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Dewas Bypass Tollway Private Limited (Part 1 of 5)

Dewas Bypass Tollway Private Limited (Part 1 of 5)

Environmental and Social Due Diligence Report

Project Number: 47083-004 December 2019

INDIA: Accelerating Infrastructure Investment Facility in – Tranche 3 Bypass Tollway Private Limited (Part 1 of 5)

Prepared by India Infrastructure Finance Company Limited for the India Infrastructure Finance Company Limited and the Asian Development Bank.

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

In preparing any country program or strategy, financing any project, or by making any designation of or reference to a particular territory or geographic area in this document, the Asian Development Bank does not intend to make any judgments as to the legal or other status of any territory or area. Environment and Social Due Diligence Report Dewas Bypass Tollway Private Limited

Due Diligence Report on Environment and Social Safeguards

By India Infrastructure Finance Company Limited (IIFCL) (A Govt. of India Enterprise)

Sub-Project: 4/6 Laning of Dewas Bypass commencing from Km 0+000 (-Dewas junction) to Km 19+800 (total length 19.800 km), in the State of on Build, Operate and Transfer (BOT) basis

November 2019

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Environment and Social Due Diligence Report Dewas Bypass Tollway Private Limited

SUB PROJECT: 4/6 Laning of Dewas Bypass commencing from Km 0+000 (Ujjain-Dewas junction) to Km 19+800 (total length 19.800 km), in the State of Madhya Pradesh on Build, Operate and Transfer (BOT) basis

Dewas Bypass Tollway Private Limited (DBTPL)

Environment and Social Safeguards Due Diligence Report (ESDDR)

Prepared by Dr. Rashmi Kadian Assistant General Manager (Environmental Specialist) ESMU, IIFCL

Mr. Krupasindhu Guru Assistant General Manager (Social Specialist) ESMU, IIFCL

Mr. Ashok Suyal Consultant - Social Safeguards

Reviewed and Approved Dr. S. S. Garg by General Manager & Head, ESMU IIFCL

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Environment and Social Due Diligence Report Dewas Bypass Tollway Private Limited

CONTENTS

PROJECT BACKGROUND ...... 5 1. PURPOSE OF THE REPORT ...... 6 2. SUB-PROJECT TITLE ...... 6 3. SUB-PROJECT BACKGROUND ...... 6 4. SUB-PROJECT LOCATION & DESCRIPTION ...... 7 5. CONCESSIONAIRE ...... 8 6. EPC CONTRACTORS ...... 8 7. INDEPENDENT ENGINEER ...... 8 8. IIFCL FUNDING ...... 9 9. STATUS OF PROJECT IMPLEMENTATION ...... 9 DUE DILIGENCE ON ENVIRONMENTAL SAFEGUARDS ...... 10 10. ENVIRONMENT SAFEGUARDS COMPLIANCE REVIEW ...... 11 11. APPLICABILITY OF ENVIRONMENTAL IMPACT ASSESSMENT NOTIFICATION .. 11 12. APPROACH TO THE ENVIRONMENT SAFEGUARDS DUE DILIGENCE REPORT: .. 11 13. COMPLIANCE OF DBTPL TO THE ESSF OF IIFCL: ...... 12 14. POLICY, LEGAL AND REGULATORY REQUIREMENT: ...... 12 15. IMPACT ASSESSMENT OF SUB-PROJECT ...... 14 16. ENVIRONMENTAL MANAGEMENT PLANS ...... 15 17. HEALTH AND SAFETY ...... 16 18. GRIEVANCE REDRESSAL MECHANISM ...... 22 19. ENVIRONMENTAL SENSITIVITY ...... 22 20. PROJECT AGAINST THE PROHIBITED INVESTMENT ACTIVITIES LIST ...... 23 21. CATEGORIZATION OF SUB-PROJECT ...... 23 22. SITE VISIT OBSERVATIONS ...... 23 23. CONCLUSIONS AND RECOMMENDATIONS ...... 25 DUE DILIGENCE ON SOCIAL SAFEGUARDS ...... 27 24. PURPOSE OF THE SOCIAL SAFEGUARDS DUE DILIGENCE ...... 28 25. PROJECT AGAINST THE PROHIBITED INVESTMENT ACTIVITIES LIST ...... 28 26. OBJECTIVE OF SOCIAL SAFEGUARDS DUE DILIGENCE ...... 28 27. APPROACH AND METHODOLOGY ...... 28 28. SOCIAL IMPACT OF THE PROJECT ...... 29 27.1 LAND ACQUISITION IN THE PROJECT ...... 29 27.2 IMPACT ON STRUCTURE ...... 30 27.3 REHABILITATION AND RESETTLEMENT IMPACT IN THE SUB-PROJECT ...... 30 27.4 IMPACT ON INDIGENOUS PEOPLE ...... 30 29. GREIVANCE REDRESSAL MECHANISM FOR THE SUB-PROJECT ...... 30 30. EMPLOYMENT GENERATION ...... 30 31. THE COMMUNITY ENGAGEMENT ACTIVITIES ...... 31 32. LABOUR LICENSE OBTAINED BY THE SUBPROJECT DEVELOPER ...... 31 33. DISCLOSURE ...... 31 34. SITE VISIT OBSERVATION ...... 31

LIST OF FIGURES

Figure 1: DBTPL road and proposed toll plaza location………………………………………………7

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Environment and Social Due Diligence Report Dewas Bypass Tollway Private Limited

LIST OF TABLES

Table 1: Salient Features of Dewas Bypass Tollway Private Limited……………….…………………7 Table 2: Status of Regulatory Permits/ Clearances Obtained related to Environmental Safeguards…..13 Table 3: Proposed EMP and its Implementation status during Construction Phase at DBTPL……...... 17 Table 4: Proposed EMP for Operation of DBTPL……………………………………………………….20 Table 5: Status of Land available at DBTPL……………………………………………………………...29

ANNEXURES

Annexure I Copy of Tree Implantation Permission Annexure II A & B Copies of Consent to Establish Annexure III Consent to Operate Annexure IV Environmental Clearance for Quarry Area Annexure V Environmental Clearance for Borrow Area Annexure VI Labour License Annexure VII Insurance Copy Annexure VIII Permission for using water Annexure IX NOC from Village Panchayat for Camp site Annexure X License for Explosives Annexure XI Sample Copy Toll Box Meeting Annexure XII Sample Copy Safety Training Programme Annexure XIII Sample Copy On Job Safety Awareness Programme Annexure XIV Organization chart HSE Annexure XV Safety Audit Report by Independent Engineer Annexure XVI Safety Audit Compliance submitted to IE Annexure XVII CTO Compliance submission to MP PCB Annexure XVIII Approved Diversion Plan Annexure XIX ROW Handover Letter

PHOTOPLATE

Photoplate I : Site Visit Photographs

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Environment and Social Due Diligence Report Dewas Bypass Tollway Private Limited

PROJECT BACKGROUND

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Environment and Social Due Diligence Report Dewas Bypass Tollway Private Limited

1. PURPOSE OF THE REPORT

1. This Environmental and Social Due Diligence Report (ESDDR) has been carried out by India Infrastructure Finance Company Limited (IIFCL) in consultation with the Concessionaire, Dewas Bypass Tollway Private Limited (DBTPL) to assess the adequacy of the project with the applicable National, IIFCL’s ESSF and ADB’s safeguard compliance. The report has been prepared as per the documents/information received from the Concessionaire and on the basis of site visit observations.

2. SUB-PROJECT TITLE

2. The sub-project includes - Four laning of existing road from Dewas Bypass (km 0.000) to intersection of NH-3 and Dewas bypass (km 7.000) and six laning of part of bypass from NH-3 and bypass intersection (km 7.000) until the intersection of the bypass and AB Road (km 19.800) in the State of Madhya Pradesh on Design, Build, Finance, Operate and Transfer (DBFOT) basis.

3. SUB-PROJECT BACKGROUND

2. Madhya Pradesh Road Development Corporation (MPRDC) in the year 2016, invited detailed bid proposals for widening and upgradation of Dewas Bypass from km 0.00 to km 19.80 on Build, Operate and Transfer (Toll) basis. The project envisages four laning of 7.00 km stretch of Dewas Bypass from Ujjain Dewas Junction (km 0.00) to km 7.00 and six laning of remaining section from km 7.00 till end of bypass at Dewas Junction (km 19.80).

3. The project stretch, Dewas Bypass, starts from the north western side of Dewas city and ends at AB Road in south western side of the city. AB Road is a part of Mumbai National Highway which witnesses a high traffic movement. The existing two lanes forms a vital link in this region connecting the northern Indian states to the Eastern Indian states and also caters to the Mumbai and Pune bound traffic. It serves the long distance traffic which is majorly plying from UP, Agra and beyond to Mumbai and beyond. Apart from long distance traffic, it also serves the short distance traffic which is mainly generated between Ujjain, , Indore, and surrounding areas.

