distance of around 1km from coast. . However, restricting the flow completely in the leeward side of port may lead to stagnation of water in this area and can cause high current speed in the seaside of port and across the channel. This in turn may cause changes in shoreline of nearby area. Thus an alternate approach was adapted by providing trestle instead of approach bund to allow free flow of water in the leeward side of port. Moreover, the alignment of breakwater was also optimized to minimise the variations in hydrodynamic conditions in the surrounding. Various layout options were studied for suitability and also considering future phases of development of port. Effect of various layout options on the current pattern in the study area was tested and layout Phase 1 and Phase 1 A was found to be causing the minimum variation in natural hydrodynamic condition and accordingly finalized. The total water availability in the Varoli River is around 187.50 MLD and water The proposal envisages water requirement of 1442 m3/day for Phase-I and 2296 m3/day for allotted for domestic purpose is around 0.25 MLD as Confirmed by WRD. No 16. Phase-lA, to be sourced from Tokar River/nearby local suppliers. It is not clear if permissions other usage is reported. CMPL is in the process of taking permission from the for withdrawal of water from River have been granted to the project proponent. authority. Current in the region is mainly tide driven. Effect of wind on current was found negligible. Direction of currents is towards north during flood tide and reverses during ebb tide. A maximum current speed of 1.6 m/s was observed at 10m The proposal also envisages following activities contour off Nargol coast during flood of spring tide and is in the order of 1.2  Berths: Phase-1- 3 Nos, Phase-IA-3 Nos (Total 6 nos) m/s during ebb. Periodic wetting and drying of seabed can be seen for up to a  Breakwaters: North Western -3650m; Southern -500m, distance of around 1km from coast.  Turning Circle: 800 m Dia. Current speed was found to be increasing due to the introduction of port  Approach Channel: Outer layout in the model. Effect of various layout options on the current pattern in 17.  Approach from berthing line to reclaimed land: 3600m the study area was tested and layouts causing the minimum variation in  Railway track and other service line on approach trestle natural hydrodynamic condition have been selected. The selected layouts  Capital Dredging: Phase-I-16.54 MCM, Phase-IA- 13.65 MCM were then adopted for further studies to ensure required tranquillity inside port  Maintenance Dredging: Phase-I- 2.1MCM , Phase-IA-2.65 MCM basin and minimum downtime of port. The breakwaters will alter the natural flow of tidal water/waves. This would lead to erosion in the area and change the geomorphology of the coastline. As per the sediment transport study, It was observed that significant amount of deposition along the breakwater and proposed bund between shoreline and proposed port. From the simulation that both erosion and accretion can be anticipated along the channel due to variation in the water depth. Moreover,

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S. No. CAT Comments CMPL Replies significant amount of deposition was observed on the lee side of the northern side of north breakwater.

The areas along the shorelines on either side of the proposed port show insignificant variation in the sediment transport pattern. An annual maintenance dredging of 2.1 MCM can be anticipated for Phase 1 and 2.65 MCM for Phase 1A.

All the above modelling studies have been discussed in Section 5.4 of Chapter 5 of CEIA/EMP report and necessary mitigation measures were suggested. Dredged material generated during approach channel creation will be used for 18. It is not clear where the material for the approach channel will be sourced. reclamation and excess material if any shall be disposed at the identified disposal site. Suitable disposal ground was identified at water depth greater than 20 m to 25 m with a spatial extent of 4 km x 7 km. The details and the coordinates of the 19. The dumping sites for the capital and maintenance dredging are not clear. dumping location are given in Section 5.4.2.1 of Chapter 5 of CEIA/EMP report. It was submitted by the representative of CMPL that none of the plant species recorded from The proposed port activities are sufficiently away from the Varoli River the core area belongs to the Rare/Endangered/Endemic /Threatened category. Few scattered mangroves and Mangroves in the study area. Impacts on mangroves are mangroves patches were observed in and along banks of Varoli river. Ecologically Sensitive studied and details are provided in Section 5.5.1.2 of Chapter 5 CEIA Report. Areas were not found within 10km radius of the project site. The HTL/LTL and CRZ Demarcation map given in Comprehensive EIA/ EMP 20. Mangroves and mudflats are ecologically sensitive and geomorphologically important areas clearly demarcates mangroves in the area. The HTL/LTL and CRZ and are classified as CRZ I [A] as per the CRZ Notification. The project proponent has failed to Demarcation report along with the map is also uploaded on MoEF&CC disclose this before the authorities. website and hard copy of the same is submitted as a part of additional We reiterate as stated in our earlier comments that 2 of the mangrove species in the state of documents. Gujarat are found only in this area. There are no declared sea turtle nesting sites in the area proposed for Port development. No turtle nesting reported at the project site during the field The project proponent has also furnished incomplete and misleading information regarding survey also. presence of sea turtles in the area. The project proponent may please be directed to conduct a 21. It was reported that the entire south Gujarat especially Valsad district has very detailed study in the nesting season. The findings of same should be made available on the limited potential / insignificant for sea turtle nesting (Sunderraj et. al (2002)). Ministry's website. Added to that there are casuarinas groves all along the coast of Nargol which make the beach unsuitable for sea turtle nesting The following has already been proposed for the Wastewater Management at In the event the proposal is granted, the project proponent should be directed to treat the the proposed Nargol port: 22. waste water and the effluents upto tertiary level. Zero discharge policy should be employed by  65 KLD STP is proposed on modular basis the project proponent.  20 KLD Oil Water separator on modular basis

