Initial Environmental Examination

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

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

Prepared by the Tamil Nadu Slum Clearance Board for the Asian Development Bank.

CURRENCY EQUIVALENTS

(as of 1 June 2020)

Currency Unit – Indian rupees (₹)

₹1.00 – $0.015

$1.00 = ₹72.18

ABBREVIATIONS

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

WEIGHTS AND MEASURES

C – Degree Celsius

km – kilometer

LPCD – liters per capita per day

m – meter

Mgd – Million gallons per day

MLD – Million Litres per day

mm – millimeter

nos. – numbers

km2 – square kilometer

dBA – A-weighted decibels

LAeq – Equivalent Continuous Sound Pressure Level

μg/m3 – micrograms per cubic meter

KLD – kiloliters per day

NOTE

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

This initial environmental examination is a document of the borrower. The views expressed herein do not necessarily represent those of ADB's Board of Directors, Management, or staff, and may be preliminary in nature. Your attention is directed to the “terms of use” section on ADB’s website. In preparing any country program or strategy, financing any project, or by making any designation of or reference to a particular territory or geographic area in this document, the Asian Development Bank does not intend to make any judgments as to the legal or other status of any territory or area.

CONTENTS

EXECUTIVE SUMMARY ....................................................................................................... i

I. INTRODUCTION ............................................................................................................ 1

A. Background ............................................................................................................. 1

B. Subproject Scope and Location ............................................................................... 2

C. Purpose/ Objectives of IEE ...................................................................................... 7

D. Report Structure ...................................................................................................... 8

II. POLICIES, LEGAL AND INSTITUTIONAL FRAMEWORK ............................................. 9

A. ADB Safeguard Policy Statement (2009) ................................................................. 9

B. National and State Laws ........................................................................................ 10

C. Applicable International Standards and Best Practices .......................................... 17

D. International Treaties/Conventions/Declarations on Environment Management .... 22

III. DESCRIPTION OF THE PROJECT ............................................................................. 24

A. Subproject Overview ............................................................................................. 24

B. Proposed Subproject Interventions at the Resettlement Site. ................................ 26

C. Proposed Subproject Interventions at the Encroachment Sites Identified for

Relocation .................................................................................................................... 40

D. Existing Condition of the Encroachment Sites Identified for Relocation ................. 40

E. Project Proposal for the Relocated Sites ............................................................... 45

IV. DESCRIPTION OF THE ENVIRONMENT (BASELINE DATA) ..................................... 47

A. Area of Impact ....................................................................................................... 47

B. Methodology used for Environment Baseline Study ............................................... 47

C. Physical Environment ............................................................................................ 47

D. Biological Environment .......................................................................................... 56

E. Social Environment ............................................................................................... 58

V. ANALYSIS OF ALTERNATIVES .................................................................................. 61

VI. ANTICIPATED ENVIRONMENTAL IMPACTS AND MITIGATION MEASURES........... 66

A. Assessment of Environmental Impacts .................................................................. 67

B. Pre-construction Impacts and Mitigation Measures ............................................... 67

C. Construction Impacts and Mitigation Measures ..................................................... 70

D. Post-Construction Impacts and Mitigation Measures ............................................. 74

VII. INFORMATION DISCLOSURE, CONSULTATION AND PARTICIPATION .................. 77

A. Consultation and Participation ............................................................................... 77

B. Public Consultation ................................................................................................ 77

C. Information Disclosure and Future Consultations .................................................. 80

VIII. GRIEVANCE REDRESS MECHANISM ....................................................................... 81

IX. ENVIRONMENTAL MANAGEMENT PLAN .................................................................. 85

A. Environmental Management Plan .......................................................................... 85

B. Implementation Arrangements ............................................................................. 141

C. Monitoring and Reporting .................................................................................... 148

D. EMP Implementation Cost ................................................................................... 149

X. CONCLUSION AND RECOMMENDATIONS ............................................................. 152

LIST OF TABLES

Table 1: Details of Subproject Scope

Table 2: Encroachment sites Identified for Relocation

Table 3: Environmental Guidelines for Subproject Selection under Output 1

Table 4: Environmental Regulatory Compliance (National and State Laws)

Table 5: Clearances and Permissions Required by the PMU for Project Construction

Table 6: Clearances and Permissions Required by the Contractor for Project Construction

Table 7: National Ambient Air Quality Standards and WHO Guidelines

Table 8: National Noise Standards and WHO Guidelines

Table 9: National Drinking Water Quality Standards and WHO Guidelines

Table 10: Standards for Sludge Reuse as Manure

Table 11: International Treaties/ Conventions/ Declarations on Environment

Table 12: Salient Features of the Reddiyarpatti Resettlement Site

Table 13: Plinth Area Details of Proposed Residential Units at the Resettlement Site

Table 14: Overall Built-up Area Details of the Buildings at the Resettlement Site

Table 15: Built-up Area Details for ADB Portion

Table 16: Site Infrastructure Details

Table 17: Subproject Interventions at the Resettlement Site

Table 18: Overall Power Requirement at the Resettlement Site

Table 19: Power Requirement at the Resettlement Site (ADB Portion)

Table 20: Water Requirement at the Resettlement Site

Table 21: Estimated Rainwater

Table 22: Green Area Details

Table 23: Solid Waste Generation at the Resettlement Site

Table 24: Subproject Interventions

Table 25: Existing Condition of the Encroachment Sites Identified for Relocation

Table 26: Rainfall information for Tirunelveli District

Table 27: Central Pollution Control Board

Table 28: Tamirabarani River Water Quality (annual average values), 2014-2015

Table 29: Groundwater Quality in Tirunelveli, 2014

Table 30: Ambient Air Quality in Tirunelveli

Table 31: Ambient Noise Levels in Tirunelveli

Table 32: MSME Industrial Units in Tirunelveli City – Zone wise

Table 33: Information on the Archaeological Monuments

Table 34: DWATS Salient Features

Table 35: Alternative Approach in Building Plan

Table 36: Outcome of the Analysis of Alternatives

Table 37: Meetings/Discussions between various stake holders

Table 38: Environmental Management Plan for Construction Site - Reddiyarpatti, Tirunelveli

District

Table 39: Environmental Management Plan for Operation and Maintenance - Reddiyarpatti,

Tirunelveli District

Table 40: Environmental Management Plan for Building Demolition Works (Encroachment

Sites identified for Relocation)

Table 41: Environmental Management Plan for Water body Restoration Works

Table 42: Pre-construction & Construction Stage Environmental Monitoring Plan

Table 43: Operation Stage Environmental Monitoring Plan

Table 44: Institutional Roles and Responsibilities for Safeguards Implementation

Table 45: Outline Capacity Building Program on EMP Implementation

Table 46: Indicative EMP Budget

LIST OF FIGURES

Figure 1: Map Showing Sites Chosen for Relocation and Resettlement

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

Figure 3: Relocation sites within 10km radius from Reddiyarpatti

Figure 4: Photograph of the Resettlement Site

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

Figure 6: Proposed Sewer Line (ADB Portion)

Figure 7: Proposed Water Supply Line (ADB Portion)

Figure 8: Proposed Storm Water Drain (ADB Portion)

Figure 9: Proposed Green Belt Area

Figure 10: STP Process Flow Diagram and SBR Structure – Water Balance for Reddiyarpatti

Resettlement Site

Figure 11: Rainwater Harvesting Structure

Figure 12: Layout for Micro Composting Center

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

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

Figure 15: Construction Schedule Bar Chart

Figure 16: Reddiyarpatti (Project area ) Location

Figure 17: Elevation profile for the Resettlement site at Reddiyarpatti

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

Figure 19: Seismic Map for Reddiyarpatti Project Area

Figure 20: Landuse Pattern (Google earth image and Bhuvan Landuse map) of the

Subproject Area

Figure 21: Groundwater Prospects for Reddiyarpatti Subproject Area

Figure 22: Location of Vallanadu Blackbuck Wildlife Sanctuary

Figure 23: Location of Koonthankulam Wildlife Sanctuary

Figure 24: National Monuments surrounding the Project Area

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

Figure 26: Grievance Redress Process

APPENDICES

Appendix 1 : Confirmation letter - Encroachments in the Water body

Appendix 2 : Land Transfer certificate

Appendix 3 : Land Use Classification Government Order

Appendix 4 : Rapid Environmental Assessment (REA) Checklist

Appendix 5 : Environmental Clearance from SEIAA

Appendix 6 : Salient Features of Major Labor Laws Applicable to Establishments

Engaged in Construction of Civil Works

Appendix 7 : Confirmation letter from Tamil Nadu Electricity Board

Appendix 8 : Certificate Indicating Resettlement site is not Vulnerable for Flooding

Appendix 9 : Acceptance Letter for Collection of Municipal Solid Waste

Appendix 10 : Permission letter for Discharge of Treated Sewage Water

Appendix 11 : Tamil Nadu Water Supply and Drainage Board (TWAD) Acceptance/

Acknowledge for the Supply of Water to Reddiarpatti Resettlement Site

Appendix 12 : Confirmation Letter for Collection and Disposal of Sludge Generated from

the STP installed at Reddiarpatti Resettlement Site

Appendix 13 : Compliance matrix for the Environmental Clearance Conditions

Appendix 14 : Groundwater Quality Test Result for Reddiarpatti Resettlement Site

Appendix 15 : IBAT Study for the Subproject Area

Appendix 16 : Health and Safety Plan/ Response and Measures for COVID 19

Appendix 17 : Sample Grievance Form

Appendix 18 : Sample Environmental Site Inspection Report

Appendix 19 : Quarterly Environmental Monitoring Template

Appendix 20 : Outline of Daily Monitoring Sheet for Contractors

Appendix 21 : Source sustainability study for supply of water to the Reddiarpatti

Resettlement Site

EXECUTIVE SUMMARY

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

Component 1: Affordable Housing for Vulnerable Communities

Component 2: Affordable Housing for Urban Poor and Migrant Workers

Component 3: Regional Planning

This subproject proposed under Output 1 is for (i) the construction of 2,124 residential housing units (which includes 876 residential units proposed under ADB funding and 1,248 residential units proposed under government of Tamil Nadu funding) and associated facilities at the resettlement site at Reddiarpatti in Tirunelveli district; (ii) demolition of 807 structures located in 9 encroachment sites identified for relocation to Reddiarpatti; and (iii) restoration of 9 water bodies. It is estimated that 807 households will be relocated to Reddiarpatti site. Executing and implementing agencies. The Government of Tamil Nadu through the Housing and Urban Development Department (HUDD) will be the executing agency (EA) and responsible for overall project management and compliance with loan assurances. The Tamil Nadu Slum Clearance Board (TNSCB) will be the Implementing Agency for Output 1. TNSCB will also be responsible for the management, coordination and execution of all subproject activities funded under IRSHUPSP. The TNSCB has set up a Project Management Unit (PMU) that will be responsible for overall supervision and coordination during subproject implementation. The PMU will be supported by Project Implementation Circle located at Salem and three Project Implementation Divisions (PIDs) are located at Madurai, Salem and Villupuram and they will be responsible for day-to-day activity and compliance with safeguards during project implementation. The PMU will be headed by Joint Managing Director/ Project Director and will be assisted by the Chief Engineer and the Superintending Engineer. They will be supported by technical, financial, safeguards and administrative staff. It is proposed to have 3 PIDs under the PMU. An Executive Engineer will head each PID. PIDs will be responsible for the implementation, management and monitoring of the subprojects. Subproject Scope: The Reddiarpatti subproject scope of work includes (i) Construction of 2,124 residential housing units (which includes 876 residential units proposed under ADB funding and 1,248 residential units proposed under government of Tamil Nadu funding) at new settlement site, (ii) Demolish 807 housing units identified for relocation across 9 encroachments, (iii) Regeneration works across 9 water bodies (that were encroached). The subproject scope of work is enclosed in Table 1.

Table 1: Details of Subproject Scope Sl.no Subproject Subproject Interventions

1 Construction and operation of 2,124 residential units (including 876 residential units funded

Main Entry

Bus Bay

Visitors Centre

Open Market

Community Hall

ii

Sl.no Subproject Subproject Interventions

by ADB) and supporting services

Convenience Store

Anganwadi

Ration Shop

Fruit Orchard

Community Farming

Hilltop Walk

Hill Walking Path

Discovery Zone

Demonstration Farm

Approach roads and internal roads

Livelihood Centre

Play Park

Outdoor Gym

Surface Parking

Driveway

Sewage Treatment Plant

Rainwater Harvesting Structures

Health Sub Centre

Solar Power streetlights

Solid Waste Management

Micro-composting Center

2 Demolishing structures in the encroachment site (prone to flooding)

Demolition of 807 structures in the 9 encroachment sites

Provide fencing to prevent further encroachment

3 Water body restoration Clearance and fencing

Restoration of water bodies, which were encroached

Provision for public parks/ recreation areas as per the community’s requirement

Avenue plantation/ landscaping

Re-greening / re-vegetation along water body / canal banks

Clearing and preventing new solid waste / sewage disposal in water bodies / channels

Implementation of site-specific plans in close coordination with ULBs or Public Works Department (PWD) e.g. waste management plan, sewerage collection and management plan, etc.

Source: TNSCB

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

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addressing the conditions (General and Specific Conditions), as given in the Environmental clearance for Reddiarpatti Resettlement Site;(ii) Update of IEE and EMP based on the water source sustainability study report (including water quality) from TWAD and (iii) Consent to Establish and Consent to Operate under air and water act for the hot mix plant /batching plant, Construction (workers) camps and proposed STP. Other project-related permissions/consents to be obtained by the Contractor are detailed in the IEE report. Project Benefits. The key objective of this project is to provide affordable housing for the people who are living in the encroached areas (encroached water bodies), which is prone for seasonal flooding. This project also benefits, the low-income families, female-headed households. Based on the climate risk assessment and heat modelling, the building plan has been developed to withstand the climate change including the high temperature. The proposed infrastructures including provision of toilets, water supply arrangement, electric connection, community center, play area shall provide an improved standard of living. Description of the Environment. The Reddiarpatti subproject site (8°40'30.13"N, 77°44'56.68"E) is located in the Tirunelveli District. The maximum elevation is at 84m AMSL and the lowest is 74m AMSL. The soil type is deep red soil, which is suitable for cultivating coconut and palmyrah trees. The maximum temperature is 39.4°C in the month of May and minimum is 21.7°C in the month of January. The minimum recorded rainfall is 107.7 mm and maximum rainfall is 639.9 mm. Annual average rainfall is 845.1 mm. The wind direction is predominantly towards North and West in the mornings and South and East in the evenings. The subproject site is in Low Damage Risk Zone II. River Tamirabarani1 is located close to the Reddiarpatti site at a distance of 7 km. Groundwater quality is observed to be good, in general it is colourless, odourless and slightly alkaline in nature. There are no sensitive areas like forest or protected areas that are located within a radius of 10km surrounding the sub project area. According to the 2011 Census, Reddiarpatti's population is 5,166. Out of this, 2,629 are males while the females count 2,537. There are no ASI sites in the near vicinity to the subproject area. Water supply to the subproject area is from the River Tamarabarani. The subproject site is well connected by the Railways, Highways (National Highways and State Highways). Potential Environmental Impacts and Mitigation Measures. The subproject is unlikely to cause significant adverse impacts that are irreversible, diverse or unprecedented because: (i) the components will involve straightforward construction and operation, so impacts will be mainly site specific and localized; and (ii) there are no significant sensitive environmental features in the subproject sites although careful attention needs to be paid to minimize disruption to the community. Land acquisition related issues are not envisaged in this project, because the proposed resettlement site belongs to TNSCB. The primary areas of impact are (i) sites for proposed project components; (ii) main routes/intersections which will be traversed by construction vehicles; and (iii) quarries and borrow pits as sources of construction materials. The secondary areas of impact are: (i) other than the delineated primary impact area; and (ii) new resettlement site (Reddiarpatti) and the 9 encroachment sites (old settlement sites) in terms of overall environmental and socioeconomic improvement. Pre-construction impacts are associated with: (i) shifting of utilities (including water supply, electricity, etc.) in the 9 encroachment sites (old settlement sites), which is chosen for relocation. Utility shifting is not envisaged in the resettlement site (Reddiarpatti) due to lack of habitation in the surrounding areas. (ii) Site selection for the source of construction materials have to be identified before construction commences with a proposed mitigation measure to procure construction materials from the government authorised / permitted quarries and

1 Tamirabarani is a perennial river; originating from Agastyarkoodam peak in the Western Ghats above Papanasam

in Ambasamudram Taluk and flows through Tirunelveli and Tuticorin districts of Tamil Nadu and drains in Gulf of Mannar.

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vendors, which will significantly reduce environmental impacts. (iii) Due to the topography of the resettlement site (which is located in a hillock with a gentle slope), in order for construction to occur it is anticipated to level the area. This will subsequently generate a huge quantity of debris, which has to be disposed in authorised areas or in low-lying areas (as long as it does not impede water flow or cause flooding) as per the direction of the PID. Similarly, the 9 encroachments sites (old settlement sites) that are chosen for resettlement will also be demolished which will generate significant quantity of construction debris, which shall be disposed in authorised areas in consultation with the Tirunelveli Municipal Corporation. (iv) Site selection of construction work camps, stockpile areas, storage areas, and disposal areas. Construction camp should be located 500 m away from the nearby settlements. Residential areas will not be considered for setting up construction camps to protect the human environment (i.e., to curb accident risks, health risks due to air, water and noise pollution, social conflicts and shortage of amenities). (v) Construction traffic will utilise existing roads for access to the work site therefore potential impacts will be of short duration, localized and can be mitigated. Construction related impacts are standard and site specific to the construction activities and not expected to be significant. Key impacts during construction are envisaged on the following aspects: (i) transportation of materials; (ii) dust generation, air and noise pollution from construction activities; (iii) sourcing of water for construction activities; (iv) handling of construction materials at site; and (v) adoption of safety measures during construction. Erosion hazards are anticipated during the project construction due to the sloping topography, hence compaction at the site will have to be conducted to maintain soil stability. Similarly, cut and fill is also anticipated which may generate significant quantity of debris, which should be disposed at the pre identified sites (identified and approved during the pre-construction stage). There are no water bodies surrounding the resettlement sites and hence impact due to runoff from the construction site is not envisaged. However, for the demolition sites (9 encroachment sites), there are surrounding water bodies and hence demolition activity and runoff from the sites will have a significant impact to the water bodies. A mitigation measure has been proposed to use silt trap to prevent pollution of water bodies. Air quality impacts due to the construction activity in the resettlement site is not expected to have a major health impact onto the surrounding areas, because of the lack of human habitat/ settlement in the project area. However, the movement of construction vehicles transporting construction materials and debris/materials to be disposed may cause increase in air pollutants within the construction zone for the resettlement site as well as the 9 encroachment sites. These are inherent construction impacts which are site-specific, low magnitude, short in duration and can be easily mitigated. For noise and vibration impacts, with exemption to piling works, most of the construction activities (including construction and demolishing works) shall be done manually with minimum use of machinery and equipment and with necessary safety precautions, for example, barricades around demolition sites, restricting pedestrian and vehicular movements. Noise from demolition works should not exceed the noise standards as set by CPCB. Hence noise and vibration impacts are not expected to be significant. However, for the piling operation, Piling Rig will be used, it will generate noise and vibration to the surrounding, since there are scattered habitations (the nearest settlement is located at a distance of 250 m), the anticipated noise and vibration impacts shall be minimal. The demolition activities shall not have any impact on the physical cultural resources since no heritage buildings are located near the encroachment sites or the resettlement site. During the project construction and operation, there is a moderate negative impact anticipated on the water resources. This is due to the utilisation of water for construction purposes and use of water for domestic purposes during operation, which will have a moderate stress on the available water resources. For construction purposes, the water shall be sourced from the

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ULB’s or the Tamil Nadu Water Supply and Drainage Board (TWAD). During the operation phase of the project, TWAD will supply water to the Reddiarpatti resettlement sites. The quality of the water will meet IS 10,500 (potable/ drinking water standard). The estimated water demand of 0.67MLD will be sourced from River Tamirabarani at Thirumalaikolundupuram, which is located at a distance of 24 km from the Reddiarpatti resettlement site. The water supply is a surface water source, as such impact on the groundwater is not envisaged. However, TWAD is carrying out various methods / procedures for groundwater recharge, which includes check dams, percolation ponds, artificial recharge pits, recharge trench, ooranies (artificial lakes) and recharge shaft, which will enhance the groundwater recharge potential. For the resettlement site rainwater harvesting structures including 19 rainwater collection pits and an 1125 m rainwater collection trench has been provided. It is estimated that 5,400,000 (54 lakh) litres of rainwater will be collected within the resettlement site. Impact on the flora and fauna during the project construction (comprises of resettlement construction works encroachment demolishing works and water body regeneration works) and operation will be negligible. This is because tree cutting is not required in the resettlement site and there are no protected areas or environmentally sensitive areas surrounding the resettlement sites. However, a few trees are observed in the encroachment areas (demolition work sites), which shall be preserved and included in the landscaping design during the water body restoration works. Impact on Occupational, Health and Safety (OHS) including exposure to work-related chemical, physical, biological and social hazard is likely to occur during proposed construction and demolishing works. Potential impacts are negative and short-term but reversible by mitigation measures including provision of PPE’s, preparation of comprehensive site-specific health and safety (H&S) plan (including asbestos material management) provided with management strategy (including training) and applying practices that are intended to eliminate, or reduce, fatalities, injuries and illnesses for workers. Major post construction impacts are specific to site clean-up activities, which include backfill of any excavation and trenches, reuse of topsoil, re-establishing the drain pattern if impacted, and removal all tools, equipment, barricades, surplus materials, debris and rubbish. Major project operation impacts include: (i) municipal solid waste generation; (ii) wastewater generation from the resettlement site, (iii) health and safety issues (including communicable diseases, fire hazard etc.) and (iv) operation of infrastructures/ amenities including STP, rainwater harvesting structures and maintenance of lawn/ green belt. For the identified impacts the TNSCB has obtained necessary permissions from the competent authority (Tirunelveli Municipal Corporation) for handling and disposing municipal solid waste (MSW) and the discharge of the treated sewage. Hence, the impact anticipated during project operation is manageable. TNSCB have obtained confirmation for the supply of water to the resettlement site from TWAD. Since water will be supplied by the TWAD, the water quality will be maintained as per the IS 10500 drinking water standard requirements. The supply of estimated water demand of 0.67MLD shall not have detrimental impact on the total water supply estimated for the Tirunelveli Municipal Corporation. The main project risk is the low institutional capacity of the PMU, PIDs and contractors and their failure to implement the EMP effectively during construction and operation stages. These risks will be mitigated by: (i) hiring of environmental specialists at PMU and PID level; (ii) providing training and capacity building on environmental and social safeguards to the PMU, PIDs, contractors and workers, (iii) developing and implementing site specific EMPs (C-EMP/ D-EMP/ R-EMP) and Standard Operation and Maintenance Plans (SOMPs); (iv) following appropriate project implementation, mitigation, monitoring and reporting arrangements; and (iv) adequate site supervision including audits of contractor’s environmental, health and safety (EHS) performance. Monitoring parameters will be identified in the environmental monitoring

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plan to check the effectiveness of EMP measures and to ensure any unidentified impacts can be readily addressed. The project risks will also be mitigated through inclusion of environmental specifications in contracts, bids and tenders for contractors. For the identified impacts, mitigation measures have been developed to reduce all negative impacts to acceptable levels for pre-construction, construction, post-construction and project operation phases. Mitigation will be assured by a program of environmental monitoring to be conducted during construction and operation phases. The environmental monitoring program will ensure that all mitigation measures are implemented and will determine whether the environment is protected as intended. It will include observations on and off-site, document checks and consultation with workers and beneficiaries. Any requirements for corrective action will be reported to the ADB. Relocated vulnerable population, especially low-income households, will be the major beneficiaries of the project. The most noticeable net environmental benefits to the population will be observed for those residing surrounding the restored water bodies. Environmental Management Plan. The identified potential environmental impacts can be managed through effective implementation of the Environmental Management Plan (EMP). An EMP is included as part of this IEE, which includes (i) mitigation measures for environmental impacts identified during the implementation stage; (ii) an environmental monitoring program, and the responsible entities for mitigating, monitoring and reporting; (iii) public consultation and information disclosure procedure; and (iv) grievance redress mechanism. A number of impacts and their significance have already been reduced by amending subproject design. The EMP will be included in the civil work bidding and contract documents. The Environmental Management Plan (EMP) Budget has been estimated to be INR 72.82 Lakh (USD 1,00,887). Consultation, Disclosure and Grievance Redress. During the course of preparing this IEE, meetings with departmental officials and other relevant government stakeholders have been conducted. The subproject components and associated clearances/ permissions/ NoCs requirement as well as the way forward for the project were discussed. Focus Group Discussions (FGDs) were also conducted with the affected aeople in the encroachment sites located at (i) Elanthaikulam, (ii) Vettuvankulam, (iii) Pillaikulam, (iv) Melaveera ragavapuram, (v) Meenakshipuram, (vi) West Kokirakulam, (vii) Karupanthurai, (viii) Kurunthudaiyarpuram, and (ix) Vellakoil. These FGDs were informal but were attended by both women and men of the affected communities. Baseline socio-economic surveys were also undertaken with the affected people and have been incorporated into this report as required. Further consultations were hampered by the ongoing coronavirus (COVID-19) pandemic and as such additional formal consultations will be undertaken once it is safe to do so and before construction commences. These additional consultations will be incorporated into the draft IEE. The feedback and suggestions from the consultations that were collected to date were utilised in the design of the project, environmental impact assessment and the resettlement plan preparation. Consultations will continue throughout the project implementation period. The draft and final IEE and EMP will be disclosed on TNSCB and ADB websites. The IEE summary will be made available at public consultations with affected peoples, site locations and on the TNSCB website. The Draft IEE report will be disclosed to a wider audience via the ADB and TNSCB websites. The consultation process will be continued and expanded during project implementation to ensure that stakeholders are fully engaged in the project and have the opportunity to participate in its development and implementation. A Grievance Redress Mechanism (GRM) is described within the IEE to ensure any public grievances are addressed quickly. The PIDs (Environmental / Social Cell) will set up a three tier common GRM acceptable to ADB at project and divisional levels to address any

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environmental and / or social issues that arise due to subproject activity. The GRM will constitute a suitable systematic process to receive, evaluate and facilitate resolution of affected persons and other stakeholder’s complaints and grievances about subproject environmental (and social) safeguards performance. It will aim to provide a time-bound, trusted and transparent mechanism to voice and resolve issues and concerns associated with the subproject implementation. The GRM will address concerns and complaints promptly via a transparent process. Complaints and their resolution will be documented and reported in quarterly project progress reports and annual safeguard reports to ADB. Monitoring and Reporting. The key institutions involved in the IEE and EMP implementation will be the PMU and PIDs. To ensure effective implementation of environmental safeguards procedures, the PMU and PIDs will include designated and trained staff and focal point persons. The PMU will be responsible for the overall supervision and compliance with (i) environmental safeguards requirements including resubmission of revised documentation for ADB concurrence, (ii) coordinate the project GRM, (iii) coordinate with line departments to ensure smooth implementation of the project2, (iv) supervise the procurement process, and (v) report to the ADB. In particular, the PMU will ensure consistency of safeguard documents with government policy, legal and administrative framework across all jurisdictions national, state and local level. The PIDs will be responsible for day to day activity and compliance with safeguards during project implementation in the field including engaging in project GRM, meaningful consultations, and oversight of the contractors or any third party consultants. The PMU will be responsible for overall safeguards reporting and monitoring, including final approval of the site-specific environmental management plan (SEMP) prepared by the contractors. The PIDs (Environment Cell) with support of the PMU (Environment Team) will conduct environmental monitoring for each subproject and provide the environment input into reporting based on site inspections, compliance checks and prepare the subproject Quarterly Progress Reports (QPRs) for submission to the PMU for final submission to ADB till the project completion report is issued. Monitoring will also encompass tracking progress on regeneration works undertaken by the PMU of previously encroached water bodies / channels and surrounding areas. The environmental monitoring report for submission to ADB shall be on a quarterly basis during construction and on an annual basis during operation. Environmental monitoring reports will be required to be submitted to ADB within 30 days from the end of the relevant period. The environmental monitoring reports will be publicly disclosed on ADB public website. Reporting to ADB will continue until a project completion report is completed. The PIDs will be responsible for safeguards monitoring and implementation, including initial review of the contractor’s SEMP before submission to PMU for final approval. The PIDs, will coordinate and interact with the PMU on compliance to ADB safeguards requirements and with relevant government agencies and local authorities on permits and clearances and update and finalize the IEE and EMP as needed. During the project implementation, the PIDs will conduct field visits and for the any identified noncompliance (with reference to EMP implementation) a suitable Action Taken Report (ATR) with a time bound corrective action plan will be prepared. The ATR will be shared with the Contractor for effective implementation of the EMP and included in the quarterly safeguard monitoring reports. After completion of the construction stage, the facility operator/ contractor will continue to submit monthly progress reports to PIDs for the first year of the operation and quarterly progress reports thereafter; these will inform the annual safeguards monitoring reports.

2 The PMU will ensure that subproject activities are synchronized between the project Resettlement Plan and EMP

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

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

I. INTRODUCTION

A. Background

1. Tamil Nadu is one of the largest states in India with acute housing shortage. According to the Government of India, the State’s housing deficit accounts for 6.66% of the national housing shortfall. Based on the income levels, the housing shortage mapping reveals that the Economically Weaker Section (EWS) adds to 56%, which is followed by Lower-Income Group (LIG) of 39% and Middle Income Group (MIG) by 4%. Tamil Nadu has 5.8 million slum residents, with the most slum residents from the EWS and the LIG. Slum areas are prone to disaster, environmental degradation and health risks. Informal settlements and slums are often situated in hazardous areas, which are congested and lack appropriate services (i.e., electricity, piped water supply, and sanitation/waste facilities). 2. As per National Urban Housing and Habitat Policy (NUHHP), several comprehensive urban initiatives have been undertaken. The most recent initiative is the Pradhan Mantri Awas Yojana-Housing for All (PMAY-HFA). In Tamil Nadu, TNSCB has been identified as the entity responsible for implementing PMAY (Urban). In its recent survey, TNSCB estimated the total demand for affordable housing at 1.4 million units. Affordable housing also needs to be made accessible to low-income migrant workers, working women and female-headed low-income households for sustainable urban development. 3. In view of this, the proposed project will promote access to an inclusive, resilient, and sustainable housing and urban development in Tamil Nadu by supporting the state in (i) relocating vulnerable communities living in high-risk areas to safe shelter; (ii) providing affordable and proper housing for urban poor households as well as for migrant workers from the economically weaker section (EWS) and lower-income group (LIG); and (iii) in regional planning. The project covers 3 proposed components as follows. 4. Component 1: Affordable Housing for Vulnerable Communities. The project will support the resettlement of slum households vulnerable to hazards to safe relocation sites. The project will work with government to introduce gradual changes in the delivery of affordable housing to the urban poor through: (i) improved design including robust O&M mechanisms including women’s participation in design, (ii) increased beneficiary consultation and participation, and (iii) a graduation approach to sustain vulnerable relocated households.3 The output will include protection of cleared waterways to restore ecological functions and prevent re-encroachment.4 5. Component 2: Affordable Housing for Urban Poor and Migrant Workers. The project will support the government’s shelter fund by piloting a public-private partnership (PPP) structure and will provide industrial housing and working women’s hostels for low-income and

3 The graduation approach is a holistic, time-bound, and carefully sequenced set of interventions to place

households on an upward trajectory from poverty. This includes four key components: (i) social assistance to support immediate needs such as subsistence and health services during transition in the relocation site; (ii) livelihood promotion through localized market assessment and household-level enterprise/employment matching; (iii) financial inclusion through financial literacy and improving access to savings and financial services to promote economic resilience; and (iv) social empowerment by improving social dynamics, including gender relations, in the families and communities.

4 Removing encroachments in waterways will have the benefit of restoring capacity to absorb water and reduce

future flooding, recharge groundwater, and potentially be alternative sources of water in water-scarce areas. Regeneration of urban areas can also result from creating public spaces. Impacts of investing in the subsector can be further increased by improving TNSCB’s design and implementation practices and policies, and further strengthening the institution. Protecting cleared areas ensures that it will not revert back to a slum. The works from protecting the cleared areas including the re-greening of banks can provide temporary construction employment for beneficiary households and provide an initial market for transport services.

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migrant workers. Financing will be deployed as Government of Tamil Nadu’s equity into the shelter fund, which may be provided as catalytic first loss capital instrument. The shelter fund would leverage the Government of Tamil Nadu equity (including the loan proceeds from ADB that would be injected as equity into the fund) to attract private sector investment into specific special purpose vehicles (SPVs) that would be established to deliver affordable housing for working women and industrial workers. 6. Output 3: Regional Planning. The project will support regional planning that integrates existing and proposed development plans and makes provisions for economic development and affordable housing to balance growth throughout the State with regard to infrastructure development, environmental protection, and disaster risk management.5 B. Subproject Scope and Location

7. Tamil Nadu Slum Clearance Board (TNSCB) have taken initiatives to relocate vulnerable communities living alongside the water bodies across the state. In the district of Tirunelveli, TNSCB have identified 9 locations (refer Table 2 and Figure 1) where vulnerable communities are living in conditions at high risk of flooding due to the water bodies. Accordingly, a screening survey has been conducted and the number of households that would be affected are identified. It was estimated to relocate 807 households to a safe location. However, the actual number of households being affected will be assessed after the social survey. This draft IEE will be updated following this and submitted to ADB for final review and disclosure. 8. Based on the land availability (preferably government land), the TNSCB has selected the Reddiarpatti site (Geo-coordinates 8°40'30.13"N, 77°44'56.68"E) as a potential resettlement site. Upon clearance of the old settlement sites/ encroachment sites, adequate measures shall be taken to prevent any encroachment and the water body catchment area shall be restored.

Table 2: Encroachment sites Identified for Relocation S.No. Location No. of Households Geo-coordinates

1 Pillaikulam 70 8°44'10.30"N 77°45'37.60"E

2 Karuppanddurai 36 8°42'31.46"N 77°41'42.14"E

3 West Kokkirakulam 52 8°43'26.11"N 77°42'40.35"E

4 Meenachipuram 113 8°43'18.62"N 77°42'21.46"E

5 Mela Veeragavapuram 42 8°44'21.55"N 77°42'51.26"E

6 Kurundhudaiyarpuram 10 8°43'9.012"N 77°42'22.75"E

7 Vellakoil 10 8°44'37.96"N 77°43'45.73"E

8 Vettuvankulam 9 8°43'50.44"N 77°44'28.02"E

9 Elanthakulam 465 8°42'42.30"N 77°44'7.41"E

Total 807 Source: TNSCB

5 Land use regulation plays an important part in determining the pattern of service land and housing occupation in

urban areas. It should be ensured that housing is provided where it is needed, rather than supporting segregation (for example at the periphery of cities) is critical in policy. Policy should provide diversity of housing at scale, typology, and price.