4. MPRDC awarded the project to Dewas Bypass Tollway Private Limited, an SPV formed by IJM Corporation Berhad and the Concession Agreement was signed on February 27, 2017. The concession period is of twenty five (25) years from Appointed Date (180 days from signing of Concession Agreement) including construction period of 730 days (2 years).

5. The scope of the project includes performance & execution of all design, engineering, financing, procurement, construction, completion, operation & maintenance (O&M) of the project corridor as set out in the Concession Agreement (CA).

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Environment and Social Due Diligence Report Dewas Bypass Tollway Private Limited

4. SUB-PROJECT LOCATION & DESCRIPTION

6. The project road comprises a 19.8 km stretch on State Highway 18 commencing from Ujjain Dewas junction. The project road would be a rigid pavement. There is one level crossing on the existing project road. The project scope includes construction of a railway over bridge, three vehicular underpasses, 2 grade separators and widening of one minor bridge. For the initial 7 km stretch from Ujjain Dewas Bypass junction, the paved carriage way shall be four lane and balance 12.8 km upto Dewas bypass - AB road junction will be six lane. The proposed toll plaza will be located at 16.5 kms from Ujjain Dewas bypass junction. The location of DBTPL is given in Figure 1 and salient features of the sub-project are given in Table 1.

Figure 1: DBTPL road and proposed toll plaza location

Table 1: Salient Features of Dewas Bypass Tollway Private Limited Particulars Features Name of Project 4/6 Laning of Dewas Bypass commencing from Km 0+000 (Ujjain-Dewas junction) to Km 19+800 (Total Length 19.800 km.), in the State of Madhya Pradesh on Build, Operate and Transfer (BOT) basis. State Madhya Pradesh District Dewas Concessioning Authority Madhya Pradesh Road Development Corporation Concessionaire M/s Dewas Bypass Tollway Private Limited Terrain Plain Project Length 19.800 km ESDDR NO. IIFCL/ESMU/ADB/2019/115/V2 7

Environment and Social Due Diligence Report Dewas Bypass Tollway Private Limited

Toll Plaza 1 at KM 16+050 Flyover (Nos.) 2 nos. Vehicular Under Pass (Nos.) 3 nos.

ROB 1

Minor Bridges 1 nos. Box Culverts 9 nos. Pipe Culverts 35 nos. Truck Laybye 1 Bus Shelter (Nos.) 19

Service roads 4 Km X 2

5. CONCESSIONAIRE

7. Incorporated in February 2017, Dewas Bypass Tollway Private Limited (DBTPL) is a special purpose vehicle (SPV) promoted by the Malaysian construction firm IJM Corporation Berhad and its investment companies to undertake the project of widening & up-gradation of Dewas Bypass Road from Km 0.00 at Ujjain Dewas Junction and ending at Km 19.80 at Indore Junction from two-lane to a four/six-lane highway in Madhya Pradesh on a Design, Build, Operate and Transfer (DBOT) basis. The project was awarded by Madhya Pradesh Road Development Corporation Limited (MPRDCL) based on competitive bidding on February 27, 2017, with a concession period of 25 years commencing from October 10, 2017 including the two year construction period.

6. EPC CONTRACTORS

8. IJM (India) Infrastructure Limited, Hyderabad is the EPC contractor for the sub-project. EPC agreement has been signed between IJM (India) and DBTPL on April 21, 2017.

7. INDEPENDENT ENGINEER

9. Lion Engineering Consultant has been signed to monitor the sub-project as Independent Engineer (IE).

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Environment and Social Due Diligence Report Dewas Bypass Tollway Private Limited

8. IIFCL FUNDING

10. The total project cost of DBTPL is ₹ 280.28 crores. The project is financed by IIFCL under Direct Lending Scheme. IIFCL has sanctioned an amount of ₹ 56 crore towards DBTPL and disbursed ₹ 39.21 crores as on 31.10.2019.

9. STATUS OF PROJECT IMPLEMENTATION

11. The sub-project is under construction and the Scheduled Commercial Operations Date (SCOD) was in October 2019. At the time of site visit during 15th October, 2019, DBTPL informed that approximately 83% physical progress has been achieved. The sub project is expected to achieve commercial operation by December 2019.

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DUE DILIGENCE ON ENVIRONMENTAL SAFEGUARDS

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10. ENVIRONMENT SAFEGUARDS COMPLIANCE REVIEW

12. The environmental due diligence (EDD) report focuses on the status and review of the applicable environmental regulatory requirements, compliance to the regulatory requirements, review of the environment related sub-project documents, implementation of environmental management measures at site, institutional arrangements for implementation and monitoring of environmental measures, environment, health & safety (EHS) related clauses in agreements, health and safety measures at work place, status of plantations and emergency preparedness.

11. APPLICABILITY OF ENVIRONMENTAL IMPACT ASSESSMENT NOTIFICATION

13. It is required that the project meets the applicable national guidelines / regulations relating to the environment, occupational health and safety and social issues. The project should have necessary clearances as well as permits and approvals for project implementation and suitable environmental management plans.

14. National Highway projects up to 100 Kms involving additional right of way or land acquisition upto 40 meters on existing alignments and 60 meters on re-alignments or by-passes are exempted from the scope of the Environmental Impact Assessment Notification, 2006 of Government of India. The total length of the sub-projects is approximately 19.80 Kms; therefore, DBTPL does not require environmental clearance and is not required to conduct an Environmental Impact Assessment (EIA) as a statutory requirement. EIA study has not been conducted for the sub-project DBTPL.

12. APPROACH TO THE ENVIRONMENT SAFEGUARDS DUE DILIGENCE REPORT:

15. The Environmental Due Diligence Report (EDDR) reviews the available documents and assesses the compliance of the sub-project with respect to environmental safeguards; regulatory clearances; environmental impacts and management measures; Health, Safety and Environment (HSE) measures; and categorization of sub-project on the basis of above review.

16. The following documents were referred in order to prepare Environmental Safeguards Due- Diligence Report:  Project Information Memorandum (PIM)  Concession Agreement  Traffic study report  Independent Engineer Report (September 2019)  Safety Audit Report by Independent Engineer  Lender’s Independent Engineer (LIE) Reports  Project Statutory Approvals/Permits  Project HSE Documents  Labour License & insurance

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 Contract Documents  Emergency Response Plan  Grievance Redressal Mechanism

17. The environmental safeguard due-diligence study was carried out for the sub-project on the basis of site visit observations and understanding project scope based on information and documents provided by Concessionaire. A detailed discussion on the environmental and social safeguards related issues was also carried out with the team of the sub-project at site.

18. On review of the documents / information related to the sub-project and on the basis of site visit, the impacts of the DBTPL on environment are envisaged, which are given in section 15 of the ESDDR. The sub-project is mitigating the environmental impacts at the site with various measures. An EMP is proposed for DBTPL in concurrence with the developer (Section 16).

13. COMPLIANCE OF DBTPL TO THE ESSF OF IIFCL:

19. The Environmental and Social Safeguard Framework (ESSF) provides the enabling mechanism to IIFCL to deliver its policy objectives and applies to projects funded by IIFCL throughout the project cycle. The ESSF defines procedures, roles, and responsibilities, at various project milestones for managing the adverse environmental impacts.

20. The environmental due diligence for DBTPL has been done as per requirements of direct lending scheme. The environmental safeguard risks during construction phase have been assessed and risks during operational phase have been evaluated. DBTPL is under construction and following the regulations and guidelines. There does not seem to be any significant risk for either IIFCL or DFI involved. The environmental measures being implemented at the sub project are proposed in the form of structured EMP with monitoring indicators to DBTPL for both construction and operational phase of sub-project. It can be concluded that DBTPL is compliant to the requirements of IIFCL’s ESSF under direct lending scheme and has adequate management measures implementation on site.

