<<

Resettlement Planning Document

Land Acquisition and Resettlement Plan for the Sanitary Landfill Document Stage: Draft Project Number: 37220 August 2008

PAK: Cities Improvement Investment Program

The Land Acquisition and Resettlement Plan for the Khairpur Sanitary Landfill is a document of the borrower. The views expressed herein do not necessarily represent those of ADB’s Board of Directors, Management, or staff, and may be preliminary in nature.

CONTENTS

Page ABBREVIATIONS iii DEFINITION OF TERMS iv EXECUTIVE SUMMARY 1

I. Scope of Land Acquisition and Resettlement 2

II. Objectives, Policy Framework and Entitlements 3

III. Gender Impact and Mitigation Measures 3

IV. Information Dissemination, Consultation and Disclosure Requirements 4

V. Grievance Redress Mechanisms 4

VI. Compensation 5

VII. Institutional Framework 5

VIII. Resettlement Budget and Financing 6

IX. Monitoring and Evaluation 6

X. Implementation Schedule 7 iii

ABBREVIATIONS

ADB – Asian Development Bank AP – Affected person CAS – Compulsory acquisition surcharge DO – Officer EA – Executing Agency Facility – Multitranche Financing Facility GoS – Government of Sindh IA – Implementing Agency LAA – Land Acquisition Act LAC – Land Acquisition Collector LAR – Land Acquisition and Resettlement LARF – Land Acquisition and Resettlement Framework LARP – Land Acquisition and Resettlement Plan NSUSC – North Sindh Urban Services Corporation P&DD – Planning and Development Department PSU – Program Support Unit SCIP – Sindh Cities Improvement Investment Program TMA – Taluka Municipal Administration TO – Taluka Officer

iv

DEFINITION OF TERMS

Affected Household: All persons residing under one roof and eating from the same kitchen, who are adversely affected by the Investment Program, or any of its components; may consist of a single nuclear family or an extended family group

Affected Persons (AP): Any person affected by loss of assets or income due to Investment Program-related changes in the use of land, water or other natural resources

Compensation: Cash or in-kind payment of the replacement cost of an asset lost due to Investment Program-related impacts

Entitlement: Range of measures comprising compensation, income restoration, transfer assistance, income substitution, and relocation, which are due to APs, depending on the nature of their losses, to restore their economic and social base

Income Restoration: Reestablishment of income sources and livelihoods of APs

Involuntary Resettlement: Unavoidable resettlement losses as a consequence of development projects, compelling APs to rebuild their lives, incomes and asset bases elsewhere

Land Acquisition: The process whereby a person is compelled by a government agency to alienate all or part of the land a person owns or possesses to the ownership and possession of the government agency for public purpose in return for compensation

Rehabilitation: Compensatory measures provided under the ADB Policy Framework on Involuntary Resettlement other than payment of the replacement cost of acquired assets

Relocation: The physical resettlement of an AP from her/his pre-Program place of residence

Replacement Cost: The value determined to be fair compensation for various types of agricultural and residential land, crops, trees, and other commodities based on current market rates; the cost of rebuilding houses and structures at current market prices of building materials and labor, without depreciation or deductions for salvaged building material

Vulnerable Groups: Distinct group of people who may suffer disproportionately from resettlement effects

1

EXECUTIVE SUMMARY

Site Ownership and Affected Persons: Land acquisition and resettlement (LAR) impacts in this solid waste management investment are minimized by acquiring land uncultivated and otherwise unused for the past 6 years from 13 owners under the provisions of the Land Acquisition Act (LAA) of 1894. There are 109 affected persons.

Site Location and Land Status: The 28.8 acres site required for the sanitary landfill is located in the Deh Chhar Jagir, Tapa Shadi Shaheed, and Taluka/Circle/District of Khairpur at Global Positioning System (GPS) coordinates 27˚33′465″N and 068˚50′702″E. The land has not been cultivated by its owners due to due to lack of water availability in the tail end reach of the Satyo Irrigation Canal. There are no built structures; no livelihood activities are undertaken. The owners stated that before 2002 cultivation was possible in years of adequate water availability in the canal.

Expected Gender Impact: An adverse differential impact by the landfill development on either the men or the women of the household is not expected. Any gender impact, if at all, would be insignificant.