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Figure 1: Map Showing Sites Chosen for Relocation and Resettlement

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

Table 3: Environmental Guidelines for Subproject Selection under Output 1 Guidelines for Subproject Selection Remarks

I. All Subprojects including supporting services

Complies with key exclusion criteria6 The resettlement site (Reddiarpatti) and 9 encroachment sites (old settlement sites) that are proposed to be demolished and renovation of water bodies are in compliance as per the exclusion criteria.

6 Subproject Exclusion Criteria

1. Environment Category A subprojects 2. No subprojects to be located within 10 km of a national park, sanctuary, wetland, mangroves, coastal

areas, backwaters, recognized biodiversity hotspots and/or within reserved forests, village forests, protected forests

3. Subprojects that involve activities in the ADB Prohibited Investment Activities List (ADB SPS, 2009, Appendix 5)

4. Subprojects that are highly complex and sensitive 5. Subprojects that are category A or have adverse impacts on indigenous people safeguards. 6. Subprojects which result in significant adverse impacts on any sensitive natural and human receptors e.g.,

species or habitat of high conservation value, significant number of trees of economic value (such as fruit bearing trees), water bodies (such as wetlands, backwaters, rivers, lakes or ponds), existing host communities / neighborhoods, schools and/or Physical Cultural Resources (PCRs)

7. Subprojects in unsafe proximity of electricity substations, high voltage transmission lines, underground cables, solid waste dumping yards, Oil /Gas pipelines, Coastal Regulatory Zone hazard line and/or polluting (heavy emissions / noisy) industrial activities

8. Subproject sites in flood prone areas, areas with a history of flooding 9. Subprojects that are not technically, financially, or economically viable

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Guidelines for Subproject Selection Remarks

Complies with ADB SPS 2009, EARF and the national and state legal and regulatory framework

The subproject activities proposed at the resettlement site, 9 encroachment sites and the water bodies comply with ADB SPS 2009, EARF and the national and state legal and regulatory framework.

The primary environmental criteria for selecting subproject sites to be relocated is vulnerability to flooding of targeted non-titled project beneficiaries without tenure security residing in encroachments (i.e., waterbodies / waterways). No new development sites in flood areas, areas with a history of flooding or areas zoned for coastal protection

Since the 9 encroachment sites to be demolished are located in encroached land of water bodies (tanks/ponds), they are vulnerable to flooding. The resettlement site has no history of flooding and it is not prone to flooding.

The selected subprojects (new development / resettlement sites) should have sufficient land for the accommodation of all project beneficiaries / resettled households and community members in line with housing space and design ratio considerations.

It is estimated to demolish 807 dwelling units in 9 encroachment sites and it is proposed to construct 2,124 residential units (876 residential units under ADB financing) which is more than the actual requirement. The buildings are designed in line with housing space and design ratio considerations based on the TNSCB guidelines.

The selected subprojects (new development / resettlement sites) should be within one-hour travel time on public transport from existing encroachments such that project beneficiaries / resettled households and community members have continued access to livelihood generation activities.

All the 9 encroachment sites are located within 10km radius with travelling distance less than 1hr from the Reddiarpatti resettlement site.

The selected subprojects (new development / resettlement sites) should be within a 2.5 km radius of public amenities or be within prescribed social infrastructure access norms.

Public amenities are located within 2.5 km radius of the resettlement site. The existing public amenities along with distance have been depicted in the Error! Reference source not found..

The selected subprojects (new development / resettlement sites) are greenfield, therefore opportunity should be taken to ensure that these are connected to existing neighbourhoods / host communities, provide comprehensive infrastructure and supporting services, generate new optimally sited open spaces of adequate size, and community spaces.

The residential units are designed as per the building norms adopted by the TNSCB. All required infrastructure and supporting services are proposed at the resettlement site. As per the proposed design the green area comes around 15% and OSR comes around 10% which is in compliance as per the subproject selection criteria of open space / green zone.

The selected subprojects should have access to or include supporting services (within the scope of this EARF)7 at new development / resettlement sites for project beneficiaries / resettled households and community members for better environmental outcome.

The resettlement site (Reddiarpatti) is proposed to have the following infrastructure facilities

Main Entry

Grand Boulevard

Bus Bay

Visitors Centre

Open Market

Community Hall

Convenience Store

Anganwadi

Ration Shop

Fruit Orchard

If there is no access to supporting services, then the subproject shall integrate supporting services in the subproject detailed engineering design for the new development / resettlement sites and for any other housing plans

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

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Guidelines for Subproject Selection Remarks

under consideration in the immediate vicinity of new resettlement sites.

Community Farming

Hilltop Walk

Hill Walking Path

Discovery Zone

Demonstration Farm

Approach roads and internal roads

Livelihood Centre

Play Park

Outdoor Gym

Surface Parking

Driveway

Sewage Treatment Plant

Rainwater Harvesting Structures

Health Sub Centre

Solar Power streetlights

Solid Waste Management

Micro Composting Center Currently there are no supporting services present at the site. Hence an EHS audit in line with the ADB SPS is not required

Resettlement of project beneficiaries shall only take place after all supporting services are available and operational at new development / resettlement sites.

As per the TNSCB policy, the resettlement process shall start only after completion of the construction activities (including all the amenities/ infrastructure facilities). Before resettlement, appropriate meaningful consultation shall be conducted.

Subprojects will conform to land use classification and relevant development control regulations and municipality approved master plan. Subprojects (new development / resettlement sites) not covered by the master plan will require further due diligence for consideration for subproject selection as long as it meets the key exclusion criteria and prescribes to the environmental guidelines for subproject selection.

As per the landuse map (recently updated) for the project area it is identified as a built-up area (residential use) (refer to Error! Reference source not found.). Land transfer certificate to TNSCB is enclosed in the Appendix 2.

Will not involve the use or installation of hazardous materials including asbestos, PCBs, lead based paint.

The implementation of the subproject Construction Environmental Management Plan (C-EMP) ensures that asbestos, mercury, PCBs and lead based paints will not be used in this project. This includes asbestos cement, gaskets, lead pipe and solder, fluorescent tubes etc. The contractor shall prepare Standard Operating Procedures (SOPs) for each material if potentially exposing workers to asbestos, PCB’s and lead.

No new construction of landfills will be supported under this sector loan.

There is no proposal for a new landfill site. The municipal solid waste shall be segregated at source into organic and inorganic waste. Organic waste shall be treated in the Micro Composting Center and for inorganic waste it shall be disposed through outsourcing carried out by the Tirunelveli Municipal Corporation

No new electricity generation / electricity high voltage transmission line and distribution substations will be supported under this sector loan.

Electricity shall be provided by Tamil Nadu Electricity Board (TNEB)

Subprojects shall utilize water sources at sustainable levels of abstraction only (i.e. without significant reductions in the

Water supply will be provided by TWAD, which is a nodal agency for supplying water across Tamil Nadu. TWAD follows all the necessary protocols to balance the water

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Guidelines for Subproject Selection Remarks

quantity or quality of the source overall), avoid polluted water sources, avoid water use conflicts by not abstracting water that is used for other purposes and ensure water quality provided complies with national drinking water standards at all times through regular monitoring.

requirement for day to day activities of the communities. TWAD maintains the drinking water standard (IS 10500). It also adopts various rainwater harvesting measures to counterbalance the water usage and water recharge. A water source sustainability study is being undertaken by TWAD which will be reincorporated in the IEE and EMP.

Subprojects should locate sewerage treatment plants as far as possible from inhabited areas, ensure sewerage is treated to national wastewater discharge standards, ensure no discharge of wastewater occur where it could be a hazard to downstream users and include measures for the safe disposal of sewage sludge.

As per the requirement, the STP is located far from the settlements and it will be fenced to prevent public entry. SBR technology has been adopted in treating the sewage to attain the national wastewater discharge standard. The treated sewage water will be utilized for gardening, and excess treated sewage water will be given to local body for watering trees and shrubs around Pallavarayan pond. The generated STP sludge will be further treated using sludge digester to remove pathogens and it will be dried. Then the dried sludge shall be disposed at Ramaiyanpatti Sewage Treatment Plant (operated and maintained by Tirunelveli Municipal Corporation).

II. Demolition works for all subprojects

Demolition works at encroachments will

exclude religious structures e.g. chapels, temples, mosques, etc.; and if cannot exclude, then replace or compensate for the religious structures in consultation with the relevant stakeholders

involve clearance and fencing

avoid cutting of trees

avoid disturbance to PCRs

repair any structure that has been inadvertently damaged

fencing around the water body perimeter or along channel banks8

The EMP prepared for the demolition works shall be implemented to minimise impacts, with further details to be addressed in the subproject specific Social Impact Assessment (SIA) / Resettlement Action Plan (RAP). Retaining of the Physical Cultural Resources (PCRs) or shifting of the PCRs shall be based on public consultation and relevant government approvals including ASI and in accordance with ADB SPS 2009.

III. Regeneration works for all subprojects

Regeneration works9 at cleared encroachments will include at a minimum

re-greening / re-vegetation of banks along water bodies / channels,

clearing and preventing new solid waste / sewage disposal in water bodies / channels

The final plan for regeneration of the water bodies will be decided by the concerned ULBs with potential TNSCB input. However, based on the activities required for water body regeneration works, an EMP has been prepared and included in this IEE, which shall assist the ULBs in minimising the impacts during regeneration works. The IEE and EMP will need to be updated once detailed design is available and the relevant EMP will have to be adopted by the contractor. TNSCB will retain responsibility for clearing the site after demolition and fencing in coordination with relevant agencies. These impacts are covered under the EMP prepared for demolition works.

8 Fencing to ensure that re-encroachment of cleared spaces does not revert back to slums and is kept as green

open space to realise ecological and public benefits from the cleared and restored waterways. 9 Regeneration works of the cleared encroachments will be undertaken such that it does not revert back to slums

and is kept as green open space to realize ecological and public benefits from the cleared and restored waterways.

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C. Purpose/ Objectives of IEE

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

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

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

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D. Report Structure

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

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

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II. POLICIES, LEGAL AND INSTITUTIONAL FRAMEWORK

A. ADB Safeguard Policy Statement (2009)

13. ADB requires the consideration of environmental issues in all aspects of ADB’s operations, and the requirements for environmental assessment are described in ADB SPS, 2009. This states that ADB requires an environmental assessment of all ADB investments. 14. Screening and Categorization: The nature of the environmental assessment required for a project depends on the significance of its environmental impacts, which are related to the type and location of the project; the sensitivity, scale, nature and magnitude of its potential impacts; the availability of cost-effective mitigation measures. Projects are screened for their expected environmental impacts and are assigned to one of the following four categories.

(i) Category A. a proposed project is classified as category ‘A’ if it is likely to have significant adverse environmental impacts that are irreversible, diverse, or unprecedented. These impacts may affect an area larger than the sites or facilities subject to physical works. An Environmental Impact Assessment (EIA) is required.

(ii) Category B. a proposed project is classified as category ‘B’ if its potentially adverse environmental impacts are less adverse than those of category ‘A’ projects. These impacts are site-specific, few of them are irreversible, and in most cases, mitigation measures can be designed more readily than for category ‘A’ projects. An Initial Environmental Examination (IEE) is required.

(iii) Category C. a proposed project is classified as category ‘C’ if it is likely to have minimal or no adverse environmental impacts. No environmental assessment is required although environmental implications needs to be reviewed.

(iv) Category FI. a proposed project is classified as category ‘FI’ if it involves an investment of ADB funds to or through a Financial Intermediary (FI). An Environmental and Social Management System (ESMS) is required.

15. Analysis of Alternatives. The best fit option should be identified for the implementation of the project in terms of location, design, technology and/or components that would avoid, and, if avoidance is not possible, minimize adverse environmental impacts and risks. 16. Anticipated Adverse Impact Mitigation and Management. When the potentially significant adverse impacts and risks cannot be avoided or prevented, appropriate mitigation measures and management actions have to be identified so that the project / subprojects are designed, constructed, and operated in compliance with ADB SPS, 2009. 17. Environmental Management Plan (EMP): An EMP, which addresses the potential impacts and risks identified by the environmental assessment, shall be prepared. The level of detail and complexity of the EMP and the priority of the identified measures and actions will be commensurate with the project’s impact and risks. 18. Public Consultation. Carry out meaningful consultation with affected persons and facilitate their informed participation. Ensure women’s participation in consultation. Involve stakeholders, including affected persons and concerned NGOs, early in the project preparation process and ensure that their views and concerns are made known and understood by decision makers and taken into account. 19. Grievance Redress Mechanism (GRM). Establish a grievance redress mechanism (GRM) to receive and facilitate resolution of the affected person’s concerns and grievances regarding the project’s environmental performance.

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

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

during project implementation upon receipt.

B. National and State Laws

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

(i) Category A projects require Environmental Clearance from the central Ministry of Environment, Forests and Climate Change (MOEF&CC). The proponent is required to provide preliminary details of the project in the prescribed manner with all requisite details, after which an Expert Appraisal Committee (EAC) of the MoEF&CC prepares comprehensive Terms of Reference (ToR) for the EIA study. On completion of the study and review of the report by the EAC, MoEF&CC considers the recommendation of the EAC and provides the Environmental Clearance if appropriate.

(ii) Category B projects require environmental clearance from the State Environment Impact Assessment Authority (SEIAA). The state-level EAC categorizes the project as either B1 (requiring EIA study) or B2 (no EIA study) and prepares ToR for B1 projects within 60 days. On completion of the study and review of the report by the EAC, the SEIAA issues the Environmental Clearance based on the SEAC recommendation. The Notification also provides that any project or activity classified as category “B” will be treated as category “A” if it is located in whole or in part within 10 km from the boundary of protected areas, notified areas or interstate or international boundaries.

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

Table 4: Environmental Regulatory Compliance (National and State Laws) Law Description Requirement

Environmental Impact Assessment Notification, 2006

The Notification imposes restrictions and prohibitions on new projects or activities and also on the expansion or modernization of existing projects or activities based on their potential environmental impacts.

As per the EIA notification, this subproject is categorised as B2 and mandated Environmental clearance from SEIAA is necessary.

ADB’s Safeguard Policy Statement 2009

Categorization of project components into A, B or C and developing required level of

This project has been “Categorized as B and accordingly this IEE has been prepared “

11

Law Description Requirement

environmental assessment for each component.

Central Ground Water Authority, Notification, 1997

It provides for regulation and control of ground water development and management

Permission needs to be granted for the extraction of Groundwater from Central Groundwater Board (CGWB)

The Environment Protection Act, 1986 The Environment Protection Rules, 1986

Emissions and discharges from the facilities to be created or refurbished or augmented shall comply with the notified standards

To comply with applicable notified standards

Water (Prevention and Control of Pollution) Act of 1974, Rules of 1975, and amendments

Act was enacted to provide for the prevention and control of water pollution and the maintaining or restoring of wholesomeness of water. Control of water pollution is achieved through administering conditions imposed in consent issued under to this Act. All pollution potential activities will require consent to establish (CtE) from Tamil Nadu Pollution Control Board (TNPCB) before starting implementation and consent to operate (CtO) before commissioning.

To obtain CtE and CtO for (i) hot mix plant /batching plant; (ii) construction (workers) camps and (iii) proposed STP Compliance to conditions and effluent disposal standards stipulated in CtE and CtO

Air (Prevention and Control of Pollution) Act, 1981, amended 1987 and its Rules, 1982.

The Act was enacted to achieve prevention, control and abatement of air pollution activities by assigning regulatory powers to CPCB and SPCB’s for all such functions. Establishes ambient air quality standards

To obtain CtE and CtO for (i) diesel generators; (ii) hot mix units / batching units; (iii) vehicles emitting air pollutants and (iv) construction camps. Compliance to conditions and emissions standards stipulated in the CtE and CtO.

Noise Pollution (Regulation and Control) Rules, 2000 and further amended

It provides for regulations to control ambient noise levels in public places from sources such as industries/ construction works/ community events, etc.

To comply with the noise standards.

The Hazardous Wastes (Management, Handling and Transboundary Movement) Rules, 2008

It provides for regulation and control of indiscriminate disposal of Hazardous waste; and its sound management to reduce risks to environmental and human health

Applicable for the subproject if it deals with generation/ handling/ storage/ processing of hazardous waste which should take cognizance of the provisions/schedules of these Rules and obtain authorization from the TNPCB.

Municipal Solid Waste Management Rules, 2016

Rules to manage municipal solid waste generated; provides rules for segregation, storage, collection, processing and disposal.

MSW (Organic Compost), end product quality as per the Fertilizer Control Order (FCO)

Solid waste generated at the proposed facilities / construction camps / housing units shall be managed and disposed in accordance with the Municipal Solid Waste Management Rules The end product of the compost should be as per the FCO stipulated quality standard, to use it as a manure for agriculture purposes

12

Law Description Requirement

Construction and Demolition Waste Management Rules, 2016

Rules to manage construction and waste resulting from construction, re-modelling, repair and demolition of civil structure. Rules define Construction and Demolition waste as comprising of building materials, debris resulting from demolition / re-modelling or repairs

Construction and demolition waste generated due to civil works at subproject construction site and/or demolition of existing civil structures at encroached areas shall be managed and disposed as per these Rules

The Ancient Monuments and Archaeological Sites and Remains Act, 1958, and the rules, 1959

Provide guidance for carrying out activities, including conservation, construction and reuse in and around the protected monuments.

Not applicable. The subproject site is not close to any of the archeological / protected monuments

Tamil Nadu State Ground Water (Development and Management) Act, 2003

This Act is to protect groundwater resources and provide safeguards against groundwater overexploitation, and to ensure its planned development and management; notifies areas for development, regulation and control of groundwater; prohibits sinking of wells and groundwater transport in notified areas without prior permission of the designated authority; requires all wells to be registered

Groundwater abstraction in any of the notified areas will be subject to the provisions of this Act.

Labor Laws The contractor shall not make employment decisions based upon personal characteristics unrelated to job requirements. The contractor shall base the employment relationship upon equal opportunity and fair treatment, and shall not discriminate with respect to aspects of the employment relationship, including recruitment and hiring, compensation (including wages and benefits), working conditions and terms of employment or retirement, and discipline. The contractor shall provide equal wages and benefits to men and women for work of equal value or type.

Appendix 6 provides applicable labor laws including amendments issued from time to time applicable to establishments engaged in construction of civil works, which will need to be followed by the subproject.

Minimum Wages Act, 1948

The employer is supposed to pay not less than the minimum wages fixed by appropriate government agency as per the provisions of this Act if the employment is a “scheduled employment” such as construction of Roads, Runways, and Buildings.

All construction / operation and maintenance workers should be paid not less than the stipulated wages under this Act.

Equal Remuneration Act, 1979

The Act provides for payment of equal wages for work of equal nature to male and female workers and for not making discrimination against genders.

Inter-State Migrant Workmen (Regulation of Employment and

Act is applicable to any establishment that employs 5 or more inter-state migrant workers

The Contractor for subprojects is to register with the Labour Department in case of hiring of

13

Law Description Requirement

Conditions of Service) Act, 1979

through an intermediary (who has recruited workers in one state for employment at an establishment situated in another state).

inter-state migrant workers. Adequate and appropriate amenities and facilities to be provided to workers including housing, sanitation, portable water, medical aid, traveling expenses from home to work place, etc.

Building and Other Construction Workers (Regulation of Employment and Conditions of Service) Act, 1996

It regulates the employment and conditions of service of building and other construction workers and provides for their safety, health and welfare

The subproject shall comply with the provisions of this Act.

Tamil Nadu State Ground Water (Development and Management) Act, 2003

This Act is to protect groundwater resources and provide safeguards against groundwater overexploitation

Groundwater abstraction in any notified areas will be subject to the provisions of this Act.

Tamil Nadu Minor Mineral Concession Rules, 1959 (corrected up to 31 March 2001)

Applicable for sand mining, quarrying and borrow areas

All projects/activities being implemented and/or funded under the sector loan shall take cognizance and comply with the provisions of this Act.

Tamil Nadu Protection of Tanks and Eviction of Encroachments Act, 2007

An Act to provide measures for checking the encroachment, eviction of encroachment in tanks which are under the control and management of Public Works Department, protection of such tanks and for matters incidental thereto.

Cleaning of encroachments / regeneration works will have to be undertaken in line with this Act.

Tamil Nadu Building and Other Construction Workers’ (Regulation of Employment and Conditions of Service) Act, 1996 and Rules, 2006

Regulates the employment and conditions of service of building and other construction workers and to provide for their safety, health and welfare measures. Provides various benefits for registered workers.

The subproject shall comply with the provisions of this Act.

Source: MoEF&CC, TNPCB, Govt of Tamil Nadu.

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

Table 5: Clearances and Permissions Required by the PMU for Project Construction Sl.no Permission/

Clearances/ Declaration

Competent Authority

Remarks Status Reference

1. Environmental Clearance as per the EIA notification 2006

State Environment Impact Assessment Authority (SEIAA)

As per the EIA notification, this subproject is categorised as B2 and mandates Environmental clearance from SEIAA is necessary

Obtained Appendix 5

14

Sl.no Permission/ Clearances/ Declaration

Competent Authority

Remarks Status Reference

2. Confirmation letter from Taluk office on the flood situation in the encroachment sites

Revenue and disaster management department, Tahsildhar, Palayamkottai

Based on the disaster information shared by the Tamil Nadu State Disaster Management Authority (TNSDMA), Palayamkottai Taluk Office has issued the certificate confirming that the 9 encroachment sites have been identified for relocation are affected due to seasonal floods

Obtained Appendix 1

3. Land Transfer certificate

Taluka office Palayamkottai

Land Transfer certificate has been issued by the Taluka office Palayamkottai (for the government land with survey number 194/7) to the TNSCB for the construction of the resettlement residential units.

Obtained Appendix 2

4. Land Use Classification (Government Order)

Office of the Principle Secretary (Govt of Tamil Nadu)

Reclassifying the Land located in the S..No. 194/7 of extent 90366 m2 (9.03.66 hectares) for the Residential usage area

Obtained Appendix 3

5. Confirmation letter from the Tamil Nadu Electricity Board (TNEB)

TNEB, Tirunelveli

TNEB has accepted the request from TNSCB, accordingly site inspection has been carried out

Obtained Appendix 7

6. Certificate indicating the Reddiarpatti resettlement site is not vulnerable for flooding

Tahsildhar, Palayamkottai

Tahsildhar of Palayamkottai have issued a certificate indicating the Reddiarpatti resettlement site is not prone to flooding

Obtained Appendix 8

7. Acceptance letter for collection of Municipal Solid Waste

Tirunelveli Municipal Corporation

TNSCB have received acceptance letter from Tirunelveli Municipal Corporation provided with the following conditions. (i) It has been

suggested to segregate MSW into organic and inorganic waste

(ii) For organic waste it has been suggested to construct a “Micro Composting Center” in the resettlement site and the cost for the operation and maintenance has to be remitted to Tirunelveli Municipal

Obtained Appendix 9

15

Sl.no Permission/ Clearances/ Declaration

Competent Authority

Remarks Status Reference

Corporation, by TNSCB.

(iii) For inorganic waste, the collection shall be outsourced by the Tirunelveli Municipal Corporation

8. Permission letter for discharge of treated sewage

Palayamkottoai Panchayat Union

Consent has been given for watering trees and shrubs around Pallavarayan pond

Obtained Appendix 10

9. Tamil Nadu Water Supply and Drainage Board (TWAD) acceptance/ acknowledge for the supply of water to Reddiarpatti resettlement site

TWAD TWAD has confirmed the supply of water for 876 residential units proposed under ADB financing in the Reddiarpatti resettlement site. The acknowledgement for the same has been included in the Appendix 11. For remaining 1248 residential units (proposed to finance under TNSCB), TWAD has been requested to supply 1.486 MLD for which official communication has been submitted to TWAD from TNSCB. The acceptance / confirmation from TWAD is required prior to contract award. Once detailed design for this associated activity is available a revised IEE and subsequent EMP for this activity should be submitted to ADB for concurrence prior to contract award for water supply construction by TWAD.

Obtained Appendix 11

10. Confirmation for Collection and disposal of Sludge generated from STP installed at Reddiarpatti Resettlement site

Tirunelveli Municipal Corporation

Confirmation letter has been issued by the Tirunelveli Municipal Corporation for the disposal of treated sludge at Ramaiyanpatti Sewage Treatment Plant (operated and maintained by Tirunelveli Municipal Corporation).

Obtained Appendix 12

16

Sl.no Permission/ Clearances/ Declaration

Competent Authority

Remarks Status Reference

11. + Source sustainability study for supply of water to the Reddiarpatti resettlement site

TWAD

Study on the source sustainability has been conducted by TWAD to balance water demand against water source availability. The study includes testing the water quality

Ongoing Appendix 21

24. Other Environmental Clearance conditions requirements. TNSCB will have to obtain approval for the STP design by an Independent approved third party or by an independent expert / reputed Academic institutions for its adequacy and a report in this regard should be submitted to the SEIAA and incorporated into the IEE before contract award or commencement of construction. 25. Clearances/permissions to be obtained by the Contractor. Following table shows the list of clearances/permissions (but not limited to) required for project construction. The contractor should ascertain the requirements prior to start of the construction and obtain all necessary clearances/permission prior to start of construction.

Table 6: Clearances and Permissions Required by the Contractor for Project Construction

Sl.no Construction Activity

Statutory Authority

Statute under which Clearance is Required

Implementation Supervision

1. Tree Cutting District Revenue Department

Clearances from the authorities as per the Tamil Nadu Timber Transit Rules, 1968 or latest.

Project Implementation Division (PID)

Project Management Unit (PMU)

2. Batching plants, Crushers and Hot mix plants

Tamil Nadu Pollution Control Board (TNPCB)

Consent to establish and consent to operate under Air Act, 1981

Contractor PID

3. Discharges from Construction activities

TNPCB Consent to establish and consent to operate under Water Act, 1974

Contractor PID

4. Storage, handling and transport of hazardous materials

TNPCB Hazardous Wastes (Management and Handling) Rules. 1989 Manufacturing, Storage and Import of Hazardous Chemicals Rules, 1989

Contractor PID

5. Sand mining, quarries and borrow areas

Department of Geology and mining, Government of Tamil Nadu

Contractor to obtain material from the existing government licensed mines/quarries; Contractor will require prior approval of PID for obtaining material from a particular source. PID to review and approve only existing licensed mines

Contractor PID

6. Groundwater extraction

Public Works Department

Tamil Nadu Groundwater Development and Management Act 2000

Contractor PID

17

Sl.no Construction Activity

Statutory Authority

Statute under which Clearance is Required

Implementation Supervision

7. Disposal of Construction and Demolition waste

TNPCB Construction and Demolition (C & D) Waste Management Rules, 2016

Contractor PID

Source: MoEF&CC, CPCB, Govt of Tamil Nadu.

C. Applicable International Standards and Best Practices

26. During the design, construction and operation of the project the PMU and Project Implementation Divisions (PIDs) will apply pollution prevention and control technologies and practices consistent with international good practice, as reflected in internationally recognized standards such as the International Finance Corporation’s (IFC) Environmental, Health and Safety (EHS) Guidelines Guidance Notes and standards of the World Health Organization (WHO). These standards contain performance levels and measures that are normally acceptable and applicable to projects. When Government of India regulations differ from these levels and measures, the PMU and PIDs will achieve whichever is more stringent. If less stringent levels or measures are appropriate in view of specific project circumstances, the PMU and PIDs will provide full and detailed justification for any proposed alternatives that are consistent with the requirements presented in ADB SPS, 2009. 27. The following IFC (World Bank Group) EHS and WHO Guidelines will be adopted in the EMP for the subprojects such as:

(i) WHO Guidelines on Air Emissions and Ambient Air Quality, Noise Management, Wastewater and Ambient Water Quality,

(ii) Guidelines for Construction and Decommissioning (2007) (iii) Guidelines for Hazardous Material Management and Waste Management (iv) Good Practice Note: Asbestos: Occupational and Community Health Issues,

May 2009 (v) Guidance Note on Workers Accommodation: Processes and Standards,

August 200610 (vi) Guidelines on Occupational Health and Safety and Community Health and

Safety (2007)

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

10 IFC Guidance Note: Workers Accommodation

18

Table 7: National Ambient Air Quality Standards and WHO Guidelines WHO Air Quality Guidelines National (µg/m3)

Applicable Per Ambient Air Global

Location a

Quality Update Second ADB SPS Parameter Standards b 2005 c Edition 2000 d (µg/m3) e

Particulate Industrial 60 (Annual) 20 (Annual) - 20 (Annual)

Matter PM10

Residential, Rural and Other Areas 100 (24-hr) 50 (24-hr) 50 (24-hr)

(µg/m3) Sensitive Area 60 (Annual) 20 (Annual) - 20 (Annual) 100 (24-hr) 50 (24-hr) 50 (24-hr)

Particulate Industrial 40 (Annual) 10 (Annual) - 10 (Annual)

Matter PM2.5

Residential, Rural and Other Areas 60 (24-hr) 25 (24-hr) 25 (24-hr)

(µg/m3) Sensitive Area 40 (Annual) 10 (Annual) 10 (Annual) 60 (24-hr) 25 (24-hr) 25 (24-hr)

Sulfur Industrial 50 (Annual) 20 (24-hr) - 50 (Annual)

Dioxide SO2

Residential, Rural and Other Areas 80 (24-hr) 500 (10-min)

20 (24-hr) 500 (10-min)

(µg/m3) Sensitive Area 20 (Annual) 20 (24-hr) - 20 (Annual) 80 (24-hr) 500 (10-min) 20 (24-hr) 500 (10-min)

Nitrogen Industrial 40 (Annual) 40 (Annual) - 40 (Annual)

Dioxide NO2

Residential, Rural and Other Areas 80 (24-hr) 200 (1-hr)

80 (24-hr) 200 (1-hr)

(µg/m3) Sensitive Area 30 (Annual) 40 (Annual) - 30 (Annual) 80 (24-hr) 200 (1-hr) 80 (24-hr) 200 (1-hr)

Carbon Industrial 2,000 (8-hr) - 10,000 (8-hr) 2,000 (8-hr)

Monoxide CO

Residential, Rural and Other Areas

4,000 (1-hr) 100,000 (15-min)

4,000 (1-hr) 100,000 (15-min)

(µg/m3) Sensitive Area 2,000 (8-hr) - 10,000 (8-hr) 2,000 (8-hr) 4,000 (1-hr) 100,000 (15-min) 4,000 (1-hr) 100,000 (15-min)

Ozone Industrial 100 (8-hr) 100 (8-hr) - 100 (8-hr)

(O3) (µg/m3)

Residential, Rural and Other Areas 180 (1-hr) 180 (1-hr)

Sensitive Area 100 (8-hr) 100 (8-hr) - 100 (8-hr) 180 (1-hr) 180 (1-hr)

Lead (Pb) Industrial, 0.5 (Annual) - 0.5 (Annual) 0.5 (Annual)

(µg/m3) Residential, Rural and Other Areas 1.0 (24-hr) 1.0 (24-hr)

Sensitive Area 0.5 (Annual) - 0.5 (Annual) 0.5 (Annual)

1.0 (24-hr) 1.0 (24-hr)

Ammonia Industrial 100 (Annual) - 100 (Annual)

(NH3) Residential, Rural and 400 (24-hr) 400 (24-hr)

(µg/m3) Other Areas

Sensitive Area 100 (Annual) - - 100 (Annual) 400 (24-hr) 400 (24-hr)

Benzene Industrial 5 (Annual) - - 5 (Annual)

(C6H6) (µg/m3)

Residential, Rural and Other Areas

Sensitive Area 5 (Annual) - - 5 (Annual)

Benzo(o) Industrial 1 (Annual) - - 1 (Annual)

Pyrene (BaP)

Residential, Rural and Other Areas

19

WHO Air Quality Guidelines National (µg/m3)

Applicable Per Ambient Air Global

Location a

Quality Update Second ADB SPS Parameter Standards b 2005 c Edition 2000 d (µg/m3) e

(ng/m3) Sensitive Area 1 (Annual) - - 1 (Annual)

Arsenic Industrial 6 (Annual) - - 6 (Annual)

(As) (ng/m3)

Residential, Rural and Other Areas

Sensitive Area 60 (Annual) - - 60 (Annual)

Nickel (Ni) Industrial 20 (Annual) - - 20 (Annual)

(ng/m3) Residential, Rural and Other Areas

Sensitive Area 20 (Annual) - - 20 (Annual) a Sensitive area refers to Ecologically sensitive areas notified by the India Central Government

b http://cpcb.nic.in/uploads/National_Ambient_Air_Quality_Standards.pdf

c WHO Air quality guidelines for particulate matter, ozone, nitrogen dioxide and sulfur dioxide. Global update 2005. WHO. 2006.

d Air Quality Guidelines for Europe Second Edition. WHO 2000.

e As per ADB SPS, the government shall achieve whichever of the ambient air quality standards is more stringent. If less stringent levels or measures are appropriate in view of specific project circumstances, the executing agency of the government will provide full and detailed justification for any proposed alternatives that

are consistent with the requirements presented in ADB SPS.

Table 8: National Noise Standards and WHO Guidelines

Noise Level WHO Guidelines Value

For Noise Levels Measured Applicable Per

Standards a Out of Doors b ADB SPS c

Receptor/ (dBA) (One Hour LAeq in dBA) (dBA)

Source Day Night 07:00 – 22:00 22:00 – 07:00 Day time Night time

Industrial area 75 70 70 70 70 70

Commercial area 65 55 65 55

Residential Area 55 45 55 45 55 45

Silent Zone 50 40 50 40 a Noise Pollution (Regulation and Control) Rules, 2002 as amended up to 2010

(http://cpcb.nic.in/displaypdf.php?id=Tm9pc2UtU3RhbmRhcmRzL25vaXNlX3J1bGVzXzIwMDAucGRm) b Guidelines for Community Noise. WHO. 1999. c As per ADB SPS, the project proponent shall achieve whichever of the ambient air quality standards is more

stringent. If less stringent levels or measures are appropriate in view of specific project circumstances, the project proponent will provide full and detailed justification for any proposed alternatives that are consistent with the requirements presented in ADB SPS, 2009.