14. POLICY, LEGAL AND REGULATORY REQUIREMENT:

21. DBTPL does not fall under the schedule of EIA Notification, 2006 that lists projects or activities requiring prior environmental clearance and hence these are exempt from obtaining environmental clearance. DBTPL is required to comply with the applicable guidelines relating to the environment, occupational health and safety in addition to complying with local pollution control board regulations. The statutory permits/clearances related to environmental aspects obtained/to be obtained from regulatory authorities as part of DBTPL development were assessed and current status of availability of such permits/clearances are given in Table 2 below:

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Environment and Social Due Diligence Report Dewas Bypass Tollway Private Limited

Table 2: Status of Regulatory Permits/ Clearances Obtained related to Environmental Safeguards S.No. Permits/Clearances Statutory Authority Current Status 1. Environmental Ministry of Not Applicable. As the sub-project length is below Clearance Environment, Forests & 100 kms (19.8 Kms), this is exempted from Climate Change obtaining environmental clearance and conducting (MoEF&CC), New EIA. 2. Forest Clearance MoEF&CC and State The sub-project does not involve any forest land. Forest Department 3. Clearance MoEF&CC The Project area does not lie within an ecologically sensitive area and is not located close to any National Park/Wildlife Sanctuary. The location of Project does not contravene any international biodiversity or ecosystem conservation conventions. Therefore, it does not require wildlife clearance or permission. 4. Tree permissions Revenue Department, Approximately 1354 nos of trees were coming in Madhya Pradesh ROW. These trees were on revenue land. Permission from tree transplantation has been taken from the Collector, District Dewas, Madhya Pradesh. All the 1354 trees have been transplanted on the proposed ROW. Copy of tree implantation permission is attached as Annexure I. 5. Consent to Establish Madhya Pradesh Consent to Establish under section 25 of Water Pollution Control Board (Prevention & Control of Pollution) Act, 1974 and (MPPCB), Madhya under section 21 of Air (Prevention & Control of Pradesh State Pollution) Act 1981 was obtained from Madhya Pradesh Pollution Control Board for RMC plant, Crusher plant, etc have been obtained. Sample copies are attached as Annexure II A & B. 6. Consent to Operate Madhya Pradesh Consent to Operate under section 25/26 of the Pollution Control Board Water (Prevention & Control of Pollution) Act, (MPPCB), Madhya 1974 and under section 21 of Air (Prevention & Pradesh State Control of Pollution) Act 1981 and amendments thereof has been obtained from MPPCB (Annexure III). 7. Quarry and Borrow District level Prior Environmental Clearance has been taken Area Permissions Environment Impact from DEIAA, Dewas for the quarry/borrow being Assessment Authority used for DBTPL sub-project. Sample copies of (DEIAA), Dewas, environmental clearances taken by the contractor Madhya Pradesh are attached as Annexure IV and Annexure V. 8. Labour & Insurance Licensing Officer, DBTPL has taken Labour License under the Dewas, Government of Contract Labour (Regulation and Abolition) Act, Madhya Pradesh 1970. The establishment has valid labour license which is enclosed as Annexure VI. Insurance policy for DBTPL is enclosed as Annexure VII. The EPC contractor also has a valid labour license and insurance.

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Environment and Social Due Diligence Report Dewas Bypass Tollway Private Limited

9. Tube-well Permissions Commissioner, The tube wells are located on revenue land, which Municipal Corporation, are being utilised by DBTPL. DBTPL has taken Dewas permissions for tube wells for drawing water for construction purpose sample copies are attached as Annexure VIII.

10. NOC for setting up Village Panchayat DBTPL has taken NOC from village panchayat for camp setting up of camp with RMC and Crusher plant (Annexure IX).

11. License for Explosives Joint Chief Controller of DBTPL has taken license for explosive transport, Explosives storage and use from the licensing authority - Joint Central Circle office, Chief Controller of Explosives Central Circle Agra, Government of office, Agra (Annexure X) India

15. IMPACT ASSESSMENT OF SUB-PROJECT

22. EIA study was not conducted for the sub-project as the project does not fall under the purview of EIA Notification and subsequent amendments as explained in Section 11 of the EDDR.

23. As the bypass has already been constructed with two lanes, adequate land was acquired along with original two-lane construction. The width of existing ROW is 60 m and length of the sub project is 19.800 km. Therefore, the impacts of the proposed project are limited because of the land acquisition during two lane construction. The entire length of the project road runs through plain terrain and passes across agricultural land and villages. The existing 2 lane pavement is rigid for the entire stretch.

24. Description of Environment: The project road comprises a 19.8 km stretch on State Highway 18 commencing from Ujjain Dewas junction. It falls under the jurisdiction of in the state of Madhya Pradesh. The project area falls in the Plateau zone. The major soil group found in the area is deep medium black soil. Soyabean, wheat and gram are the major crop of the area. The rainfall in the district is approximately 1000 mm annually. The land use pattern in the sub-project section is agricultural. The climate of the project area is characterized by hot dry summer, followed by well distributed rainfall in and winter. There is no forest land involved in DBTPL. The sub-project does not pass through any protected area. 1354 number of trees were coming in the ROW of the project. No archaeological and historical monuments are located along the project road.

25. The main impacts envisaged due to various activities at the sub-project are summarised in the paragraphs below:

26. Impact on Land Environment: The sub-project involves strengthening and widening of the existing two to four/six lane bypass. The sub-project involves widening/reconstruction of existing road within available ROW without any substantial land acquisition, impact on the physiography of the area is not significant. During construction phase the topography at sub-project location will ESDDR NO. IIFCL/ESMU/ADB/2019/115/V2 14

Environment and Social Due Diligence Report Dewas Bypass Tollway Private Limited

change due to excavation of borrow areas, cuts and fills for project road and construction of project related structures. Risk of contamination of soil exists from construction material and oil spills. The impacts are temporary and are manageable with mitigation measures which are given in Section 16.

27. Impact on Water Resources: The sub project is not crossing any perennial river. Water resources may be impacted near the construction camp. This can be minimized by proper handling of material and proper disposal of sewage and proper erosion control. During the operation stage the leakage or spillage from damaged vehicles or badly maintained vehicles may lead to contamination of water bodies. EMP has been proposed to manage these impacts.

28. Impact on Air Quality: The setting up of camp including ready mix concrete plant, hot mix plant, and crusher plant. Up-gradation works at sub-project stretch shall involve generation of dust and release of other pollutants leading to the localised degradation of air quality. All the belt conveyors are to be covered with canopy to control the dust pollution. Ready mix concrete plant to be well equipped with the cartage filters. All aggregate stock yards are provided with water sprinkling system. Mitigation measures are in place to manage these temporary impacts.

29. Impact on Noise Environment: Impact on noise environment is envisaged during both construction and operation phases. During construction phase, noise is generated due to use of heavy equipment and processing facilities. Adequate distance from sensitive sites is to be kept for controlling noise disturbances.

30. Impact on Biological Environment: No National Park or Wildlife Sanctuary is located within close proximity of the project road and there is no notified animal corridor/migration route is present in the project area. No Protected / Reserve Forest are located along the project road. About 1354 trees falling in revenue land were coming in the ROW expansion. Permission for transplanting these trees has been obtained from respective authority. All the trees have been transplanted in a scientific manner in the proposed ROW. No significant impacts on other flora and fauna are anticipated at the sub-project. Necessary mitigation measures have been recommended where construction/maintenance is proposed.

16. ENVIRONMENTAL MANAGEMENT PLANS

31. The sub-project does not require EIA as a statutory requirement. The project is being developed on the existing ROW as far as possible. The sub-project has been implementing various mitigation measures to minimize risk to environment. A project specific Environment Management Plan (EMP) has been formulated and proposed to the developer as part of due diligence which consists of a set of mitigation measures; monitoring and institutional measures applicable to construction and operation stages of the project. The EMP also defines roles and responsibilities of various parties.

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32. The proposed EMP has been formulated on the on the basis of documents/information shared by developer and site visit. The status of EMP implementation during construction phase is also given in Table 3 on the basis of site visit observations. The EMP proposed for operation phase is given in Table 4.

17. HEALTH AND SAFETY

33. DBTPL has deployed route patrolling vehicles, etc with requisite staff for incident management as per Concession Agreement for maintenance of the project highway during construction and ensures the project highway is in trafficable & motorable condition.

34. The Traffic Safety Arrangements during execution of works is being carried out by the Contractor for safe movement of vehicles on the project highway. The Contractor has provided sufficient road signs, temporary barriers, gunny bags filled with soil with reflective stickers etc. at the construction sites.

35. DBTPL follows the safety guidelines and conducts safety training programmes for staff at site including labour. The records for the same are maintained at the sub-project site. Sample copies of toll box meetings, safety training programmes and on job safety awareness are attached as Annexure XI, XII and XIII.

36. First aid boxes and fire fighting systems are maintained at sub-project camp sites.

37. DBTPL has adequate institutional arrangement to look after HSE related aspects. The organizational chart for HSE is given as Annexure XIV.

38. Safety Consultant has been appointed for the sub-project as per Article 18 of the Concession Agreement. The consultant conducts road safety audit on periodic basis. Sample report is attached as Annexure XV. DBTPL submits compliance report to the audit observations to the Safety Consultant (Annexure XVI).