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S. No. CAT Comments CMPL Replies  The water used for dust suppression in the conveyor transfer points and the stockyards will get absorbed to the extent of the property of the material and remaining water will be collected through proper drainage  Storm water management Coal is one of the items be transported and stored under the proposed project. The storage The impact on air environment due to the operation of Nargol Port has been and transportation of coal will lead to immense air pollution in the area. The coal dust will predicted based on air quality modelling studies. The AAQ model studies impact the mangroves, the biodiversity the fishes Varoli is a fishing area and has fishermen covered the following: 23. colony/colonies].  Point sources i.e. Emissions from Ships/Vessels during Berthing The increase in vehicular traffic and transport of cargo like coal, etc., would be further  Area Source i.e. Coal Stockyard for Particulate Matter (PM) detrimental and would impact the health of the residents. The project proponent has failed to  Line source from increased vehicular activity on Five (05) Port access take into consideration the existing pollution whilst proposing the project roads such as SH 185, SH 29, SH 5A, CSH and MDR  Volume Sources such as transfer points on the coal conveyer system, (Un)loading points at coal berths, at trucks loading and train loading areas The 1st highest 24 Hour average and annual average Resultant Concentrations (Incremental Concentrations due to the Proposed Project + Baseline Concentrations due to Existing Levels) of NOX, PM10, PM2.5 and SO2 at all receptor locations are found to be well within the National Ambient Air Quality Standards (NAAQS), 2009.

Measures to reduce Air Pollution are as follows:  Covered Coal Storages  Wind Barrier It was observed during the public hearing that the locals are already aggrieved due to the  Covered Conveyor 24. pollution in the nearby industrial areas. The transportation would increase the movement of  Dust Suppression System at stockyard, Transfer towers, at trucks leading to further augmentation in the air pollution. berth/Unloaders, at wagon loading, at Truck loading Silos, Discharge and feeding points of Conveyors etc.  Use of Specialised Unloaders  Proper house keeping  Trucks before leaving the loading area shall be covered with tarpaulin and also the railway wagons  Trucks Tyres and areas susceptible for coal dust before leaving premises shall be cleansed washed to remove coal particles.  Greenbelt

The details of the Air Quality Modelling Studies are discussed in Section 5.6.2 of Chapter 5 of CEIA/EMP report. 25. As stated in the GCZMA minutes, the representative of the CMPL has submitted that due to Shoreline Changes model Study for the Erosion/Accretion has been carried

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S. No. CAT Comments CMPL Replies proposed project, erosion would take place out and same has been discussed in Section 5.2.3.4 of Chapter 5 of CEIA/EMP report.

From the model study it is observed that erosion takes place over a stretch 3.8 km towards north of proposed reclaimed area of port and 0.9 km of accretion towards south of proposed reclaimed area of port. Also, simulated result from the model indicates erosion at the average rate of 4 m/year adjacent to the north of proposed Port and accretion at rate of 1.4 m/year adjacent to the south of proposed port. The rate of accretion and erosion has reducing trend alongshore on either side of the proposed reclaimed area of port. Based on the analysis of the results, it is noticed that the rate of shoreline evolution decreases over the years.