Table 9: National Drinking Water Quality Standards and WHO Guidelines

National Standards for Drinking Water a, b WHO Guidelines for Drinking

Water Quality, 4th Edition, 2011c

Applicable Per ADB SPS d, e Group Parameter Unit

Max. Concentration

Limit

Physical Turbidity NTU 1 (5) - 1 (5)

pH 6.5 – 8.5 None 6.5 – 8.5

Color Hazen Units 5 (15) None 5 (15)

Taste and Agreeable - Agreeable

Odor

TDS mg/l 500 (2,000) - 500 (2,000)

Iron mg/l 0.3 - 0.3

Manganese mg/l 0.1 (0.3) - 0.1 (0.3)

Arsenic mg/l 0.01 (0.05) 0.01 0.01

Cadmium mg/l 0.003 0.003 0.003

Chromium mg/l 0.05 0.05 0.05

Cyanide mg/l 0.05 None 0.05

20

National Standards for Drinking Water a, b WHO Guidelines for Drinking

Water Quality, 4th Edition, 2011c

Applicable Per ADB SPS d, e Group Parameter Unit

Max. Concentration

Limit

Fluoride mg/l 1 (1.5) 1.5 1 (1.5)

Lead mg/l 0.01 0.01 0.01

Ammonia mg/l 0.5 none established 0.5

Chemical Chloride mg/l 250 (1,000) none established 250 (1,000)

Barium mg/l 0.7 None 0.7

Sulphate mg/l 200 (400) None 200 (400)

Nitrate mg/l 45 50 45

Copper mg/l 0.05 (1.5) 2 0.05 (1.5)

Total mg/l 200 (600) - 200 (600)

Hardness

Calcium mg/l 75 (200) - 75 (200)

Zinc mg/l 5 (15) none established 5 (15)

Mercury mg/l 0.001 0.006 0.001

Aluminum mg/l 0.1 (0.3) none established 0.1 (0.3)

Anionic mg/l 0.2 (1.0) None 0.2 (1.0)

Detergents

Phenolic mg/l 0.001(0.002) None 0.001(0.002)

Compounds

Residual mg/l 0.2 5 0.2

Chlorine

Microbial E-coli MPN/100ml Must not be detectable in any 100 ml sample

Must not be detectable in any 100 ml sample

Must not be detectable in any 100 ml Sample indicator Total Coliform MPN/100ml

a http://cgwb.gov.in/Documents/WQ-standards.pdf. b Bureau of India Standard 10500: 2012 (Indian Standard, Drinking Water — Specification (Second Revision). c Health-based guideline values. d As per ADB SPS, the government shall achieve whichever of the drinking quality standards is more stringent. If

less stringent levels or measures are appropriate in view of specific project circumstances, the executing agency of the government will provide full and detailed justification for any proposed alternatives that are consistent with the requirements presented in ADB SPS, 2009.

e Figures in parenthesis are maximum limits allowed in the absence of alternate source.

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

21

Table 10: Standards for Sludge Reuse as Manure

30. The Guidelines for Reuse of STP effluent and sludge are provided in Appendix 16 of the EARF. 31. The Central Pollution Control Board notifications and guidelines for operation of DG sets (that may be used for supporting services) are available at: https://cpcb.nic.in/genset-notifications/ 32. Core Labor Standards. ADB is committed to due consideration of Core Labor Standards (CLS) in the design and implementation of subprojects. A CLS handbook has been developed by ADB with cooperation of International Labor Organization (ILO). The TNSCB PMU will ensure compliance to applicable CLS of ADB-ILO during project implementation including:11

(i) Freedom of association and the effective recognition of the right to collective bargaining

22

(ii) Elimination of all forms of forced or compulsory labor (iii) Effective abolition of child labor (iv) Elimination of discrimination in respect of employment and occupation.

D. International Treaties/Conventions/Declarations on Environment Management

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

Table 11: International Treaties/ Conventions/ Declarations on Environment Sl. no

International Treaties/ Conventions/ Declarations

Description

1. United Nations Conference on the Human Environment - Stockholm 1972

To coordinate global efforts to promote sustainability and safeguard the natural environment

2. Convention on International Trade in Endangered Species of Wild Fauna and Flora (CITES), 1975

Its aim is to ensure that international trade in specimen of wild animals and plants does not threaten their survival

3. Ramsar Convention, 1971, 1975 The Convention on Wetlands is the intergovernmental treaty that provides the framework for the conservation and wise use of wetlands and their resources

4. The Basel Convention on the Control of Transboundary Movements of Hazardous Wastes, 1989

The Convention aims to protect human health and the environment against the adverse effects resulting from the generation, transboundary movements and management of hazardous wastes and other wastes

5. Strategic Approach to International Chemicals Management (SAICM)

SAICM is an international non-binding policy framework to support efforts to achieve the Johannesburg Plan of Implementation (WSSD) goal for chemicals, notably “achieve by 2020 that chemicals are used & produced in ways that lead to the minimization of adverse effects on human health & the environment”

6. United Nations Conference on Environment and Development (UNCED), 1992, 2002

The conference had three objectives (Agenda – 21, Rio Declaration and Millennium Development Goals), to secure renewed political commitment for sustainable development, to assess the progress and implementation gaps in meeting previous commitments, and to address new and emerging challenges

7. United Nations Framework Convention on Climate Change (UNFCCC), 1992

Kyoto Protocol, 1997

It operationalizes the United Nations Framework Convention on Climate Change by committing industrialized countries to limit and reduce greenhouse gases (GHG) emissions in accordance with agreed individual targets

8. The Vienna Convention, 1985

Montreal Protocol on Ozone depleting substances, 1992

It sets binding progressive phase out obligations for developed and developing countries for all the major ozone depleting substances, including chlorofluorocarbons (CFCs), halons and less damaging transitional chemicals such as hydrochlorofluorocarbons (HCFCs)

9. Convention on Biological Diversity, 1992

Cartagena Protocol on Biosafety, Ratified on 17th January, 2003

It is an international treaty governing the movement of living modified organism (LMO) resulting from modern biotechnology from one country to another

10. Convention to Combat Desertification, 1996

It is the only binding international agreement linking environment and development to sustainable soil management

23

Sl. no

International Treaties/ Conventions/ Declarations

Description

11. Rotterdam Convention on Prior Informed Consent Procedure for certain Hazardous Chemicals in International Trade, 2002

It is a multilateral treaty to promote shared responsibilities in relation to importation of hazardous chemicals

12. Stockholm Convention on Persistent Organic Pollutants (POPs), 2001

It aims to eliminate or restrict the production and use of Persistent Organic Pollutants (POPs)

24

III. DESCRIPTION OF THE PROJECT

A. Subproject Overview

34. The subproject will be in implemented in Reddiarpatti Village, Palayamkottai Taluk of Tirunelveli District where TNSCB has identified 9 encroachment sites located around 9 tanks/ponds that are vulnerable to flooding. Based on the land availability (preferably government land) in Palayamkottai Taluk, TNSCB has identified Reddiarpatti (8°40'30.13"N, 77°44'56.68"E) in Palayamkottai Taluk as a resettlement site. Coordinates of the 9 encroachment sites are presented in Table 2 in Chapter 1. 35. Figure 3 shows the map of the locations of 9 encroachment sites chosen for relocation, and location of the resettlement site at Reddiarpatti. Area within 10 km radius of the resettlement site is also shown in the map. There are no environmental sensitive areas including protected areas, eco sensitive zones or ecologically sensitive areas notified by the MoEF&CC located within 10 km radius of the resettlement site.

Figure 3: Relocation sites within 10 km radius from Reddiarpatti

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

(i) Key Exclusion Criteria. Reddiarpatti resettlement site, 9 encroachment sites and 9 water bodies (proposed for regeneration) are not falling under the exclusion criteria as suggested in the EARF. (a) None of the subproject activities (construction, demolition and

regeneration) are falling under the Environmental category “A” (b) The subproject areas are not located within the 10km radius national

park, sanctuary, wetland, mangrove reserve, biodiversity hotspot, reserve or protected forest area and CRZ zone.

(c) The subproject is not falling under the ADB Prohibited Investment Activities List (ADB SPS, 2009, Appendix 5)

25

(d) The subproject is not highly complex and sensitive12 (e) The subproject activities do not affect the PCRs e.g. local heritage sites

/ archaeological sites13, places of worship, etc., (f) The subproject is not located near electricity substations, high voltage

transmission lines, underground cables, solid waste dumping yards, Oil /Gas pipelines, Coastal Regulatory Zone hazard line and/or polluting (heavy emissions / noisy) industrial activities

(g) Subproject sites are in flood prone areas, areas with a history of flooding.

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

flooding and occupied by the slum dwellers. (b) The resettlement site proposed at Reddiarpatti will host 2124 dwelling

units (including 876 dwellings units proposed under ADB financing) for the 807 HH to be evicted from the 9 encroachment sites, which is sufficient to accommodate project beneficiaries / resettled households and community members in line with housing space and design ratio considerations.

(c) New site should be within one-hour travel time on public transport from existing settlement sites / encroachments). The resettlement site at Reddiarpatti meets this criterion. Figure 1 in Chapter 1 shows that the resettlement site is located within 10 km from the sites chosen for relocation and they are well connected by roads. Hence the travel time will be less than 1 hour.

(d) New site should be within a 2.5 km radius of public amenities or be within prescribed social infrastructure access norms. The resettlement site at Reddiarpatti meets this criterion. The existing public amenities around the resettlement site have been depicted in Error! Reference source not found. in Chapter 1.

(e) The subproject is designed to have 10% OSR and 15% green belt area. (f) New site should provide comprehensive infrastructure and supporting

services, generate new optimally sited open spaces of adequate size, and community spaces including space for training and community enterprise.

(g) Reddiarpatti resettlement site is in conformation to the land use classification, relevant development control regulations and DTCP approved master plan.

(h) No new construction of Landfills, electricity generation/ electricity high voltage transmission line and distribution substations are proposed under this subproject.

(i) Water source sustainability is maintained through supply of water by TWAD and the quality of the water is as per the IS 10500 (drinking water standard),

(j) 1.8 MLD capacity Sewage Treatment Plant is proposed to treat the sewage generated from the Reddiarpatti resettlement site, the treated

12 Projects that ADB deems as highly risky or contentious or involve serious and multidimensional and generally

interrelated potential social and/or environmental impacts. 13 ASI clarification is requested for the ancient wall like structure located near to the encroachment site. Based on

the recommendations/ suggestions care shall be taken to preserve the wall from damages.

26

water shall be utilised for gardening, rainwater harvesting, and excess treated water shall be given to the Tirunelveli Municipal Corporation. The sludge generated in the STP shall be further digested to remove the pathogens and the dried sludge will be treated along with the organic waste in the Micro Composting Center

(k) Demolition works at 9 encroachment sites will

exclude religious structures e.g., chapels, temples, mosques, etc.

Involve clearance and fencing around the water body / canal banks14

avoid cutting of trees

avoid disturbance to PCRs (l) Regeneration works at cleared encroachments includes

re-greening / re-vegetation along water body / canal banks

clearing and preventing new solid waste / sewage disposal in water bodies / channels

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

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

Table 12: Salient Features of the Reddiarpatti Resettlement Site Features Description

Plinth Area 78,544.42 m2

Built-up Area 85,729.72 m2

Total Housing/ Residential Units

2,124 (including 876 ADB funded dwelling units and 1,248 Government of Tamil Nadu funded dwelling units)

Total Occupancy 10,620 persons

Administration area The proposed relocation site falls in Reddiarpatti Village, Palayamkottai Taluk of Tirunelveli District

Topography The site is located on the hill lock having a gentle slope towards northern direction

Road Connectivity It is well connected to NH 7 and located at a distance of 4.5 km from the Tirunelveli city bus terminus

Site nearby It abuts private land on one side and is adjacent to an existing TNSCB settlement and upcoming (under construction) TNSCB settlement for about 450 families15

Distance from resettlement site to encroachment sites

All the encroachment sites proposed for relocation to this new site are located at a distance of 9 to 10 km (refer Error! Reference source not found.),

Environmental sensitivity

No sensitive natural or environmental sensitive receptors are in close proximity to the proposed relocation site. The nearest residential units are located at distance of 250m from the site

14 Fencing to ensure that re-encroachment of cleared spaces does not and to derive public benefits from the cleared

and restored waterways. 15 The presence of the TNSCB settlements near the project site is also included in the project scope for

environmental assessment.

27

Features Description

Electricity TNEB have confirmed to provide electricity to the Reddiarpatti resettlement site for which approximately 10 to 15 transformers will be provided within the resettlement site.

Health facilities Primary health care center is located at a distance of 2.5 km

Water supply 1279.28KLD of water (as per IS 10500 drinking water standard) will be supplied by the Tamil Nadu Water Supply and Drainage (TWAD).

Wastewater treatment

1.8 MLD STP will be constructed within the resettlement site for treating wastewater (grey water and black water) generated from the resettlement site. It is proposed to have Sequencing Batch Reactors (SBR) for treating wastewater. SBR is a variant of Activated Sludge Process (ASP) technology and is essentially a batch treatment through the combination of primary settling, aeration, secondary settling and decanting the treated sewage in a series of sequences. The treated wastewater quality will met the requirement of the CPCB waste water discharge standard. The treated water will be utilised for flushing, landscaping purposes and for groundwater recharge. The remaining excess treated water shall be used for watering trees and shrubs around Pallavarayan pond.

Solid waste management

Tirunelveli Municipal Corporation have requested TNSCB to construct 3 MT capacity Micro Compost Center within the resettlement site to treat the organic waste generated from the resettlement site. For inorganic waste disposal it will be outsourced by the Tirunelveli Municipal Corporation.

Treated Sewage Discharge

Palayamkottoai Panchayat Union has given consent for watering trees and shrubs around Pallavarayan pond by using the treated sewage generated from the STP located at Reddiarpatti Resettlement site.

STP sludge management

It is proposed to have a sludge digester tank (anaerobic sludge digestion) in the STP to digest the sludge into dry sludge for further disposal. The treated sludge shall be stored in the sludge drying bed and when it reaches its full capacity, it shall be collected and disposed at Ramaiyanpatti Sewage Treatment Plant (Operated and maintained by Tirunelveli Municipal Corporation).

Figure 4: Photograph of the Resettlement Site

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

28

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

29

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

Table 13: Plinth Area Details of Proposed Residential Units at the Resettlement Site

Sl.no Phase Block Type

No. of Units per Floor

No. of Floors

No. of Blocks

Total No. of Units

Plinth Area per Unit (m2)

Total Plinth Area (m2)

1 Phase 1 Q 4 4 15 480 37.16 17,566.50

2

Phase 2

B 8 4 8 256 35.71 9,141.76

3 C 14 4 10 560 36.67 20,535.20

4 D 15 4 1 60 36.78 2,206.80

5 E 16 8 6 768 37.96 29,222.64

Total 40 2124 184.28 78,672.90 Source: TNSCB Layout Drawing for Reddiarpatti Subproject (highlighted blocks are funded by ADB)

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

30

Figure 6: Proposed Sewer Line (ADB Portion)

Figure 7: Proposed Water Supply Line (ADB Portion)

31

Figure 8: Proposed Storm Water Drain (ADB Portion)

Figure 9: Proposed Green Belt Area

32

Table 14: Overall Built-up Area Details of the Buildings at the Resettlement Site

Sl.no Description Built-up Area (m2)

1 Residential Buildings 78,544.42

2 Other Amenities

2.1 Ration Shop 149.10

2.2 ICDs 258.90

2.3 Commercial Shop 244.90

2.4 Community Hall 1126.00

2.5 V.Center 7.53

2.6 Market 191.10

2.7 Livelihood Center 306.40

2.8 Middle school 1221.00

2.9 Health Sub Centre 87.72

Subtotal 3,592.65

Grand Total 85,729.72

Table 15: Built-up Area Details for ADB Portion Sl.no Description Built-up Area (m2)

1 Residential Buildings 31,883.76

2 Other Amenities

2.1 Ration Shop 151.09

2.2 ICDS 207.12

2.3 Commercial Shop 323.54

2.4 Community Hall 569.72

2.5 V.Center 58.74

2.6 Market 136.21

2.7 Livelihood Center 375.27

2.8 Health Sub Centre 87.72

Subtotal 1,909.41

Grand Total 33,664.69 Source: As per DPR, TNSCB

Table 16: Site Infrastructure Details

Sl.no Infrastructure Facilities ADB Portion/ Section

Non ADB Portion/ Section

1. Sewer Line (m) 4683 200

2. Water Supply Pipeline (m) 9644 470

3. Storm Water Drain (m) 1383 280

4. Green Belt (sq,m) 8815.45 5018.00

5. STP (sq,m) 1260.04 NA

6. Micro Composting (sq,m) 706.28 NA

7. Internal Road (sq,m) 3891 4600

8. Streetlights (nos) Lumpsum 60

9. Rainwater Harvesting (Nos) 19 NA

10. Rainwater Harvesting Trench (m) 1125 828

11. Paver block (sq,m) 8133 2808 Source: TNSCB

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

33

Table 17: Subproject Interventions at the Resettlement Site Subproject Subproject Interventions

Construction and operation of 2,124 residential units (including 876 residential units funded by ADB) and supporting services

Main Entry

Bus Bay

Visitors Centre

Open Market

Community Hall

Convenience Store

Anganwadi

Ration Shop

Fruit Orchard

Community Farming

Hilltop Walk

Hill Walking Path

Discovery Zone

Demonstration Farm

Approach roads and internal roads

Livelihood Centre

Play Park

Outdoor Gym

Surface Parking

Driveway

Sewage Treatment Plant

Rainwater Harvesting Structures

Health Sub Centre

Solar Power street lights

Solid Waste Management

Micro composting plant Source: TNSCB Layout Drawing for Reddiarpatti Subproject

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

Table 18: Overall Power Requirement at the Resettlement Site Sl.no Particulars Unit kW

1 Residential Use

No of residential units proposed 2,124

Power required per residential unit (Assuming 1 kW per 1 residential unit)

2,124

2 Pump Room

No of Pump Rooms 3

Power requirement for the Pump Room (Assuming 6 kW per Pump Room)

18

3 STP

Assuming power consumption by STP is in the range between 95kW to 100kW

96

4 Streetlight

Proposed Street lights 120

Power required for the Street Lights [Assuming 50 W per Street Lamp]

6

34

Sl.no Particulars Unit kW

5 Micro Composting Center

Power required for shredder, conveyer belt and indoor lighting system

50

Total Power Requirement 2294

Table 19: Power Requirement at the Resettlement Site (ADB Portion)

Sl.no Particulars Unit kW

1

Residential Use

No of residential units proposed 876

Power required per residential unit (Assuming 1 kW per 1 residential unit)

876

2

Pump Room

No of Pump Rooms 4

Power requirement for the Pump Room (Assuming 6 kW per Pump Room)

24

3

STP

Assuming power consumption by STP is in the range between 95 kW to 100 kW

100

4 Streetlight

Proposed Street lights 120

Power required for the Street Lights [Assuming 50 W per Street Lamp]

6

Total Power Requirement 1,006

Source: TNSCB.

44. In the event of power outages, an onsite Diesel Generator (DG Set) of 80 KVA, 415V, 3 Phase, 50 Hz @ 1500 RPM will be used to support STP operation. Stack height of 2 m shall be maintained for 80 KVA DG Set as per TNPCB norms, the height of the stack should be 2 m from the height of the building (height of the building +2 m). The DG set shall be fitted with acoustic enclosures. 45. Water Requirement and Supply. The total water requirement during construction is estimated to be 100L/Day, the source of water for construction shall be arranged by the Contractor through the ULB or the TWAD. The water requirement during operation is estimated to be 1.8MLD (including ADB and Non ADB residential units), which shall be supplied by the TWAD and relevant calculations can be found in Table 20 (Refer Appendix 11 for the commitment letter issued by the TWAD for the supply of water). The water will be sourced from River Tamirabarani at Thirumalaikolundupuram, which is located at a distance of 24 km from the Reddiarpatti resettlement site. 46. The wastewater generation from the project is estimated to be about 1.8MLD (including ADB and Non ADB dwelling units), which will be treated in a proposed Sewage Treatment Plant (STP)16 with a capacity of 1.8MLD. A portion of treated wastewater will be reused for flushing (520.72 KLD) and gardening (303.15 KLD), remaining treated water (967.15 KLD) will be used for watering trees and shrubs around Pallavarayan pond. The assumptions for estimating the water requirement is given in the following table.

Table 20: Water Requirement at the Resettlement Site

S. No. Project Components No. of Units Occupancy Rate @

Total Occupancy (Nos.)

1 Residential unit 2124 5 person per unit 10620.0

16 The technology for the STP shall be selected based the suggestions from the SEIAA. However, it is proposed to

have a STP having SBR technology.

35

S. No. Project Components No. of Units Occupancy Rate @

Total Occupancy (Nos.)

2 Floating Population 10% of the total residential population

1062.0

3 Community Hall 2 200 per unit 400.0

4 Anganvadi 5 40 person per unit 200.0

5 Staff and Visitors 10% of the total population

20.0

6 School 11 40 persons per unit 450.0

7 Staff and Visitors 10% of the total population

45.0

8 Ration Shop 3 5 person per unit 15.0

9 Convenience Store 25 2 persons per unit 50.0

10 Livelihood center 1 75 person per unit 75.0

11 Health care center 1 5 person per unit 5.0

12 Visitors & Maintenance Staff

10 to 15% from Convenience store, Livelihood center, Health care center etc

30.0

Total Occupancy 12972.0

As per the National Commission on Integrated Water Resources Development (NCIWRD) norms rural area shall be provided with 75 to 150 Litre Per Capita Per Day (LPCD) have been recommended for the year 2025 and 2050. For this subproject 100 LPCD has been proposed. Hence the estimated water requirement is 1.3 MLD (1.29 MLD).

12972*100 = 12,97,200 Litres

(1297.2 KLD)

Green area Development/ landscaping

Area for Green area development (13,833 m2) × 3.5 lts/ m2 48,415.5 (KLD) 48.42 (MLD)

Rounded 50.0 (MLD)

Source: Conceptual Plan, TNSCB.

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

36

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

37

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

Figure 11: Rainwater Harvesting Structure

(i) Rainwater volume estimation (a) As per the secondary information (refer Chapter 4 Description of the

Environment) the project district receives annual rainfall of 1050.60 mm (b) The rainfall intensity has been estimated to be 2.87 mm / day (c) The total built-up area is worked out to be 69870.72 m2

38

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

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

(ii) Rainwater Harvesting Structure. It is proposed to construct 19 RWH structure/pits with a diameter of 1.2m (clear) and height of 2.40m. Each residential block will be connected to the RWH structure/pit. The total volume of rainwater that can be collected by a RWH structure/ pit is estimated to be 2.71 m3, hence 19 RWH structures/ pits will collect 51.54 m3 of rainwater. The structure of the RWH is shown in the Figure 11.

(iii) Rainwater Harvesting Trenches. The resettlement site will be provided with 1125 m of rainwater harvesting trenches along the perimeter of the site. The trench will be 1 m wide by 1.5 m deep filled with pebbles. The volume of rainwater that can be collected in the trench is estimated to be 1687.50 m3.

(iv) Paver block all-around the buildings. It is proposed to provide paver blocks for the walkway, parking area and surrounding the buildings above a filling of 45cm. The gaps between the paver block will not be sealed, which will allow the rainwater to percolate further into the ground. The total area of the paver block is estimated to be 8133 m2. The volume of rainwater that can be collected by this system is estimated to be 3659.85 m3.

Table 21: Estimated Rainwater

Sl.no Infrastructure Quantity Volume of rainwater that can be Collected

1. Rainwater Harvesting Structures/Pits 19 nos 51.57 m3

2. Rainwater Harvesting Trenches 1125 m 1687.50 m3

3. Paver block all-around the buildings 8133 m2 3659.85 m3

Total 5398.89 m3 = 54 Lakh Litres Source: TNSCB

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

Table 22: Green Area Details Sl. No Green Belt Details m2

1 Green Belt - 1 924.22

2 Green Belt - 2 431.14

3 Green Belt - 3 819.67

4 Green Belt - 4 749.87

5 Green Belt - 5 340.15

6 Green Belt - 6 71.64

7 Green Belt - 7 785.18

8 Green Belt - 8 743.46

9 Green Belt - 9 3,001.00

10 Green Belt - 10 585.93

11 Green Belt - 11 628.23

12 Green Belt - 12 382.11

13 Green Belt - 13 900.57

14 Green Belt - 14 742.62

15 Green Belt - 15 455.28

39

Sl. No Green Belt Details m2

16 Green Belt - 16 2,172.00

17 Green Belt - 17 99.96

Total 13,833.03

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

Figure 12: Layout for Micro Composting Center

40

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

Table 23: Solid Waste Generation at the Resettlement Site Sl.no Solid water

generation sources

Occupancy load

Per capita Generation

(kg/day)

Total Solid waste

generation (kg/day)

Total Bio Degradable

Waste (kg/day)

Total Non-Bio

Degradable Waste

(kg/day)

1 Residential Units

10620 0.6 6,372 3,823.2 2,548.8

2 Staff and visitors

1062 0.2 212.3 127.4 84.9

3 STP Sludge - - 495 495 0

Total (kg/day) 7,079.3 4,445.6 2,633.7 Source: Conceptual Plan

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

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

41

53. The proposed unit plan and details with respect to the blocks and other amenities are detailed in the master plan presented in Figure 5. C. Proposed Subproject Interventions at the Encroachment Sites Identified for

Relocation

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

Table 24: Subproject Interventions Sl.no Subproject Subproject Interventions

1 Demolishing structures in the encroachment site (prone to flooding)

Demolition of 807 structures in the 9 encroachment sites

Providing fencing to prevent further encroachment

2 Water body restoration Clearance and fencing

Restoration of water bodies, which were encroached

Deepening of the ponds/ tanks to restore the water storage capacity

Restoring the catchment area

Provision for public parks/ recreation areas as per the community’s requirement

Avenue plantation/ landscaping

D. Existing Condition of the Encroachment Sites Identified for Relocation

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

42

Table 25: Existing Condition of the Encroachment Sites Identified for Relocation Sl.no Location Observations

1

Karupanthurai (Encroachment site proposed

for Relocation)

Dwelling units situated along the banks of the River Thamirabarani

Area faced severe floods in years 1989,1992 and 2015

Drinking water is supplied through Corporation

Encroachers are not having patta

SWM is maintained by the corporation

Street light facility is provided

Common toilets has been provided; however open defecation is common

Residents do not have patta

Livelihood opportunities available in nearby areas

The nearest Eco sensitive location (Vallanadu Black Buck Wildlife sanctuary) is located at a distance of 20km

The resettlement site (Reddiarpatti) is located at a distance of 7km

2

Elanthai Kulam

Dwelling units are located in the Elanthai Kulam periphery area

Residents do not have patta

Approximately 15m has been encroached in the Elanthai Kulam for the linear section and more than 200m encroached in the nonlinear (front area) section

Concrete structures have been built on the lake-bed after filling

Religious structures constructed (church / temple)

Situated at a distance of 4.5 km from the proposed relocation site

Drinking water is supplied through corporation; some of the dwelling units are having their own bore well facility

Street light facility is provided

SWM maintained by the corporation.

Common public toilets has been provided; however, open defecation is common

Household wastewater directly discharges into the pond / tank (kulam)

Place of worship on the bund of the pond

The nearest Eco sensitive location (Vallanadu Black Buck Wildlife sanctuary) is located at a distance of 15.25km

The resettlement site (Reddiarpatti) is located at a distance of 4.2km

43

Sl.no Location Observations

3

West Kokarakulam (at the banks of the

Thamirabarani River)

Dwelling units situated along the banks of the River Thamirabarani

Area faced severe floods in years 1989,1992 and 2015

Drinking water is supplied through Corporation

Encroachers are not having patta

SWM is maintained by the corporation

Street light facility is provided

Common toilets has been provided; however open defecation is common

Residents do not have patta

Livelihood opportunities available in nearby areas

The nearest Eco sensitive location (Vallanadu Black Buck Wildlife sanctuary) is located at a distance of 19.2km

The resettlement site (Reddiarpatti) is located at a distance of 6.7km

4

Pillaikulam

Dwelling units are located in the Pillaikulam periphery area

Residents do not have patta

Drinking water is supplied through bore well provided with a pump house

SWM is maintained by the Corporation

Some dwelling units have toilet facilities, however these discharge directly into the pond/ tank (kulam).

Most the dwelling units G+1 ‘pucca’ / concrete structures

Street light facility is provided

Pillaikulam is located at a distance of 13 km from the proposed relocation site

The nearest Eco sensitive location (Vallanadu Black Buck Wildlife sanctuary) is located at a distance of 12.1km

The resettlement site (Reddiarpatti) is located at a distance of 6.1km

5 This encroachment site is located on the bank of the River Tamirabarani

It is observed that filling has been done in the water body for extending the encroachment

Street light facility is provided

Solid Waste Management is an issue (not maintained properly).

44

Sl.no Location Observations

Meenachipuram

Common public toilets has been provided; however, open defecation is common

Street light facility is provided

Area is prone to flooding

Residents do not have patta

The resettlement site (Reddiarpatti) is located at a distance of 7.2 km

The nearest Eco sensitive location (Vallanadu Black Buck Wildlife sanctuary) is located at a distance of 18.5km

6

Mela Veeraragavapuram

Dwelling units are located in the embankment of a PWD Pond

Encroachers have filled the water body to extend their land area

Street light facility is provided

Solid Waste Management is an issue (not maintained properly).

Common public toilets have been provided; however, open defecation is common

Most the dwelling units G+1 ‘pucca’ / concrete structures

Residents do not have patta

The resettlement site (Reddiarpatti) is located at a distance of 8.15 km

The nearest Eco sensitive location (Vallanadu Black Buck Wildlife sanctuary) is located at a distance of 17.3km

7

Kurunthudaiyarpuram

This encroachment site located on the bank of the River Tamirabarani

It is observed that filling has been done in the water body for extending the encroachment

Street light facility is provided

Drinking water is supplied through bore well provided with a pump house

Solid Waste Management is an issue (not maintained properly).

Common public toilets has been provided; however, open defecation is common

Most the dwelling units G+1 ‘pucca’ / concrete structures

Residents do not have patta

The resettlement site (Reddiarpatti) is located at a distance of 6.9 km

The nearest Eco sensitive location (Vallanadu Black Buck Wildlife sanctuary) is located at a distance of 18.3km

45

Sl.no Location Observations

8

Vellakoil

This encroachment site located at a distance of 300m from the River Tamirabarani

Street light facility is provided

Drinking water is supplied through Corporation

Solid Waste Management is an issue (not maintained properly).

Common public toilets have been provided; however, open defecation is common

Residents do not have patta

The resettlement site (Reddiarpatti) is located at a distance of 8.0 km

The nearest Eco sensitive location (Vallanadu Black Buck Wildlife sanctuary) is located at a distance of 15.6km

9

Vettuvankulam

Dwelling units are located in the embankment of a PWD Pond

Street light facility is provided

Drinking water is supplied through Corporation

Solid Waste Management is an issue (not maintained properly).

Common public toilets has been provided; however, open defecation is common

Residents do not have patta

The resettlement site (Reddiarpatti) is located at a distance of 6.12 km

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

56. Demolition Works. The 9 encroachment sites having 807 dwelling units identified for relocation shall be demolished manually. Prior to the demolishing activities, the sites/ locations for disposal of the demolished waste shall be identified by the Tirunelveli Municipal Corporation, who will be assisted by the PID (TNSCB). The encroached sites shall be fenced and a monitoring mechanism will be in place to prevent further encroachment. Further revision in the estimated dwelling units at the encroachment sites or change in the approach toward the demolishing activities should be reflected in the IEE and accordingly the EMP also has to be revised. 57. Regeneration Works. The water bodies located within the 9 encroachment sites and its catchment area, which was encroached shall be regenerated and restored. In addition, the inlet to the water body shall be cleared of obstructions and deepening of the water body shall be done. Based on the assessment, enhancement measures like provision of walkway, recreation area, public park area, and children play area shall be explored to make the water body usable to the public. The enhancement measures shall be identified based on the public consultations. 58. Climate Resilience Measures. A study on the Climate Change Risk and Vulnerability Assessment (CRVA) for the IRSHUPSP has been conducted for Climate Risks, Climate Adaptation and Climate Finance. As per the study the resettlement site (Reddiarpatti) does

46

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

(i) Water Supply (a) Level of consumption of water may be lowered further using more water

efficient appliances, taps, and showerheads; (b) Use drought-tolerant plants to reduce the need for watering the

landscaping, increasing water efficiency; (c) Community-based messaging/campaigns to promote water efficiency; (d) To use swales and ponds on parts of the site for effective rainwater

harvesting; and (e) To incorporate natural drainage channels and lakes into storm water

management plan. (ii) Provision of green space, community farming, livestock

(a) Explore improved shading opportunities for community recreation areas, market and milk booth

(iii) Roads and pavement areas (a) Reduce area of impermeable surfaces to minimise run-off. (b) Use of pavement materials to ensure resilience to extreme

temperatures. (c) Use of permeable materials that provide additional cooling benefits.

E. Project Proposal for the Relocated Sites

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

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Figure 15: Construction Schedule Bar Chart

48

IV. DESCRIPTION OF THE ENVIRONMENT (BASELINE DATA)

A. Area of Impact

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

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

(i) Project details, reports, maps and other documents prepared by TNSCB; (ii) Discussions with technical experts of the ADB team, TNSCB, and other

relevant government agencies; (iii) Secondary data from project reports and published articles; and (iv) Literature on land use, soil, geology, hydrology, climate, socioeconomic

profiles, and other planning documents collected from government agencies and websites.