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Table 3: Proposed EMP and its Implementation status during Construction Phase at DBTPL

Impact/Issues EMP Responsibility Monitoring Status of EMP Implementation indicators Impact on air environment due  All the vehicles deployed for DBTPL  Dust pollution  Approach roads in project area are to fugitive emissions and dust construction of the project will have to measurements/obser paved and water sprinkling is being generation due to construction keep “Pollution under Control” (PUC) vations or complaint done at the sub-project to control activities certificates. dust of locals  DG sets will also emit air pollutants in  Vehicles have restricted speed in the area during construction period. The  Compliance report camp area emission generated during construction submission to  All vehicles used for DBTPL have will be temporary and localized in MPPCB valid pollution control certificate nature.  Workers are provided with PPEs  Vehicles carrying construction material  Camp site is located away from shall be covered to avoid spilling. settlements  Paved approach roads to be maintained  Plants at camp are having CTO  Water sprinkling in dust prone areas from Madhya Pradesh Pollution  Personal protective equipment for Control Board and compliance to workers the conditions of PCB is being  RMC and Batching plants to possess submitted by DBTPL on regular valid CTO basis (Sample copy attached as Annexure XVII).  RMC plant is equipped with dust collector to control emissions  DBTPL has informed during site visit that the MP PCB officials regularly visit project site Noise from construction  Construction equipment to be properly DBTPL; Contractor; Complaint from locals  Equipment and vehicles are vehicles, machinery and maintained. Sub contractor properly maintained at site equipment  Noisy construction activity to be avoided  Vehicles have restricted speed in during night and close to sensitive camp area receptors  Workers are provided with PPEs  Traffic management and re-routing during  Training is provided to staff construction to avoid the accumulation of noise  Honking restrictions on project vehicles  PPEs to be provided to workers

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Impact/Issues EMP Responsibility Monitoring Status of EMP Implementation indicators Borrow Area Management  Topsoil to be stockpiled and protected for DBTPL; Contractor Rehabilitation records To be done after project construction is use over  Borrow areas to be rehabilitated by levelling or converted to pond in consultation with the owner Contamination of soil / water  Vehicles and equipment to be maintained DBTPL; Contractor Records of fuel and  During site visit it is informed by at project site waste oil to be the developer that fuel is not stored  Fuel storage to be kept away from maintained at camp site, as there if a fuelling drainage and on impervious surface station opposite camp site and fuel  Waste oil to be stored appropriately and is taken from the fuelling station as disposed to authorized vendors  Water to be sourced from authorised / per requirement. permitted sources  Waste oil to be sold to SPCB authorised vendors as and when required  Water is sourced from authorised suppliers through tankers Impact on water resources  Storm water drains in the entire stretch DBTPL Records and  Drainage system is under except service roads at DBTPL is maintenance of construction proposed drainage and rain  Rain water harvesting pits will be  Runoff drainage provided at service roads, water harvesting pits constructed once the alignment is flyovers etc. complete  Rain water harvesting pits are proposed at culverts Avenue trees  1354 number of trees on revenue land DBTPL  Records of trees  Tree transplantation permissions were coming in the ROW up gradation. planted and were obtained Permission was taken by DBTPL for transplantation to  Videography of the tree shifting shifting all trees in the proposed ROW be maintained at activity was done by developer  All 1354 trees have been transplanted in a site scientific manner.  Survival records are maintained at

 Avenue plants are proposed along the  Survival records to site. In first six months the survival project stretches as per IRC-SP-21:2011. be maintained at record of implanted trees was about Approximately 5000 trees are planned to site 90%. be planted in avenue plantation, which  Avenue plantation will begin from will begin in next monsoon. the year 2020. ESDDR NO. IIFCL/ESMU/ADB/2019/115/V2 18

Environment and Social Due Diligence Report Dewas Bypass Tollway Private Limited

Impact/Issues EMP Responsibility Monitoring Status of EMP Implementation indicators  The avenue plants proposed to be planted on either side of the road in two rows. Median Plantation Median planation to be done as per IRC. DBTPL Survival records to be  Median plantation has been done Approximately 667 plants will be planted every maintained at site on 50% of stretch. km.  Median plantation is being maintained at site Site for storage and  Camp to be maintained at minimum DBTPL; Contractor Training records to be  Camp site is away from habitation construction camp distance of 500 m from habitation maintained at site  Storage is done at designated areas,  Emergency response plan will be in place with markings and signboards. towards meeting unforeseen  Emergency response plan is in emergencies. place for DBTPL  Workers to be trained for handling  Trainings are imparted to labour materials and staff and records maintained at site Sewerage and solid waste  For sewage disposal, septic tanks with DBTPL; Contractor On site observation  Septic tanks with soak pits are disposal soak pits will be provided at campsites. provided at site.  Proper sanitation facilities at the camp to  Proper toilets are provided at camp. be provided.  Camp haul roads are maintained  Salvage material/ demolition wastes will with salvage material / demolition be reused to the possible extent in wastes embankments, shoulders, slopes,  There is no labour camp at site, the approach roads and temporary campsites labour are staying in rented accommodation and commuting from villages nearby Traffic management & safety  Secure traffic control during construction DBTPL; Contractor On site observations;  Contractor has provided sufficient  Safety measures to be undertaken by accident incident road signs, temporary barriers, installing road signs and markings for records gunny bags filled with soil with safe and smooth movement of traffic. reflective stickers etc. at the construction sites  All traffic diversions are approved. Diversion Plan is attached as

ESDDR NO. IIFCL/ESMU/ADB/2019/115/V2 19

Environment and Social Due Diligence Report Dewas Bypass Tollway Private Limited

Impact/Issues EMP Responsibility Monitoring Status of EMP Implementation indicators Annexure XVIII  Sufficient light arrangement has been done at construction zone and diverted areas  Marshalls are deployed 24 *6 at all junctions for traffic management.  Concessionaire has deployed route patrolling vehicles, etc with requisite crew for incident management as per Concession Agreement for maintenance of the project highway during construction and ensures the project highway is in trafficable & motorable condition Occupational Health and  Labourers shall be equipped with DBTPL; Contractor Training records to  All workers and labourers are Safety proper safety gears like helmets, gloves be maintained at site equipped with appropriate PPE’s and gum boots.  HSE induction trainings are  Training of workers to be ensured organized for labour and staff.  Drinking water to be supplied to  RO plant is installed at the camp workers site for drinking water for staff and workers

Table 4: Proposed EMP for Operation of DBTPL Impact/Issues EMP Responsibility Monitoring indicators Noise  Multi layered plantation to serve as mitigation option DBTPL  On site observations for operation phase  Records of safety week  Effective traffic management and good road condition shall be maintained to reduce the noise level  Speed limitation and honking restrictions may be enforced near sensitive locations.  Create awareness in locals and drivers through

ESDDR NO. IIFCL/ESMU/ADB/2019/115/V2 20

Environment and Social Due Diligence Report Dewas Bypass Tollway Private Limited

Impact/Issues EMP Responsibility Monitoring indicators programmes Embankment protection  Periodic maintenance of stabilizing measures at DBTPL On site checks & observations embankments like turfing etc. Water logging  Regular maintenance and cleaning of drains DBTPL On site checks & observations Maintenance of Safety  Traffic control measures to be enforced strictly DBTPL  Safety signage to be displayed and  Monitor and ensure that all safety provisions included maintained at site in design and construction phase are properly  Accident incident reports to be maintained maintained at site  2 Highway patrol units for round the clock patrolling to be available at site  One ambulance to be available at toll plaza  One tow-away facility for the break down vehicles Avenue / Median Plantation &  Avenue plants are proposed along the project stretches as DBTPL  Records of trees planted and Maintenance per IRC-SP-21:2011. Approximately 5000 trees are transplantation to be maintained at planned to be planted in avenue plantation, which will site begin in next monsoon.  Survival records to be maintained  The avenue plants proposed to be planted on either side of at site the road in two rows.  Planted trees and shrubs in Avenue and Median Plantation to be properly maintained  Tree survival list to be maintained for planation effectiveness Redressal of public grievances  DBTPL shall maintain a complaint register at toll plaza DBTPL  Complaint Record register  DBTPL shall define a mechanism to handle and manage grievances raised by road users, project affected persons and employees/workers including those of sub- contractors.  DBTPL shall send copy of the register to Concessioning Authority and Independent Engineer

ESDDR NO. IIFCL/ESMU/ADB/2019/115/V2 21

Environment and Social Due Diligence Report Dewas Bypass Tollway Private Limited

18. GRIEVANCE REDRESSAL MECHANISM

39. Developer has confirmed that they are maintaining a register at site for grievances. Record of any grievance or demand received from locals is maintained at the site office.

40. Redressal of Public Grievances will be done during operation phase as per Article 46 of the Concession Agreement. The Concessionaire has to maintain complaint register at the toll plaza for recording public grievances. The complaint register will be shared with the Concessioning Authority every 7 days for review.

41. The Grievance Redress Mechanism should outline mechanism to handle and manage grievances raised by road users, project affected persons and employees/workers including those of sub-contractors.

19. ENVIRONMENTAL SENSITIVITY

42. The environmental sensitivity of DBTPL has been assessed by reviewing various documents, supplemented by field visit and consultation with the developer.