Consultation and Information Dissemination: The majority of Affected Persons (AP) household heads participated in a consultation meeting on 12 July 2008. The contents of the Land Acquisition and Resettlement Plan (LARP) were discussed. The APs are being provided with a Sindhi Summary of the Land Acquisition and Resettlement Plan (LARP). This will be available at the Taluka Municipal Administration (TMA) office for public inspection. A Grievance Redress Mechanism has been stipulated in the LARP and was explained to the APs during the consultation meeting.

Land Acquisition Process: The TMA Khairpur through the GoS will acquire 28.8 acres of the land with compensation at the replacement cost of PRs 400,000 per acre plus 15% compulsory acquisition surcharge (CAS), free of taxes, registration and transfer costs, amounting to PRs 460,000 per acre. The Collector of has notified Section 4 of the LAA on 12 July 2008. Compensation to the AP will be paid in full prior to the possession of the land and the award of civil works contracts. A resettlement budget totaling PRs 15,235,200, including contingencies is provided. Monitoring requires the provision of documents demonstrating the conclusion of negotiations with the AP and payment of compensation. An implementation schedule indicates milestones within an approximate timeframe.

2

I. Scope of Land Acquisition and Resettlement

1. The objective of the Sindh Cities Improvement Investment Program (SCIP or the Investment Program) is to improve the quality, reliability and coverage of water supply, waste water and solid waste management (SWM) services by incentivizing and supporting effective management and sustainable financing of urban service providers. The Investment Program consists of four parts: (i) urban planning, institutional development and program management support, including implementation support through technical assistance for a Program Support Unit (PSU), an Urban Policy and Strategic Planning Unit, and urban services corporations (USCs); (ii) urban water supply and waste water management improvement with the construction and rehabilitation or extension of various related infrastructure facilities; (iii) SWM improvement with the provision of related infrastructure facilities, including four sanitary landfills under Tranche 1; and (iv) transition and operational support funding to USCs. SCIP is financed by the Asian Development Bank (ADB) through a Multitranche Financing Facility (the Facility), which includes several subprojects in each tranche. The first tranche provides investments in urban planning, institutional reforms and program implementation support, as well as water supply, wastewater and solid waste infrastructure in the urban areas of , New Sukkur, Rohri, Khairpur, and Shikarpur. The first tranche supports operationalization of the North Sindh Urban Services Corporation (NSUSC). This short land acquisition and resettlement plan (LARP) has been prepared for the Khairpur Sanitary Landfill under the first tranche.

2. Land acquisition and resettlement (LAR) impacts in this SWM development are minimized by TMA acquiring land uncultivated and otherwise unused for the past 6 years from 13 owners under the provisions of the Land Acquisition Act (LAA) of 1894. A total of 109 persons will be affected.

3. To assess the permanent impact of land acquisition for the construction of a sanitary landfill on 28.8 acres of private land, two site visits and walks at the affected land were undertaken and the related certified land revenue documents (Appendix 1) and cadastre maps (Appendix 2) were inspected and collected at the office of the District Officer (DO) of the Revenue Department at Khairpur. The 28.8 acres site required for the sanitary landfill is located in the Deh Chhar Jagir, Tapa Shadi Shaheed, and Taluka/Circle/District of Khairpur at Global Positioning System (GPS) coordinates 27˚33′465″N and 068˚50′702″E and registered with the Khairpur Revenue Department office as plots 303, 304, 305, 310, 617 and 619. The land belongs to 13 owners and has not been cultivated for the past 6 years due to lack of water availability in the tail-end reach of the Satyo Irrigation Canal and due to groundwater salinity.. It has no built structures; no livelihood activities of any form are undertaken. The owners stated that before 2002 cultivation was possible in years of adequate water availability in the canal. Table 1 provides some key data about the affected persons (APs) and affected assets. Appendix 3 and 4 provide more comprehensive census and socio-economic data.

3

Table 1: Affected Persons and Assets in the Khairpur Sanitary Landfill Development

Item No. Households 13a Persons 109 Male 58 Female 51 Vulnerable households 0 Acres 28.8 Agricultural land No. of owners 13 >10% productive income Acres 0 generating assets lost No. of owners/lessees 0 Residential land Acres 0 Structures No. 0 No. of persons 0 APs to be displaced No. of households 0 a Data for one household is missing due to the absence of the owner from the proposed sanitary landfill area.