Necessary mitigation measures were also suggested such as follows:  Continuous monitoring of shoreline with the help of high resolution satellite imageries during operation phase  Based on the monitoring results, appropriate techniques such as sand bypassing from accreting area to eroding area, as appropriate shall be carried out to maintain the stability of coast  Based on the monitoring results, the sand trap may be created where the high accretion is observed  Dredging of the area to be accreted/ sand trap shall be carried out regularly (as a part of maintenance dredging) and the material shall be used for maintaining the eroding coastal stretch, if observed. The excess/unusable material shall be disposed at the identified offshore disposal location. Baseline data was generated including air quality for the area towards north of the project site where the existing industries emission were accounted. The same was utilized in the air quality modeling as discussed in point no. 23 & 24 to calculate the Resultant Concentrations (Incremental Concentrations The project proponent has also failed to provide with a Cumulative Impact Assessment report. due to the Proposed Project + Baseline Concentrations due to Existing 26. The air quality of area north to the proposed project site is already polluted due to the presence Levels). of the Industrial Development Corporation. The 1st highest 24 Hour average and annual average Resultant Concentrations of NOX, PM10, PM2.5 and SO2 at all receptor locations are found to be well within the National Ambient Air Quality Standards (NAAQS), 2009. The extension of ToRs has been granted multiple times to the project proponent. This defeats The extension of ToRs has been taken as per the applicability of MoEF&CC 27. the purpose of ToRs being granted for a limited period. Office Memorandums released from time to time.

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S. No. CAT Comments CMPL Replies The written queries of Ms. Shweta Bhatt received from GPCB were addressed 28. We would also like to point out that we were not allowed to speak during the public hearing. and Submitted.

S. No. CAT Comments CMPL Replies Replies to the mail dated Fri, May 20, 2016 at 7:19 PM This is with reference to the upcoming CRZ EAC meeting to be held on 23rd and 24th May 1. 2016. It has come to our notice that the Committee is going to consider the Environmental and - CRZ clearance for the Development of Nargol Port at Valsad District (agenda no. 6.3.1). Total land requirement for Phase 1 and Phase 1A development is about 175.5 Ha. It is proposed to develop most of the Port facilities of Phase 1 and Phase 1 With reference to the aforementioned, at the outset we object to the proposed project. The A in the reclaimed land (behind berthing Line and in inter tidal area) as project is a port which is proposed in the coastal area of Valsad District. This project will lead to suggested by GMB. An area of 171.5 Ha of land requirement is estimated for the reclamation of 171.5 hectares of the coastal area. Moreover, the reclamation would be on Phase 1 and Phase 1 A development except for LSB Complex (4.0 Ha will be 2. the mudflats of the area, which would be in violation of the CRZ Notification 2011. onshore forest land). Furthermore, the project is proposed in the vicinity of the mangroves of the area. It is pertinent No CRZ I(A) area is reported for the area proposed for Nargol Port to note over here that 2 of the mangrove species in the state of Gujarat are found only in this Development as per the CRZ map prepared by MoEF&CC Authorized agency. location. The proposed port activities are sufficiently away from the Varoli River mangroves and Mangroves in the study area. Impacts on mangroves are studied and details are provided in Section 5.5.1.2 of Chapter 5 CEIA Report Sand will be sourced from where the sandy material has been identified during the geotechnical survey. Based on the geotechnical investigation, required quantity of sand is available in south of the inner channel and some portions in north of channel between (-) 13.0 m CD to (-) 14.0 m CD contour. The same is given in Section 2.7.10 of Chapter 2 of Comprehensive EIA/EMP report. Also, With regards to the reclamation, the draft EIA report mentions that "overburden from the quarry the details of the identified quarries and access route to the project site are and dredged sand is proposed to be used". The project proponent has failed to clarify from given in Section 5.2.2.1 of Chapter 5 of CEIA/EMP report. where it will source the sand. The draft EIA report also mentions that it is proposed to make Necessary study was already made to analyze the shoreline changes due to 3. use of containment bunds /dikes, geo bags, etc. I say that this will lead to alteration of the Nargol Port development covering both erosion and accretion aspects as a part of CEIA and it was observed that erosion takes place over a stretch of 3.8 km existing shoreline and change the existing HTL. Furthermore, the reclamation could eventually towards north of proposed reclaimed area of port and 0.9 km of accretion lead to flooding in the surrounding area. towards south of proposed reclaimed area of port. The average rate of erosion is 4m/year adjacent to the north of proposed reclaimed area and accretion at rate of 1.4m/year adjacent to the south of proposed reclaimed area. The rate of accretion and erosion has reducing trend alongshore on either side of the proposed reclaimed area of port. Appropriate mitigation measures were suggested in the CEIA report to protect the shoreline. They are,