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

a) Location, Area and Connectivity

63. Reddiarpatti is located in Palayamkottai Block of Tirunelveli district17 in Tamil Nadu. The geo coordinates of Reddiarpatti is 8°40'30.13"N, 77°44'56.68"E. It is positioned in a semi urban area of Tirunelveli district of Tamil Nadu, it is one of the 47 villages of Palayamkottai Block of Tirunelveli district. The resettlement site is located at a distance 12.5 km from the Tirunelvel Town. The site is located on a hill lock, on the Southern direction, National Highways 44 traverses through the resettlement site at a distance of 600 m. There is no development or settlements in the Eastern direction. However, towards the Northern direction and the Western direction, considerable number of settlements are observed in the Thirumal nagar (500 m from the resettlement site) and Mahilchi Nagar (1km from the resettlement site) respectively. 64. All the sites chosen for relocation are located within 10 km from the resettlement site at Reddiarpatti. Coordinates of the encroachment sites are given in Table 2 in Chapter 1. Total area of the resettlement site (as per FMB) is 90,366 m2 (9.03 ha). The land is owned by Government of Tamil Nadu. None of the construction sites, including Reddiarpatti resettlement

17 Tirunelveli is the sixth largest city in Tamil Nadu after Chennai, Madurai, Coimbatore, Trichy and Salem.

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

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

Figure 16: Reddiarpatti (Project area) Location

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

b) Topography, Soils and Geology

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

Figure 17: Elevation profile for the Resettlement site at Reddiarpatti

67. In Tirunelveli, the soil type has been classified into: i) Deep Red soil; ii) Red Sandy Soil; iii) Black Cotton Soil; iv) Saline Coastal Alluvium; and v) River Alluvium. In the resettlement area, the soil type is Deep Red soil, which is suitable for cultivating coconut and palmyrah trees. 68. As per the study conducted by the Central Groundwater Board (CGWB), Tirunelveli district has a wide variety of geological formations ranging from Precambrian to recent period. The rock types within the district can be broadly classified into (i) Charnokite group of rocks; (ii) Gneissic group of rocks; (iii) Shell limestone, (iv) Tuffaceous kankar and (v) Tertiary kankar. Project area has predominant zone of quartzite beds and associated crystalline limestone and

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

c) Climate and Rainfall

69. Tirunelveli experiences a tropical climate. The maximum temperature is 39.4°C in the month of May and minimum is 21.7°C in the month of January. From the middle of February, the temperature increases gradually. The weather is quite hot in the month of April to June. Sometimes reaches 42.5°C. With the onset of the southwest monsoon by beginning of June, there is some drop-in temperature. The period from November to January is the coolest part of the year. 70. There are two principle monsoon seasons: southwest (June to August/Sept) and northeast monsoons (October to January). Tirunelveli receives an annual average rainfall of 845.1 mm. The average rain fall in the district is 845.1 mm, most of which is received during the northeast monsoon. Much higher rainfall, above 1000 mm per year, is received in the district that are close to Western Ghats.

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

Table 26: Rainfall information for Tirunelveli District Year South West

Monsoon North-East Monsoon

Winter Season

Hot Weather Season

Total % Deviation from Normal (+ or – or =) from Normal

Normal Actual Normal Actual Normal Actual Normal Actual Normal Actual

2011-12 142.4 107.7 467.2 639.9 69.3 70.7 166.2 100.7 845.1 919 8.75

2012-13 142.2 36.9 467.2 515.8 69.3 98.9 166.2 169.7 844.9 821.3 -2.8

2013-14 142.4 237 467.2 412.8 69.3 70.4 166.2 314.1 845.1 1034 22.39

2014-15 142.4 118.8 467.2 847.5 69.3 19.5 166.2 317.9 845.1 1304 54.27

2015-16 142.4 158.8 467.2 1051 69.3 6.8 166.2 111.1 845.1 1333 58

2016-17 142.4 77.32 467.2 178.8 69.3 42 166.2 84.96 845.1 383.1 -54.67

2017-18 142.4 212.6 467.2 665.5 69.3 25.8 166.2 84.96 845.1 988.9 17.01

Source: Department of Economics and Statistics, Chennai

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71. Winds are generally light to moderate in strength. The wind direction is predominantly towards North and West in the mornings and South and East in the evenings. Between May and September winds are mainly north westerly or westerly and from October to February winds are mainly north easterly or easterly. During the months of April and May, the weather is often cloudy for many days until thunderstorms occur. In the southwest and northwest monsoon seasons, the sky is heavily clouded or overcast. 72. Humidity is the highest during the period of October-December and found to be the highest in the month of November with 98% humidity and the minimum occurs in May at 29%. The relative humidity in general, during the year, is between 56.6% and 72.9% in the district, except during the northeast monsoon season, when it is over 74.3%. d) Seismicity

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

Figure 19: Seismic Map for Reddiarpatti Project Area

e) Land Use

74. The landuse pattern of the project area (Reddiarpatti) has been assessed through the Bhuvan18 Map. The project is falling under the urban built-up which is surrounded by the barren area and scrub forest. Majority of the land use belongs to built-up, which is followed by agriculture and forest area. The 9 encroachment sites are located in urban built-up area (within Tirunelveli Municipal Corporation limit). TNSCB have constructed some residential apartments near the Reddiarpati project area, which is located at a distance of 50 m.

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

Indian Space Research Organisation

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

f) Drainage System

75. Thamarabarani, Nambiar, Chittar and Karamaniar are the important rivers draining the Tirunelveli district, which originates from the Western Ghats and runs across the gentle slopes of the mid lands and confluence in Bay of Bengal. Out of five rivers, River Tamirabarani19 is located in the eastern direction and it is 7km from the Reddiarpatti site. It acts as the main drainage point in the project area. As discussed in the topography section, the slope from the site is towards the River Tamirabarani, which is the main source of irrigation as well as provides drinking water facilities to the settlements in the Tirunelveli district. In the encroachment sites, due to the presence of the structures (dwelling units), the catchment area of the water bodies has been affected.

19 Tamirabarani is a perennial river; originating from Agastyarkoodam peak in the Western Ghats above

Papanasam in Ambasamudram Taluk and flows through Tirunelveli and Tuticorin districts of Tamil Nadu and drains in Gulf of Mannar.

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g) Surface Water

76. Elandhakulam is the nearest surface water body located in the northern side at a distance of 6 km from the project site and River Tamirabarani is located in the eastern side at a distance of 7km. The project area lies within the watershed expanse of the Tamirabarani River Basin. The water from the River Tamirabarani is treated and supplied to the settlements in the Tirunelveli District, similarly, in near future, the water supply to the Reddiarpatti (project area) shall be arranged from the same river source. 77. Water quality of surface water bodies is classified by Central Pollution Control Board into five (A, B, C, D and E, see Table 27) quality classes according to their quality suitability for designated best use. Water quality monitoring of River Tamirabarani is conducted regularly by TNPCB and samples are collected regularly from 12 sampling points. According to the water quality data collected for the period 2014 to 2015, the river water quality is classified as “B”. Annual average value of pH of water ranges between 6.2 and 7.7, Biochemical oxygen Demand (BOD) ranges between 2.0 and 5.0 mg/l. At Authoor and Eral the TDS concentration was recorded high (878 mg/l and 347 mg/l respectively). The presence of Coliforms was observed in all the samples, indicating the contamination due to the sewage inlet into the river. None of these monitoring stations are located near to the project area. The closest monitoring station to the project site is Kokirakulam, which is located at distance of 6.8 km. These are located far up stream or far down stream of the Tirunelveli City. In comparison with the WHO water quality standard, except Manganese all other water quality parameters are within the stipulated limits.

Table 27: Central Pollution Control Board

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Table 28: Tamirabarani River Water Quality (annual average values), 2014-2015

Sl. No. Parameters Units Cheranm devi

Kokira kulam

Murapa nadu

Thiruvidai marudur

Amba samudram

Authoor Eral Kallidai Kurichi

ADB SPS EARF

1 DO mg/l 6 6 7 7 7 7 7 7 -

2 BOD at 27°C mg/l 3 3 2 3 5 3 2 3 -

3 COD mg/l 33.33 38.67 28.67 33.33 29.33 41.33 29.33 32.67 -

4 pH 6.4 6.5 6.8 7.7 7.7 7.2 7 6.2 6.5 to 8.5

5 EC mhos/ cm

110 144 220 80 65 1281 473 74 -

6 Ca++ mg/l 26.58 32.25 67.0 16.17 12.08 117.7 92.25 14.75 75

7 Mg2+ mg/l 9.0 12.0 31.0 6.58 5.75 115.3 46.67 7.08 0.1

8 Na+ mg/l 8.33 10.25 13.17 5.83 4.86 106.30 24.83 5.25 -

9 K+ mg/l 1.5 2.1 2.6 1.3 1.3 10.8 4.7 1.3 -

10 PO43- mg/l 0.12 0.13 0.07 0.09 0.14 0.09 0.08 0.13 -

11 NO3- mg/l 0.19 0.35 2.16 0.24 0.11 0.45 0.24 0.2 45

12 SO42+ mg/l 11.69 14.67 14.43 9.23 6.97 52 18.7 9.06 200

13 Cl- mg/l 15.46 17.63 25.08 12.97 10.72 367.9 41.67 11.55 250

14 F- mg/l 0.01 0.01 0.01 0.01 0.01 0.01 0.01 0.01 1

15 Total Alkalinity mg/l 37.92 45.13 83.5 25.42 18.00 142.0 119.5 23.92 -

16 TDS mg/l 80.5 105.5 158.17 59.17 49.5 878.0 347.17 55.5 500

17 Turbidity NTU 6.75 6.0 4.75 5.0 4.5 5.83 6.0 5.0 1

18 Total Coliform MPN/ 100 ml

56.0 82.0 45.0 45.0 46.0 62.0 60.0 52.0 Must not be detectable in any 100 ml sample

BOD = biochemical oxygen demand, COD = chemical oxygen demand, DO = dissolved oxygen, mg/l = milligram per liter, ml = milliliter, MPN = most probable number, NTU = Nephelometric Turbidity Unit, pH = potential of hydrogen, TDS = total dissolved solids. Source: Tamil Nadu Pollution Control Board.

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h) Groundwater

78. Tirunelveli district is underlined by both porous and fissured formations. The important aquifer systems in the district are created by Weathered and fractured hard rock formations of Archaean age and Porous sedimentary formations ranging in age from Tertiary and Recent. The porous formations are found as small patch in the south-eastern part of the district. The porous sedimentary river alluvium is found along the river courses and the thickness of alluvium is restricted to 5-6 m. 79. As per the Central Groundwater Board (CGWB) study, the thickness of weathered zone in the Tirunelveli district is up to 30 meter below ground level (mbgl). The groundwater exploration in the district downs to a depth of 200 mbgl by CGWB has revealed that in the western part of the district potential fractures are encountered beyond 100 mbgl while in the rest of the area, potential fractures are restricted to 100 mbgl. The well yield is in the range of 63 to 270 litres per minute. The depth to water level in the district varies between 1.19 to 13.35 mbgl during pre-monsoon; depth to water level varies between 0.18 to 7.97 mbgl during post monsoon. The seasonal fluctuation shows a fall in water level, which ranges from -0.12 to -2.14 mbgl, and rise in water level, which ranges from 0.33 to 11.24 mbgl. 80. As per the information collected from the National Remote Sensing Centre (BHUVAN), Reddiarpatti is falling under the ground water scarce area. It is depicted in the following Error! Reference source not found.. As an enhancement measure rainwater harvesting structures are proposed at each building blocks as well as in surface water drains.

Figure 21: Groundwater Prospects for Reddiarpatti Subproject Area

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

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Table 29: Groundwater Quality in Tirunelveli, 2014 Sl.no Parameters Units BIS standard Sankarnagar Vannar

pettai Rajagopalapuram IOB

Colony

1 Total hardness mg/l 300-600 220 52 310 328

2 pH 6.5 - 8.5 7.68 8.14 7.05 7.56

3 EC - 789 135 1042 980

4 Ca++ mg/l 75-200 50 12 88 85

5 Mg2+ mg/l 30 - 100 23 5 22 28

6 Na+ mg/l 200 75 7 88 75

7 K+ mg/l - 15 2 19 13

8 PO43- mg/l - 0.21 0.02 0.27 0.16

9 NO3- mg/l 45-100 3 0 6 6

10 SO42- mg/l 200-400 41 4 44 26

11 CL- mg/l 250 90 14 140 146

12 F- mg/l 0.1 – 1.5 0.8 0.1 0.1 0

13 Total Alkalinity mg/l - 232 42 280 240

14 TDS mg/l 500-2000 536 95 708 667

i) Ambient Air Quality and Noise levels

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

Table 30: Ambient Air Quality in Tirunelveli

Sl.no Parameters Locations

AAQ Standard

WHO standard

Tirunelveli Town Pettai

1 Particulate Matter (PM10) 65 45 50 60

2 Particulate Matter (PM2.5) 15 12 25 100

3 Oxides of sulphur (SOx) 13 9 20 80

4 Oxides of Nitrogen (NOx) 21 15 80 80

Source: TNPCB/ Air Quality

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

Table 31: Ambient Noise Levels in Tirunelveli Sl.no Location Leq Day Time Leq Night Time

1 Tirunelveli Town (Residential) 61.8 57.9

2 Pettai (commercial) 56.8 54.3

Noise quality Standard (CPCB)

Residential 55.0 45.0

Commercial 65.0 55.0

WHO Standards for Noise

Industrial 70.0 70.0

Residential 55.0 45.0 Source: TNPCB/ Ambient Noise Levels

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D. Biological Environment

84. Tirunelveli is an urban area surrounded by land that was converted from agricultural use many years ago. There is no remaining natural habitat in the town. The flora is limited to artificially planted trees and shrubs and the fauna comprises of domesticated animals (cows, goats, pigs and chickens), plus other species are able to live close to man (urban birds and rodents). River Tamirabarani, which flows through the town, is an important part of its ecosystem and it is 7km from Reddiarpatti. River Tamirabarani, has high seasonal fluctuations inflows, with very high flow during monsoon to or linear flow/ no flow during summers. 85. As per the IBAT study (refer Appendix 15), the Vellanadu Blackbuck Wildlife Sanctuary is located at a distance of 10 km from the Reddiarpatti resettlement site, however as per the Google Earth as well as the forest maps, it is located at a distance of 15.4km. Another wildlife sanctuary (Koonthankulam BirdSanctuary), is located at a distance of 20 km from the Reddiarpatti resettlement site. Considering the forest department information, it shall be concluded that there are no protected areas, eco sensitive zones or ecologically sensitive areas notified by MoEF&CC within a radius of 10 km from the Reddiarpatti resettlement site. 86. As per the MoEF&CC guideline for Eco Sensitive Zone, there are no sensitive areas like forest or protected areas located at a radius of 10 km surrounding from the Reddiarpatti (project area). Vallanadu Blackbuck Wildlife Sanctuary is the nearest to the Reddiarpatti project area, which is located at a distance of 15.4 km. Which is followed by Koonthankulam Bird Sanctuary, which is located at a distance of nearly 20 km. 87. Vallanadu Blackbusk Wildlife Sanctuary. The Vallanadu Blackbuck Sanctuary is an isolated hillock with scrub forest in Thoothukudi Revenue District situated on eastern side of Tirunelveli – Tuticorin highway. The Vallanadu Wildlife Sanctuary is a protected area by the Tamil Nadu Forest Department. It is created for the protection of blackbuck antelope and it is spread over an area of 16.41 sq km. Thorny hardwood and xerophytes (Dalbergia horrida (see Dalbergia), Dichrostachys cinerea, Vachellia horrida, Acacia planifrons, Albizia amara, Zizyphus sp. and a few Azadirachta indica, Dodonia viscosa[clarification needed], Carissa carandas, Pterolobium hexapetalum, Euphorbia, Acalypha fruticosa and Ocimum tenuiflorum) are predominantly observed in this sanctuary. Apart from the xerophytes, some of the common trees observed are jackfruit, betel nut palm, Jamun and Mangoes. The dominating faunal species are Blackbuck (Antilope cervicapra), Spotted deer (Axis axis), Macaque monkey (Macaca mulatta), Jungle cat (Felis chaus), common monkey (Macaca sinica), Wild cat (Felis silvestris), Mongoose (Herpestes edwardsi), Black naped hare (Lepus nigricollis), Scaly anteater (Manis crassicaudata), Viper snake (Crotalus horridus) and Rat snake (Ptyas mucosa).

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Figure 22: Location of Vallanadu Blackbuck Wildlife Sanctuary

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

Figure 23: Location of Koonthankulam Wildlife Sanctuary

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E. Social Environment

a) Demographic Profile

89. All the 9 encroachments are located within the Tirunelveli Municipal Corporation. It covers an area of 108.65 km². As of 2011 India census, Tirunelveli Municipal Corporation has a population of 473,637 of which 233,659 are male while 239,978 are female. Population of Children with an age of 0-6 is 46,624 which is 9.84 % of total population. Female Sex Ratio is 1027 against the state average of 996. Moreover, the Child Sex Ratio is around 951 compared to Tamil Nadu state average of 943. Literacy rate is 90.39 %, which is higher than the state average of 80.09 %. The male literacy rate is around 94.75 % while female literacy rate is 86.18 %. The growth rate of urban agglomeration20 is 20.22%. 90. According to Census 2011, Reddiarpatti's population is 5,166. Out of this, 2,629 are males while females make up 2,537. This village has 577 children in the age bracket of 0-6 years among them 298 are boys and 279 are girls. Literacy rates in Reddiarpatti village is 77%. 3,983 out of a total of 5166 population are literate. Among males the literacy rate is 81% as 2,154 males out of total 2,629 are literate while female literacy rate is 72% as 1,829 out of total 2,537 females are educated in this Village. The negative side is that illiteracy rate of Reddiarpatti village is 22%. Here 1,183 out of total 5,166 people are illiterate. Male illiteracy rate is 18% as 475 males out of total 2,629 are uneducated. In females the illiteracy rate is 27% and 708 out of total 2,537 females are illiterate in this village. In Reddiarpatti village out of total population, 2083 are engaged in work activities. 78.54 % of workers describe their work as Main Work (Employment or Earning more than 6 Months) while 21.46 % are involved in Marginal activity providing livelihood for less than 6 months. Of 2083 workers engaged in Main Work, 64 are cultivators (owner or co-owner) while 116 are agricultural labourer.

b) Socio-Economic Features

91. The economy of Tirunelveli district is chiefly agro based, given its vast agricultural hinterland. It is also rich in mineral resources like limestone, garnet sand etc. that contribute to the region’s economy. Small Industrial Development Corporation (SIDCO) has developed an Industrial estate in the Pettai area on the northern part of the city. The city has the distinction of having the first spinning mill established under co-operative movement at Pettai in 1958. Tamilnadu Sugar Corporation limited has established a factory at Tirunelveli. Due to limestone deposits, there are cement factories in the vicinity of the city. 92. There are 25 medium and major industries such as Cement, Cotton yarn, Sugar, Rice bran oil, Printing papers and flour Mill etc. Beedi rolling, safety matches making, mat weaving and processing and manufacturing of palm fibre and articles from Palm trees and hand loom weaving of textiles are the main household industries that are found in the city and its adjoining hinterland. Some of the famous products from Tirunelveli area include: Korai mats from Pathamadi, Kallidaikurichi Pappads, Karukurichi mud pots. 93. The river and the centuries old irrigation system associated with it, have made Tirunelveli district, a major ‘rice bowl’ of Tamil Nadu. The primary crops grown in the region are paddy and cotton; people are also engaged in the cultivation of spices and condiments (like cumbu, ragi) groundnut, pulses, gingelly, coconut, chilies, and indigo. The most common tree is the Palmyra palm, a raw material in cottage industries.

20 An urban agglomeration is a continuous urban spread constituting a town and its adjoining outgrowths (OGs), or

two or more physically contiguous towns together with or without outgrowths of such towns.

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Table 32: MSME Industrial Units in Tirunelveli City – Zone wise Sl.no Zones Number of Micro, Small and Medium Scale

Establishment Units

1 Thatchanallur Zone 37

2 Palayamkottai Zone 66

3 Melapalayam Zone 31

4 Tirunelveli Zone 60

Total 194 Source: MSME, Tirunelveli District

c) Infrastructure

94. Water Supply. The main source of water supply for Tirunelveli Corporation is from River Tamirabarani. About 55 MLD of treated water is supplied to the city with per capita supply of 116 lpcd from 11 head works, covering 55 wards. A new water supply scheme by proposing Ariyanayagipuram Anicut across River Tamirabarani has been designed to meet the growing demand of the Tirunelveli Municipal Corporation area that envisages supply of 135 LPCD. 95. Sewerage. Tirunelveli town and the junction (area around the railway station) of the corporation area has had an underground drainage system installed since 1989. The corporation is divided into 4 Administrative zones. The sewage generated from each zone is collected through a network of street sewers to a collection well. The sewage collected in each zone is pumped to the sewage treatment plant constructed at Ramaiyanpattai of capacity 24.20 MLD. The treated effluent is let into the open channel and utilized for Agriculture. The total length of sewer line is 187.27 km with 7,924 manholes. The total number of house service connections is 22,226. The Underground sewerage System (UGSS) is proposed and the work is in progress near the project site. 96. Solid Waste Management. Sanitation in the Tirunelveli Municipal Corporation is effectively operated by 17 sanitary units. About 100 metric tonnes of solid waste is collected from the city daily by door-to-door collection. The per capita waste generation is about 350 gram per day and total generation is around 180 tons per day. 97. Transportation. The project site is well connected by road, rail and air ways. The proposed project is located nearer to Varanasi to Kanyakumari highway road (NH-7). Palayam Kottai Railway Station is station is located at 4.41 km, NW direction from the project site. Reddiarpatti bus stand is 0.94 km from the project site. The closest airport to the city is the Thoothukkudi airport (28 km), located at Vaagaikulam in Thoothukkudi district. 98. Hospitals. There are many government and private hospitals and small clinics that are available in the Reddiarpatti. Few of them are Arogya Vanam Health Centre, Savera Dental Care, JK Hospital and Primary Health Center are located less than a kilometre from the resettlement site. 99. Education Institutions. Reddiarpatti is a school cluster in Palayamkottai Rural block of Tirunelveli district, the project area has about 20 schools. This cluster includes private and government schools. Some of the well-known schools includes Good Shepherd School, Rose Mary Matric. Higher. Secondary. School, Sri Jayendra Swamigal Silver Jubilee School, Apple Kids International Pre School, High School for the Blind, Pushpalata British International School, A.U.P.E.T. Chinmaya Vidyalaya, Adithya Vidhya Niketan School and Sringeri Sarada Vidyalaya Matriculation Higher Secondary School (nearest to the resettlement site located at a distance of 2.5km).

d) Cultural and Heritage sites

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

Table 33: Information on the Archaeological Monuments Sl.no Protected Monument Location Distance from

Reddiarpatti ( km)

National Monuments

1 Bhaktavatsala Temple Cheranmahadevi 20.20

2 Valisvara Temple Tiruvalisvaram 25.20

3 Two rock cut temples with inscriptions in Varunachimalai

Thirumalapuram 46.60

4 Ancient Site Kunnathur 8.80

State Protected Monuments

5 Poola Udaiyar Inscription and Bed Pandian kudiyiruppu

53.20

6 Iranyan kudiyiruppu Nanguneri 22.45

7 Tiruneelakandar Temple Pananjadi 15.60

Source: ASI

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

Figure 24: National Monuments surrounding the Project Area

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V. ANALYSIS OF ALTERNATIVES

102. During project preparation, comprising of screening and design preparation, various alternatives were identified and analysed to help in decision making. A. With and Without project alternatives

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

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

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

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

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proposed within the resettlement sites, which will marginally reduce the use of TNEB power supply. Internal roads have been designed with storm water drains that will prevent flooding/ ponding of water within the resettlement site. It is proposed to have rainwater harvesting pits/ structures surrounding the residential blocks as well as in common areas to tap the rainwater to increase the groundwater recharge potential. It is planned to have native floral species in the green area/ landscaping areas. 5 years of periodic operation and maintenance has been proposed. 106. A graduation program shall be conducted for the relocated people to improve self-sustainability and to access to better economic opportunities that will help to improve living standards. This subproject also aims to improve the gender balance and women empowerment by assisting the women in the family, women headed households and elderly people through skill development training programs (under the Tamil Nadu Skill Development Corporation). C. Without Project Scenario

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

(i) substandard housing and lack of hygiene; (ii) significant health risks (due to mosquito breeding and spread of vector borne

diseases); (iii) They lack basic facilities like road, electricity and drinking water (iv) The illegal nature of housing makes encroachers susceptible to extortion (v) They are more prone to disasters like urban floods

108. Key Social issues. It is evident from the site visits, that none of the encroachment sites are provided with a household connection to water supply as a common water tap is provided for the entire community of slum dwellers at a distance of 500 m to 1 km (min distance). This is a difficult situation especially for women. All the encroachment sites do not have basic infrastructure facilities as those that are available are too far for people or are poorly designed and in unhygienic conditions. The quality of life is observed to be below average, as most of them are working as daily labours. The dwelling structures do not have strength to withstand climate hazards (including heavy rain, wind and increase in temperature). The approach roads are too narrow and are without streetlights, which is not safe for the night time road users especially women. 109. Key Environmental issues. The catchment area of the water bodies has been encroached and as a result the natural drains are closed with the water bodies in a dilapidated condition. Some of the water body area has been covered by wild thorny bushes and contains solid waste from the encroachers and the general public. Proper toilet facilities are not available and untreated sewage water is discharged into the water body which deteriorates water quality and indirectly causes ground water contamination. D. Alternate Technology Adopted for STP

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

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

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

Table 34: DWATS Salient Features Sl.no

DWATS Components

Advantages Disadvantages

1 Settler simple, durable, underground need regular de-sludging

2 Anaerobic Baffled Reactor

simple, durable, little permanent space, high treatment efficiency

required large space

3 Anaerobic filter simple, durable, underground, high treatment efficiency

costly, filter blockage

4 Planted Gravel Filter

high efficiency, no nuisance, no wastewater on ground

need permanent space, requited intensive maintenance with expertise, relatively costly

(ii) SBR Technology. SBR aeration system is similar to an Activated Sludge

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

The advantages of using SBR include its:

ability to adapt to different volumes of influent;

work with automated controls; and

requiring less space than a system using multiple tanks

The disadvantages of this process are:

that is necessitates sophisticated controls and timing units; and

requires more maintenance than conventional systems

E. Alternative Approaches to the Resettlement site design

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

Table 35: Alternative Approach in Building Plan CATEGORY Traditional TNSCB Building

Plan Proposed TNSCB Building Plan (ADB

funded)

URBAN DESIGN

Overall Focus Cost efficiency, number of units

Quality of life, people centric designs that are future ready (without compromising on cost and number of units)

Site Approach Design assumes site to be an independent plot of land, often with minimal connection (spatial and programmatic) with the surrounding context

Integrated, sustainable design solutions

Environmental Sustainability

Minimal solutions created to respond to the context and environmental sustainability

Providing environmentally sensitive design solutions to ensure minimum carbon footprint, while creating a healthy and comfortable living environment

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CATEGORY Traditional TNSCB Building Plan

Proposed TNSCB Building Plan (ADB funded)

Inclusive Design

Inadequate consideration of different user groups.

Creating design strategies that focus on vulnerable groups within the community such as children, differently abled, the aged, youth and women

Spatial and Circulation Hierarchy

Hierarchy of spaces absent thereby making the open spaces monotonous

Creating a hierarchy of open and community spaces with appropriate density to support diverse forms of social interactions

Vehicular movement typically prioritized; vehicular circulation paths also intersect with pedestrian paths creating unsafe environments for the residents

Promoting pedestrian circulation and networks over vehicular circulation in order to create safe spaces for all users; creating safe interactions

Open Space Design

Design approach typically treats open spaces as "left over spaces" rather than integrating them cohesively.

Spatial design that focuses on the design of shared public spaces to nurture harmony of collective action

Landscape Design

Inadequate focus on landscape design

Open spaces that integrate native, natural landscapes that are didactic, productive as well as recreational in their functions

Walkability Lack of walkable spaces Promoting Walkability- nodes typically within 3m, 5m and 7m walking radii

Block Arrangements

Standardised block patterns does not create unique identity to the communities

Enhancing a sense of identity and belonging through block design

Closely placed blocks to optimize efficiency reduces privacy

Design allows for greater distance between blocks where possible and avoids the situation where the longer side of blocks face one another

Blocks are designed close to each other with less focus on the human scale

Designing blocks that are perceivable for the human scale

Eyes on the Street

Design has leftover/ narrow alleyways/ spaces which are poorly maintained and end up being blighted unsafe regions of the community

Designing neighborhoods such that they avoid redundant areas away from sight which are prone to poor maintenance and blight; activating spaces between buildings and adding value through artwork and other design solutions

Promoting Physical and Mental Well Being

Inadequate attention to open space programming that promotes physical and mental well being

Creating programmatic interventions in open spaces that enable physical and mental recreation for different age groups

Cater to the physical and emotional needs of different groups of people in the design of spaces

Visual Quality Minimal visual quality features incorporated in the design

Emphasizing visual quality of spaces through the introduction of nodes, elevation design etc to name a few

BLOCK DESIGN

Block Orientation

Buildings are oriented without critical consideration of site features, daylight and wind paths

Building orientations to be responsive to the site conditions/ context, with a focus on improved interior thermal comfort

Façade Design Minimal intervention on facade design and almost restricted to the same style across all sites

Enhancing the external appearance of buildings through innovative façade design, with a focus on optimizing O&M costs

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CATEGORY Traditional TNSCB Building Plan

Proposed TNSCB Building Plan (ADB funded)

Openings Buildings are designed with minimal openings creating dark and long corridors and un-aesthetic built form; lack of adoption of passive surveillance

Visualising and designing blocks as a product of solids and voids to create spaces for interaction and enhance the quality of the common spaces

Block Length Blocks accommodate large number of units creating long and dark corridors

Incorporating limited housing units within each block to ensure shorter corridors that help with way finding

Building Heights

Repetitive blocks that creates a sense of monotony

Creating modulated block forms with varying heights to add to the character of the community while adding vibrancy

UNIT DESIGN

Efficiency Units are maximised to have maximum efficiency

Carpet area maximised to create a healthy living environment

Space Segregation

Minimal spaces are designed within the units without segregation of spaces

Addition of ante space and balconies to create better circulation and segregation of activities in spaces

Creating multi-functional spaces to enhance better usage of spaces while not compromising on the sizes

Storage Areas Minimal storage facilities are provided within the units

Creating multiple storage facilities within the unit for residents to store their personal belongings

F. Outcome based on the analysis

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

Table 36: Outcome of the Analysis of Alternatives Sl.no Infrastructure facilities and other amenities With Project Without Project

1. Well-structured Residential Building

2. Electricity

3. Water supply

4. Approach Road

5. Convenience shop

6. Ration shop

7. Anganwadi

8. Milk booth

9. Community Hall

10. Livelihood Center and Library

11. Health Sub Centre

12. Street Lights

13. Sewage Treatment Plant

14. Solid waste management

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VI. ANTICIPATED ENVIRONMENTAL IMPACTS AND MITIGATION MEASURES

113. This chapter on the anticipated environmental impacts and mitigation measures is based on the preliminary detailed design for the Reddiarpatti resettlement site and proposed demolition works and water body regeneration works are based on the consultations had with TNSCB officials. The given information will have to be updated/ revised once the detailed designs are finalized for resettlement site and plans for demolition at the encroachment sites and water body regeneration works are completed. 114. Screening of potential environmental impacts is categorized into four categories considering project phases: location impacts and design impacts (pre-construction phase), construction phase impacts and operations and maintenance phase impacts:

(i) Location impacts. Impacts associated with site selection, including impacts on environment and resettlement or livelihood related impacts on communities

(ii) Design impacts. Impacts arising from project design, including the technology used, scale of operations etc.

(iii) Construction impacts. Impacts resulting from construction activities including site clearance, earthworks, civil works, etc.

(iv) O&M impacts. Impacts associated with the operation and maintenance of the infrastructure built in the project.

115. The proposal envisages construction of (i) residential units (large scale construction activity provided with essential amenities), (ii) demolishing activity (for the identified 9 encroachment sites (old settlement sites), which are chosen for relocation), (iii) restoration of water bodies (at 9 relocated locations) and (iv) Operation and maintenance (O&M). The construction of residential units along with supporting urban infrastructure and services at Reddiarpatti and demolishing works at the encroachment sites identified for relocations are located in the adjoining area of the existing buildings and hence this would result in environmental impacts typical to the construction activities. The land identified for construction of residential units at Reddiarpatti belongs to the TNSCB and hence it is free from any encumbrances. 116. The sites identified for demolition (encroachment sites for relocation) are located within the settlement area. Gaining free access and movement of workers, vehicles and other construction related machinery would be an issue that will be addressed by obtaining requisite permissions, consultations with affected stakeholders and public information dissemination before commencement of demolition works on site. Identity cards and vehicle permits shall be provided by the Contractor for all such movement to and from the construction site. A Traffic Management Plan (TMP) should be prepared by the Contractor in consultation with PIDs and affected stakeholders. 117. Other impacts related to construction activities such as generation of dust and noise, removal of construction debris and demolition wastes etc. are envisaged which shall be minimized and addressed by adopting safe engineering practices and appropriate methodology for demolishing works and water body restoration works. Caution will be exercised in planning for safe construction and operations phase to minimize disturbance to the adjoining existing activities. Provision for water for construction will be made through municipal water supply or through mobile water tankers. 118. Land Acquisition and Resettlement. As indicated earlier, the land proposed (8.99 ha) for construction of residential units and associated services belongs to the TNSCB21, similarly the encroachment areas (proposed for demolition) are owned by the Tirunelveli Municipal

21 90366sqm of land is required for the ADB financed portion of the resettlement site.

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Corporation and hence land acquisition is not envisaged. As per the Resettlement Framework (RF), the proposed categorisation for this subproject is Category “A”, for involuntary resettlement (IR) as it results in physical or economical displacement for 807 Households (HH). 119. Design Considerations to Avoid Environmental Impacts The following are design considerations to avoid environmental impacts:

(i) Incorporation of adequate drainage provisions (ii) Provision for adequate cross ventilation (iii) Adoption of design compatible with the natural environment and suitable

selection of materials to enhance the aesthetic appeal and to blend with the natural surroundings.

(iv) Straight lines and simple geometry in the proposed landscape and architectural features.

(v) Natural tree species in the proposed landscape (vi) A separate area has been designated (away from the residential blocks) in the

layout plan for managing municipal solid waste generated in the resettlement site

(vii) Ensure water demand can be met sustainably and reused wherever possible. The STP and treated water is proposed to be utilised for flushing and gardening purposes by reducing the water demand.

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

121. Determination of Area of Influence. The primary impact areas are (i) sites for proposed project components; (ii) main routes/intersections which will be traversed by construction vehicles; and (iii) quarries and borrow pits as sources of construction materials. The secondary impact areas are: (i) Other than the delineated primary impact area; and (ii) areas surrounding the Reddiarpatti site in terms of over-all environmental and socioeconomic improvement. 122. In the case of this subproject the components will involve straight forward construction and operation, and impacts will be mainly localized, short in duration and expected during construction and operation period. B. Pre-construction Impacts and Mitigation Measures

123. Consents, permits, clearances, no objection certificate (NOC), etc. Necessary consents/NOC as per Table 5, Table 6, para 53 and 54 will be required to be obtained during pre-construction phase and before any civil works commence. A copy of Consent/Permission/Clearance/ NoC should be included in the monitoring reports and submitted to the PID and PMU. Failure in obtaining the same will result in delay of work and may lead to stoppage of works. 124. Mitigation measures. The following measures will be conducted during the detailed design phase prior to construction for the resettlement site, demolition and regeneration works:

(i) Obtain all necessary consents, permits, clearance, NOCs, etc. prior to start of civil works.