4. According to the AP census and socio-economic sample survey carried out, the 13 AP households consist of 109 persons, 58 of which are males and 51 females; there are 26 male and 20 female children. The majority of the male owners sampled have some education (4 primary, 2 F.A., 1 B.A. and 1 none), while only one woman has primary education and the others none. All 13 heads of household and titled land owners are male. The households belong to the Lakho, Katohar and Shambani sub-castes of the Baluch caste. The main occupation of all APs is farming, while three of them are also in government service. The per capita per month incomes of the households range from PRs1,190 to PRs13,333 and there are no vulnerable households with monthly per capita incomes below the poverty line. All of the APs reported to own other productive farm land and, while losing in most cases more than 10 percent of their total agricultural land, none are losing productive farm land due to the long-term non-cultivation of the affected land.

II. Objectives, Policy Framework and Entitlements

5. The objective of this LARP is to stipulate all relevant procedures and compensation entitlements for the acquisition of land under the Khairpur Sanitary Landfill, while safeguarding the livelihoods of APs. The Land Acquisition and Resettlement Framework (LARF) for SCIP determines all provisions of this LARP. The policy framework and entitlements for the Investment Program are based on the Land Acquisition Act (LAA) of 1894 and successive amendments as applicable to the Province of Sindh, the Sindh Katchi Abadi Act of 1987 and the ADB Policy on Involuntary Resettlement of 1995, as indicated in Section F of the LARF. This LARP has been prepared by the Government of Sindh (GoS). The compensation and rehabilitation entitlements of APs are set out in Section G of the LARF.

III. Gender Impact and Mitigation Measures

6. The 13 owner households of the affected land do not currently and for the past 6 years derive any income or other benefits supporting their livelihoods from the uncultivated land. Therefore, an adverse differential impact by the landfill development on either the men

4 or the women of the household is not to be expected and any gender impact, if at all, would be insignificant.

IV. Information Dissemination, Consultation and Disclosure Requirements

7. This LARP was prepared after consultation with stakeholders. Sixteen APs were consulted by the LAR consultants to the Investment Program in a public consultation meeting in the Khairpur District Coordination Officer’s office on 11 July 2008. The Taluka Nazim, TMA staff, DO Revenue and relevant Mukhtiarkar and Tapadar of the Revenue Department were also present. They were informed about the proposed landfill development and intent to acquire their land by involuntary acquisition under the LAA. The owners stated their intention to sell the land at a market price to be negotiated with TMA and GoS. The Land Acquisition Collector (DO Revenue) has notified section 4 of the LAA and thus set the cut-off date for the proposed sanitary landfill site for 12 July 2008. The Nazim of has initiated negotiations about an open market purchase of the land by the TMA. The ownership records at the Revenue Department office in Khairpur were cross-checked and verified.

8. The Sindhi summary of this LARP is being sent to the APs, and is available at the TMA Office for public inspection. The English version of the full LARP is on the ADB website.

V. Grievance Redress Mechanisms

9. To address AP grievances about LARP implementation, a Grievance Committee will be established. However, with careful observance of the provisions of the LARF and LARP by all stakeholders involved, grievances can be avoided. The APs were informed of the Grievance Redress Mechanism during the public consultation on 12 July 2008, and through the publication of this LARP. Table 3 sets out the successive steps of the grievance redress mechanism.

Table 3: Grievance Redress Mechanism Step Responsible Actors to be addressed by Provisions Affected Persons (AP) 1 North Sindh Urban Services Corporation Informal settlement within 10 days of lodging of complaint (NSUSC) Safeguards Cell 2.a Grievance Committee Discussion, referral and resolution of complaint within 30 days 2.b Land Acquisition Collector (LAC) / District Land and crop compensation related grievances Officers (DO) Revenue at Khairpur 2.c NSUSC Safeguards Cell Grievances pertaining to all other types of assets 3.a Grievance Committee AP re-lodges complaint within 1 month of decision under step 2 with supporting documents; to be referred to NSUSC Management 3.b NSUSC Management Rules on re-lodged complaint within 21 days in accordance with LARF 4 Appropriate Court of Law In accordance with sections 18 to 22 of LAA (1894)