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S. No. CAT Comments CMPL Replies . Continuous monitoring of shoreline with the help of high resolution satellite imageries during operation phase . Based on the monitoring results, appropriate techniques such as sand bypassing from accreting area to eroding area, as appropriate shall be carried out to maintain the stability of coast . Based on the monitoring results, the sand trap may be created where the high accretion is observed . Dredging of the area to be accreted/ sand trap shall be carried out regularly (as a part of maintenance dredging) and the material shall be used for maintaining the eroding coastal stretch, if observed. The excess/unusable material shall be disposed at the identified offshore disposal location The proposed Nargol port marine facilities such as breakwaters are about 6.1 km away from the shoreline. Detailed Hydrodynamic studies were carried as a part of CEIA study and presented in the report. The following are the observations made from the study:

. Current in the region is mainly tide driven. Effect of wind on current was found negligible. Direction of currents is towards north during flood tide and reverses during ebb tide. A maximum current speed of 1.6 m/s was observed at 10m contour off Nargol coast during flood of spring tide and is in the order of 1.2 m/s during ebb. Periodic wetting and drying of seabed can be seen for up to a distance of around 1km from coast.. However, restricting the flow completely in the leeward side of port may lead to stagnation of water in this area and can cause high current speed in the seaside of port and across the channel. This in turn may cause changes in shoreline of nearby area. Thus an alternate approach was adapted by providing trestle instead of approach bund to allow free flow of water in the leeward side of port. Moreover, the alignment of breakwater was also optimized to minimise the variations in hydrodynamic conditions in the surrounding. Various layout options were studied for suitability and also considering future phases of development of port. Effect of various layout options on the current pattern in the study area was tested and layout Phase 1 and Phase 1 A was found to be causing the minimum variation in natural hydrodynamic condition and accordingly finalized. The present proposal is only for Phase I and IA. The piece-mealing of the project will lead to The CEIA report is prepared for the Phase 1 and Phase 1A of Nargol Port 4. fragmentation of the existing ecosystem and will be detrimental to the environment. Development as per approved ToR. Future Phases or Master Plan