(ii) Acknowledge in writing and provide report on compliance of all obtained consents, permits, clearance, NOCs, etc.

(iii) Include in detailed design drawings and documents all conditions (e.g. the

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location of the STP should be away from the settlement area and the treated water should meet the discharge standards as per the TNPCB) and provisions if necessary

(iv) The demolished materials from the 9 encroachment sites should be recycled to the maximum extent possible (3R concept should be adopted).

(v) For asbestos material disposal, an appropriate inventory has to be carried out and proposed management measures implemented before any demolition activity occurs by the Asbestos Expert/ Environmental Specialist in the encroachment sites. Care should be taken in disposal of the asbestos materials (used as roofing materials) as per the relevant protocols/ hazardous waste management rules 2016 (refer to the EMP for Asbestos material management).

(vi) In compliance to the Noise Standards, the proposed construction activities should be implemented in a controlled manner, the dB(A) levels for residential area (day time noise level 55 dB(A) and night time noise level 45 dB(A)) should be maintained.

(vii) Pre-construction environmental monitoring as indicated in Table 42 will be conducted by the Contractor under the supervision of the PID. The outcome of the analysis shall be referred as baseline information for key environs (Air, Water and Noise).

(viii) Conduct consultation with the local communities and provide detail in the language that is understandable to the local community regarding project activities and the anticipated impacts as part of the project information dissemination (prior to the start of the construction and demolition activity).

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

(i) Identify and include locations and operators of these utilities in the DPR to prevent unnecessary disruption of services during the construction phase.

(ii) Require contractors to prepare a contingency plan to include actions to be done in case of unintentional interruption of services.

(iii) Require contractor to obtain from the PIDs the list of affected utilities and operators;

(iv) If relocations are necessary, contractors along with PIDs will coordinate with the providers/line agencies to relocate the utility.

(v) Consult with the local communities if there is a need for interruption of services (especially during the demolition activities)

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

(i) Ensure the ADB SPS 2009 requirements are met while dealing with physical cultural resources

(ii) Continually consult Archaeological Survey of India and/or State Department of Archaeology to obtain an expert assessment of the archaeological potential of the site.

(iii) Consider alternatives if the site is found to be of medium or high risk. (iv) Include state and local archaeological, cultural and historical authorities, and

interest groups in consultation forums as project stakeholders so that their expertise can be made available.

(v) Develop a chance find protocol for use by the construction contractors in conducting any excavation work, to ensure that any chance finds are

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

127. Site selection of construction work camps, stockpile areas, storage areas, and disposal areas. Priority is to locate these near the project location. However, if it is deemed necessary to locate elsewhere, sites to be considered will not promote instability and result in destruction of property, vegetation, irrigation, and drinking water supply systems. Residential areas will not be considered for setting up construction camps to protect the human environment (i.e., to curb accident risks, health risks due to air and water pollution and dust, noise, and to prevent social conflicts, shortages of amenities, and crime). Extreme care will be taken to avoid disposals near forest areas or in water bodies. 128. Site selection of sources of materials. Significant quantities of bricks, coarse aggregate and fine aggregate will be required for construction works (including the construction works in the resettlement site as well as water body regeneration works). The contractor should procure these materials only from the quarries permitted/licensed by Department of Geology and Mining. The contractor should, to the maximum extent possible, procure material from existing quarries, and creation of new quarry areas should be avoided as far as possible. If new quarries are required then the contractor will be responsible for obtaining all permissions and clearances, including environmental clearance for mining. The contractor should factor in the time required for obtaining clearances including conduct of EIA if required under the law. It will be the construction contractor’s responsibility to verify the suitability and legal status of all material sources and to obtain the approval of Department of Geology and Mining and local revenue administration, as required. 129. Erosion control. Most of the impacts will occur due to excavation and earth movements during construction phase. Prior to commencement of civil works, the contractor will be required to:

(i) Develop an erosion control and re-vegetation plan to minimize soil loss and reduce sedimentation.

(ii) Minimize the potential for erosion by balancing cuts and fills to the extent feasible.

(iii) Identify and avoid areas with unstable slopes and local factors that can cause slope instability (groundwater conditions, precipitation, seismic activity, slope angles, and geologic structure).

(iv) Minimize the amount of land disturbed as much as possible. Use existing roads, disturbed areas, and borrow pits and quarries when possible. Minimize vegetation removal. Stage construction to limit the exposed area at any one time.

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

(i) Plan transportation routes so that heavy vehicles do not use narrow local roads, except in the immediate vicinity of delivery sites.

(ii) Schedule transport and hauling activities during non-peak hours. (iii) Locate entry and exit points in areas where there is low potential for traffic

congestion. (iv) Keep the site free from all unnecessary obstructions. (v) Drive vehicles in a considerate manner.

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C. Construction Impacts and Mitigation Measures

131. The impacts during the proposed construction works are standard and site-specific to the construction activities and are not expected to be significant. The Environmental Management Plans (EMP’s) specifies the necessary mitigation measures to be strictly followed by the Contractors and supervised by the PIDs. Key impacts during construction are envisaged on the following aspects (i) transportation of materials, (ii) dust generation, air and noise pollution from construction activities, (iii) sourcing of water for construction activities, (iv) handling of construction materials at site and, (v) adoption of safety measures during construction. However, the prepared EMPs (refer to chapter VIII) should be updated as construction EMPs based on the site conditions by the contractor under the supervision of the PIDs. 132. Construction Schedule and Method. As per the detailed design, construction activities in the resettlement site is expected to take 24 months (tentatively), demolition activities in the 9 encroachment sites shall take 6 months and the 9 water bodies regeneration works is expected to take 6 to 12 months for completion. The proposed interventions for the resettlement site will be constructed manually with minimum use of machinery and equipment and with necessary safety precautions, for example, barricades around demolition sites, restricting pedestrian and vehicular movements. Noise from demolition works should not exceed the noise standards as set by CPCB. Any damage to surrounding buildings will require work to be stopped immediately and rectified before work can recommence.. The materials from the demolishing works will be reused to the maximum extent possible. Materials will be brought to site by trucks and will be stored on unused areas within the project site. The working hours will be 8 hours daily. Night works will be avoided except on an emergency basis or due to high day-time traffic as per prevailing conditions at the time of construction. This shall be further considered by the PID but only in consultation with the local communities. 133. There is sufficient space for a staging area, construction equipment, and stockpiling of materials. However, the Contractor will need to remove all construction and demolition wastes on a daily basis. 134. Erosion Hazards. The resettlement site at Reddiarpatti is located in a small hill lock and hence the risk of erosion is high. For the demolishing works, the encroachment sites are located in the built-up area and therefore the risk of erosion is low. However, the Contractor will require to:

(i) Save topsoil removed during excavation and use to reclaim disturbed areas, as soon as it is possible to do so.

(ii) Use dust abatement such as water spraying to minimize windblown erosion. (iii) Provide temporary stabilization of disturbed/excavated areas that are not active

under construction. (iv) Apply erosion controls (e.g., silt traps) along the drainage leading to the water

drains. (v) Maintain vegetative cover within unused land to prevent erosion and

periodically monitor the area to assess erosion. (vi) Clean and maintain catch basins, drainage ditches and culverts regularly. (vii) Conduct routine site inspection to assess the effectiveness and the

maintenance requirements for erosion and sediment control systems.

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

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

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especially at the time of drilling the piles, which may disturb the surrounding area due to vibration.

(ii) The Contractor should check the soil stability and to avoid highly erodible soils (if any) and also the slope stability.

(iii) Appropriate compaction has to be conducted in arresting the loose soil, which may lead to erosion

(iv) The use of chemical stabilizers shall be explored

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

(i) The project sites (including the resettlement site and the water body regeneration sites) are in a water scarce area where the use of groundwater is prohibited for construction purposes, hence the contractor should arrange for water, which shall be either purchased from the ULB or the TWAD. The agreement and / or MoU has to be shared with the PID. For any other arrangements for the source of water, the evidence of the same has to be furnished to the PID.

(ii) Schedule civil works during non-monsoon season, to the maximum extent possible.

(iii) Ensure drainages within the construction zones are kept free of obstructions. (iv) Keep loose soil material and stockpiles out of drains and flow-lines. (v) Avoid stockpiling of excavated and construction materials (sand, gravel,

cement, etc.) unless covered by tarpaulins or plastic sheets. (vi) Conduct periodic Environmental Monitoring to check the water quality as

indicated in the Table 42. (vii) Use silt trap for the surface runoff to prevent sediments entering into the nearby

irrigation tank/ water bodies. (viii) Re-use/utilize, to maximum extent possible, excavated materials. (ix) Dispose any residuals at identified disposal site (PID will identify approved

sites). (x) Dispose waste oil and lubricants generated as per provisions of Hazardous

Waste (Management and Handling) Rules, 1989.

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

(i) Conduct regular water spraying on earth piles, trenches and sand piles. (ii) Conduct regular visual inspection in the construction zones to ensure that there

are no excessive dust emissions. (iii) Spreading crushed gravel over backfilled surfaces if re-surfacing of disturbed

areas cannot be done immediately. (iv) Maintain construction vehicles and obtain “Pollution Under Control” (PUC)

certificate from Emission Testing Centres (authorised by TNPCB). (v) Obtain CtE and CtO for batching plants, crushers, diesel generators, etc., if is

to be used in the project from TNPCB. (vi) Conduct periodical environmental monitoring for ambient air as per schedule

given in EMP (Table 42).

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

(i) Plan activities in consultation with the PID’s so that activities with the greatest potential to generate noise are conducted during periods of the day which will result in least disturbance.

(ii) Minimize noise from construction equipment by using vehicle silencers and fitting jackhammers with noise-reducing mufflers.

(iii) Create awareness among drivers not to use horns unless it is necessary to warn other road users or animals of the vehicle’s approach.

(iv) Shut off idling equipment. (v) Night time construction activities should be avoided and no piling works shall

occur at night, and only be considered on an emergency basis or due to high day-time traffic as per prevailing conditions at the time of construction

(vi) Follow day time ambient noise levels as per Noise Pollution (Regulation and Control) Rules and conduct periodical environmental monitoring for ambient noise as per schedules given in EMP Table 42

(vii) Ensure vehicles comply with Government of India noise limits for vehicles. Pollution Under Control (PUC) should be available for every construction equipment and vehicles.

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

(i) Conduct site induction and environmental awareness. (ii) Limit activities within the work area. (iii) Do not remove or harm existing vegetation except those required under

proposed contract (iv) Strictly instruct workers not to cut trees for fuel wood. (v) Replant trees in the area using minimum ratio of 10 trees for every 1 tree cut,

if any. Replacement species must be approved by District Forest Department.

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

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

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disposal. Include in waste management plan designated/approved disposal areas.

(iii) Coordinate with Municipal Authorities/ ULB’s for beneficial use of demolished materials or immediately dispose to designated areas.

(iv) Recover used oil and lubricants and reuse; or remove from the sites. (v) Avoid stockpiling and remove immediately all demolished materials, excess

construction materials, and solid waste (removed concrete, wood, packaging materials, empty containers, oils, lubricants, and other similar items).

(vi) Prohibit disposal of any material or wastes (including human waste) into drainage, nallah, or watercourse.

(vii) Any waste that contains asbestos, or is contaminated with asbestos, must be double-bagged, labelled and placed in a covered, locked skip. This includes asbestos sheets, asbestos pipeline, asbestos cement etc. Care should be taken in the handling and disposal of the asbestos materials as per the relevant protocols/ hazardous waste management rules 2016 and the EMP (refer EMP for Asbestos material management).

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

(i) Disallow worker exposure to noise level greater than 85 dB(A) for a duration of more than 8 hours per day without hearing protection. The use of hearing protection shall be enforced actively.

(ii) Develop a comprehensive site-specific health and safety (H&S) plan. The overall objective is to provide guidance to Contractor on establishing a management strategy and applying practices that are intended to eliminate, or reduce, fatalities, injuries and illnesses for workers performing activities and tasks associated with the project.

(iii) Include in H&S plan measures such as: (i) type of hazards during excavation works; (ii) corresponding personal protective equipment for each identified hazard; (iii) H&S training for all site personnel; (iv) procedures to be followed for all site activities; and (v) documentation of work-related accidents.

(iv) The working hours will be 8 hours daily. Night works should be avoided, however, it may be considered on an emergency basis or due to high day-time traffic as per prevailing conditions at the time of construction. During such requirements, appropriate consultation with the local communities will be conducted. However, due to the close location of existing residential buildings to the resettlement site, piling works will be prohibited at night.

(v) Provide H&S orientation training to all new workers to ensure that they are appraised of the rules of work at the site, personal protective protection, and preventing injury to fellow workers.

(vi) Ensure that first aid kit is available at site and it should be easily accessible for all workers in terms of emergency.

(vii) Provide medical insurance coverage for workers. (viii) Secure construction zone from unauthorized intrusion and accident risks

through provision of barriers, guards and warning signs. (ix) Ensure the core labour standards are adopted (i). Universal and indivisible

human rights, (ii) Freedom from forced labour (iii) Freedom from child labour (iv) Freedom from discrimination at work

(x) Provide adequate supply of potable drinking water. (xi) Provide clean eating areas where workers are not exposed to hazardous or

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noxious substances. (xii) Provide visitor orientation if visitors to the site can gain access to areas where

hazardous conditions or substances may be present. Ensure also that visitor/s do not enter hazard areas unescorted.

(xiii) Ensure the visibility of workers through their use of high visibility vests when working in or walking through heavy equipment operating areas.

(xiv) Ensure moving equipment is outfitted with audible back-up alarms. (xv) Mark and provide sign boards in the construction zone, and areas for storage

and disposal. Signage shall be in accordance with international standards and be well known to, and easily understood by workers, visitors, and the general public as appropriate.

(xvi) Prior to any demolition activity an asbestos walk-over by an Asbestos specialist will be required to mark any potential asbestos waste and a demolition and handling protocol will be developed. Demolition activity undertaken in these areas will require appropriate PPE to be worn. Any waste that contains asbestos, or is contaminated with asbestos, must be double-bagged, labelled and placed in a covered, locked skip. This includes asbestos sheets, asbestos pipeline, asbestos cement etc. Exposure to asbestos causes Asbestosis (chronic lung disease), hence care should be taken in disposal of the asbestos materials as per the relevant protocols/ hazardous waste management rules 2016 (refer to the EMP for Asbestos material management)

(xvii) COVID-19. WHO has declared COVID-19 as a pandemic which has affected entire world including India. In view of the prevailing COVID-19 pandemic, the Contractors and workers would need to take additional measures to avoid the spread of the disease and shall follow various guidelines/guidance notes issued by the national/state government, WHO, ILO, World Bank/IFC from time to time. As described in these guidelines, the Contractors shall undertake a COVID risk assessment of project area and prepare a COVID Response and Management Plan (C-R&MP) and submit to TNSCB and PID for approval. A brief guidance on “To Do” List prepared from these documents is provided in Appendix 16.

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

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

(i) Backfill any excavation and trenches, preferably with excess excavation material generated during the construction phase.

(ii) Use removed topsoil to reclaim disturbed areas.

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(iii) Re-establish the original grade and drainage pattern to the extent practicable. (iv) Stabilize all areas of disturbed vegetation using weed-free native shrubs,

grasses, and trees. (v) Restore staging areas and temporary work areas. (vi) Remove all tools, equipment, barricades, signs, surplus materials, debris, and

rubbish. Demolish buildings/structures not required for O&M. Dispose in designated disposal sites.

(vii) Request in writing from PIDs that construction zones have been restored. (viii) Solid waste (debris, excavated soils, etc.) from the demolishing sites and

restoration of water body site should be disposed by the contractor as per the guidance of the Environmental specialist of PIDs.

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

(i) Rain water Harvesting Pit management. (a) Regular inspection and cleaning of catchment, gutters, filters and tanks

reduce the likelihood of contamination. (b) Water from other sources should not be mixed with that in the tank. (c) TNSCB will carry out routine management of the RWH pits

(ii) Management of the STP (a) For initial 5 years, the construction contractor shall maintain and

operate the STP. Thereafter a separate Contractor shall be engaged for operation and maintenance of STP. During the operation, the STP will be operated by a skilled operator, who will be required to wear all the essential PPE’s (including but not limited to gloves, masks, safety shoes and safety eyewear) to safeguard themselves from any hazards likely occurring from the STP.

(b) TNSCB will carry out regular inspection of the STP to prevent any impacts, including pollution of ground water and nearby water courses.

(c) The sludge generated from the STP shall be further treated in the sludge digester tank (anaerobic sludge digestion) in the STP to digest the sludge into dry sludge. The treated sludge shall be stored in the sludge drying bed, which is proposed in an area of 189 m2 and when it reaches its maximum capacity it will be disposed off in the Ramaiyanpatti Sewage Treatment Plant (Operated and maintained by Tirunelveli Municipal Corporation).The treated sludge shall be as per compost quality standard given in the Solid waste management rules 2006 (schedule II A, standards for composting) for which the O&M contractor/ service provider shall perform scheduled monitoring as suggested by the Environmental specialist from PID.

(iii) Maintenance of sanitation facilities, solid waste collection and regular maintenance of constructed amenities. TNSCB will carry out maintenance of the sewer system (including the pipeline, collection system etc.), carry out the regular collection of wastes, and will also ensure that: (a) Sanitation facilities do not result in pollution of groundwater (b) Sanitary facilities do not interfere with other utilities and block access to

buildings, causing nuisance to neighbouring areas. (c) Municipal Solid Waste will be segregated as organic waste and

inorganic waste. Both organic and inorganic waste shall be collected by the Tirunelveli Municipal Corporation, organic waste will be composted in the Micro Composting Center and will be used a manure. The inorganic waste disposal will outsourced by the Tirunelveli Municipal

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Corporation (d) No spillage will happen during the transfer of waste and all wastes will

be transported to a designated solid waste treatment site. (e) Staff collecting the municipal solid waste will be provided with

necessary PPE’s (including gloves, masks and boots) (iv) Fire fighting equipment’s including the fire extinguisher and sand buckets has

to be regularly maintained. Fire extinguishers have to be regularly checked for the expiry date and has to be refilled or replaced as required prior to the expiry date. Any wet sand (if any) in the bucket should be replaced with dry sand

(v) Management of the Micro Composting Center (a) Odour is a major concern in composting but the inoculants eliminate or

reduce the odour to the barest minimum. The vegetation buffer around the project site is another mitigation factor that will reduce the spread of odour.

(b) Noise generation will be limited to the equipment (shredder, conveyor belt etc) to be used in the Composting Center and to move materials around. The level of noise will be insignificant but personnel at the noisy end of the operation will be mandated to wear earmuffs.

(c) The operation of the compost facility is not expected to significantly affect the surface and ground water quality. The floor of the compost pads will be concretized to reduce permeability. All employees will be trained properly on good operational practices, plant safety procedures and good housekeeping. All employees will also be provided PPEs (high visibility clothing, hard hats gloves, masks, ear protection and boots) and trained on how to appropriately use them during operations of the composting center.

(d) It is expected that composting may indeed encourage some form of animal and birds activities (attracted by the rodents, snakes, cats, dogs and scavenging birds), which shall be prevented through construction of boundary wall with appropriate covering.

(e) The aesthetics of the resettlement site shall not be affected by the micro composting center as it located at the end in the resettlement area and public access will be prohibited.

(vi) Other amenities including Landscaping, children play area and street lights shall be handed over to Palayakottai Panchayat Union for maintenance and operation.

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VII. INFORMATION DISCLOSURE, CONSULTATION AND PARTICIPATION

A. Consultation and Participation

145. The active participation of stakeholders including local community, NGOs/CMROs, etc., in all stages of project preparation and implementation is essential for successful implementation of the project. It will ensure that the subprojects are designed, constructed, and operated with utmost consideration to local needs, ensures community acceptance, and will bring maximum benefits to the people. Public consultation and information disclosure is a must as per the ADB Safeguard Policy Statement (2009). 146. Most of the main stakeholders have already been identified and consulted during preparation of this IEE, and any others that are identified during project implementation will be brought into the process in the future. Primary stakeholders of the subproject include vulnerable communities/ residents, surrounding residents, sensitive receptors at the resettlement site (including hospitals and schools) shopkeepers and petty shop business people living along the water bodies, government and utility agencies responsible for provision of various services in project area, community representatives, TNSCB and ADB. 147. COVID-19 has prevented further planned consultations with affected people at the encroachment sites and around the resettlement site. Further formal consultations are expected to be held prior to construction and will be incorporated into the draft IEE. B. Public Consultation

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

1. Consultation during Project Preparation

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

Table 37: Meetings/Discussions between various stake holders Sl.no Date Stakeholder

Department Details

1 12th March 2019

Directorate of Town and Country Planning (DTCP)

Consultation was conducted with Mr. Krishna Moorthy, Deputy Director of Town and Country Planning. The following key points were discussed

Various planning options in determining the landuse and its categorisation has been discussed in detail

The preparation of the landuse map across Tamil Nadu was explained to the ADB team

2 5th December 2020

Tamil Nadu Pollution Control Board (TNPCB)

Consultation was conducted with Dr. S. Selvan, Chief Environmental Engineer, TNPCB and Mr.R.Ramasubbu Joint Chief Environmental Engineer. The followings are the key outcome of the meeting

Disposal of Construction and Demolition waste: Various policies and regulations adopted by the TNPCB has been discussed. It was informed that Permissions/ NoC from the TNPCB is required, if the construction and demolishing waste (C&D) is equal to or greater than 20 tons per day or 300 tons per project in a month.

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Sl.no Date Stakeholder Department

Details

Environmental clearance for the subprojects: TNPCB informed that based on the built-up area the project will be categorised as either A or B. It was also indicated that since the built-up is less than 150,000 sq.m, the Reddiarpatti subproject will be categorised as 8B, which requires an Environmental Clearance from the SEIAA.

Storage and handling of Hazardous materials: It was informed that a licence is not required for storing of Diesel, if the total quantity in possession does not exceed 2500 litres in non-bulk ( i.e. drums) or 1000litres in a receptacle / tank (i.e. bulk)

Sewage Treatment Plant: TNPCB mandates the need for a STP in the resettlement site, it was informed that the project owner/ project proponent can choose any available technology for treating the waste water, however the treated water quality parametera should met the stipulated limits prescribed by the CPCB.

Solid waste management: it was informed that all the corporations/ municipalities/ town panchayats are facilitated with appropriate waste collection, handling, transport and disposal system and hence it shall be managed by the ULB’s. However the handling of waste should be as per the Municipal Solid Waste Management Rules, 2016

3 5th December 2020

Adyar River Restoration Trust

Consultation was conducted with Dr. S. Viswanathan, Senior Environmental Scientist. The procedures/ methodology adopted in restoration of the Adyar River Estuary (Adyar Poonga) has been discussed in detail.

The resettlement issues in evacuating the encroachers from the estuary area and allocation of the resettlement sites for the project affected persons.

Compensation measures adopted including livelihood assistance, transportation allowances and other provisions are discussed in detail.

Restoration of the water body and its challenges.

Restoration of the mangroves in the estuary area.

Monitoring and reporting system for the biodiversity in the Adyar estuary area.

2. Consultations with the Affected Community

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

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(i) Lack of basic facilities including water supply, street lights and proper approach roads;

(ii) Flooding issues during monsoon season; some of the settlements located near Tamarabarani river have experienced severe flood during 1989, 1992 and 2015;

(iii) Encroachers have resided at the same place for 30 years; (iv) Patta is not available for the encroachers; (v) Common toilets has been provided; however open defecation is a common

issue (vi) Most residents work as daily labours and housemaid workers; (vii) Schools/ educational institutions, hospitals are located in accessible distances; (viii) Drinking water supply is provided by Tirunelveli Municipal Corporation; (ix) Some encroachers showed willingness to relocate, but some have shown their

unwillingness for relocation

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

Elanthaikulam Karupanthurai

Pillaikulam Kokkirakulam

3. Consultation during construction

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

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work sites, public information boards will also be provided to disseminate project related information. C. Information Disclosure and Future Consultations

152. Executive summary of the IEE will be translated in Tamil and made available at the offices of TNSCB, PID’s and also displayed on their notice boards. Hard copies of the IEE will be accessible to citizens as a mean to disclose the document and at the same time creating wider public awareness. Electronic version of the IEE in English and Executive Summary in English and Tamil will be placed in the official website of the TNSCB after approval of the IEE by ADB. Stakeholders will also be made aware of grievance register and redress mechanism. 153. Public information campaigns to explain the project details to a wider population will be conducted. Public disclosure meetings will be conducted at key project stages to inform the public of the progress and future plans. Prior to start of construction, the PIDs will issue notification on the start date of implementation in the TNSCB website. Subproject information brochure/ pamphlets will be issued to the local communities for better understanding, the brochure/ pamphlets shall include the EMP cost. A board showing the details of the project will be displayed at the construction sites for the information of general public. Local communities will be continuously consulted regarding location of construction camps, access and hauling routes and other likely disturbances during construction.

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VIII. GRIEVANCE REDRESS MECHANISM

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

(i) Review and document eligible complaints of project stakeholders; (ii) Proactively address grievances; (iii) Provide the complainants with notice of the decisions made; (iv) Prepare periodic reports to summarize:

(a) the number and types of complaints received and resolved at all levels; (b) chosen actions and time required for resolution; and (c) final outcomes of the grievances; and (d) Make the reports available to ADB as part of the regular Safeguards

Monitoring Reports. (v) Eligible complaints will include

(a) those related to the project activities, (b) any of the service providers, (c) any person responsible for carrying out the project, (d) complaints on misuse of funds and other irregularities, and (e) grievances due to any safeguards, labor and gender issues.

155. The PIDs (Environment / Social Cell) will establish a common GRM acceptable to ADB at divisional levels for addressing any environment and/or social issues that arise due to subproject activity. The GRM will constitute a suitable systematic process to receive, evaluate and facilitate resolution of affected persons and other stakeholder’s complaints and grievances about subproject environmental (and social) safeguards performance. It will aim to provide a time-bound, trusted and transparent mechanism to voice and resolve issues and concerns associated with the subproject implementation. 156. Public awareness campaigns in the project area of influence will ensure that knowledge of the grievance redress procedures is generated. The PIDs (Environment / Social Cell) will conduct awareness campaigns to ensure that all affected persons and vulnerable households are made aware of grievance redress procedures, entitlements and anticipated environmental impacts. 157. Affected persons will have the flexibility of conveying grievances/suggestions by dropping grievance redress/suggestion forms in complaints/ suggestion boxes to be installed by the PIDs (Environment / Social Cell) or by writing in a complaint register in the PID office or by e-mail, or by registering complaints by post (as per the PMU’s existing grievance redress mechanism). Careful documentation of the name of the complainant, date of receipt of the complaint, address/ contact details of the person, location of the problem area, and how the problem was resolved will be undertaken. The PID (Environment / Social Cell) officers will have the overall responsibility for timely grievance redress on environmental and social safeguards issues and for registration of grievances, related disclosure, and communication with the aggrieved party. The proposed template of a grievance registration form is provided in Appendix 17. All the documents made available to the public will include information on the contact number, address and contact person for registering grievances, and will be disseminated throughout the project area of influence by the PIDs (Environment / Social Cell).

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158. Proposed GRM.22 In case of grievances that are immediate and urgent in the perception of the complainant, the on-site Contractor/Animator/Community Officer / Assistant Engineer / Junior Engineer from PID (Environment / Social Cell) will provide the most easily, accessible or the first level of contact for the quick resolution of grievances. Contact phone numbers and names of the concerned staff and contractors, will be posted at all construction sites in visible locations.

(i) 1st level grievance: The on-site contractor/ Animator/ Community Officer/ Assistant or Junior Engineer of the PID will receive and record the complaint at the subproject site. Alternatively, the complaint can be registered by phone call, message, email, or on the TNSCB website. The complaint will be reviewed and the on-site contractor/ animator / Community Officer / Assistant or Junior Engineer of the PID will try to resolve the issue on-site in consultation with the aggrieved party. This will be done within 7 days of receipt of a complaint/ grievance.

(ii) 2nd level grievance: All grievances that cannot be redressed within 7 days at the field level (on-site) will be brought to the notice of the Community Development Officer of the PID and the Environment Specialist of the Environment Cell in the PID. The PID Community Development Officer / Environmental Specialist of the Environmental Cell / PID Executive Engineer (PID Head) will resolve the grievance within 14 days of receipt of a complaint/ grievance with support of the PIU Superintending Engineer.

(iii) 3rd level grievance: If the grievance is not resolved at PID Community Development Officer / Environmental Specialist/ Executive Engineer (PID Head) level, the grievance will be referred internally to Chief Community Development Officer / Environmental Consultant of PMU / the Chief Engineer of IRSHUPSP. The grievance at this level will be resolved within 21 days of its receipt. All resolutions shall be communicated to the aggrieved party / complainant(s).

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

22 Any IRSHUPSP specific grievance which comes in through TNSCBs existing system (refer to Section 3) will be

routed back to the project specific GRM to level 1.

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Figure 26: Grievance Redress Process

160. In the event that the established GRM is not in a position to resolve the issue, the affected persons can also use the ADB Accountability Mechanism by directly contacting (in writing) the complaint receiving officer at ADB headquarters or the ADB India Resident Mission. The complaint can be submitted in any of the official languages of ADB’s Developing Member Countries. The ADB Accountability Mechanism information will be included in the project information document to be distributed to the affected communities, as part of the project GRM. 161. Record-keeping. The PID will keep records of grievances received, including contact details of the complainant, the date the complaint was received, the nature of the grievance, agreed corrective actions and the date these were affected and the final outcome. The number of grievances recorded and resolved and the outcomes will be displayed/disclosed in the PID office, as well as reported in monitoring reports submitted to ADB on quarterly (during construction) and annual basis (during operation). 162. Periodic review and documentation of lessons learned. The PMU will periodically review the functioning of the GRM and record information on the effectiveness of the mechanism, especially on the program’s ability to prevent and address grievances. 163. Costs. All costs involved in resolving the complaints (meetings, consultations, communication and reporting/ information dissemination) will be borne by the PID. 164. Country legal procedure. An aggrieved person shall have access to the country's legal system at any stage, and accessing the country's legal system can run parallel to accessing the GRM and is not dependent on the negative outcome of the GRM. 165. ADB’s Accountability Mechanism. If the established GRM is not in a position to resolve the issue, the affected person also can use the ADB Accountability Mechanism through directly contacting (in writing) the Complaint Receiving Officer (CRO) at ADB headquarters or the ADB India Resident Mission. The complaint can be submitted in any of the official languages of ADB’s developing member countries. Before submitting a complaint to the Accountability Mechanism, it is recommended that affected people make a good faith effort to resolve their problems by working with the concerned ADB operations department (in this case, the resident mission). Only after doing that, and if they are still dissatisfied, they could approach the Accountability Mechanism. The ADB Accountability Mechanism

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

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IX. ENVIRONMENTAL MANAGEMENT PLAN

A. Environmental Management Plan

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

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

167. The EMP will guide environmentally-sound practices at the time of construction and operation of the subprojects and ensure efficient lines of communication between TNSCB PMU, PIDs, and contractors. The EMPs will (i) ensure that the activities are undertaken in a responsible non-detrimental manner; (ii) provide a pro-active, feasible and practical working tool to enable the measurement and monitoring of environmental performance on site; (iii) guide and control the implementation of findings and recommendations of the environmental assessment conducted for the subproject; (iv) detail specific actions deemed necessary to assist in mitigating the environmental impact of the subproject; and (v) ensure that safety recommendations are complied with. The EMPs includes a monitoring program to measure the environmental condition and effectiveness of implementation of the mitigation measures. It will include observations on- and off-site, document checks, and interviews with workers and beneficiaries. The IEE and EMP will be included in the bid and contract documents to ensure compliance to the conditions set out in this document. 168. The contractor will be required to submit to PIDs, for review and approval, a Site Environmental Management Plan (SEMP) including (i) proposed sites/locations for construction work camps, storage areas, hauling roads, lay down areas, disposal areas for solid and hazardous wastes; (ii) specific mitigation measures following the approved EMP; and (iii) monitoring program as per EMP and (iv) prepare a COVID Response and Management Plan (C-R&MP). No works are allowed to commence prior to approval of SEMP. 169. A copy of the EMP and approved SEMP will be kept on site during the construction period at all times. 170. As per the prefeasibility report, the water supply is expected to be arranged through a 24km pipeline through pumping and detailed design is still underway. This is an associated activity to this subproject and once enough information is available, the PID environmental specialist shall prepare the EMP for this activity in accordance with ADB SPS with assistance from the PMU environmental specialist. Accordingly, this IEE and EMP will need to be revised and submitted to ADB for concurrence prior to appointment of the contractor by TWAD. The prepared EMP will need to be adopted by the contractor, who undertakes the pipeline laying works, and it shall be monitored and reported by both TWAD and PID. The key observations should be reflected in the quarterly safeguard reports to ADB. 171. For civil works, the contractor will be required to (i) carry out all the mitigation and monitoring measures set forth in the approved SEMP; and (ii) implement any corrective or preventative actions set out in environmental monitoring reports that the employer will prepare from time to time to monitor implementation of this IEE and SEMP. The contractor shall allocate adequate budget for compliance with these SEMP measures, requirements and actions.

87

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

88

Table 38: Environmental Management Plan for Construction Site - Reddiarpatti, Tirunelveli District

Sl.no Environmental Issues Mitigation Measures Indicators and

Targets Responsibility

for implementation

Responsibility for Supervision

1. Location Impacts

1.1 Location impacts pertain to siting of facilities for construction of new buildings/ dwelling units at Reddiarpatti, Tirunelveli District

Clearing of wild vegetation’s

Maintain slope for natural drain

Excess earth disposal

The siting of facilities will be in line with the EARF and DTCP approved Master Plan.

The site allotted for the construction of new buildings / dwelling units at Redidiyarpatti belongs to Tamil Nadu Slum Clearance Board (TNSCB). Hence there are no LA Issues anticipated.

The land is vacant and located in a hilly area (78 m elevation) having gentle slope towards northern direction. Hence levelling operations have to be conducted for the construction purpose. By doing so it is anticipated to generate excavated excess earth/ soil (cut and filling), which has to be disposed in an authorised/ identified landfill or disposal area. If the site is a new disposal area, then it has to be approved by the PID.

There are few trees identified in the project site, which has to be preserved through design considerations or it shall be transplanted to the designated landscaping area.