43. The environmental sensitivity assessment is given below:  The sub-project is being developed on the existing right of way. At certain places (vehicle under pass, flyover and administrative block for toll plaza) additional land is required. Developer has informed that this additional land requirement for toll plaza building is 1.2 Ha, which is private land and acquisition is in process.  The sub-project sites are not located in any protected area like wildlife sanctuary / national park or in close proximity of any eco-sensitive area.  During site visit and as per discussions with the sub-project staff, it was informed that no wild animals are sighted in and around the sub-project area.  No forest area is getting affected due to the sub-project.  1354 trees were coming in the ROW, which are shifted to the proposed ROW.  As informed by the concessionaire, no important cultural or heritage sites are getting affected due to the sub-project.  The sub-project has the necessary approvals and permits from regulatory authorities.  The impacts of the sub-project are temporary in nature and are manageable with EMPs.

ESDDR NO. IIFCL/ESMU/ADB/2019/115/V2 22

Environment and Social Due Diligence Report Dewas Bypass Tollway Private Limited

20. PROJECT AGAINST THE PROHIBITED INVESTMENT ACTIVITIES LIST

44. The sub - project does not involve any prohibited activity as per the Prohibited Investment Activities List (PIAL) of ADB.

21. CATEGORIZATION OF SUB-PROJECT

45. The sub-project can be classified as Category B based upon ADB’s EA requirements as per their Safeguard Policy Statement (2009). This classification is based on the review of the available documents and site visit with respect to the environmental sensitivity due to project activities.

22. SITE VISIT OBSERVATIONS

46. A site visit was undertaken by IIFCL’s Environmental and Social Safeguard Specialists and Social Safeguard Consultant on 15th October 2019. The site visit was undertaken to review the implementation of the project’s environmental and social safeguards. During the site visit, following staff were mainly consulted regarding environmental safeguards related measures implemented at the project site:

(a) Mr N Ramesh Narendra, Team Leader (b) Mr T Subramanyam, Team Leader, IJM (India) Infrastructure Ltd. (c) Mr Mahesh Chandra, Senior Vice President, IJM (India) Infrastructure Ltd. (d) Mr Shekh Josaif Hussain, EHS Officer

47. The sub-project is under construction and more than 83% works are complete at the site. Based on the discussions with above mentioned officials and visit, the site observations are given below:

 The sub-project has obtained necessary clearances/permits from the State Pollution Control Board and other regulatory organizations and is complying with the reporting / monitoring requirements.  The sub-project is involves strengthening and widening of highway in the existing ROW.  Tree shifting is complete at site. The trees are maintained and in the initial six months survival of 90% was recorded. Avenue plantation will begin during monsoon of 2020. Median plantation in about 50% of the stretch is complete and is being maintained. Developer has been informed to keep a record of plantations and survival rate.

ESDDR NO. IIFCL/ESMU/ADB/2019/115/V2 23

Environment and Social Due Diligence Report Dewas Bypass Tollway Private Limited

 Utility shifting at site is almost complete. 100% of land is available for highway up-gradation.  The workers and staff at the site were seen wearing personal protective equipment such as helmets, jackets, boots, gloves etc.  Regulatory signs, warning signs and direction signs were available at all relevant places at site.  Traffic marshals could be seen at all junctions.  There is one camp site at the sub-project.  There is no labour camp at sub project. Developer has informed that most labour is local and are commuting from nearby villages. The other workers are also housed in rented accommodations. Good standards of health and hygiene were maintained at camp. Dust bins were placed at different locations. Toilets were available at the camp site for staff with continuous water supply. Good housekeeping was maintained at the site.  Pantry is being run at the camp site.  All waste water being generated at the sub-project premises is disposed in septic tanks/soak pits.  RO water purifier of large capacity is available at camp for drinking water purpose.  Adequate EHS staff was present at the site and understood their commitments.  On discussions with the site staff, it was observed that tool box talk, safety induction trainings are done for labour as well as staff.  Vehicle movement in the administrative premises was very limited and control by Security at entrance of camp.  No oil spillage was observed at the site. Developer has informed that they are not storing fuel at the camp site as a fuelling station is available across the road and fuel is procured as and when required.  Concrete demolition waste is kept at secured and identified location and is being utilized for low laying area development and leveling purpose by local community.  The permits and NOCs required for the project are in place.  Fire extinguishers and first aid kits were available at camp site.  Emergency contact numbers have been displayed at appropriate locations.  Records of safety trainings, mock drills and various inspections/audits are maintained at site office.

ESDDR NO. IIFCL/ESMU/ADB/2019/115/V2 24

Environment and Social Due Diligence Report Dewas Bypass Tollway Private Limited

48. The site visit photographs are given in Photoplate - I.

23. CONCLUSIONS AND RECOMMENDATIONS

49. It is concluded on the basis of review of the available information, reconnaissance site visit and interaction with sub-project staff it can be concluded that the concessionaire DBTPL is complying with the requirements as per the national and state guidelines and regulations. The 19.8 km road strengthening and widening project in the State of Madhya Pradesh is unlikely to pose any adverse environmental risks given the nature of the activities.

50. There are no legally protected areas, cultural heritage sites and forest land located within and/or in close proximity to the sub-project. However, the sub-project activities have reversible environmental impacts which have been managed.

51. Based upon the available documents and site visit, it is concluded that the concessionaire has undertaken adequate environmental safeguard measures. The conclusions for the sub-project are given below:

 The sub-project has been planned as per the National and State Government requirement and not in anticipation to ADB operation.  The project site is not located in an ecologically sensitive area.

 The sub-project is being developed in the existing ROW and some additional land is being acquired for administrative block, flyovers etc. which is land.

 The project does not involve diversion of forest land. However, approximately 1354 trees were coming in ROW which have been shifted to proposed ROW. The concessionaire will be doing avenue and median plantation on the entire stretch.

 The sub-project has the required national and local level permits and approvals for project implementation.  Concessionaire has confirmed continuous compliance with the terms and conditions stipulated while according statutory clearances /approvals /consents. Concessionaire was implementing environment management measures at site and a structured EMP has been proposed for the sub project. The EMP implementation will be monitored by IIFCL.  The institutional arrangement available for the implementation of environment, health & safety appears to be adequate.  The concessionaire is maintaining adequate safety at the site. The EMPs will minimize any significant negative impact on environment.

ESDDR NO. IIFCL/ESMU/ADB/2019/115/V2 25

Environment and Social Due Diligence Report Dewas Bypass Tollway Private Limited

 During site visit and discussion with the project developer, the implementation of management measures was found to be adequate.  After approval from the ADB the ESDDR will be uploaded on website for public disclosure.

52. Based on the site visit and due diligence findings, it can be deduced that the sub-project has no significant environmental safeguard issues. The sub-project, therefore, does not appear to involve any kind of reputational risk to ADB funding on environmental safeguards.

ESDDR NO. IIFCL/ESMU/ADB/2019/115/V2 26

Environment and Social Due Diligence Report Dewas Bypass Tollway Private Limited

DUE DILIGENCE ON SOCIAL SAFEGUARDS

ESDDR NO. IIFCL/ESMU/ADB/2019/115/V2 27

Environment and Social Due Diligence Report Dewas Bypass Tollway Private Limited

24. PURPOSE OF THE SOCIAL SAFEGUARDS DUE DILIGENCE

53. The Social Safeguards Due Diligence Report (SSDDR) has been carried out by India Infrastructure Finance Company Limited (IIFCL) in consultation with the Concessionaire, Dewas Bypass Tollway Pvt. Ltd. (DBTPL) to assess the Social safeguards compliances of the project with the applicable National Policies. The report has been prepared as per the documents/information received from the concessionaire and subsequent to the site visit on 15th October 2019. The information given in the SSDDR is agreed and confirmed by the Concessionaire.

25. PROJECT AGAINST THE PROHIBITED INVESTMENT ACTIVITIES LIST

54. The sub project does not involve any prohibited activity as per the Prohibited Investment Activities List (PIAL) of ADB.

26. OBJECTIVE OF SOCIAL SAFEGUARDS DUE DILIGENCE

55. Social Safeguards due diligence study is carried out to assess the social safeguards monitoring compliance status of the project as per the applicable National policies/procedures as observed during the site visit as well as the information received. The main objective of this Social Safeguard Due Diligence Report (SSDDR) is:

 To assess the likely social impacts and its minimization/mitigation majors adopted for the project with respect to land acquisition, compensation , Indigenous people affected, involuntary resettlement and common properties resources affected, if any, in terms of displacement, loss of incomes, and community links:

 To ascertain, in case of any adverse impact, if appropriate mitigation measures have been taken during the project planning, designing and frameworks established for carrying out safeguard measures during the construction stage to minimize and mitigate such if any adverse impacts.