10. If necessary, the aggrieved AP will first address the Safeguards Cell of the NSUSC, whose officers will strive for an informal settlement within 10 days of lodging of the complaint. If the complaint cannot be settled, it will be referred to the Grievance Committee. Within 30 days the Committee will discuss the matter and refer land and crop compensation related grievances to the Land Acquisition Collector (LAC)/District Officers (DO) Revenue at Khairpur, or grievances pertaining to other types of assets and incomes to the NSUSC

5

Safeguards Cell, and obtain a resolution. If the complaint still remains unresolved, it can be re-lodged by the AP within one month of the LAC or Safeguards Cell decision with the Grievance Committee which refers it to the Management of NSUSC. The AP must produce all relevant documents supporting his claim. The Management of NSUSC will rule on the issue(s) within 21 days of its re-lodging with the Grievance Committee. The NSUSC decision must be in compliance with the provisions of the LARF. If the grievance redress mechanism fails to satisfy the aggrieved AP, he can submit the case to the appropriate court of law as set out in sections 18 to 22 of the LAA (1894).

11. The Grievance Committee will comprise the Mukhtiarkar and Tapadar of the Khairpur Taluka and Shadi Shaheed Tapa, respectively, the elected Khairpur Taluka Councilor of the Shadi Shaheed Tapa, the TO Infrastructure and Services of the Khairpur TMA, the Social Safeguards Officer of the NSUSC Safeguards Cell, and an APs’ representative.

VI. Compensation 12. Upon request by the Nazim of TMA Khairpur the LAC/DO Revenue invoked section 4 of the LAA and determined 12 July 2008 as the cut-off date (Appendix 5). TMA will acquire 28.8 acres of land of the plots with the survey numbers 303, 304, 305, 310, 617 and 619. Compensation at the current market rate (replacement cost) of PRs400,000 per acre plus 15% CAS, free of taxes, registration and transfer costs, amounting to PRs 460,000 per acre, will be provided to the APs. 1 Compensation to the AP will be paid in full prior to the possession of the land and the award of civil works contracts.

VII. Institutional Framework 13. Roles and responsibilities for the design, implementation and supervision of LAR functions within SCIP are vested with a number of different institutional actors. Planning and Development Department (P&DD) of the GoS as the Investment Program Executing Agency (EA) and through its Program Support Unit (PSU) will provide counterpart finances including the LAR budget, supervise the preparation of this LARP, and oversee the compliance of the Investment Program and its subprojects with the LARF and this LARP. The PSU, however, will carry out LARP preparation functions, until these can be assumed by NSUSC upon its operationalization. Responsibility for LARP implementation functions, as well as any update of the LARF and this LARP, will be transferred to the Safeguards Cell of the NSUSC.

14. The NSUSC Safeguards Cell will closely liaise with the Khairpur District Revenue Office and its pertinent Taluka and Tapa offices. Under the Provincial Board of Revenue, the Khairpur District Revenue Office, with the DO Revenue, who is also the Land Acquisition Collector (LAC), and its officers at the Khairpur Taluka level, Mukhtiarkar, and Shadi Shaheed Tapa level, Tapadar, is responsible for land administration, valuation and acquisition. These officers verify and validate LARPs and compensation rates, and deliver compensation for land, crop and tree compensation to the AP. The GoS will acquire the land under the LAA and transfer ownership to the Khairpur TMA. The TMA will transfer long-term use rights for the establishment and operation of the sanitary landfill to the NSUSC through a

1 Khairpur land prices trend higher as the area generally comprises prime date cultivation land. Cultivated prime date land, with date palms, costs PRs700,000 per acre. The value of acquired land, being uncultivated, but in proximity to such land with date palms is discounted at PRs400,000 per acre. Details on land records are available in Appendix 1. The Khairpur Taluka Mukhtiarkhar signed on the statement of current land value at PRs400,000.

6

Services and Asset Management Agreement (SAMA) entered into between the TMA and the NSUSC.