List of tree species

Tree cutting permit / permission from the competent authority

Identification of Disposal site for disposing debris and excavated soil

PID PMU

1.2 Lack of sufficient planning to assure long term sustainability of the developments

In accordance with the provisions in the sub-project selection criteria, the sub-project design shall include adequate provisions for ensuring effective maintenance and protection of the assets created so as to ensure the long term sustainability of the sites.

The designs will be worked out and implemented in accordance with the provisions.

DPR and designs Approved from competent authority

Work plan prepared and approved by PID

PID PMU

89

Sl.no

Environmental Issues Mitigation Measures Indicators and Targets

Responsibility for

implementation

Responsibility for Supervision

No construction activity of any kind shall be taken up in the OSR area

1.3 Land acquisition (Socio economic Impacts)

No additional land will be required, the proposed project at Rediyarpatti is designed to implement within the available 8.99 ha land area

Resettlement and/or land acquisition problems are not anticipated in the construction activities.

In case of any additional land acquisition, the compensation as per the Entitlement matrix given in the Resettlement Framework (RF) shall be adopted

Revenue records PID PMU

1.4 Clearing of trees/ Removal of vegetation

All reasonable measures shall be undertaken to ensure that no native fauna is harmed or placed at risk during the course of the clearing activities

As per the proposed design, felling of trees is not envisaged at any stage of the project. However, under unavoidable conditions if any of the trees are required to be cut/ felled, then prior permission as per existing procedure from Forest department, ensuring appropriate compensation including compensatory plantation at 1:10 ratio as stipulated by the High Court of Madras (WP No 7811/2010 and MP No 1/2010 dated 25/06/2010).

Tree count information and compensation ratio

PID PMU

2. Design and Pre-Construction Impacts

2.1 Increased storm water runoff from alterations of the site’s natural drainage patterns due to excavation works in the Reddiarpatti site, construction of Aganvadi, Community hall, Ration

Design of proposed building components will enable efficient drainage of the sites and maintain natural drainage patterns. The siting of the project components, involving physical construction shall be done to ensure no

Site drainage plan to be prepared and applied

Construction of drains to prevent

PID PMU

90

Sl.no

Environmental Issues Mitigation Measures Indicators and Targets

Responsibility for

implementation

Responsibility for Supervision

shop, addition of paved surfaces and approach roads.

disruption of natural drainage patterns or flows into the nearby drain/nallah.

Construction activities (including excavation and trenching works) shall be restricted during the monsoon season.

The Contractor shall discuss with the PID to carryout necessary construction activities in the monsoon season by providing appropriate safety measures to the satisfaction of the PID.

water logging at site during rains

2.2 Consents, permits, clearances, NOCs, etc.

All the necessary approvals/ permissions/ clearances/ NoCs as given in the Environmental Clearance (EC) for Reddiarpatti Resettlement Site should be obtained by the PID and verified by PMU before start of the construction activities or as per the conditions given in the EC. This includes STP design approval from a third party.

The findings and recommendations from the source sustainability study23 (performed by TWAD) has to be completed and incorporated into the IEE prior to a contractor being appointed by TWAD.

. The study shall include water quality information as well.

Meaningful consultations with communities to keep them informed of anticipated activities and associated impacts

General Conditions and Specific Condition as mentioned in the Environmental Clearance

Source sustainability study

Consultation meeting outcomes and records

PID PMU

2.3 Water supply pipeline laying activities shall have direct air and

The impacts of the water supply pipeline will need to be assessed once enough

Revised IEE and EMP

PID and TWAD PMU

23 The water source sustainability study should indicate the project shall utilize water sources at sustainable levels of abstraction only (i.e., without significant reductions in the

quantity or quality of the source overall), avoid polluted water sources, avoid water use conflicts by not abstracting water that is used for other purposes and ensure water quality provided complies with national drinking water standards at all times through regular monitoring. This requires identification of all users of the water source and that the water source can be appropriately recharged. The water source sustainability study to be conducted should be incorporated into the relevant IEE and EMP.

91

Sl.no

Environmental Issues Mitigation Measures Indicators and Targets

Responsibility for

implementation

Responsibility for Supervision

noise impacts to the public as well as other construction impacts.

information is available and this IEE and EMP should be revised and submitted to ADB for concurrence prior to a contractor being appointed.

The contractor appointed for water supply will be required to adopt the EMP.

Contractor records

2.4 Selection of materials and construction technologies, if not carefully chosen, will adversely impact the visual appeal of the buildings

Designs to be worked out in such a manner that exposed steel and concrete structures are avoided

The design brief for all building components proposed will strictly conform to the TNSCB requirements.

Any new landscaping elements will only utilize native species to protect local biodiversity

list of approved quarry sites and source of material

List of trees/ shrubs for landscaping

List of materials to be procured for construction works included in BOQ

PID PMU

2.5 Integration of energy efficiency and energy conservation programs in design of building components

The detailed designs for the building components shall ensure that environmental sustainability principles, including energy efficiency, resource recycling, waste minimization etc. are integrated, and designs accordingly worked out.

All the electrical and mechanical equipment’s used in the construction works shall be energy efficient and ISO certified as per BOQ provisions.

DPR and designs approved from competent authority

Use of energy efficient and ISO certified equipment in construction works

PUC for all construction vehicles

PID PMU

2.6 Odour / smell from Sewage Treatment Plant (STP) and Municipal solid waste (MSW) collection area

The detailed design/ layout should have designated STP and the MSW areas, which should be located away from the settlement to prevent the odour nuisance

DPR and designs approved from competent authority

PID PMU

92

Sl.no

Environmental Issues Mitigation Measures Indicators and Targets

Responsibility for

implementation

Responsibility for Supervision

MSW should be collected frequently

STP should be maintained

2.7 Noise pollution from the pumps used for lifting water to the OHT’s

Pump house should be located away from the residential blocks and it should be acoustic proof

Regular maintenance is required

conducting frequent Noise monitoring

PID PMU

2.8 Sourcing of water for construction activities

Contractor shall purchase water from ULB or TWAD for the construction activities. The agreement/ MoU has to be shared with the PID.

Use of groundwater for construction purpose is prohibited.

Water demand during construction should be reduced by use of premixed concrete, curing agents and other best practices prevalent.

Tapping of surface water from river sources should not affect the downstream water users (appropriate permission for the same from the TWAD/ PWD should be obtained)

Tapping of surface water from tanks/ ponds should be in consultation with the local communities and the same records should be submitted to the PID and PMU.

For any other arrangements for the source of water, the evidence for the same has to be furnished to the PID

Regular monitoring is required

Feedback from the local communities

Contractor and PID

PMU

2.9 Installation of Diesel Generators As per the CPCB norms, place the Diesel Generators (DG’s) in an acoustic enclosure or other sound insulation

Standards prescribed by the CPCB

Contractor and PID

PMU

93

Sl.no

Environmental Issues Mitigation Measures Indicators and Targets

Responsibility for

implementation

Responsibility for Supervision

Place the DG’s at least 100 m from the nearest new building for housing

Low Sulphur Diesel shall be used for operating diesel generator

Ensure DG sets comply with the noise standards prescribed by the CPCB

conducting frequent noise monitoring

3. Pre-Construction activities by Contractor

3.1 Submission of updated EMP / SEMP; EMP implementation and reporting

Appoint Environment, Health and Safety Supervisor Supervisor to ensure EMP implementation

Submission of updated EMP/ SEMP prior to starting of work,

Timely submission of monthly monitoring reports including documentary evidence on EMP implementation such as photographs and consultation records.

SEMP documents shall include information about site restoration, noise and dust control, wastewater management, spills response, community and site health and safety, traffic control, tree cutting, construction of labour camps, storage areas, hauling roads, regulatory permissions, disposal areas for solid and hazardous wastes, sensitive features like schools and hospitals

Provide project-related information to stakeholders, communities and/or affected people before and during construction works including at least 7 days prior to the start of works and again at least 1 day prior to works through issuing a pamphlet booklet to affected persons.

Unsatisfactory compliance with EMP Contractor consultation records

Contractor and PID

PMU

3.2 Consents, permits, clearances, NOCs, etc.

Obtain all necessary consents, permits, clearance, NOCs, etc. prior to the award of civil works.

All the project related clearances should be obtained

Contractor and PID

PMU

94

Sl.no

Environmental Issues Mitigation Measures Indicators and Targets

Responsibility for

implementation

Responsibility for Supervision

Ensure that all necessary approvals for construction to be obtained by the contractor are in place before the start of construction

Acknowledge in writing and provide a report on compliance of all obtained consents, permits, clearance, NOCs, etc.

as indicated in the Table 5, Table 6, para 53 and 54

3.3 Sources of construction materials (Impact on natural land contours, vegetation, disturbance to natural drainage patterns, water logging, and water pollution.)

Maximize the re-use of earth-cut materials, spoils, and construction & demolition debris / wastes

Specify materials that are recycled, have recycled content or are from sustainable sources

Obtain construction materials only from government-approved quarries with prior approval of PID

PID to review, and ensure that proposed quarry sources have all necessary clearances/ permissions in place prior to approval

Contractor to submit to PID the documentation every month with the details of the material obtained from each source (quarry/ borrow pit)

Avoid the creation of new borrow areas, quarries, etc., for the project; if unavoidable, contractor to obtain all clearances and permissions as required under law, including Environmental Clearance (EC) prior to approval by PID

Contractor to prepare a list of approved quarry sites and sources of materials with the approval of PID before any construction commences

Contractor and PID

PMU

3.4 Construction Camps – Location, Selection, Design and Layout

The construction camps will be located at 500m away from settlements and water bodies. The construction camps including separate female and male sanitation facilities, shelter, canteen, first aid, health care, day

Location of construction camp approved by PID

Construction camp having all the basic

Contractor and PID

PMU

95

Sl.no

Environmental Issues Mitigation Measures Indicators and Targets

Responsibility for

implementation

Responsibility for Supervision

crèche facilities must be adequately drained, and must not be subject to periodic flooding.

The camps must be located such that the drainage from and through the camps will not risk any domestic or public water supply.

All sites must be graded, ditched and rendered free from depressions such that water may get stagnant and cause a nuisance.

The contractor shall provide the dispenser for the disposal of Sanitary Napkins

MSW and domestic sewage generated from the construction camp should be disposed on day to day basis. The collection of waste and sewage shall be done by the Tirunelveli Municipal Corporation for which the contractor should get approval from the corporation accordingly with the assistance from the PID.

Potable water (as per IS 10500 standard) to the labours/ construction workers should be provided by the Contractor

Comply with the ban on one time use and throwaway plastics under Tamil Nadu Government Order

First Aid Room shall be provided in the project site during the entire construction and operation phases of the project

amenities with proper sanitary conditions drainage and watery supply

3.5 Stockpiling of materials Storage of construction material confined to work sites in a way to ensure that there is no obstruction to natural drainage pattern, efficient drainage is maintained

Stockpiles to be covered to reduce dust generation

Location of construction camp approved by PID

Approved materials management plan.

Contractor and PID

PMU

96

Sl.no

Environmental Issues Mitigation Measures Indicators and Targets

Responsibility for

implementation

Responsibility for Supervision

Develop and implement the Materials Management Plan (including warehouses / storage)

3.5 Establishment of baseline environmental conditions prior to start of civil works

Conduct documentation of location of components, areas for construction zone (camps, staging, storage, stockpiling, etc.) and surroundings (within direct impact zones), locations of environmental monitoring Include photos and GPS coordinates

The monitoring parameters and the frequency of the monitoring should comply with the Environmental Monitoring Plan (Table 42)

Baseline environmental profile including ambient air, noise, water quality as per the standards indicted in the monitoring plan (Table 42)

Contractor and PID

PMU

3.6 Drinking water availability and water arrangement

The contractor will be responsible for arrangement of water in every workplace at suitable and easily accessible place for the whole construction period.

Sufficient supply of cold potable water (as per IS 10500) to be provided and maintained.

If the drinking water is obtained from an intermittent public water supply then, storage tanks will be provided.

Records of drinking water supply to workers

Feedback from workers

Contractor and PID

PMU

3.7 Identification of disposal sites Location of disposal sites will be finalized by the Environmental Specialist of the PID and he will confirm that disposal of the material does not impact natural drainage courses or surface water bodies or low lying areas and that no endangered / rare flora is impacted by such materials.

The disposal sites shall be identified in consultation with the Tirunelveli Municipal Corporation

Information on the disposal site should be included in the IEE (update/ revise it accordingly)

Disposal site selected and approved by PID

Records of materials disposed at disposal site

Log book maintained for debris disposal

Contractor and PID

PMU

97

Sl.no

Environmental Issues Mitigation Measures Indicators and Targets

Responsibility for

implementation

Responsibility for Supervision

3.8 Shifting of Utilities Identify and include locations and operators of these utilities in the detailed design documents to prevent unnecessary disruption of services during the construction phase.

Require contractors to prepare a contingency plan to include actions to be done in case of unintentional interruption of services.

Obtain from the PID the list of affected utilities and operators;

If relocation is necessary, Contractor will coordinate with the providers to relocate the utility and communicate the dates and duration in advance to affected communities / persons / businesses.

List showing utilities to be shifted

Contingency plan for services disruption

Contractor and PID

PMU

3.9 Social and Cultural Resources No cultural properties or religious structures shall be removed or relocated without the knowledge and written consent of the concerned parties or communities and local administration as the case may be. Sites for the relocation of these religious structures shall be identified following the choice of the community.

As far as possible, the architectural elements of the structure should be conserved/reflected/translated into the design of new structures following the wishes of the community

For any Chance find, consult Archaeological Survey of India (ASI) or Tamil Nadu Archaeology Department to obtain an expert assessment of the archaeological potential of the site.

Consider alternatives if the site is found to be of medium or high risk.

Chance find protocol

Contractor and PID

PMU

98

Sl.no

Environmental Issues Mitigation Measures Indicators and Targets

Responsibility for

implementation

Responsibility for Supervision

Include state and local archaeological, cultural and historical authorities, and interest groups in consultation forums as project stakeholders so that their expertise can be made available.

Develop a protocol for use by the construction contractors in conducting any excavation work, to ensure that any chance finds are recognized and measures are taken to ensure they are protected and conserved.

3.10 Circulation plan during construction in the densely populated areas

Prior to mobilization and commencement of site activities, contractor has to prepare site work plan approved by Engineer24 so that no works or activities shall interrupt safe passage of local residents/ road users during construction stage, including development of alternatives access routes, traffic regulations, signage etc., during construction

The sensitive receptors like residential settlements, schools and hospitals in the close proximity of the resettlement site have to be consulted to discuss the site work plan for their suggestions and feedback, accordingly the plan shall be modified. The Contractor with support of the PID will carry out dissemination of these information

Site work plan prepared by contractor and approved by PID

Traffic plan and records of road signage’s

Contractor and PID

PMU

3.11 Access Traffic congestion near the entry and exit points from the roads adjoining the proposed project site must be avoided

Plan transportation routes (NH-7, Tirunelveli-Moolaikaraipatti Road etc.,) so that heavy vehicles do not use narrow local roads, except in the immediate vicinity of delivery sites.

Temporary Traffic management Plan

Contractor and PID

PMU

24 Engineer refers to Project Implementation Division (PID)

99

Sl.no

Environmental Issues Mitigation Measures Indicators and Targets

Responsibility for

implementation

Responsibility for Supervision

Schedule transport and hauling activities during non-peak hours.

Locate entry and exit points in areas where there is low potential for traffic congestion.

Keep the site free from all unnecessary obstructions.

Drive vehicles in a considerate manner.

3.12 Occupational health and safety Comply with IFC EHS Guidelines on Occupational Health and Safety

Develop comprehensive site-specific health and safety (H&S) plan. The overall objective is to provide guidance to Contractors on establishing a management strategy and applying practices that are intended to eliminate, or reduce, fatalities, injuries and illnesses for workers performing activities and tasks associated with the project.

Include in H&S plan measures such as: (i) type of hazards in the construction site; (ii) corresponding personal protective

equipment for each identified hazard; (iii) H&S training for all site personnel

(including labours); (iv) procedures to be followed for all site

activities; and (v) Documentation of work-related accidents.

Provide medical insurance coverage for workers.

Contractor to nominate an on-site environment, health and safety officer.

Contractor shall undertake a COVID risk assessment of project area and prepare a COVID Response and Management Plan (C-R&MP) and submit to PID for approval

Health and safety (H&S) plan

Contractor and PID

PMU

100

Sl.no

Environmental Issues Mitigation Measures Indicators and Targets

Responsibility for

implementation

Responsibility for Supervision

3.13 Site clearance activities including delineation of construction areas

Commencements of site clearance activities shall be undertaken after permissions of PID to minimize environmental impacts.

All areas used for construction and camp activities shall be restored to their former conditions after project completion and no impact to the baseline environment indicators have been confirmed.

Construction and workers camp sites should be restored as per the original situation

Contractor and PID

PMU

3.14 Excessive disturbance to communities due to prolonged construction

Meaningful consultations with communities to keep them informed of anticipated activities, in particular those that may result in disruption with respect to area access, utilities, and noisy or dust-generating activities that are likely to result in significant disturbance

Identify and adhere to strict construction schedule

Liaise with schools that are in close proximity to construction sites on school examination periods and scale down construction activities and avoid noisy activities (including piling) during such periods

Alert communities and residents if night time construction work shall occur nearby (no night time construction within 500 m of the nearest household) and ensure safe alternative access is provided

Ensure communities are aware of Grievance Redress Mechanism (GRM) entry points

Create awareness of health & safety risks of transmittable diseases (HIV/AIDs / COVID-19), child labor, bonded labor or forced labor

Develop and implement the Community Health and Safety Plan

Community Health and Safety Plan Contractor consultation records

Contractor and PID

PMU

4. Construction Impacts

101

Sl.no

Environmental Issues Mitigation Measures Indicators and Targets

Responsibility for

implementation

Responsibility for Supervision

4.1 Improper stockpiling of construction materials cause impacts starting from obstruction of drainage, disturbance/ safety hazard etc.

Adequate safety precautions will be ensured during transportation of quarry material from quarries to the construction site.

Vehicles transporting material will be covered to prevent spillage.

Operations to be undertaken by the contractor as per the direction and satisfaction of Engineer.

Proper stockpiling of construction materials

vehicles transporting construction materials covered to prevent spillage

Contractor and PID

PMU

4.2 Impacts due to Batching Plant operation

Batching plant shall comply with the requirements and specifications of the relevant current emission control legislation.

Batching plant shall be located within the project construction area and as far as possible from residential/settlements/commercial establishments at least300m in the downwind direction.

The Contractor shall submit a detailed layout plan for all such sites and seek prior approval of PID before entering into a formal agreement with a landowner for setting-up such sites.

Actions by PID against any non-compliance shall be borne by the Contractor at his own cost.

Arrangements to minimize dust pollution through the provision of windscreens, mist spray units, and dust encapsulation shall have to be provided at all such sites.

Specifications of batching plant shall comply with the requirements of the relevant current emission control legislation and Consent / NOC for such plant shall be submitted to the PID

Batching Plants should be kept/ stationed away from residential /settlements and at least 300m in the downwind direction from nearby sensitive receptors.

Contractor and PID

PMU

102

Sl.no

Environmental Issues Mitigation Measures Indicators and Targets

Responsibility for

implementation

Responsibility for Supervision

No such installation by the Contractor shall be allowed till all the required legal clearances are obtained from the competent authority and the same is submitted to the PID.

4.3 Quarry, borrow areas operations If quarry, borrow areas are exclusively opened for the project, the contractor shall ensure that they qualify all the legal conditions to operate such areas.

Consent to Operate (CtO) for quarry sites have to take from Tamil Nadu Pollution Control Board (TNPCB) and a copy of the same has to be kept in record and submitted to PID.

Contractor has to comply all the conditions stipulated in Consent to Operate document.

If contractor purchases the materials from other party he has to ensure that quarry has obtained the necessary clearance from Tamil Nadu Pollution Control Board (TNPCB) and should take a copy of it and submit in PID.

list of approved quarry sites and sources of materials

CtE and CtO certificated obtained by contractors for quarry sites, batching plant and DG sets and submitted to PID

Contractor and PID

PMU

4.4 Stripping, stocking and preservation of top soil

The topsoil from areas of cutting and areas to be permanently covered (proposed site construction of building) will be stripped to a specified depth of 150mm, trans located and stored in stockpiles.

The stockpiles will be covered with gunny bags or tarpaulin. It will be ensured by the contractor that the topsoil will not be unnecessarily trafficked either before stripping or when in stockpiles. Such stockpiled topsoil will be returned to cover the disturbed area and cut slopes.

Top soil preservation plan prepared and approved by PID

Record of top soil excavated, preserved and reutilized

Contractor and PID

PMU

4.5 Soil and water pollution due to storage of fuels, lubricants,

Fuel and lubricant storage areas shall be designed in such a way that oil may not contaminate soil or water.

Proper storage of fuel and lubricants

Contractor and PID

PMU

103

Sl.no

Environmental Issues Mitigation Measures Indicators and Targets

Responsibility for

implementation

Responsibility for Supervision

construction vehicles and construction wastes

The floor of storage area shall be protected by impermeable membrane and covered by roof so that it is not affected by rain.

Oil pumps should be used to take out the oil from the container and no oil spillage shall take place.

All the construction waste should be disposed properly after end of the day so that it may not create nuisance at site.

Soil and water pollution parameters shall be monitored as per the monitoring plan.

Dispose waste oil and lubricants that have been generated as per provisions of Hazardous Waste (Management and Handling) Rules, 1989.

Inspect all vehicles daily for fluid leaks before leaving the vehicle staging area, and repair any leaks before the vehicle resumes operation

Strictly prohibit open defecation by workers in nearby areas

Impermeable membrane used in flooring of storage yard to prevent soil and water pollution

Construction waste disposal records

Waste management plan

4.6 Siltation of drains/ water bodies due to spillage of construction wastes

Silt fencing to be provided at construction sites during rain period to prevent sediments from the construction site to enter into the watercourses/ nearby settlements. The number of units of silt fencing to be installed is to be decided by the Engineer.

Haul roads on the site and approaches to the watercourse (or drains leading to watercourses) will be regularly cleaned to prevent the build-up of mud; areas of bare soil will be kept to a practical minimum to reduce silt runoff.

Site fencing

Numbers of Silt traps constructed at site

Proper drainage system provided at site

Regular cleaning of drains during rain period

Contractor and PID

PMU

104

Sl.no

Environmental Issues Mitigation Measures Indicators and Targets

Responsibility for

implementation

Responsibility for Supervision

Extraneous construction wastes will be transported to the pre-identified disposal site for safe disposal.

4.7 Emission from Construction Vehicles, Equipment and Machinery

The discharge standards promulgated under the Environmental Protection Act will be strictly adhered to.

All vehicles, equipment and machinery used for construction will conform to the relevant Standard.

All vehicles, equipment’s and machinery used for construction will be regularly maintained to ensure that pollution emission levels comply with the relevant requirements.

All the construction vehicles shall have Pollution under Control (PUC) certificates to check air pollution.

PUC available for all vehicles

maintenance record of construction vehicles and equipment

Contractor and PID

PMU

4.8 Erosion Hazards The resettlement site is located in a small hillock and hence the risk of erosion is anticipated. Hence the Contractor will require to:

Save topsoil removed during excavation and use to reclaim disturbed areas, as soon as it is possible to do so.

Use dust abatement such as water spraying to minimize windblown erosion.

Provide temporary stabilization of disturbed/excavated areas that are not active under construction.

Apply erosion controls (e.g., silt traps) along the drainage leading to the water drains.

Maintain vegetative cover within unused land to prevent erosion and periodically monitor the area to assess erosion.

Clean and maintain catch basins, drainage ditches and culverts regularly.

Slope stability

Frequent monitoring during the piling operation

Monitoring noise and vibration

Contractor and PID

PMU

105

Sl.no

Environmental Issues Mitigation Measures Indicators and Targets

Responsibility for

implementation

Responsibility for Supervision

Conduct routine site inspection to assess the effectiveness and the maintenance requirements for erosion and sediment control systems

4.9 Cut and fill (soil erosion and dust pollution)

. The Contractor should check the soil stability and to avoid highly erodible soils (if any) and also the slope stability.

Appropriate compaction will have to be conducted in arresting the loose soil that will occur during trenching and piling works, which may lead to erosion

The use of chemical stabilizers shall be explored under unforeseen situations where blasting may be required. The Contractor shall discuss with the PID to work out a plan accordingly to use chemical stabilizers to avoid blasting.

Appropriate PPEs (as per Material Safety Data Sheet (MSDS)) have to be provided by the contractor to the workers/ labours who are involved in the use of chemical stabilizers.

Slope stability

Contractor and PID

PMU

4.10 Pilling Operation (Noise and Vibration Impacts)

The Contractor should perform construction activities in a phased manner especially during drilling the piles, which may disturb the surrounding area due to vibration

Frequent monitoring during the piling operation Monitoring noise and vibration

Contractor and PID

PMU

4.10 Generation of Dust The contractor will take every precaution to reduce the levels of dust at construction sites to the satisfaction of the Engineer.

All earth works to be protected / covered in a manner acceptable to the satisfaction of the Engineer to minimize dust generation.

records of housekeeping

records of water sprinkling at site

vehicles carrying excavated soil covered

Contractor and PID

PMU

106

Sl.no

Environmental Issues Mitigation Measures Indicators and Targets

Responsibility for

implementation

Responsibility for Supervision

Clearance will be affected immediately by manual sweeping and removal of debris, or if so directed by the Engineer, the road surfaces will be hosed or watered using necessary equipment.

Construction site shall regularly be wetted by sprinkling of water during dusty conditions especially during summer seasons and winds.

Ambient Air Quality monitoring has to be performed as per the Environmental Monitoring Program as indicated in the Table 42.

AAQ parameters (Particulate matter (PM10 & PM2.5), SOx, NOx, CO) to be monitored (Table 42)

4.11 Noise from construction activities and equipment

The Contractor will ensure appropriate noise monitoring is carried out continuously especially during piling works.

Prior to any heavy equipment/machinery/piling works the contractor should inform surrounding areas as well and it will be prohibited at night. Specify the limit for noise for the piling works.

Maintenance of vehicles, equipment and machinery will be regular and to the satisfaction of the Engineer, to keep noise from these at a minimum.

All vehicles and equipment used for construction will be fitted with exhaust silencers. During routine servicing operations, the effectiveness of exhaust silencers will be checked and if found to be defective will be replaced.

Noise limits for construction equipment used in this project (measured at one metre from the edge of the equipment in free field) such as compactors, rollers, front loaders,

maintenance record of construction vehicles and equipment

exhaust silencers working properly

use of proper PPEs as work sites

records of noise monitoring as per EMP (Table 42)

Contractor and PID

PMU

107

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Responsibility for Supervision

concrete mixers, cranes (movable), vibrators and saws will not exceed 75 dB (A).

Notwithstanding any other conditions of contract, noise level from any item of plant(s) will comply with the noise standards specified by CPCB.

If specific noise complaints are received during construction, the Contractor may be required to implement one or more of the following noise mitigation measures, as directed by the Engineer:

Shut off idling equipment.

Reschedule construction operations to avoid periods of noise annoyance identified in the complaint.

Notify nearby residents whenever extremely noisy work will be occurring.

The Contractor shall provide necessary PPEs as per the direction of the environmental specialist (PID)

The Contractor shall adopt IS 5121-1969 (Indian standard Safety Code for Piling and Other Deep Foundation Works) to ensure safety is maintained during the piling operations

Ambient Noise levels has to be monitored as per the Environmental Monitoring Program

4.12 Impacts on flora and fauna Strictly instruct workers not to cut trees for fuel wood

Do not harm existing vegetation in the area except for those indicated in site plan

Limit activities within the work area.

Strictly prohibit poaching of birds and animals in the vicinity of work sites

Baseline information of the flora and fauna for the project area

Contractor and PID

PMU

108

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implementation

Responsibility for Supervision

4.13 Material Handling at Site All workers employed on mixing asphaltic material, cement, concrete etc., will be provided with protective footwear and protective goggles. Workers, who are engaged in welding works, will be provided with welder’s protective eye-shields. Workers engaged in stone breaking activities will be provided with protective goggles and clothing and will be seated at sufficiently safe intervals.

use of proper PPEs as work sites

records of PPEs procured and issued for use

Contractor and PID

PMU

4.14 Disposal of Construction Waste /Debris / Cut Material

The waste generated will be reused in the construction activities, either as a fill material or otherwise, based on its suitability of reuse to the maximum extent possible.

Safe disposal of the extraneous material will be ensured in the pre-identified disposal locations. In no case, any construction waste will be disposed around the project locations indiscriminately.

Burning of municipal solid waste or hazardous waste will be prohibited.

records of excavated soil and

records of reuse and disposal of excavated soil

disposal site identified and approved

AAQ parameters (Particulate matter (PM10 & PM2.5), SOx, NOx, CO) to be monitored

Contractor and PID

PMU

4.15 Safety Measures During Construction

Personal Protective Equipment (PPE) for workers on the project and adequate safety measures for workers during handling of materials at site will be taken up.

The contractor has to comply with all regulations regarding safe scaffolding, ladders, working platforms, gangway, stairwells, excavations, trenches and safe means of entry and egress.

Appropriate safety measures have to be adopted for the construction during the night

use of PPEs

records of PPEs procured and issued for use

compliance of all regulations regarding scaffolding, ladders and work at height

Contractor and PID

PMU

109

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time (Lux level shall be equivalent to a minimum of two 500 watt flood lights)

4.16 Risk caused by Force Majure All reasonable precaution will be taken to prevent danger of the workers and the public from fire, flood, drowning, etc.

All necessary steps will be taken for prompt first aid treatment of all injuries likely to be sustained during the course of work.

records of first aid facilities at site

records of safety training to workers

Contractor and PID

PMU

4.17 Malaria Risk The Contractor will, at his own expense, conform to all anti-malarial instructions given to him by the Engineer; mosquito prevention at site should be done

The frequency of the testing for malaria should be increased during the monsoon season

records of use of mosquito prevention measures at site and work camps

anti-malaria instructions to workers

Contractor and PID

PMU

4.18 Clearing of Construction Camps & Restoration

Contractor to prepare site restoration plans for approval by the Engineer. The plan is to be implemented by the contractor prior to demobilization.

On completion of the works, all temporary structures will be cleared away, all rubbish should be removed, , excreta or other disposal pits or trenches filled in and effectively sealed off and the site left clean and tidy, at the Contractor’s expense, to the entire satisfaction of the Engineer.

restoration plan for site and work camps prepared

restoration of site and work camps as per plan

Contractor and PID

PMU

4.19 Influx of migrant workers

Local labourer’s to be given preference for job opportunities and each contractor should be bound by this commitment

The Contractor has to adopt a Code of Conduct for the migrant labour to resolve any issues with locals

Ensure labour-related regulations are met

Health and safety risks

Chances of spread of sexually transmittable diseases like AIDS

Water pollution

Contractor and PID

PMU

110

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implementation

Responsibility for Supervision

In case of hiring outside labour, ensure that their working conditions as well as camps meet local regulations and the best practices of the industry (refer to IFC Workers' Accommodation: Processes and Standards)

Health & Safety Risks due to Transmittable diseases (HIV/AID and Covid-19) / awareness plan

111

Table 39: Environmental Management Plan for Operation and Maintenance - Reddiarpatti, Tirunelveli District

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1. Operation and Maintenance Impacts

1.1 Solid waste (debris, excavated soils, etc.)

Re-establish the original grade and drainage pattern to the extent practicable.

Restore access roads, staging areas, and temporary work areas.

Remove all tools, equipment, barricades, signs, surplus materials, debris, and rubbish. Demolish buildings/structures not required for O&M. Dispose in designated disposal sites.

Request in writing from PID that construction zones have been restored.

Pre-existing condition

Contractor (till the DLP period) and

PID

PMU

1.2 Proposed Buildings/ Dwelling units may result congestion, increased pollution.

Creating awareness through Consultation

The 3 R’s (Reduce, Reuse, and Recycle) approaches have to be explained to the settled communities in order to reduce the pollution level (waste minimisation, water minimisation etc.,)

The environmental monitoring action plan during the operation stage will result in monitoring of the environmental impacts after project implementation.

Conducting regular consultations

Monitoring plan during project operation

Social Team PID TNSCB /

Palayakottai Panchayat Union

PMU

1.3 Rain water Harvesting Pit management

Regular inspection and cleaning of catchment, gutters, filters and tanks reduce the likelihood of contamination.

Water from other sources should not be mixed with that in the tank.

Storm water drains will be maintained periodically to maintain free flow of storm water without any obstacles

Monitoring plan during project operation

TNSCB/ Palayakottai

Panchayat Union

PMU

1.4 Management of the STP

TNSCB will carry out regular maintenance of the STP to prevent any impacts, including pollution of ground water and nearby water courses.

proper sanitation and solid waste management

TNSCB/ Palayakottai

Panchayat Union

PMU

112

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TNSCB shall appoint an Environmental Engineer with necessary qualification for the operation and maintenance of the STP, All the necessary PPE’s should be provided to the STP operator.

It is the sole responsibility of the TNSCB that the treated sewage water disposed (as per PART A Schedule VI of the Environmental Protection Rules 1986)for green belt development/ avenue plantation should not pollute the soil/ ground water/ adjacent canals/ lakes/ ponds, etc

The excess treated water will be used for watering trees and shrubs around Pallavarayan pond.

Any sludge after anaerobic treatment and drying will be disposed of with the municipal solid waste (organic waste). The treated sludge shall be as per compost quality standard given in the Solid waste management rules 2006 (schedule II A, standards for composting).

Workers who interact with any sludge will be provided all appropriate PPE’s including gloves, safety shoes, protective eyewear and masks

1.5 Unhygienic condition due to poor maintenance of sanitation facilities and irregular solid waste collection in the project site necessitate regular maintenance of constructed amenities.

TNSCB will carry out maintenance of the sewer system (including the pipeline, collection system etc.,), and carry out the regular collection of wastes, and will also ensure that Sanitation improvements proposed do not result in pollution of groundwater.

proper sanitation and solid waste management

TNSCB/ Palayakottai

Panchayat Union

PMU

113

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Sanitary facilities do not interfere with other utilities and block access to buildings, cause nuisance to neighbouring areas.

House hold hazardous waste such as batteries, small electronics, CFL bulbs, expired medicines and used cleaning solvent bottles should be segregated at source, collected once in a month from residences and disposed as per the SWM Rules 2016.

Municipal Solid Waste will be segregated as organic waste and inorganic waste. The segregated organic waste shall be composed in the micro composting center. Inorganic waste shall be collected by the Tirunelveli Municipal Corporation and it will be disposed in the corporation MSW dumping area.