27. APPROACH AND METHODOLOGY

56. The Social safeguard due diligence study for Dewas Bypass Tollways Pvt Ltd (DBTPL) has been carried out after reviewing the documents made available by the subproject developer. On site visit to the project location by the Environment and Social Safeguards Specialist and Social Consultant, discussion with the project developer and various permits and approvals relating to the project to understand the salient features of the project and social concerns. The following ESDDR NO. IIFCL/ESMU/ADB/2019/115/V2 28

Environment and Social Due Diligence Report Dewas Bypass Tollway Private Limited

documents/Reports/Licenses/permits and notifications were referred in order to prepare the Social Safeguard Due Diligence Report:  Project Information Memorandum (PIM);  Right of Way (RoW) handover letter  Concession Agreement  Lender’s Independent Engineer (LIE) Reports  Independent Engineer Report  Labour License & insurance

28. SOCIAL IMPACT OF THE PROJECT

27.1 Land Acquisition in the Project

57. Land acquisition is not in the scope of the project developer and it is under the purview of the Concessioning Authority, Madhya Pradesh Road Development Corporation (MPRDC). Land acquisition for the project DBTPL for 4/6-laning of Dewas Bypass from Km. 0+000 (Ujjain-Dews Junction) to Km. 19+800 (Total Length 19.800) in the state of Madhya Pradesh on Build, Operate and Transfer (BOT) basis has been completed by MPRDC. During the discussion and subsequent to the mail received from the project developer it was informed that the land acquisition including the present right of way was acquired by the authority MPRDC in the year 2009.

58. As per provision of the Concession Agreement, 100% the Right of Way (RoW) encumbrance free for 4/6 laning of Dewas Bypass to the extent of 60m has been handed over to the Concessionaire by MPRDC. At the time of two laning of the project, the land was acquired in the year 2009 and handed over in one phase to the project developer after awarding the work in 2017. The RoW hand over letter is attached as Annexure XIX.

59. During the discussion it was told that the total land including the present right of way was acquired at the time of two laning of project and the additional right of way for accommodating the future widening of the existing road for 4/6 laning was kept on median. As per the information provided by the project developer the purpose wise land for 4/6 laning of Dewas Bypass is given in Table 5:

Table 5: Status of Land available at DBTPL Sl. No. Purpose Land in Hectare (Ha.) 1. Widening of the existing road for 4/6 laning 118.8 2. Realignment Nil 3. Toll Plaza & Truck lay bye 1.20 Total 120

ESDDR NO. IIFCL/ESMU/ADB/2019/115/V2 29

Environment and Social Due Diligence Report Dewas Bypass Tollway Private Limited

60. Land acquisition process was initiated prior to IIFCL’s involvement and not in anticipation of ADB financing.

27.2 Impact on Structure

61. The sub-project stretch falls in Dewas district in the state of Madhya Pradesh. The entire section of project road is passing through plain terrain. As informed by the concessionaire and noted during the site visit, that no structure is getting affected due to the project.

27.3 Rehabilitation and Resettlement impact in the sub-project

62. During the site visit it was informed that there was no involuntary resettlement because of land acquisition for the project. Further during the site visit it was observed that there was no rehabilitation and resettlement in the project.

27.4 Impact on Indigenous people

63. As information provided by the concessionaire the project does not disturb indigenous people in the project and does not have adverse impact or create any threat to the survival of any indigenous community along the alignment, hence no indigenous people affected in this sub- project.

29. GREIVANCE REDRESSAL MECHANISM FOR THE SUB-PROJECT

64. The Grievance Redressal Register is maintained at project site to ensure that any affected person’s grievances are adequately addressed and to facilitate timely project implementation. During the site visit it was observed that the project authority has formed their own institutional arrangements to deal with complaints on site resolve of the issues concerns.

30. EMPLOYMENT GENERATION

65. As informed by the concessionaire, the project land acquisition was completed during 2 to 4- laning of project in the year 2009, so the project does not impact the livelihood of the local people. It has been confirmed by the concessionaire that employment opportunities are being provided to the local people for various unskilled and semi-skilled activities like security guards and office assistants, drivers.

66. During the discussions it was informed that the employment opportunity is being given to more than 70 local people belongs to the nearby areas during the project construction period. Further it was also informed that during the operation of toll plaza as much as possible local people will be given employment opportunity at toll plaza location.

ESDDR NO. IIFCL/ESMU/ADB/2019/115/V2 30

Environment and Social Due Diligence Report Dewas Bypass Tollway Private Limited

31. THE COMMUNITY ENGAGEMENT ACTIVITIES

67. As information provided by the concessionaire, to reach the local people, DBTPL has under taken few of community development activates to reach the local people during the construction stage of the project. The subproject developer celebrated its road safety week, blood donation camp, free medical check-up camp, health and hygiene awareness camps has also been under taken under community development initiatives as per the demands made by the local community / nearby village/Panchayats.

32. LABOUR LICENSE OBTAINED BY THE SUBPROJECT DEVELOPER

68. The Labour license has been granted to the subproject developer Dewas Bypass Tollway Pvt. Ltd. (DBTPL) under Section 12 (1) of the Contract Labour (Regulation and Abolition), Act, 1970. The Labour Commissioner, Government of Madhya Pradesh, Dewas has issued the license for construction of Dewas Bypass. As per the labour licenses the subproject developer can employ as contract labour in the establishment shall not, on any day, exceed 300 Nos. The labour license is attached as Annexure VI.

33. DISCLOSURE

69. After approval from the ADB, the report will be uploaded for public disclosure in ADB and IIFCL’s website.

34. SITE VISIT OBSERVATION

70. A site visit was undertaken by IIFCL’s Environment and Social Safeguard Specialists and Social Safeguards Consultant on15th October, 2019. The site visit was undertaken to review the implementation of the project’s environmental and social safeguards parameters at the project site. . The sub-project at the time of site visit was in the stage of construction, and more than 83% of construction activity was completed and the Concessionaire is hopeful to achieve the COD in the month of December 2019.

71. During the site visit and discussions with subproject developer it was observed/noted that :

 The sub-project has been prepared by Madhya Pradesh Road Development Corporation Ltd. (MPRDC) as per its own funding requirement and not anticipation to ADB operation;

 Land acquisition process was initiated and completed prior to IIFCL’s involvement and not in anticipation of ADB financing.;

ESDDR NO. IIFCL/ESMU/ADB/2019/115/V2 31

Environment and Social Due Diligence Report Dewas Bypass Tollway Private Limited

 Land acquisition to the extent of 60m Right of Way (RoW) for 6-laning of this project was completed during 2 laning of project in the year 2009.

 There is no Rehabilitation and Resettlement in the project.

 The subproject do not have any indigenous people in the project;

 Construction workers are provided with ready access to on- or off-site health care check- up facilities and are being provided with first aid facilities for minor injuries;

 As informed during the site visit it was confirmed that no fatal accident happened in the project till date.

 Emergency contact numbers have been displayed at the prominent places in project site.

 During the site visit it was observed that, workers and staffs at the site were seen wearing personal protective equipment such as helmets, jackets, boots, gloves etc.

 As informed by the project developer, after discussions with the local people, the affected cultural properties are being relocated by the concessionaire;

 Local labours are being engaged in the construction activities for skilled as well as unskilled activities;

 It seems that the sub-project does not appear to involve reputational risk to Asian Development Bank funding on social safeguards and recommended for funding under the proposed project.

 Concessionaire has undertaken community development activities based on the demands raised by the local people.

72. Based on the site visits observations and desk review, it appears that the sub-project have no negative significant social safeguard issue.

ESDDR NO. IIFCL/ESMU/ADB/2019/115/V2 32

Collector Court — District Dewas (M.P.)

Letter no./1529/Reader/2017 Dewas, Dated 22- ■-■ ugust-2017

Case no. 09/v-69/2016-2017 :: Permission Letter::

Divisional Manger, Madhya Pradesh Road Development Corporation Limited

through its letter no. 2406/M.P.R.D.C./Dewas Bypass/ R.O.D./R.O.B. 2017 Ujjain,

dated 03-08-2017, stating that under B.O.T. scheme on Dewas Bypass — 4 lane/ 6

lane trees obstructing the road is to be implanted, at present about 1300 tress are

marked to be implanted from 5 to 10 years. Out of which for 495 trees implantation

work is under progress and for 805 trees implantation work is to be done. So

permission for implantation of these marked 1300 trees should be given.

Hence under Madhya Pradesh Land Revenue Code 1959, under section 240 as

stated above permission for implantation of 1300 trees is given with the condition that during implantation Madhya Pradesh Road Development Corporation Ujjain will be totally responsible for life of trees (keep the trees alive).

As stated above during implantation Madhya Pradesh Road Development

Corporation Ujjain will be totally responsible to pay the claim amount for any kind of life/animal loss.

Sd/- Collector Distrcit — Dewas (M.P.) Pg. no./1530/Reader/2017 Dewas, dated 22-August-2017 cc to :- Divisional manager, Madhya Pradesh Road Development Corporation Limited, Ujjain for information and compliance.