VIII. Resettlement Budget and Financing 15. The affected land is valued at the replacement cost of land of approximately equal type and quality (irrigated cultivated but unused, flat, salinity affected, adjacent to minor road, 12 km to Khairpur town) determined by a local land sales survey for the period of one year preceding the cut-off date for the landfill development. The problem of chronic underreporting of land values for tax evasion purposes is overcome by applying the reported market rates for the preceding 12 months known to local land administration officers and confirmed by some of the APs. The unit rates for involuntary land acquisition include 15% CAS. The LAC of Khairpur District according to LAA Section 23 has indicated a replacement cost for the land to be acquired at the current market value of PRs400,000 per acre, to which a CAS of PR 60,000 per acre is added. The concerned Muktiarkhar has certified this rate in the land record appended to this LARP. Table 4 indicates the proposed cost of land acquisition for the Khairpur sanitary landfill under the LAA and ADB Policy.2

Table 4: Budget for Land Acquisition and Resettlement Plan of Khairpur Sanitary Landfill

Asset type Unit Unit cost (PRs) No. of units Cost (PRs) Land Agricultural, irrigated and uncultivated Involuntary acquisition (incl. 15% CAS) Acre 460,000 28.8 13,248,000 Contingencies 15% 1,987,200 Total 15,235,200

16. The total amount assessed will be deposited by the Executing Agency (EA) in the treasury accounts of the Khairpur District, who must make payment of compensation money to the entitled APs within 60 days after the notice of award under Section 6 of the LAA. Payment of compensation will be made no later than 60 days (2 months) prior to the actual possession of the acquired land. No land will be possessed by the LAC or handed over to the IA for commencement of construction works without full payment of due compensation to the affected landowner. However, in case of a dispute, the assessed/allocated amount of compensation will be pledged in the name of the concerned AP, pending a decision by the court in accordance with the LAA. In this case, the IA may possess the land before payment of compensation, but will hold all construction works until the final settlement of all compensation cases.

IX. Monitoring and Evaluation

17. As only a payment of cash compensation is required, monitoring will be confined to the provision of documents which demonstrate the conclusion of negotiations with the AP and evidence of payment of compensation, to be submitted to ADB prior to the award of civil works contract.

2 In the case of an open market purchase the final unit rate will be determined by the negotiations between the TMA and the land owner.

7

X. Implementation Schedule

18. The LARP implementation schedule is in Table 5.

Table 5: Land Acquisition and Resettlement Plan Implementation Schedule Month of subproject

implementation No. Activity 1 2 3 Action Plan for Subproject Land Acquisition and 1. Resettlement (LAR) 2. Set-Up of LAR Institutions 2.1 Designation of all concerned LAR staff 2.2 Training of all concerned LAR staff 2.3 Grievance redress mechanism in place 3. Land Acquisition and Resettlement Plan (LARP) Update 3.1 Detailed measurement survey update 3.2 Public consultations and negotiations on update 3.3 Updated resettlement plan and budget 3.4 Submission of updated LARP to NSUSC 3.5 Dissemination & agreement on update with APs 3.6 Submission of updated LARP to Executing Agency/PSU; TMA 3.7 Submission of updated LARP to ADB 3.8 Approval of Final LARP with budget 3.9 Public Disclosure of Final LARP 4. LARP Implementation 4.1 Notice of award of compensation under Section 6 of the LAA 4.2 Disbursement of compensation and finalization of land transfer 4.3 Submission of payment receipts to NSUSC and ADB 5 Documentation of LAR process 5.1 Award of civil works contracts 6 Review of LARP implementation (Monitoring) ADB = Asian Development Bank; NSUSC = North Sindh Urban Services Corporation; PSU = Program Support Unit; TMA = Taluka Municipal Administration.

8

LAND RECORD DATA KHAIRPUR SITE, REVENUE DEPARTMENT KHAIRPUR

10

12

14

Revenue Record by Survey Number

Revenue Record by Owner Name

16

CADASTRE MAP KHAIRPUR SITE

AFFECTED PERSONS CENSUS KHAIRPUR SANITARY LANDFILL SITE 18 No. Name of AP / land owner Gender HH Age No HH Children Titled Plot (male/female) Head HH members male/female ownership numbers (yes/no) Head (yes/no) 3 Appendix 1 Abdullah s/o Ghulam Rasool Saeed Khan male yes 30 4 1m yes 303 Lakho