The transfer of waste will also ensure no spillage and all wastes will be transported to a designated solid waste treatment site.

1.6 Micro Composting Center (Odour, leachate and animal menace)

Composting center shall be fenced and will have access to authorised staffs only (public access will be prevented)

Periodic clearing of food waste will be done to reduce the accumulation, which will attract birds, animals including rodents.

Appropriate slopes will be maintained within the Micro compost center, so that the generated leachate doesn’t flow or seep out of the composting center.

Leachate collection pits shall be designed based on the slope for collection of leachates. The collected leachates will be treated in the STP

proper sanitation and solid waste management

TNSCB/ Tirunelveli Municipal

Corporation

PMU

114

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Care shall be taken to avoid leachate entering the rainwater structures (including Rainwater harvesting pits and Trenches).

The orientation of the compost plant will be positioned such that the direction of the wind (carries the odour) will not affect nearby tenements.

Appropriate sign boards will be kept at the entrance and inside the composting centre. The information board will include contact number of the plant operation, EHS office and emergency contact numbers.

1.7 Fire fighting / Emergency preparedness

Fire fighting equipment including fire extinguishers and sand buckets has to be annually maintained. Fire extinguishers have to be checked regularly for the expiry date and has to be refilled or replaced accordingly. Wet sand (if any) in the bucket should be replaced with dry sand

Fire mock drills should be conducted as a part of emergency preparedness to create awareness among the residents

Fire extinguisher expiry date

Emergency preparedness plan

Training records

Contractor (during the DLP) TNSCB

PMU

1.8 Occupational Safety and Health (OHS)

To ensure that the workers can be clearly seen by equipment operators, workers should wear brightly-colored (e.g. orange or yellow) clothing or vests. Reflective tape or strips on clothing are also helpful.

Unless one is working in an enclosed cab, a hard hat should be used to protect the head from impact for any tasks involving flying or falling objects including mixing, turning, grinding and wood chipping

Protecting the eyes is necessary from dusts and bioaerosols and from potential impact from projectiles.

Dress Code for workers

Use of proper PPEs as work sites

Records of PPEs procured and issued for use

TNSCB/ Tirunelveli Municipal Corporation

PMU

115

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Unvented goggles give the best protection for gases and vapours, while still providing impact protection.

A face shield could be used over goggles

Ear muffs, plugs, semi-inserts, and other noise reduction devices must be worn during exposure to noisy work or equipment

Respiratory protection should be worn for all the dust-generating tasks, unless working inside an enclosed cab with its own air filtration equipment

116

Table 40: Environmental Management Plan for Building Demolition Works (Encroachment Sites identified for Relocation)

Sl.no Environmental Issues Mitigation Measures Indicators and

Targets Responsibility

for implementation

Responsibility for

Supervision

1. Consent, NOC’s, Permissions and SEMP

Contractor should obtain Permissions/ NoC from the TNPCB if the construction and demolishing waste (C&D) is equal to or greater than 20 tons per day or 300 tons per project in a month

Before the dumping of the demolition waste, an agreement with the Tirunelveli Municipal Corporation and concerned agencies to dispose the debris should be obtained and be included in the EMP/SEMP.

Contractor shall undertake a COVID risk assessment of project area and prepare a COVID Response and Management Plan (C-R&MP) and submit to Tirunelveli municipal corporation /PID for approval

Obtain labour insurance and labour licences for workers involved in the demolishing activities which should be included in the SEMP.

Submission and approval of updated EMP/ SEMP prior to starting of work to Tirunelveli Municipal Corporation /PID.

Conduct consultation with the local communities and provide detail in the language that is understandable to the local community regarding project activities and the anticipated impacts as part of the project information dissemination (prior to the start of the demolishing activity).

Display the project related information including the GRM details at the project (demolishing) site.

Estimated quantity of the Construction and Demolition Waste

Demolition Contractor / Tirunelveli Municipal

Corporation

PID/PMU

117

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2. Clearing of trees/ Removal of vegetation

All reasonable measures shall be undertaken to ensure that no native fauna is harmed or placed at risk during the course of the demolishing activities. However, under unavoidable conditions if any of the trees are required to be cut/ felled, then prior permission as per existing procedure from Forest department, ensuring appropriate compensation including compensatory plantation at 1:10 ratio as stipulated by the High Court of Madras (WP No 7811/2010 and MP No 1/2010 dated 25/06/2010).

Tree count information and compensation ratio

Demolition Contractor / Tirunelveli Municipal

Corporation

PID/PMU

3. Assessment of Environmental Parameters

Baseline parameters for Water quality and Soil quality have to be assessed prior to commencement of work.

Water and Soil quality parameters

Demolition Contractor / Tirunelveli Municipal

Corporation

PID/PMU

4. Asbestos containing materials (ACM)

Hire an Asbestos Expert to undertake training for all workers / contractors in identifying existing ACM and on Occupational Environment, Health and Safety related to potential hazardous material exposure (refer to TOR included as an Appendix 12 of EARF)

Conduct detailed walk over survey by ACM expert to ascertain the location of any ACM prior to any demolition activity

Demolition works conducted without disturbing any ACM

Support contractor assigned person (Contractor ACM) in conducting site assessment (across selected encroachments), developing inventory of existing ACM including tagging and marking locations of existing ACM in all site maps.

Inventory of structures using Asbestos as celling or roofing materials

Estimation of quantity of ACM

Disposal mechanism / plan under the guidance of the Asbestos Expert.

Demolition Contractor / Tirunelveli Municipal

Corporation

PID/PMU

118

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Responsibility for

Supervision

Develop ACM management plan /protocol for compliance with asbestos policies of major

international agencies25 and national requirements

Submission of site assessment, inventory, and ACM management plan to PID/PMU for review and approval

Contractor-ACM to carry out general awareness campaigns on ACM exposure for field staff and community

Conduct training of workers on ACM during orientation / induction

Construction Stage

5. Potential adverse impact on sensitive receptors

Demolition works to avoid sensitive receptors such as Physical Cultural Resources (PCRs) and will specifically exclude: o Religious structures e.g. chapels,

temples, mosques, etc. o Avoid cutting trees o Any damage to surrounding or properties

needs to be rectified immediately

List including a map with (geo-coordinates) showing PCRs in the demolition area

Preparation of Contingency plan for conservation of the PCRs

Demolition Contractor / Tirunelveli Municipal

Corporation

PID/PMU

6. Air, Noise and Dust Pollution During the Dismantling of the building

Prior information to the adjacent settlements/ residence regarding the demolishing process, scheduling of the activities etc.

Water spraying at the demolition site

Fencing / Install barriers (GI sheets, geo-net) especially at the side of the building facing the road) to shield from dust and aggregates

Avoid usage of machines/equipment with extra noise;

records of housekeeping

maintenance record of construction vehicles and equipment

exhaust silencers working properly

Demolition Contractor / Tirunelveli Municipal

Corporation

PID/PMU

25 In the USA, standards and approaches for handling asbestos are prescribed by the Occupational Health and Safety Administration (OHSA) and the Environmental Protection

Agency (EPA) and can be found at http://www.osha.gov/SLTC/asbestos

119

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implementation

Responsibility for

Supervision

Do not accumulate and burn waste at the site

Carry out demolition activities stage wise, give adequate notice and information of activities to the adjoining stakeholders

Provide project-related information to stakeholders, communities and/or affected people before and during construction works including at least 7 days prior to the start of works and again at least 1 day prior to works through issuing a pamphlet/ booklet to affected persons

Manual demolition methods shall be preferred and only if justified due to safety issues minimal use of machinery and equipment with safety precautions will be utilised.

Erecting barricades around demolition sites and restricting pedestrian and vehicular movements.

Any damage to surrounding buildings will require work to be stopped immediately and rectified before work can recommence.

Noise level from any item of plant(s) or machinery will comply with the noise standards specified by CPCB.

If specific noise complaints are received during construction, the Contractor may be required to implement one or more of the following noise mitigation measures, as directed by the Engineer:

Shut off idling equipment.

Reschedule construction operations to avoid periods of noise annoyance identified in the complaint.

Notify nearby residents whenever extremely noisy work will be occurring.

records of water sprinkling at site

Covered vehicles carrying the excavated soil

Records of Noise and Air Quality monitoring as per EMP as listed out in Table 42.

Contractor consultation records

120

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Supervision

Noise level measurements shall be taken once before the start of the demolition works to establish the baseline; and daily during demolition works

Ambient Noise levels has to be monitored as per the Environmental Monitoring Program

7. Impacts on the existing public utilities

Public utilities like road, electric poles, telecom poles will not be disturbed from the demolition activities. However, if it is disturbed, the Contractor should inform the appropriate agency and immediately the issues should be rectified. Till that time the demolition activity should be put on hold.

List showing utilities in the demolishing area

Contingency plan for services disruption

Demolition Contractor / Tirunelveli Municipal

Corporation

PID/PMU

8. Land and Water Pollution Identify proper location to dispose wastewater from demolition and other activities in consultation with respective local bodies

Silt fencing should be provided surrounding the water body to prevent surface runoff from the demolishing site entering the water bodies

Dispose the waste water in identified location considering the environment and safety aspects

Prohibit the contamination of groundwater

Hazardous waste (Asbestos) should be stored separately and it should be handed over to the authorised Hazardous waste handling agency (as approved by TNPCB)

Before the dumping of the demolition waste, an agreement with the Tirunelveli Municipal Corporation and concerned agencies to dispose the debris should be obtained prior to any demolition activity occurring.

Designated site for disposal should be identified in coordination with Tirunelveli Municipal Corporation

Site fencing

Numbers of Silt traps constructed at site

Proper drainage system provided at site

Regular cleaning of drains during monsoon period

Inventory details of the Hazardous waste (Asbestos)

Use site photographs and baseline information (chapter 4) for selection of site for dumping construction and demolishing wastes

Demolition Contractor / Tirunelveli Municipal

Corporation

PID/PMU

121

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implementation

Responsibility for

Supervision

9. Waste generation (including demolition debris/ waste) and improper disposal

Develop and Implement Waste Management Plan for demolition works in consultation with Tirunelveli Municipal Corporation

Demolition stage: o Transport of recyclables /scrap/

discarded equipment either to identified depots or to be handed over to subproject beneficiaries for use or re-sale

o Store all refuse and construction & demolition debris / waste generated on demolition sites away from water bodies / water sources / drainage and in designated areas and remove them from these locations for disposal to approved disposal sites or re-use for backfilling / site reclamation

o Maximize the re-use of spoils, construction & demolition debris / wastes to minimize waste disposal

o For construction & demolition debris / waste, licensed companies will be hired to collect, transport and dispose of wastes at licensed dump facilities

o Biodegradable waste such as cleared vegetation may be provided to local communities for use

o The proponent shall provide the dispenser for the disposal of Sanitary Napkins

o Waste burning will be prohibited o No final waste disposal on site / off-site

unless in approved disposal facilities / landfills

records of excavated soil and

records of reuse and disposal of excavated soil

Identification and approval of disposal site

Waste Management Plan

Demolition Contractor / Tirunelveli Municipal

Corporation

PID/PMU

122

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Responsibility for

Supervision

o Comply with the ban on one time use and throwaway plastics under Tamil Nadu Government Order

10. Disturbance to the local Population and pedestrians

Install corresponding signs, hoarding boards, organization of bypasses (as per the MoRTH specifications).

Install barriers (GI sheets, geo-net) especially for the building facing the road side to shield from dust and aggregates

Provide adequate street lighting, hard barricading at demolition site for the night to prevent accident

Conduct consultation with the local communities and provide detail in the language that is understandable to the local community regarding project activities and the anticipated impacts as part of the project information dissemination (prior to the start of the demolishing activity).

Display the project related information including the GRM details at the project (demolishing) site.

Demolition activity should not be carried out in the night time (as per the labour law and 8 hours working time should be adopted)

Site work plan prepared by Demolition Contractor and approved by ULB

Traffic plan and records of road signage’s

Demolition Contractor / Tirunelveli Municipal

Corporation

PID/PMU

11. Noise and Vibration Impact Precaution will be taken while using the machines and equipment, during demolition

Before any works commences, conduct situation analysis in the subproject area of influence for checking structural integrity of nearby building that may be affected by vibration during demolition works. This includes taking appropriate photos and videos.

maintenance record of construction vehicles and equipment

records of noise monitoring as per Table 42

contractor site and consultation records

Demolition Contractor / Tirunelveli Municipal

Corporation

PID/PMU

123

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Supervision

Noise level measurements shall be taken once before the start of the demolition works to establish the baseline; and daily during demolition works

Contractor will be responsible for creating awareness among the operators to ensure careful handling of machines and equipment and heavy vehicles like excavators and dump trucks during mechanical demolition

The contractor will inform the surrounding settlements/ residences and community in prior to operations that bear the risk of nuisance and accidents.

The contractor shall maintain the records of the consultations including dates, names and actions agreed to.

The contractor will be responsible for compensating if there are any damage to structures due to vibration resulting from demolition.

Any damage to surrounding buildings will require work to be stopped immediately and rectified before work can recommence.

Ambient Noise levels has to be monitored as per the Environmental Monitoring Program

12. Traffic and pedestrian road congestion

Traffic congestion near the entry and exit points from the roads adjoining the proposed project site must be avoided

The transportation vehicles will be parked within the premises of demolishing site

Prohibit the parking of the transportation vehicles outside the demolition site

Put hoarding board to inform the pedestrian, road users and adjacent commercial shops/

maintenance record of construction vehicles and equipment

contractor site specific plan

Demolition Contractor / Tirunelveli Municipal

Corporation

PID/PMU

124

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Supervision

offices about the activities. The mitigation activities should be recorded and documented.

13. Safety for the Demolition Workers Prepare H&S plan and include the measures such as (i) type of hazards during demolishing works; (ii) corresponding personal protective equipment for each identified hazard; (iii) H&S training for all site personnel; (iv) procedures to be followed for all site activities; and (v) documentation of work-related accidents

An environment, health and safety site officer should also be nominated by the demolition contractor.

Make mandatory the use of safety gears/ PPEs (helmets, safety belts, masks, gloves and boot) by workers depending on nature of work.

Necessary planning and safety approach will be made for rescue during emergency.

The ULB will have to check whether the provisions made in the Construction Safety Plan are implemented accordingly.

Workers will be provided with first aid and health facilities at the site.

There will be provision for group accidental insurance for the workers.

First Aid Room shall be provided in the project site during the entire construction and operation phases of the project

Child labour is strictly prohibited in all the activities executed by the Contractors

penalty for non-compliance to be tied with payment withholding and/or termination of contract

Respective provisions will be included in the contract document with contractor.

use of PPEs

records of PPEs procured and issued for use

EHS training records

compliance of all regulations regarding ladders, work at height etc

Demolition Contractor / Tirunelveli Municipal

Corporation

PID/PMU

125

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Responsibility for

Supervision

14. Impacts due to the Transportation from the Demolition area

The transportation of the waste and other materials should be in safe manner considering the rule of road traffic.

The schedule for the transportation should be made not to coincide during peak traffic hours,

Safety measures to be considered while transporting the materials

Covering the trucks with plastic sheets to prevent dust pollution and other hazards

Temporary Traffic Management Plan

Demolition Contractor / Tirunelveli Municipal

Corporation

PID/PMU

15. Site selection of waste disposal The waste from the demolition activities will be disposed on the prescribed area in consultation with Tirunelveli Municipal Corporation.

The waste disposal should not be near to any type of water resource or environmentally sensitive area

Disposal area should be far from the community and settlement

The disposal of waste should not further deteriorate the surrounding environment.

The identified site should be approved by the Tirunelveli Municipal Corporation

Disposal site selected and approved by Tirunelveli Municipal Corporation

Records of materials disposed at disposal site

Log book maintained for debris disposal

Demolition Contractor / Tirunelveli Municipal

Corporation

PID/PMU

16. Construction Site Restoration Contractor to prepare site restoration plans for approval by the Tirunelveli Municipal Corporation. The plan has to be implemented by the contractor before demobilization

On completion of the works, all rubbish/ construction debris, other disposal pits or trenches filled in and effectively sealed off and the site left clean and tidy, at the Contractor’s expense, to the entire satisfaction of the Tirunelveli Municipal Corporation.

Visual observation taking before and after photos for record

Demolition Contractor / Tirunelveli Municipal

Corporation

PID/PMU

126

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implementation

Responsibility for

Supervision

17. Labour Requirements The Contractor, for any unskilled labour, should draw from the local communities to avoid any additional stress on the existing facilities (medical services, power, water supply, etc.)

The Contractor shall provide training to build the skills of locally-recruited labour.

The contractor has to adopt a Code of Conduct for the migrant labours to sort out any issues with the locals

As per the contractual obligations

Demolition Contractor / Tirunelveli Municipal

Corporation

PID/PMU

18. Social and Cultural Resources No cultural properties or religious structures shall be removed or relocated without the knowledge and written consent of the concerned parties or communities and local administration as the case may be. Sites for the relocation of these religious structures shall be identified following the choice of the community.

As far as possible, the architectural elements of the structure should be conserved/reflected/translated into the design of new structures following the wishes of the community

For any Chance find, consult Archaeological Survey of India (ASI) or Tamil Nadu Archaeology Department to obtain an expert assessment of the archaeological potential of the site.

Consider alternatives if the site is found to be of medium or high risk.

Include state and local archaeological, cultural and historical authorities, and interest groups in consultation forums as project stakeholders so that their expertise can be made available.

Chance find protocol Contractor and PID

PMU

127

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implementation

Responsibility for

Supervision

Develop a protocol for use by the construction contractors in conducting any excavation work, to ensure that any chance finds are recognized and measures are taken to ensure they are protected and conserved.

128

Table 41: Environmental Management Plan for Water body Restoration Works

Sl.no Environmental Issues Mitigation Measures Indicators and

Targets Responsibility

for implementation

Responsibility for

Supervision

1. Pre-Construction

1.1 Assessment of Environmental Parameters

Baseline parameters for Water quality and Soil quality have to be assessed prior to commencement of work.

Water and Soil quality parameters

Contractor / Tirunelveli Municipal

Corporation

PID/PMU

1.2 Consent, NOCs, Permissions and SEMP

Contractor should obtain Permissions/ NoC from the TNPCB if the desilting material is equal to or greater than 20 tons per day or 300 tons per project in a month

Before the disposal of the desilting materials/ silt waste, make an agreement with the Tirunelveli Municipal Corporation and concerned agencies to dispose the debris.

Obtain labour insurance and labour licence for the workers involved in the demolishing activities

Submission and approval of updated EMP/ SEMP prior to starting of work to the Tirunelveli Municipal Corporation

Operation and maintenance plan should also be prepared prior to completion of construction.

Estimated quantity of the Construction and Demolition Waste

Operation and maintenance plan

Written agreement on disposal of construction and demolition waste

Approved SEMP by PID in consultation with Tirunelveli Municipal Corporation.

Contractor/ Tirunelveli Municipal

Corporation

PID/PMU

1.3 Workers camp / labours accommodation

Provide water and sanitation facilities (situated separately for men and women); regular cleaning and disinfection of site

Provide adequate electricity / lighting

Provide potable water / storage tanks

Conduct regular health check-up / provide access to medical care

First Aid Room shall be provided in the project site during the entire construction and operation phases of the project

Location of construction camp approved by PID

Construction camp having all the basic amenities with proper sanitary conditions drainage and watery supply

Contractor / Tirunelveli Municipal

Corporation

PID/PMU

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The proponent shall provide the dispenser for the disposal of Sanitary Napkins

Provide solid waste bins and collection; no final disposal on-site or burning of wastes is allowed in the workers camp / labours accommodation

Comply with the ban on one time use and throwaway plastics under Tamil Nadu Government Order

Discharge construction / workers camp sewage / wastewater into onsite septic tanks or connect to local public sewer system

Contractor health and waste disposal records

1.4 Lack of sufficient design and planning to ensure long term sustainability and protection of assets created

Develop and Implement Regeneration Works Standard Operation & Maintenance Plan (SOMP), including a minimum: o Clearance and fencing o Re-greening / re-vegetation of banks /

land along water bodies and channels o New plantations with native species o Implement site specific plans in close

coordination with Tirunelveli Municipal Corporation e.g. waste management plan, sewerage collection and management plan, etc

o Preference should be given to low GHG embedded materials.

o The possibilities of using local materials or recycled materials should be explored.

Detailed design/ master plan for regeneration works

Contractor / Tirunelveli Municipal

Corporation

PID/PMU

2. Construction stage

2.1 Permissions from various departments

During construction, the permits obtained by the contractor shall be periodically examined and validity be ensured. This includes the Consent for the Batching plants from where the contractor sources the concrete, Labour License, insurances etc.

Maintain record for Validity information with respect to the permissions/ NoC’s

Contractor / Tirunelveli Municipal

Corporation

PID/PMU

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2.2 i. De-silting of the Lake ii. Construction of diversion

drains iii. Strengthening of Bunds.

The desilted earth should be disposed in an designated area in consultation with the Tirunelveli Municipal Corporation

The Contractor should make sure that no appreciable change to the drainage course shall occur due to the construction of diversion channel.

Wetting of soil before trench excavation, wetting of brick, metal and sand before handling

Construction residues such as metal cuttings/ shavings, wood, packing materials and containers should be disposed as per applicable legal requirements (please refer Table 4)

Maintain record of de-silted soil quantity

Record for solid waste management at site

Contractor / Tirunelveli Municipal

Corporation

PID/PMU

2.3 Transportation of Construction materials

Traffic congestion near the entry and exit points from the roads adjoining the proposed project site must be avoided

Vehicles transporting construction materials prone to fugitive dust emissions should be covered

Trucks carrying sand should be provided with tarpaulin sheets to cover the bed and sides of the trucks

Idling of delivery trucks or other equipment should be avoided during loading and unloading operations

Sprinkling of water (for materials such as blue metal, sand and brick) before unloading to suppress dust generation

Adequate care should be taken to prevent spillage of earth or construction materials offsite and in haul routes. Any such spillage should be removed immediately, and the area cleaned

Maintain records of housekeeping

records of water sprinkling

covered vehicles carrying Construction materials

Contractor / Tirunelveli Municipal

Corporation

PID/PMU

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2.4 Storage of construction materials/ Stockpiling of materials

Construction materials should be stored within the project area, without affecting the traffic and other common utilities.

Storage of materials for regeneration works confined to work sites, such as there is no obstruction to natural drainage pattern at site; covered to reduce dust generation

Maintain register for construction materials

Contractor / Tirunelveli Municipal

Corporation

PID/PMU

2.5 i. Management of Excavated silt ii. Construction debris and

excavated materials.

The excavated silt should be transported in covered trucks and register should be maintained at the site.

Excavated silt is removed from the site every day preventing storage

Location for disposal of excavated silt should be identified in consultation with the Tirunelveli Municipal Corporation

Floating materials like plastics, weeds should be sent to the SWM (composting and plastic segregation) facility of the Tirunelveli Municipal Corporation.

The Contractor should ensure that silt is dry during transportation to the disposal site and dripping shall not be permitted.

Maintain records of excavated soil

records of reuse and disposal of excavated soil

disposal site identified and approved

Contractor / Tirunelveli Municipal

Corporation

PID/PMU

2.6 Traffic Management Traffic management should be in place by the Contractor with adequate placement of traffic signals and traffic control personnel, when the vehicles are passing through the local roads and near the project site. Transportation of the construction materials to project site and excavated silt/ wastes for disposal covered trucks shall be during non-peak hours

Temporary Traffic Management Plan

Contractor / Tirunelveli Municipal

Corporation

PID/PMU

2.7 Nuisance to neighbourhood community

If possible, the materials should be transported through the temporary approach road formed without disturbing the neighbourhood community

maintenance record of construction vehicles and equipment

Contractor / Tirunelveli Municipal

Corporation

PID/PMU

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Safety hard barricading should be provided while construction of drains near the structures restricting entry to work place and signage’s should be placed.

Work site lighting during night where ever required should be provided during the implementation.

Adequate slope gradient should be maintained while strengthening the bund while working in the boundary of the site

Storage of materials should be within the earmarked areas of project area, without disturbing the nearby community

Conduct consultation with the local communities and provide detail in the language that is understandable to the local community about project activities and the anticipated impacts as part of the project information dissemination (prior to the start of the demolition activity)

Display the project related information including the GRM details in the project (demolishing) site.

Demolition activity should not be carried out at night (as per the labour law and 8 hours working time should be adopted)

records of noise monitoring as per EMP

contractor consultation records

2.8 Operation of construction machinery

All construction vehicles should comply with emission standards and be maintained properly Wind shields or Install barriers (GI sheets, geo-net) should be installed all along the site boundary to abate the dust carried over to the neighbouring areas.

Use of Ready-mix Concrete wherever possible shall be explored. In the case of use of

PUC available for all vehicles

maintenance record of construction vehicles and equipment

records of water sprinkling

Contractor / Tirunelveli Municipal

Corporation

PID/PMU

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Concrete Mixer, Concrete Mixer should be mounted on shelter with top and sides closed.

Sprinkling of water on metal & sand should be carried out before handling

2.9 Dust Pollution near settlements All earth work should be protected/ covered to minimize generation of dust.

Area under construction should be covered & equipped will dust collector.

Construction material should be covered or stored in such a manner so as to avoid being affected by wind direction.

Unpaved haul roads near / passing through residential and commercial areas to be watered thrice a day.

Trucks carrying construction material to be adequately covered to avoid the dust pollution and to avoid the material spillage.

Maintain records of housekeeping

maintenance record of construction vehicles and equipment

exhaust silencers working properly

records of water sprinkling at site

covered vehicles carrying excavated soil

records of Air Quality monitoring as per EMP

Contractor / Tirunelveli Municipal

Corporation

PID/PMU

2.10 Vehicular noise pollution at residential / neighbouring settlements.

Maintenance of vehicles, equipment and machinery should be regular to keep noise from these at a minimum.

All vehicles and equipment used for construction should be fitted with exhaust silencers. During routine servicing operations, the effectiveness of exhaust silencers should be checked and if found to be defective, it should be replaced.

Notwithstanding any other conditions of contract, noise level from any item of plant(s) will comply with the noise standards specified by CPCB.

If specific noise complaints are received during construction, the Contractor may be required to

Maintenance record of construction vehicles and equipment

Exhaust silencers working properly

Records of noise monitoring as per EMP

Contractor / Tirunelveli Municipal

Corporation

PID/PMU

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implement one or more of the following noise mitigation measures, as directed by the Engineer:

Shut off idling equipment.

Reschedule construction operations to avoid periods of noise annoyance identified in the complaint.

Notify nearby residents whenever extremely noisy work will be occurring.

2.11 Chance finds Construction contractors to follow these measures in conducting the excavation work o All fossils, coins, articles of value of

antiquity, structures and other remains or things of geological or archaeological interest discovered on the site shall be the property of the Government and shall be dealt with as per provisions of the relevant legislation.

o The contractor will take reasonable precautions to prevent his workmen or any other persons from removing and damaging any such article or thing. He will, immediately upon discovery thereof and before removal acquaint the ULB’s of such discovery and carry out the instructions for dealing with the same.

o Stop work immediately to allow further investigation if any finds are suspected;

o Create awareness among the workers, supervisors and engineers about the chance finds during excavation work The ULB’s will inform State Archaeological Department if a find is suspected and seek direction from ASI prior to recommencing the work.

Maintain record for the Chance find

Contractor / Tirunelveli Municipal

Corporation

PID/PMU

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o Develop a protocol for use by the construction contractors in conducting any excavation work, to ensure that any chance finds are recognized and measures are taken to ensure they are protected and conserved

2.12 Pollution from Fuel and Lubricants Contractor shall ensure that all vehicle/machinery and equipment operation, maintenance and refuelling will be carried out in such a fashion that spillage of fuels and lubricants does not contaminate the ground.

Contractor will arrange for collection, storing and disposal of oily wastes to the pre-identified disposal sites

Proper storage of fuel and lubricants

Impermeable membrane used in flooring of storage yard to prevent soil and water pollution

Contractor / Tirunelveli Municipal

Corporation

PID/PMU

2.13 Site clearance/ levelling Sprinkling of water to reduce dust generation.

All vehicles, equipment and machinery to be procured for construction shall confirm to the relevant Bureau of Indian Standards (BIS) Norms and relevant emission/safety norms and/or standards

Maintain record for water sprinkling and

Records of PUC’s for construction vehicles and equipment’s

Contractor / Tirunelveli Municipal

Corporation

PID/PMU

2.14 Identification and selection of Quarries

The Contractor will identify materials from existing licensed quarries

Maintain record of MoU/ NOC’s/ Consent from TNPCB for the quarries

Contractor / Tirunelveli Municipal

Corporation

PID/PMU

2.15 Labour requirements and facilities The contractor should engage local labours to avoid conflict with local communities

The contractor has to adopt a Code of Conduct for the migrant labours to sort out any issues with the locals

Labour camp (if any) should be provided with water and sanitation facilities.

All the basic amenities as mentioned in the Factory Act, BOCW Act and Safety, Health &

Maintain labour register

Contractor / Tirunelveli Municipal

Corporation

PID/PMU

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Welfare at Work (Construction) Regulation 2013, should be provided by the contractor

2.16 Occupational health and Safety Prepare H&S plan and include the measures such as (i) type of hazards during demolishing works; (ii) corresponding personal protective equipment for each identified hazard; (iii) H&S training for all site personnel; (iv) procedures to be followed for all site activities; and (v) documentation of work-related accidents

An environment, health and safety site officer should also be nominated by the contractor.

Workers should be provided with necessary occupational health and safety equipment such as protective face mask, head gear, eye shields / protective goggles and safety gloves etc.

Emergency contact numbers including Ambulance should be displayed at the project site and labour accommodation. First aid will be made available at site.

Health check-up for the labourers should be carried out periodically due to exposure to slushy soil.

Elevated platforms should be equipped with handrails, toe boards and non-slip surfaces Personal Floatation devices (life vests), First Aid Kits, Fire Extinguisher, Tow rope, etc. shall be provided on vehicles / floats while working near water filled portions of the water body

Maintain records on accidents, near misses

Approved health and safety plan

Contractor / Tirunelveli Municipal

Corporation

PID/PMU

2.17 Safety Measures During Construction

Personal Protective Equipment (PPE) for workers on the project and adequate safety measures for workers during handling of materials at site will be taken up.

Adequate strutting should be provided to avoid collapse of soil.

use of PPEs

records of PPEs procured and issued for use

compliance of all regulations

Contractor / Tirunelveli Municipal

Corporation

PID/PMU

137

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The contractor has to comply with all regulations regarding safe scaffolding, ladders, working platforms, gangway, stairwells, excavations, trenches and safe means of entry and egress.

The used construction materials including nails, wooden pieces and other waste generated should be immediately removed from the work site after completing the construction work

Where ever required, signage’s, reflectors and work site lighting should be provided

regarding scaffolding, ladders and work at height

2.18 Barricading site The construction site should be barricaded with adequate marking, flags, reflectors etc. for safety of general traffic movement, neighbouring settlements and pedestrians

Maintain record and to replace the damaged / broken reflector/ barricade tapes

Contractor / Tirunelveli Municipal

Corporation

PID/PMU

2.19 Clearing of site and restoration On completion of the works, the left-over construction materials should be removed by the contractor from project site for reuse/ proper disposal.

All temporary structures will be cleared away, all rubbish cleared, excreta or other disposal pits or trenches filled in and effectively sealed off and the site left clean and tidy, at the contractor’s expenses, to the entire satisfaction of the ULB.

Site photographs, before and after completion of the works

Site inspection report

Contractor / Tirunelveli Municipal

Corporation

PID/PMU

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Table 42: Pre-construction & Construction Stage Environmental Monitoring Plan Monitoring field Monitoring location Monitoring parameters Frequency Responsibility

Construction phase

Construction disturbances, nuisances, public and worker safety,

All work sites ((i) Construction site at Reddiarpatti, (ii) Building Demolition Works (9 encroachment sites) and (iii) Water body Restoration Works (9 sites))

(i) Implementation of construction stage EMP including dust control, noise control, traffic management, and safety measures.

(ii) Site inspection checklist to review implementation is appended at Appendix 18

Weekly during construction

Contractor under the supervision of PID (sampling locations shall be identified by the Environment specialist of PID)

Ambient air quality Pre-Construction Stage: one sample at each location Construction stage: two samples at each location Sampling locations: (i) Construction site at Reddiarpatti, (ii) Building Demolition Works (9 sites) (iii) Water body Restoration Works (9 sites) Sampling method: At the work sites during pre-construction stage and 50 m downwind direction near the work sites during the construction stage

PM10, PM2.5 NO2, SO2 and CO (i) Once before start of construction (pre-construction) (ii) Monthly monitoring during peak construction activity, which will be followed by quarterly monitoring (till the project completion).

Contractor under the supervision of PID (sampling locations shall be identified by the Environment specialist of PID). The environmental specialist (PID), shall decide the frequency of the monitoring as per the construction schedule

Ambient noise Similar to ambient air quality locations and sample size including methodology.

Day time and night time noise levels

(i) Once before start of construction (pre-construction) (ii) Monthly during construction stage (till the project completion)

Contractor under the supervision of PID (sampling locations shall be identified by the Environment specialist of PID). The environmental specialist (PID), shall decide the frequency of the

139

Monitoring field Monitoring location Monitoring parameters Frequency Responsibility

monitoring as per the construction schedule

Surface water quality Pre-Construction Stage: one sample at each location Construction stage: one sample at each location Sampling location (i) Building Demolition Works (9 sites) (ii) Water body Restoration Works (9 sites)

pH, Oil and grease, Cl, F, NO3, TC, FC, Hardness, Turbidity BOD, COD, DO, E-coli, Total Alkalinity ,heavy metals and pesticides.

Every quarter during construction stage (till the project completion) For demolition this will be daily during the construction period

Contractor under the supervision of PID (sampling locations shall be identified by the Environment specialist of PID)

Environmental statement for each financial year ending 31 March in Form V

TNSCB official website As per Environment (Protection) Rules, 1986

Annual (Financial Year) PID/ PMU

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Table 43: Operation Stage Environmental Monitoring Plan Monitoring field Monitoring location Monitoring parameters Frequency Responsibility

Operation phase

Ambient air quality Operation Stage: Two samples at Reddiarpatti resettlement site Sampling method: one sampling location should be located at 50 m downwind direction from the Reddiarpatti site and another sampling location should be located within the premises

PM10, PM2.5 NO2, SO2 and CO Every quarter during operation (for 2 years)

Contractor under the supervision of PID’s during the DLP

Ambient noise Similar to ambient air quality location and sample size and same methodology.