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7r77, 745 !;it Erm. , Trviii.-st cl:bIZ1DOraT 3u.AcT c i 3n7 Tct -11z1G11ef I

Consent Order Regional office M.P. Pollt.ition Control Board

Devoe:: Tole 07272251170

GREEN-SMALL CTE-Fresh VALID UP TO: CTE CONSENT NO: **" PCB ID: 111548

NO: /MPPCB/DEW

M/s. I,—( Ind ,e) Infrastructure Ltd,

Survey No. 384/2/2,403/2/2,405/2/2,384/4/4,405/3,384/2/3 & 403/2/1, Shankarghad, De., Dist : Dewas,

Subject: Grant of Consent to Establish under section 25 Of the Water (Prevention & Control of Pollution) Act,1974 under section 21 of the Air (Prevention & Control of Pollution) Act,1981

Rol-. Your Consent to Establish Application Receipt N.. 321949 Dt. 18/05/2017.

Without prejudice tO the powers of this Board under section 25 of the Water (Prevention & Control of Pollution) Aet,1974 under section 21 of the Air (Prevention & Control of Pollution) Act,1981 and without reducing your responsibilities under the said

in any way, this is to inform you that this Board grants Consent to Establish for setting up of an industrial plant/activities at • nkarghad, Dewas, Phone No. 7702200185

SUBJECT TO THE FOLLOWING CONDITIONS

Location: 384/2/2,403/2/2,405/2/2,384/4/4,405/3,384/2/3 & 403/2/1, Shankarghad, Dewas, Contact N.. 7702200185

b. The capital investment in lakhs: Rs. 90

c. Product & Production Capacity:

Product CTE Qty/y RMC Plant 238200Mater cube/year

(Two lakh thirty eight thousand two hundred meter Cube per year)

The consent (For operation) as required shall be granted to your industry after fulfillment of all the Conditions mentioned

above. For this purpose you shall have to make an application to this Board in the prescribed proforma at least two months before

the expected date of commissioning of your Industry. TOO applicant shall not operate the unit without obtaining consent for

operation from the Board and shall not bring In to use any out let for the discharge of effluent and gaseous emission.

Enclosures:-

* Conditions under Water Act * Conditions under Air Act

* General conditions

SSseelthaftom LIDALR ANNEX , NEAR BIMA NAGAR , VIJAY NAGAR , INDORE - 452010 , MADHYA PRADESH e g MILIT Regional Officer e-Signed On 31/05/2017 16:39:15 (Organic Authentication on AADHAR from UIDAI Server) PvitaNy Sign with Aulhatar TPAV # U2DM7D1J6D

Consent No:CTE-45626,Validity:17/05/2018, Outward No: 10202,31/05/2017, TPAV # U2DM7D1J6D

cPSIgnaci (Physical Slenatare NOT P.,,„.: 1 /5 NI ,

Consent Order

To'.: 07272251170

CONDITIONS PERTAINING TO WATER (PREVENTION & CONTROL OF POLLUTION) ACT 1974 :-

1. The daily quantity of trade effluent at out fall of the unit shall not exceed 0.000 KUday, and the daily quantity of sewage

at out fall of the unit shall not exceed 1.000 KL/da y

2. Trade Effluent Treatment: -

The applicant shelh provide comprehensive effluent treatment system as per the proposal submitted to the Board and

maintain the same properly to achieve following standards -

0H Betweer, 5.5 — 9.0 TDS NOt exceed 2100 r../.

Suspended Souris Not exceed 100 mail. 1000 mu/l .

BOD 3 Deye 270C Not exceed 30

COD Not exceed 250 10

For other parameters general standards of discharge as notified under EP Act 1986 shall be applicable.

3. Sewage Treatment The applicant Shall provide comprehensive sewage treatment system as per the proposal submitted

the Board and maintain the same properly to achieve following standards - ,—

0H Between 5.5 — 9.0

Suspended SOl,ds Not exceed 100

BOD 3 D., 27° C N. exceed 100 moll.

COD Not exceed 250 rng/i

Oe end grease Not exceed 10 rag/.

1.1M11.11111111111 )! WC : 68.000 VVWG : 1.000 Waite: Source . 1

1 Domestic Purpose 2. 000 1.000 Borew.,,

2 Mnrg Process 66.000 0.000 Borewo,

4. The effluent shall be treated up to prescribed Standards and reuse In the process, for cooling and for green belt

devolvement/gardening within premises. Hence zero discharge condition shall be practiced. In no case treated effluent shall

be discharged outside of industry/unit premises.

5. Water meter preferably electromagnetic/ultrasonic type with digital flow recording facilities shall be installed separately

for category wise consumption of water as per Water (Prevention and Control of Pollution) Cass Act 1977 For Industrial cooling/boiler feed, mine spray, process & domestic purposes and data shall be submitted online through XGN monthly

patrak/staternents. The industry/unit shall also monitor the treated wastewater flow and report the same online through

Cr monthly patrak/statements.

6. Any change in production capacity, process, raw material used etc. and for any enhancement of the above prior

permission of the Board shall be obtained. All authorized discharges shall be consistent with terms and conditions of this

consent. Facility expansions, production increases or process modifications which result new or increased discharges of

pollutants must be reported by submission of a fresh consent application for prior permission of the Board

7. All treatment/control facilities/systems installed or used by the applicant shall be regularly maintained In good working

order and operate effectively/efficiently to achieve compliance of the terms and conditions or this consent

8. The Consent does not authorize or approve the Construction of any physical structures or facilities or the undertaking of

any work in any water CourSe or within its high flood level (HFL) area

9. The specific effluent limitations and pollution control systems applicable to the discharge permitted herein are set forth as

above conditions.

10. Compilation of Monitoring '

i. Samples and measurements taken to meet the monitoring requirements specified above shall be representative of the

volume and nature of monitored discharge.

ii. Following promulgation of guidelines establishing test procedures for the analysis of pollutants, all sampling and

analytical methods used to meet the monitoring requirements specified above shall conform to such guidelines unless

otherwise specified sampling and analytical methods shall conform to the latest edition of the Indian Standard specifications

and where it is not specified the guidelines as per standard methods for the examination or Water and Waste latest edition of

Consent No:CTE-45626,Validity:17/05/2018, Outward No: 10202,31/05/2017, TPAV # U2DM7D1J6D a - Sigrieb (Physical Signature NOT reguires) Page: 2 /5 111 I •

Consent Order Regional office

Dewey ,.../#'4•000"%esior -esso"ftssiegoft...... Tc,le : 07272251170 -.6110keisolfiis.r

the American Public Health Association, New York U.S.A. shall be used.

The applicant shall take samples and measurement to meet the monthly requirements specified above and report online

through XGN the same to the Board.

11. Recording of Monitoring -

I. The applicant shall make and maintain online records of all information resulting From monitoring activities by this

Consent. ii. The applicant shall record for each measurement of samples taken pursuant to the requirements of this Consent as

followS:

(I) The date, exact place and time of sampling

(II) The dates on which analysis were performed

(iii)Who performed the analysis?

(iv)The analytical techniques or methods used and

(v)The result of all required analysis

If the applicant monitors any Pollutant more frequently as is by this Consent he shell include the results of such

monitoring in the calculation and reporting or values required in the discharge monitoring reports which may be prescribed

by the Board. Such increased frequency shall be Indicated on the Discharge Monitoring Report Form.

iv. The applicant shall retain for a minimum of 3 years all records of monitoring activities including all records of Calibration and maintenance of instrumentation and original strip chart regarding continuous monitoring instrumentation.

The period of retention shall be extended during the course of any unresolved litigation regarding the discharge of

pollutants by the applicant or when requested by Central or State Board or the court.

12. Reporting of Monitoring Results: -

Monitoring Information required by this Consent shall be summarized and reported by submitting a Discharge Monitoring

report on line to the Board.

13. Limitation of discharge of oil Hazardous Substance in harmful quantities: -

The applicant shall not discharge oil or other hazardous substances in quantities defined as harmful in relevant regulations

into natural water course. Nothing In this Consent shall be deemed to preclude the institution of any legal action nor relive

the applicant From any responsibilities, liabilities, or penalties to which the applicant is or may be subject to clauses.

14. Limitation of visible floating solids and foam:

During the period beginning date of issuance the applicant shall not discharge floating solids or visible Foam.

15. Disposal of Collected Sol id -

All hazardous waste/sludge shall be disposed of as per the Authorization issued under Hazd & other waste Ru les 2016.

And/other Solids Sludges, dirt, slit or other pollutant separated from or resulting from treatment shall be disposed of in such

a manner as to prevent any pollutant from such materials from entering any such water Any live Fish, Shall fish or other

animal collected or trapped as a result of intake water screening or treatment may be returned to eaters body habitat.

16. Provision for Electric Power Failure -

The applicant shall assure to the consent issuing authority that tho applicant has installed or provided for an alternative

electric power source sufficient to operate all facilities utilized by the applicant to maintain compliance with the terms and

conditions of the Consent.

17. Prohibition of By pass system -

The diversion or by -pass of any discharge from facilities utilized by the applicant to maintain compliance with the terms

and conditions of this Consent in prohibited except

i. where unavoidable to prevent loss of life or severe property damage, or

ii. Where excessive storm drainage or run off would damage any facilities necessary for compliance with the terms and

conditions of this Consent. The applicant shall immediately notify the Consent issuing authorities in writing of each such

diversion or by -pass in accordance with the procedure specified above for reporting non -compliance.