2 Habibullah s/o Ghulam Rasool Saeed Khan male yes 41 10 4m/2f yes 303 Lakho 3 Ali Muhammed s/o Ghulam Rasool Saeed Khan male yes 41 3 1m yes 303 Lakho 4 Sahib Khan s/o Ghulam Rasool Saeed Khan male yes 53 10 1m/2f yes 303 Lakho 5 Ghulam Shabir s/o Mohbat Khan – bought from late Shah Bux Saeed Khan male yes 58 8 1m yes/no reg. 304, 305 Darejo (no Rev. record)* Lakho 6 Ali Murad s/o Panjhal Abdul Hussain male yes 60 5 1m yes 310, 617, Katohar 619 7 Esso s/o Hussain Bux Abdul Hussain male yes 45 4 2m yes 310, 617, Katohar 619 8 Ali Hassan s/o Abdul Hussain Abdul Hussain male yes 42 6 2m/1f yes 310, 617, Katohar 619 9 Panjhal s/o Pathan Khan Abdul Hussain male yes 50 14 5m/3f yes 310, 617, Katohar 619 10 Mazhar Ali s/o late Jan Muhammad – inherited (no Rev. record)* Jan Muhammad male yes 35 7 2m/3f yes/no reg. 619 Katohar 11 Gaji Dino s/o Ali Bux Abdul Hussain male yes 70 15 4m/3f yes 619 Katohar 12 Late Sher Muhammad s/o Ghous Bux (claims son’s property, gave Abdul Hussain male no 30, died 22 2m/6f yes/no reg. 310, 617, to son and registered)* Katohar 619 13 Rustum Shambani s/o Ghulam Muhammad – bought from Roshan UKNOWN, male unknown unknown Unknown unknown yes/no reg. 304, 305 Abassi 1985 (no Rev. record)* originally Abdul Hussain Katohar, now Nara region Total 12 males 108 26m/20f 13 yes/ 4 no reg. Note:These cases require regularization in the revenue record during LARP implementation. All non registered transactions were verbally confirmed by the previous owner and/or land revenue officers.

Appendix 3 19

No. Name of AP / land owner Acres lost Total (acc. to acres respondent) owned 1 Abdullah s/o Ghulam Rasool 1 8 2 Habibullah s/o Ghulam Rasool 1 8 3 Ali Muhammed s/o Ghulam Rasool 1 8 4 Sahib Khan s/o Ghulam Rasool 1 25 5 Ghulam Shabir s/o Mohbat Khan – 4.75 15 bought from late Shah Bux Darejo (no Rev. record) 6 Ali Murad s/o Panjhal 2.675 20 7 Esso s/o Hussain Bux 2.675 4 8 Ali Hassan s/o Abdul Hussain 2.675 7 9 Panjhal s/o Pathan Khan 2.675 4 10 Mazhar Ali s/o late Jan Muhammad – 1 11 inherited (no Rev. record) 11 Gaji Dino s/o Ali Bux 1.3375 12 12 Late Sher Muhammad s/o Ghous Bux 2.675 13.5 (claims son’s property, gave to son and registered) 13 Rustum Shambani s/o Ghulam 4.375 unknown Muhammad – bought from Roshan Abassi 1985 (no Rev. record) Total 28.8375

20 Appendix 2

AFFECTED PERSONS SOCIO-ECONOMIC SAMPLE SURVEY KHAIRPUR SANITARY LANDFILL SITE Item No. Male respondents: 8 Households sampleda Female respondents: 9 None: 1 Primary: 4 Education, men F.A.: 2 B.A.: 1 None: 8 Education, women Primary: 1 Farmer: 8 Occupations Government Service: 3 Laborer: 1 Male: 8 Female: 0 Income earners (male/female) 2 inc. earners in HH: 1 3 inc. earners in HH: 1

Tenants using affected land 0 Male respondents: 8 Affected land not used for any purpose Female respondents: 9 Male respondents: 8b “Loss of land causes loss of income” Female respondents: 8b Male respondents: 6 “Project acceptable if no environmental harm” Female respondents: 2 Male respondents: 1 Project good if it improves people of area” Female respondents: 1 Male respondents: 7 Desire employment in project Female respondents: 0 Other land: 9 Alternative sources of employment, women respondents Handicraft skills: 7 Husband employed: 2 a Although it was intended to sample only 20 percent of the AP households, the respondents to the socio- economic sample survey were more numerous as they met with the enumerators in groups of men and women (separately) in the two . The responses of eight men and nine women were thus recorded and are listed here. b The respondents stressed that although they did not currently earn income from the affected land and had not done so for 6 years, they indicated the loss of potential future income from crops planted during occasional years with high water availability.

Appendix 5 21

REQUEST FOR LAND ACQUISITION BY TALUKA NAZIM AND NOTIFICATION BY DISTRICT COLLECTOR

22 Appendix 5

Appendix 5 23