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S. No. CAT Comments CMPL Replies development stage or during expansion stage, separate application will be made and impacts will be studied in entirety. One of the comments for the Public hearing was "There are numerous reports/articles mentioning turtle nesting sites along the coastline of Valsad. One of them also mentions Nargol as one of the nesting location. Please mark the precise site on a map". The Project proponent has replied stating that there are no declared turtle nesting sites in the proposed port location and that it was not observed during the field survey also. They further state that Sunderraj There are no declared sea turtle nesting sites in the area proposed for Port (2002) has reported that Valsad district has limited potential/insignificant for sea turtle nesting. I development. No turtle nesting reported at the project site during the field say that this is absolutely misleading. The report "Status of the Breeding population of sea survey also. 5. turtles along the Gujarat Coast, 2002" clearly states that "the coast was surveyed randomly It was reported that the entire south Gujarat especially Valsad district has very only covering 28.5 kms in small stretches at 19 locations This coast was surveyed out of the limited potential / insignificant for sea turtle nesting (Sunderraj et. al (2002)). nesting season (end of April). In addition to intensive discussion with the local people each Added to that there are casuarinas groves all along the coast of Nargol which location was surveyed by covering short distances of 05.to 2.5 km. Based on the interview with make the beach unsuitable for sea turtle nesting the locals, out of locations, records of nesting in 14 places indicate that, nesting takes place widely. Villagers reported nesting of both Olive and Green turtles with low numbers." It further says that "this coast has potential for turtle nesting. It is very essential to re-survey this coast well within nesting season." There are no declared sea turtle nesting sites in the area proposed for Port development. No turtle nesting reported at the project site during the field survey also. Furthermore, another report by the Gujarat Ecology Commission, 2012 states that "The sea It was reported that the entire south Gujarat especially Valsad district has very 6. waters here have a population of sea turtles and several other marine creatures like the limited potential / insignificant for sea turtle nesting (Sunderraj et. al (2002)). jellyfish, dolphins and crabs have also been spotted' Added to that there are casuarinas groves all along the coast of Nargol which make the beach unsuitable for sea turtle nesting. Details of crab catch in the Valsadn dwistric is report in the EIA and other species such as Dolphins were not observed during the survey period. One of our other comment was "The list of mangroves is incomplete. Please furnish complete list along with photographs of the mangrove species". The project proponent here has failed to provide a complete list and have replied that the list is complete and the mangroves observed The list of mangroves reported in the Section 4.7.2.3 is complete. The are Avicennia marina, Avicennia alba, Sonneratia apetala, Excoecaria agallocha and 7. mangroves are Avicennia marina, Avicennia alba, Sonneratia apetala, Rhizophora murcronata. I say that mangrove species Avicennia officinalis, Aegiceras Excoecaria agallocha and Rhizophora mucronata. corniculatum, Lumnitzera racemosa and Acanthus illifolius are also observed in this area. Of this, Excoecaria agallocha and Lumnitzera racemosa are observed only in this area in the State of Gujarat. The project proponent has also failed to provide with a Cumulative Impact Assessment report. Baseline data was generated including air quality for the area towards north of The air quality of area north to the proposed project site is already polluted due to the presence the project site where the existing industries emission were accounted. The 8. of the Industrial Development Corporation. The increase in vehicular traffic and transport of same was utilized in the air quality modeling as discussed in point no. 23 & 24 cargo like coal, etc., would be further detrimental and would impact the health of the residents. to calculate the Resultant Concentrations (Incremental Concentrations

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S. No. CAT Comments CMPL Replies The project proponent has failed to take into consideration the existing pollution whilst due to the Proposed Project + Baseline Concentrations due to Existing proposing the project. Levels). The 1st highest 24 Hour average and annual average Resultant Concentrations of NOX, PM10, PM2.5 and SO2 at all receptor locations are found to be well within the National Ambient Air Quality Standards (NAAQS), 2009. Moreover, during the Public hearing I was not allowed to represent our comments citing the reason that I was not from the project area. It is important to state over here that this is against the Principle of Natural Justice and also in violation to the directives of the order of the Hon'ble High Court of Delhi, dated 28th May 2010, in Writ Petition (Civil) 9317 of 2009 "From the terms of the Notification dated 14th September, 2006 it seems, prima facie, that so far as a public The written queries of Ms. Shweta Bhatt received from GPCB were addressed 9. hearing is concerned, its scope is limited and confined to those locally affected persons and Submitted. residing in the close proximity of the project site. However, in our opinion, the Notification does not preclude or prohibit persons not living in the close proximity of the project site from participating in the public hearing they too are permitted to participate and express their views for or against the project. "This order was mentioned during the hearing. As can be observed, the reply received from the project proponent regarding our comments is not satisfactory. The project proponent may be directed to furnish detailed response along with The written queries of Ms. Shweta Bhatt received from GPCB were addressed 10. supporting documents for same. Moreover, the public hearing is against the spirit of the EIA and Submitted. Once again the detailed replies to all the queries received Notification 2006 and in violation of the mentioned High Court Order since our representations from MoEF&CC are being submitted as a part of this clarification. were not allowed to be made during the hearing. We would be grateful if you would kindly give us a hearing before any decision for the 11. - proposed project is taken.

l:\ports\2012\c1121113 - eia for nargol port\outputs\reports\ec clarifications\ec clarfication 22.09.2017\annexure e - replies to cat.doc Page 11 L&T INFRASTRUCTURE ENGINEERING LIMITED (Formerly Known as L&T-RAMBØLL CONSULTING ENGINEERS LIMITED) 6-3-1192/1/1, 5th Floor, Block No.3, White House, Kundan Bagh, Begumpet, Hyderabad – 500 016 Ph: 91-040-40354444; Fax: 91-040-40354430