18. Industry/Institute/mine management shall submit the information online through XGN in reference to compliance of

consent conditions.

Consent No: CTE-45626,Va I idity : 17/05/2018, Outward No: 10202,31/05/2017, TPAV # U2DM7 D1J6 D

„-Signed (Physical Signature NOT requires) Page: 3 / 5 111 I

Consent Order RRegionalCIf_110 fl a I office M.P. Pollution /roloot BoOrc.1

Dewar

T010 07272251170

CONDITIONS PERTAINING TO AIR (PREVENTION & CONTROL OF POLLUTION) ACT 1981 :-

1. The applicant Brig" l provide comprehensive air pollution control System consisting of control equipments as per the proposal

submitted to the Board with reference to generation of emission and Same shall be operated & maintained continuously so as to

achieve the level or pollutants to the following Standards: -

2 . Ambient air quality at the boundary of the industry/unit premises shall be monitored and reported to the Board regularly on quarterly basis: The Ambient air quality norms are prescribed in M0EF gazette notification no. GSR/826(E). dated: 16/11/09. Some of the parameters are as follows:

a. Particulate Matter (less than 10 micron) - 100 pg/m3 (PM10 pg/m3 24 hrs. basis) b. Particulate Matter (less than 2.5 micron) - 60 p0/0,3 (PM2.5 pg/r03 24 hrs. basis) c. Sulphur Dioxide [S02] (24 hrs. Basis) - 80 ps/0,3 0. Nitrogen Oxides [Na<] (24 hrs. Basis) - 80 Ng/m3 e. Carbon Monoxide [CO] (8 hrs. Basis) 2000 pg/m3

3. The industry shall take adequate measures For control of noise level generated from industrial activities within the

premises less than 75 dB(A) during day time and 70 dB(A) during night time.

4. The Industry/unit shall make the necessary arrangements for control of the fugitive emission from any source of

erniSSion/section/activities.

5. All other fugitive emission sources such as leakages, seepages, Spillages etc shall be ensured to be plugged or sealed or

made airtight to avoid the public nuisance.

6. The industry/ unit shall ensure all necessary arrangements For control of odour nuisance from the industrial activities or

process within premises

7. All the internal roads shall be made pucca to control the fugitive emissions of particulate matter generated due to

transportation and internal movements. Good housekeeping practices shall be adopted to avoid leakages, seepages, spillages

etc..

Additional Air condition:-

1.Inclustr y shall take effective steps for extensive tree plantation within or around the Industry/unit premises for general

Improvement of environmental conditions.

2.Unit shall install appropriate air pollution control equipments at all points of emission at the earliest of the plant and shall

Ensure that these are always kept In running and in good working order all time.

3.The approach road should be properly developed and should be sprayed with water

Consent No:CTE-45626,Validity:17/05/2018, Outward No: 10202,31/05/2017, TPAV # U2DM7D1J6D 4 / 5 III I II

Consent Order ReglonAl orrice M.P. Pollution Control Board ■••■•■•04AMMIN.INOVIII Dowas •■•••• —•Norall"-•%.,e Tele : 07272251170 ■4111110111.werar....

"414.1gir-

GENERAL CONDITIONS:

2. The applicant shall allow the Starr or Madhya Pradesh Pollution Control Board and/or their authorized representative.

upon the representation of credentials:

a. To inspect raw material stock: manufacturing processes, reactors, premises etc to perform the functions or the

Board. b. To enter upon the applicant's premises where an effluent source is located or in which any records are required to

be Kept under the terms and conditions of this Consent.

c. To have access at reasonable times to any records required to be kept under the terms and Conditions of thiS

Consent.

d. To inspect at reasonable times any monitoring equipment or monitoring method required in this Consent: or,

e. To sample at reasonable times any discharge or pollutants.

3. This consent/authorisation is transferable, in case of change of ownership/management and addresses of new Owner/partner/Directors/proprietor should Immediately apply For the same.

4. The issuance of this Consent does not convey any property ri ghts in either real or personal property or any exclusive

(-or privileges, nor does it authorise any invasion of personal rights, nor any infringement of Central, State or local laws or

'egulatiOn5.

5. Industry shall install separate electric metering arrangement for running of pollution control devices and this arrangement

shall be made in such Fashion that any non Functioning of pollution Control devices Shall immediately Stop electric Supply to

the production and shall remain tripped till such time unless the pollution control device/devices are made functional. The

record of electricity consumption For running of pollution control equipment shall be maintained and submitted to the Board

every month

6. This consent is granted in respect of Water pollution control Act 1974 or Air Pollution Control act, 1981 or Authorization

under the provisions of Hazardous and other Waste (Management & Transboundary movement) Rules 2016 onl y and does

not relate to any other Department/Agencies. License required from other Department/Agencies have to be obtained by the

unit separately and have to comply separately as per there Act / Rules.

7. Balance consent/authorisation fee, If any shall be recoverable by the Board even at a later date.

8. The applicant shall submit such information, forms and fees as required by the board not letter than 180 day prior to the

date of expiration of this consent/authorisation

9. Knowingly making any false statement for obtaining consent or compliance of consent conditions shall result In the

imposition of criminal penalties as provided under the section 42(g) of the Water Act or section 38 (g) of the Air Act

10. After notice and opportunity for the hearing , this consent may be modified, suspended or revoked by the Board in whole

3r In part during Its term for cause including, but not limited to, the Following

(a) Violation of any terms and conditions or this Consent.

(b) Obtaining this Consent by misrepresentation of failure to disclose fully all relevant Facts.

(c) A change in any Condition that requires temporary or permanent reduction or elimination of the authorized discharge.

11. On violation of any of the above - mentioned conditions the consent granted will automatically be taken as canceled and

necessary action will be initiated against the industry.

isrtimfroakliliS dl.R ANNEX , NEAR BIMA NAGAR , VUAY NAGAR , INDORE - 452010 , MADHYA PRADESH WSW ( PRegionarbfficet) e-Signed On 31/05/2017 16:39:15 (Organic Authentication on AADHAR from UIDAI Server) Dlitaivr.i Sign w4h AChiktaf TPAV # U2DM7D1J6D Consent No:CTE-45626,Validity:17/05/2018, Outward No: 10202,31/05/2017, TPAV # U2DM7D1J6D ■ Signed (Physical Signature NOT 5 / 5 ill I

O Consent Order Regional office NI.P. Pollution Control Board Dewas

Tele : 07272-251170

GREEN-SMALL CCA-Renewal Validity (A/W) 31/5/2020 CONSENT NO: *** PCB ID: 1115481 Consent No:AW-65109 )" &ik-ttn)5/2 )19

To, The Occupier, M/s. Ijm(India) Infrastructure Ltd, Survey No.384/2/2,403/2/2,405/2/2,384/4/4,405/3,384/2/3 & 403/2/1, Shankarghad, Tehsil & District Dewas (M.P.)

Subject: Renewal of Consent under section 25 of the Water (Prevention & Control of Pollution) Act,I 974 under section 21 of the Air (Prevention & Control of Pollution) Act,1981 Ref: Your renewal of Consent Application Receipt No. 823746 Dt. 27/04/2019

With reference to your above application for renewal of consent has been considered under the aforesaid Acts and existing rules therein. The M. P. Pollution Control Board has agreed to renewed consent up to 31/5/2020, subject to the fulfillment of the terms & conditions, enclosed with this letter and.

SUBJECT TO THE FOLLOWING CONDITIONS :- a. Location: Survey No.384/2/2,403/2/2,405/2/2,384/4/4,405/3,384/2/3 & 403/2/1, Shankarghad, Tehsil & District Dewas. b. The capital investment in lakhs: Rs. 90 c. Product & Production Capacity: S.No. Products Qty/y 1. RMC Plant 238200Meter cube/year (Two lakh thirty eight thousand two hundred meter cube per year)

Note:- For any change in above industry Mall obtain _fresh consent from the hoard . The Validity of the consent is up to 31/05/2020 and has to be renewed before expiry of consent validity. Online application through XGN with annual license fees inthisregard shall be submitted to this office 6 months before expiry of the consent/Authorization. Board reserves the right to amend/cancel / revoke the above condition in part or whole as and when required. Enclosures:- * Conditions under Water Act * Conditions under Air Act

* General conditions

cue LEW e 90 MTN'

D.O.Pro, for. we V* ...Law.. e-Signed On 09/05/2019 17:28:28 ALOK KUMAR JAIN (Organic Authentication on AADHAR from UIDAI Server) Regional Officer TPAV # 947786ENF4

This Certificate generated from xgnmp.nic. in are valid and does not require physical signatures. the certificate can be validated online from xgn.mp.nic.in using "TPAV" Number. Page: I 5