Day time and night time noise levels

Every quarter during operation (for 2 years)

Contractor under the supervision of PID’s during the DLP

Surface water quality Operation Stage: one sample at each water body restoration site

pH, Oil and grease, Cl, F, NO3, TC, FC, Hardness, Turbidity BOD, COD, DO,E-coli, Total Alkalinity ,heavy metals and pesticides.

Every quarter during operation (for 2 years)

Contractor under the supervision of PID’s during the DLP

Water quality (potable water supplied by TWAD)

Operation Stage: One sample at each water sump

pH, Oil and grease, Cl, F, NO3, TC, FC, Hardness, Turbidity BOD, COD, DO,E-coli, Total Alkalinity ,heavy metals and pesticides.

Monthly monitoring TWAD under the supervision of PID’s (Cost for monitoring should be borne by the TWAD)

Micro Composting Center

Operation Stage: Two samples to be collected ((i) Final Compost product and (ii) leachate from the compost center

Arsenic, Cadmium, Chromium, Copper, Lead, Mercury, Nickel, C/N ratio, Moisture, Bulk density, Total Organic carbon, Total Nitrogen, Total Phosphate, Total Potassium, Particle Size and Conductivity

Monthly monitoring Tirunelveli Muncipal Corporation (TMC) under the supervision of PID’s (Cost for monitoring should be borne by the TMC)

STP (Treated Water) Operation Stage: Two water samples to be collected at (i) Inlet and (ii) outlet from the STP. One sample to be

Total suspended solids, pH, Oil and grease, Ammonical nitrogen, Biochemical Oxygen, Dissolved Oxygen, and Phenolic compounds (as C6H5OH)

Monthly monitoring STP service provider/ third party monitoring under the supervision of PID’s (Cost for monitoring should be

141

Monitoring field Monitoring location Monitoring parameters Frequency Responsibility

collected at the treated water receiving pond. One sludge sample should be collected

Sludge sample should be tested for Fecal Coliforms/ pathogenic bacteria

borne by the STP service provider)

Environmental statement for each financial year ending 31 March in Form V

TNSCB official website As per Environment (Protection) Rules, 1986

Annual (Financial Year) PID/ PMU

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B. Implementation Arrangements

173. TNSCB will be responsible for the management, coordination and execution of all subproject activities funded under IRSHUPSP. The Government of Tamil Nadu has approved the formation of the Project Management Unit (PMU) for the project vide G.O.(2D) No.27, Housing &Urban Department (SC2(2)) Department, dated: 12.02.2019. The Joint Managing Director/ Project Director will head the PMU and be supported by technical, financial, safeguards and administrative staff 174. Project Management Unit (PMU). The PMU will be headed by Joint Managing Director/ Project Director and will be assisted by the Chief Engineer, Superintending Engineer and the Executive Engineer. The PMU will design the infrastructure, manage the tendering of contracts, supervise the construction / demolition process, assure the technical quality of design and construction, provide advice/ assistance on institutional capacity development and ensure subproject compliance to ADB 2009, EARF, RF and loan covenants. The PMU shall appoint the contractors to build the infrastructure elements and will manage the construction and commissioning activities. The PMU will seek Government clearance for submission and disclosure of the environmental, social and resettlement monitoring reports to ADB. To ensure effective implementation of environmental safeguards procedures, an environmental consultant will be assigned to the environmental team of the PMU. The environmental consultant will be supported by an Assistant Executive Engineer and two (2) Assistant Engineers who will be full-time employees of the TNSCB. The PMU will be responsible for the following environmental safeguard activities:

(i) Ensure subproject compliance to GOI, GoTN statutory and legal environmental requirements, ADB SPS 2009, the project EARF, and loan covenants

(ii) Ensure subprojects conforms to exclusion criteria and subproject selection guidelines as stipulated in the EARF

(iii) Review and approve subproject category for environment (iv) Review and approve subproject IEE studies and reports and EMPs; ensure that

updated subproject IEEs and EMPs reflect final subproject detailed design and submit to ADB for approval

(v) Check whether all relevant permits / environmental clearances/approvals as per GoI and GoTN are obtained in a timely manner

(vi) Ensure that full IEE studies and EMPs are included in bidding documents, contract clauses and civil works

(vii) Ensure an efficient subproject implementation in line with IEE studies and reports and EMPs with adequate budget

(viii) Review and approve quarterly environmental monitoring reports submitted by PIDs (Environment / Social Cell) and submit to ADB

(ix) Support the preparation of quarterly and annual monitoring reports and submit to ADB

(x) Ensure effective GRM set up and monitor grievances redress process and ensure timely redress

(xi) Ensure adequate awareness campaigns, information disclosure is held within affected communities / host communities to minimize resistance and ensure hassle free transition for the project beneficiaries to new resettlement sites.

(xii) Periodical review of safeguards related loan covenants, and the compliance in project implementation

(xiii) Organize periodic capacity building and training programs for subproject staff in safeguards

(xiv) Ensure that subproject activities are synchronized between the RPs and EMP implementation

(xv) Ensure that any damage to areas and infrastructure outside the agreed work sites (Corridor of Impact assessed in RP) will be restored to pre-construction

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conditions and will be subject to compensation at contractor cost and through written agreement with the land owner, as applicable

(xvi) Ensure availability of budget for safeguards activities (xvii) Ensure disclosure of EARF, IEEs and EMPs, and monitoring documents (xviii) Ensure that IEE studies and GOI EIA studies for a subproject is prepared

concurrently to avoid any inconsistencies and ensure robust environmental assessment is undertaken.

175. Project Implementation Divisions (PIDs). The PMU will be supported by the Project Implementation Unit Circle (PIU) and a total of three (3) PIDs, established at Madurai, Salem and Villupuram for implementation of IRSHUPSP. The Superintending Engineering of the PIU Circle will be in charge of all PIDs in the Circle. Each of the PIDs will be headed by an PID Head or Executive Engineer. The PIU Circle and PIDs will be responsible for the implementation, management and monitoring of the subprojects and supervision of contractors and all day to day activities in the field. The PID located in Madurai will be responsible for Implementation, management and monitoring of the Reddiarpatti Resettlement site. 176. To ensure effective implementation of environmental safeguards procedures, three (3) environmental specialists will be hired as independent consultants and assigned to the Environment Cell of each PID. The environmental specialist will be supported by one (1) Assistant / Junior Engineer that will be full time employee of the TNSCB. PID (Environment Cell) will be responsible for the following environmental safeguard activities.

(i) Identify/select subprojects in compliance with the key exclusion criteria and subproject selection guidelines stipulated in EARF

(ii) Conduct regular site visits for overseeing compliance with safeguards (iii) Prepare screening checklists and submit to PMU for categorization; update

checklist and category as and when required to reflect subproject changes, and report to PMU

(iv) Work closely with design teams to include environmental considerations in subproject location, design and technical specifications.

(v) Identify and obtain statutory environmental clearance/permissions/approvals required for subproject

(vi) Include standards/conditions, if any, stipulated in regulatory clearances, consents in the subproject detailed design

(vii) Conduct environmental baseline surveys (viii) Prepare subproject IEE studies and reports and EMPs and submit to PMU for

approval (ix) Update subproject IEE studies and reports and EMPs to reflect any changes in

subproject during detail design / implementation; IEE shall reflect the final subproject design; IEE shall also be updated in case of any unanticipated impacts

(x) Conduct adequate awareness campaigns are held with affected persons and within the host communities to minimize resistance and ensure hassle free transition for the affected persons / resettled households to new locations

(xi) Conduct meaningful consultation in compliance with the EARF; disclose relevant information on safeguards to stakeholders, affected people etc. reflect inputs from public consultation in subproject IEE studies and reports and EMPs

(xii) Integrate EMP into the bid and contract documents (xiii) Review and approval of contractor’s site specific EMP (e.g. C-EMP / D-EMP/

R-EMP), individual sub-plans and SOMPs as indicated in Appendix 3 of EARF. (xiv) Ensure implementation of C-EMP / D-EMP / R-EMP, individual sub-plans and

SOMPs as indicated in Appendix 3 of EARF by contractors

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(xv) Establish GRM at divisional level; coordinate grievance redress process, registration, records, information dissemination, etc., and ensure timely actions by all parties; report to PMU

(xvi) Conduct training and capacity building activities (workshops, hands-on trainings, visits etc.) to contractors and field level staff as well as participating ULBs or PWDs (as necessary) in C-EMP/D-EMP/R-EMP, individual sub-plans and SOMPs implementation

(xvii) Undertake internal monitoring and supervision and record observations throughout the subproject implementation period

(xviii) Review and approval of contractor’s monthly report, consolidation into quarterly progress reports and submission to PMU

(xix) Submit periodic monitoring reports26 to the PMU, who will then submit these to the ADB.

177. Contractors. Contractors will appoint their own Contractor Environment, Health and Safety (C-EHS) and Contractor Grievance Redressal Mechanism (C-GRM) staff as well as Contractor Asbestos Containing Materials (C-ACM) staff for construction works at resettlement sites, demolition sites / removal of encroachments and regeneration works27. All

the contractors will be required to prepare a site-specific EMP (C-EMP / D-EMP / R-EMP), individual sub-plans and Standard Operation and Maintenance Plans (SOMP). The contractors will bear the costs of preparing these site-specific plans included in the EMP. The contracts will not be awarded until the SEIAA has approved all environmental clearances, other relevant permits and clearances have been obtained, ADB has approved the subproject IEEs and EMPs and corresponding subproject EMPs are included in the bid and contract documents. The following are the key safeguards tasks for contractors.

(i) Submit site specific EMP for construction, demolition and regeneration works, individual sub-plans and SOMPs to PID

(ii) Attend training and capacity building sessions (iii) Conduct orientation and daily briefing sessions to workers on EHS (iv) Ensure that appropriate worker facilities (workers accommodation / camps) are

provided at the work sites in line with this EARF (v) Register and maintain records of all work-related accidents, and undertake

remedial actions to mitigate/minimize recurrence (vi) Implement EMP measures and report to PIDs if any new impacts are surfaced;

seek guidance from PID as required in EMP implementation (vii) Conduct environmental monitoring (air, noise, etc.) as per the monitoring plan (viii) Prepare monthly EMP monitoring reports and submit to PID (ix) Address any grievances effectively and in timely manner

178. The PMU and PIDs will ensure that the contractors are aware of their obligations including specific provisions requiring contractors to comply with: (i) all applicable labour laws and core labour standards on (a) prohibition of child labour as defined in national legislation for construction and maintenance activities; construction site should not hire any child below 18 years of age; (b) equal pay for equal work of equal value regardless of gender, ethnicity, or caste including no discrimination against pregnant women and (c) prohibition of forced labour; and with (ii) the requirement to disseminate information on health & safety risks due to transmittable diseases, including HIV/AIDS and COVID-1928, to employees.

26 The periodic monitoring report will focus on the progress of implementation of the safeguard, issues encountered

and measures adopted, follow-up actions required, if any, as well as the status of compliance with subprojects selection criteria and relevant loan covenants.

27 C-ACM staff appointment will be for demolition / removal of encroachment works only. 28 The Ministry of Health and Family Welfare, Government of India has released the Environmental and Social

Management Framework for India #COVID19 Emergency Response and Health Systems Preparedness Project;

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179. If the TNSCB PMU fails to comply with the loan and legal agreements on safeguards requirements, ADB will seek corrective measures and work with the TNSCB PMU to achieve compliance. If the TNSCB PMU fails to re- establish compliance, then ADB may exercise remedies, including suspension, cancellation or acceleration of maturity that are available under ADB legal agreements. Before resorting to such measures, ADB will use other available means to rectify the situation satisfactory to all parties to the legal agreements, including initiating dialogue with the parties concerned to achieve compliance with legal agreements. Further details on institutional roles and responsibilities for safeguards implementation are presented in Table 44.

Table 44: Institutional Roles and Responsibilities for Safeguards Implementation Project Stage Tasks

Responsible Agency

Implementation Supervision

Subproject identification and finalization Preliminary design

Ensuring that the key exclusion criteria and environmental guidelines for subproject selection are adhered to

Prepare REA and No Mitigation (Scoping) checklists

Categorize the subproject

PIDs (Environment Cell)

PMU (Environment Team)

Identify GOI and GoTN regulatory requirements (clearances/approvals/ consents etc.)

Check latest amendments to EIA

Notification 2006 for environmental clearance requirement and subproject categorization (B1 / B2)

Preparation of subproject IEE studies and reports and EMPs

PIDs (Environment Cell)

PMU (Environment Team)

Delineating and mapping of catchment areas of encroached water bodies and/or areas vulnerable to flooding hazards and mapping

Delineating and mapping ROW for water canals / channels

PID (Environment Cell)

PMU (Environment Team)

Conduct survey and develop database for information management for:

Number of project beneficiaries

full demographic and socio-economic profiles of project beneficiaries

complete inventory of livelihood and asset losses due to physical and economic displacement of the project beneficiary

information on environmental impacts of the subproject at the beneficiary-level

PID / PMU with support of other public / state agencies

PMU

Detailed design

Mitigation measures specified in subproject IEE studies and reports

PIDs (Environment Cell)

PMU (Environment Team)

particularly Annex IV: India COVID-19 Project – Clauses for Inclusion in Civil Works Contracts; The document can be accessed here: https://www.mohfw.gov.in/pdf/EnvironmentalandSocialManagementFrameworkforindiaCOVID19EmergencyResponseandHealthSystemsPreparednessProjectP173836.pdf The Ministry of Law and Justice, Government of India has released the Occupational Safety, Health, Working Conditions Code, No. 37, 28th September 2020; the document can be accessed here: http://dgms.gov.in/writereaddata/UploadFile/Occupational Safety Health Code Act 2020 as assented by the President of India637370849494550871.pdf

146

Project Stage Tasks

Responsible Agency

Implementation Supervision

incorporated in subproject detailed design

Updating of subproject IEE studies and reports to integrate any changes in subproject after approval of studies and reports

Conducting capacity development activities for staff, hired workers, contractors

PIDs (Environment Cell)

PMU (Environment Team)

For subprojects involving facilities and/or business activities that already exist or are under construction, undertake an environment and/or social compliance audit, including on-site assessment, to identify past or present concerns related to impacts on the environment. Where non-compliance is identified, a Corrective Action Plan shall be prepared, and agreed on by ADB and the TNSCB PMU (Environment Team) and implemented, accordingly.

PIDs (Environment Cell)

PMU (Environment Team)

Obtain all necessary environmental clearances, consents, and no objection certificates (NOCs) as per the national and state legal framework prior to bid invitation and/or award of contract29

PIDs (Environment Cell)

PMU (Environment Team)

Meaningful consultations carried out in a manner commensurate with the impacts on affected stakeholders. The consultation process and its results to be documented and reflected in the subproject IEE reports.

PIDs (Environment Cell / Social Cell) /

PMU (Environment Team / Social Impact Assessment Team)

Information Disclosure: For Category B

Disclosure on the TNSCB website of the draft subproject IEEs and EMPs; updated IEEs and EMPs including corrective action plans; environmental monitoring reports.

Disclosure of draft IEE (and EMP) in a timely manner, in an accessible place and in a form and language understandable to affected people and other stakeholders. Any revised IEE (and EMP) should be disclosed to affected people and other stakeholders.

PIDs (Environment Cell) PMU (Environment Team)

PMU (Environment Team)

Disclosure on ADB website of the final subproject IEE studies and reports and EMPs; updated subproject IEE studies and reports

ADB ADB

29 TNSCB will take into cognizance that it is a best practice to obtain all necessary environmental clearances,

consents, etc., prior to bid invitation; however, these must be clearly obtained prior to award of contract.

147

Project Stage Tasks

Responsible Agency

Implementation Supervision

and EMPs and corrective action plans; environmental monitoring reports.

Incorporate final subproject EMP into bid/contract documents

PIDs (Environment Cell)

PMU (Environment Team)

Appraisal EMP and other environmental covenants are incorporated into the sector loan agreement and project administration memorandum (PAM)

Approval of subproject IEE studies and reports and EMPs prior to invitation of bids

All clearances are in place prior to invitation of bid / award of contracts / start of work

PIDs (Environment Cell)

PMU (Environment Team)

Effective GRM established prior to award of contracts

PIDs (Environment Cell)

PMU (Environment Team)

Approval ADB will be responsible for regular review and timely approval of subproject IEE studies and reports and EMPs (draft and final)

ADB -

Bid Invitation and Award of Contracts

Approval of subproject IEE studies and reports and EMPs a must prior to bid invitations

Subproject EMPs to be incorporated into contracts.

Ensure all statutory national and state clearances prior to award of contracts

PIDs (Environment Cell)

PMU

Subproject Implementation

Development and approval of site-specific Construction-EMP and Demolition-EMP by contractors and individual sub-plans

Implementation of above EMP including monitoring and reporting plans by contractors and submission of monthly reports to PIDs (Environment Cell),

Submission of Quarterly progress reports (Environment Cell) to PMU (Environment Team) including corrective action plan where a non-compliance is Identified

Conduct public consultation and awareness programs as per EARF

Overall compliance monitoring and submission of quarterly, monitoring report during construction stage and annual reporting during operation stage by PMU (Environment Team) to ADB

ADB will be responsible for reviewing regular monitoring reports

Contractors PIDs (Environment Cell) PMU (Environment Team)

PMU

148

180. Training Needs. The following Table 45 presents the outline of capacity building program to ensure EMP implementation. These capacity building and trainings will be conducted at the offices of PMU and PIDs by the environmental safeguards specialist of PID, which are part of project implementation set-up, and therefore no separate or additional costs are envisaged. Adequate costs are already considered in project’s capacity building program. The detailed program and specific modules will be customized for the available skill set after assessing the capabilities of the target participants and the requirements of the project by the PMU.

Table 45: Outline Capacity Building Program on EMP Implementation Sl.no Description Target Participants and

Venue Cost and Source of Funds

1 Introduction and Sensitization to Environmental Issues (1 day)

ADB Safeguards Policy Statement

Government of India and Tamil Nadu applicable safeguard laws, regulations and policies including but not limited to core labor standards, OH and S, etc.

Incorporation of EMP into the project design and contracts

Monitoring, reporting and corrective action planning

All staff and consultants (if any) involved in the subproject PMU Office (combined program for all PIDs)

Included in the overall program cost

2 EMP implementation (1/2 day)

EMP mitigation and monitoring measures

Roles and responsibilities

Public relations, - Consultations

Grievance redress

Monitoring and corrective action planning

Reporting and disclosure

Construction site standard operating procedures (SOP)

Chance find (archeological) protocol

Work near ASI monuments

AC pipe protocol

Traffic management plan

Waste management plan

Site clean-up and restoration

All PID staff, contractor staff and consultants (if any) involved in the subproject PID Office

To be conducted by PID (Environmental Specialist) at the PID office; part of project implementation cost

3 Contractors Orientation to Workers (1/2 day)

Environment, health and safety in project construction

Once before start of work, and thereafter regular briefing every month once.

Daily briefing on safety prior to start of work

All workers (including unskilled laborers)

Awareness & on-site training for workers and staff on sludge handling and disposal in existing STP repair work

Contractors’ EHS officer to conduct program, with guidance of PID

149

C. Monitoring and Reporting

181. The prepared IEE is based on the draft design for the resettlement site and likely construction activities in the demolishing sites and water body regeneration works. Hence upon finalising the detailed design for the resettlement site and preparation of the work plan for the demolishing sites and water body regeneration sites, this IEE has to be reviewed based on the updated information for the subproject. This includes, as soon as further information on the water supply works are made available (refer to para 167), this IEE needs to be updated and a separate EMP has to be prepared by the environment specialist PID, submitted to the environmental consultant PMU for review. Further consultations (that have been prevented due to COVID-19) at various places (including at encroachment sites and around the resettlement site) have to be conducted and the outcomes/ feedback and suggestions shared by the communities have to be incorporated in the project design, if not appropriate response have to be shared with the communities to their satisfaction. The revised draft IEE will then need to be submitted to ADB for concurrence. The EMP will need to be adopted by the water work construction contractor (appointed by TWAD) which has to be updated. 182. All subproject EMPs will have internal monitoring. The PIDs (Environment Cell) with support of the PMU (Environment Team) will conduct internal environmental monitoring for each subproject and provide the environment input based on site inspections, compliance checks and prepare the subproject Quarterly Progress Reports (QPRs) for submission to the PMU for final submission to ADB till the subproject completion report is issued. Monitoring will also encompass tracking progress on regeneration works undertaken by the PMU of previously encroached water bodies / channels and surrounding areas. 183. The environmental monitoring report30 for submission to ADB shall be on quarterly basis

during construction and on an annual basis during operation (refer to Appendix 19 for subproject environmental monitoring report template). Environmental monitoring reports will be required to be submitted to ADB within 30 days from the end of the relevant period. The environmental monitoring reports will be publicly disclosed on ADB public website. Reporting to ADB will continue until a project completion report. is completed. 184. Types of subproject monitoring that may be conducted under subproject specific EMP will include:

(i) Project readiness monitoring. To be conducted by the PIDs (Environment Cell)

(ii) Environmental monitoring. To be conducted by PIDs (Environment Cell) and contractors across all stages of project implementation as described in the subproject specific EMP and assessing compliance with applicable GOI environmental quality standards and/or International standards and best practices

(iii) Compliance monitoring. To be conducted by the PMU / PIDs to verify EMP compliance across all stages of subproject implementation

(iv) Demolition works monitoring. To be conducted by the PMU (Environment Team) / PIDs (Environment Cell).

(v) Regeneration works monitoring. To be conducted by the PMU (Environment Team) / PIDs (Environment Cell).

185. ADB will oversee subproject compliance on the basis of the quarterly (during construction), l and annual (during operation) environmental monitoring reports provided by the PMU (Environment Team) and site visits (generally one to two times per year). For any

30 The environmental reporting will cover EMP implementation, focusing on compliance and any needed corrective

actions.

150

non-compliance, ADB will make suitable recommendations for undertaking remedial measures for mid-term correction and improvement, if required. ADB’s monitoring and supervision activities are carried out on an on-going basis until a Project Completion Report is completed. 186. The contractor(s) will submit monthly progress reports to the PIDs (Environment Cell) on C-EMP/ D-EMP/ R-EMP implementation and SOMPs/ O&M EMP, which will inform the quarterly safeguards monitoring reports as part of the project QPR. The contractor monthly progress reports will include compilation of daily monitoring sheets that is duly signed by C-EHS. The template for daily monitoring sheet for contractors during construction stage is provided as Appendix 20. 187. During operations of the new housing development and regeneration works, the contractors will also submit monthly progress reports to PIDs (Environment Cell) on New Housing Development SOMP/O&M EMP and R-EMP for the first year of operation and quarterly progress reports thereafter. These will inform the annual safeguard monitoring reports. The contractor’s monthly (and quarterly) progress reports will include compilation of daily monitoring sheets corresponding to the operation of assets created. The subproject specific IEE will include a template for daily monitoring sheets during operation stage. D. EMP Implementation Cost

188. As part of good engineering practices in the project, there have been several measures such as safety, signage, dust suppression, procurement of personal protective equipment, provision of drains, etc. and the costs for which will be included in the design costs of specific subprojects. Therefore, these items of costs have not been included in the IEE budget. Only items not covered under budget for construction are considered in the IEE budget. 189. This is a large construction project and hence is expected to cause significant air, water and noise pollution. However, the implementation of the mitigation measures and required environmental reporting and monitoring in line with the environmental monitoring plan and included within the bidding and contract documents as separate line items will ensure that the environmental impacts will not be significant or irreversible. An appropriate Environmental Management Budget has been estimated to carry out the monitoring requirements. 190. The cost of water sprinkling for dust suppression and providing personal protective equipment to construction workers shall be borne by contractor as part of conditions of contract. In addition, the sources of funds for mitigation measures including monitoring during the construction stage are also to be borne by the contractor. These are deemed to be included as part of the contract price amount quoted by the contractor for the works. The costs of components for monitoring in operation stage and the capacity building costs are to be funded by the PMU. The EMP cost is given in the following table.

Table 46: Indicative EMP Budget Sl. No.

Particulars Unit Total

Number Rate (INR)

Cost (INR)

Source of fund

A. Monitoring Measures (Reddiarpatti Resettlement Site)

a) Pre-construction Monitoring

1 Air quality monitoring Per sample 1 10,000 10,000 PID

2 Noise Levels Per location 1 4,000 4,000 PID

3 Water Quality Per Sample 1 10,000 10,000 PID

b) Construction Monitoring

4 Ambient Air Quality Per Sample 24 10,000 2,40,000 Contractor budget

151

Sl. No.

Particulars Unit Total

Number Rate (INR)

Cost (INR)

Source of fund

5 Ambient Noise Quality Per Sample 24 4,000 96,000 Contractor budget

6 Water Quality Per Sample 24 10,000 2,40,000 Contractor budget

c) Post Construction Monitoring (Residential Units)

7 Ambient Air Quality Per Sample 20 10,000 2,00,000 Contractor budget (DLP)

8 Ambient Noise Quality Per Sample 20 4,000 80,000 Contractor budget (DLP)

9 Water Quality Per Sample 20 10,000 2,00,000 Contractor budget (DLP)

d) Post Construction Monitoring (Infrastructure Facilities)

10 Water Quality (TWAD water supply)

Per Sample 20 10,000 2,00,000 TWAD Budget

11 Leachate Analysis (Micro Composting Center)

Per Sample 30 10,000 3,00,000

Tirunelveli Municipal Corporation budget

12 Water Quality (STP) Per Sample 60 10,000 6,00,000 STP Service Provider Budget

Sub- Total (A) 21,80,000

B. Monitoring Measures (Demolishing Sites)

a) Pre-construction Monitoring

1 Air quality monitoring Per sample 9 10,000 90,000 PID

2 Noise Levels Per location 9 4,000 36,000 PID

3 Water Quality Per Sample 9 10,000 90,000 PID

b) Construction Monitoring

4 Ambient Air Quality Per Sample 54 10,000 5,40,000 Contractor budget

5 Ambient Noise Quality Per Sample 54 4,000 2,16,000 Contractor budget

6 Water Quality Per Sample 54 10,000 5,40,000 Contractor budget

c) Post Construction Monitoring

7 Ambient Air Quality Per Sample 9 10,000 90,000 Contractor budget (DLP)

8 Ambient Noise Quality Per Sample 9 4,000 36,000 Contractor budget (DLP)

9 Water Quality Per Sample 9 10,000 90,000 Contractor budget (DLP)

Sub- Total (B) 17,28,000

C. Monitoring Measures (Water Body Regeneration Works)

a) Pre-construction Monitoring

1 Air quality monitoring Per sample 9 10,000 90,000 PID

2 Noise Levels Per location 9 4,000 36,000 PID

3 Water Quality Per Sample 9 10,000 90,000 PID

b) Construction Monitoring

4 Ambient Air Quality Per Sample 108 10,000 10,80,000 Contractor budget

5 Ambient Noise Quality Per Sample 108 4,000 4,32,000 Contractor budget

6 Water Quality Per Sample 108 10,000 10,80,000 Contractor budget

c) Post Construction Monitoring

152

Sl. No.

Particulars Unit Total

Number Rate (INR)

Cost (INR)

Source of fund

7 Ambient Air Quality Per Sample 9 10,000 90,000 Contractor budget (DLP)

8 Ambient Noise Quality Per Sample 9 4,000 36,000 Contractor budget (DLP)

9 Water Quality Per Sample 9 10,000 90,000 Contractor budget (DLP)

Sub- Total (C) 30,24,000

D. Capacity Building – Training Cost (includes cost estimate for the subproject components (including resettlement site construction, demolishing works and water body regeneration works), and not included in the package costs)

1 Sensitization Workshop L.S 1,50,000 PMU

2 Training Session I L.S 1,00,000 PMU

3 Training Session II L.S 1,00,000 PMU

Sub -Total (D) 3,50,000

Total (A+B+C+D) INR 72,82,000

153

X. CONCLUSION AND RECOMMENDATIONS

191. The proposed subproject is in line with the sub-project selection criteria for the program. The subproject conforms to all GoI and ADB regulations, policies, and standards including all necessary government permits and clearances. 192. During the subproject construction, there are possible negative environmental impacts envisaged. As per the Initial Environmental Examination (IEE), the specific management measures laid down in the EMPs will effectively address any likely environmental impacts due to the subproject. The effective implementation of the measures proposed will be ensured through building enhanced capacity through training on environmental management within the PIDs and PMU with overall supervision for environmental issues by the environmental consultant within the PMU. Further, the environmental monitoring plans provide adequate opportunity towards course correction to address any residual impacts during construction or operation stages. 193. The draft IEE carried out for the subproject shows that the proposed components/ interventions will result in net environmental benefits, and that any likely environmental impact can be addressed through proper location, planning and design of the proposed subproject; control of construction activity and mitigation measures. The EMPs provide for mitigation of all identified impacts and reflected within the contract clauses for the environmental provisions will be part of the civil works contracts. Consultation on the proposed designs have been undertaken with stakeholders and no significant issues requiring redress in terms of environmental safeguards are known to exist at present. However, further consultations (that have been prevented due to COVID-19) at various places (including at encroachment sites and around the resettlement site) have to be conducted and the outcomes/ feedback and suggestions shared by the communities have to be incorporated in the project design, if not appropriate response have to be shared with the communities to their satisfaction. Accordingly, this IEE have to be revised. 194. The water supply to the resettlement site will be sourced from River Tamirabarani at Thirumalaikolundupuram, which is located at a distance of 24 km. For which water source sustainability study has been conducted by the TWAD. Being an associated activity to this subproject, once detailed design information is available (including the pump house, water supply pipeline and water storage units), the PID environmental specialist shall prepare the EMP in accordance with ADB SPS with assistance from the PMU environmental specialist. Accordingly, this IEE and EMPs will need to be revised and submitted to ADB for concurrence. 195. The positive benefits of this project is to provide affordable housing for the people who are living in the encroached areas (encroached water bodies), which is prone for seasonal flooding. This project also benefits low-income families and female-headed households. Based on the climate risk assessment and heat modelling, the building plan has been developed to withstand the climate change including the high temperature. The proposed infrastructure including the provision of toilets, water supply, electric connection, community centre and play areas shall provide an improved standard of living. This IEE has been prepared based on the preliminary information and hence upon finalising the detailed design, this IEE and EMPs (including the BoQ) have to be updated and relevant contractor clauses should be included in the EMPs. 196. Based on the findings of the IEE, there are no significant impacts and the classification of the subproject as Category “B” is confirmed. No further special study or detailed environmental impact assessment (EIA) needs to be undertaken to comply with ADB SPS (2009).

0 Appendix 1

Confirmation letter - Encroachments in the Water body

Appendix 1 1

2 Appendix 1

Appendix 1 3

0 Appendix 2

Land Transfer certificate

0 Appendix 3

Land Use Classification (Government Order)

Appendix 3 1

2 Appendix 3

0 Appendix 4

Rapid Environmental Assessment (REA) Checklist

Instructions: (i) The project team completes this checklist to support the environmental classification of a project. It is to be attached to the environmental categorization form and submitted to the Environment and Safeguards Division (RSES) for endorsement by the Director, RSES and for approval by the Chief Compliance Officer. (ii) This checklist focuses on environmental issues and concerns. To ensure that social dimensions are adequately considered, refer also to ADB's (a) checklists on involuntary resettlement and Indigenous Peoples; (b) poverty reduction handbook; (c) staff guide to consultation and participation; and (d) gender checklists. (iii) Answer the questions assuming the “without mitigation” case. The purpose is to identify potential impacts. Use the “remarks” section to discuss any anticipated mitigation measures.

Country/Project Title:

Sector Division:

Screening Questions Yes No Remarks

A. Project Siting Is the project area…?

Densely populated?

No, the Reddiarpatti (resettlement site) is sparsely populated and is located in the boundary of the Tirunelveli Corporation (min 5 to 6 km from the city center, which is a densely populated area). But the 13 encroachment sites to be relocated are situated in Tirunelveli Municipal Corporation, a densely populated area.

Heavy with development activities?

No, the site is classified as government waste land with no developmental activities. But the 13 encroachment sites to be relocated are situated in Tirunelveli Municipal Corporation, heavy with development activities

Adjacent to or within any environmentally sensitive areas?

Cultural heritage site

Not envisaged. Both the Reddiarpatti Resettlement Site as well as 9 encroachment sites do not have any of the listed environmental sensitive areas either in the vicinity or adjacent.

Protected Area

Wetland

Mangrove

Estuarine

Buffer zone of protected area

Special area for protecting biodiversity

Bay

B. Potential Environmental Impacts Will the Project cause…

impacts on the sustainability of associated sanitation and solid waste disposal systems and their interactions with other urban services.

Yes, the proposed resettlement project shall have an impact on the existing sanitation and solid waste disposal systems due to the addition of significant additional population who have relocated from other localities to the Reddiarpatti. However, sustainability of the associated

IND: Proposed Inclusive, Resilient and Sustainable Housing for the Urban Poor

Project in Tamil Nadu – Reddiarpatti, Tirunelveli

Urban Development and Water

Appendix 4 1

Screening Questions Yes No Remarks

sanitation and solid waste disposal system will be managed by the Tirunelveli Municipal Corporation.

deterioration of surrounding environmental conditions due to rapid urban population growth, commercial and industrial activity, and increased waste generation to the point that both manmade and natural systems are overloaded and the capacities to manage these systems are overwhelmed?

No, the proposed resettlement project will have a moderate impact on the surrounding environment due to the commercial activities (small shops, stores, restaurants, households etc) and an increase in waste generation. However, this increase shall be managed as the waste will be segregated at the source and the generated MSW will be collected and disposed by Tirunelveli Municipal corporation. In addition to this the generated sewage will be treated and disposed as per the discharge standard and hence the deterioration to the surroundings shall be mitigated to acceptable levels.

degradation of land and ecosystems (e.g. loss of wetlands and wild lands, coastal zones, watersheds and forests)?

There are no wetlands, wild lands, coastal zones, watersheds and forests at or nearby the resettlement site or the encroachment sites to be relocated.

Dislocation or involuntary resettlement of people?

Yes, the proposed subproject will involve the dislocation of the flood affected and socially vulnerable people who are living near the water bodies. A Resettlement Framework and related Resettlement Plan have been prepared.

Disproportionate impacts on the poor, women and children, Indigenous Peoples or other vulnerable group?

Yes, the proposed subproject does target those who are socially vulnerable living close to water bodies. However, this impact is expected to be positive as the subproject will help improve access to improved livelihoods and also reduce their risk to flood hazards.

Degradation of cultural property, and loss of cultural heritage and tourism revenues?

Not envisaged

Occupation of low-lying lands, floodplains and steep hillsides by squatters and low-income groups, and their exposure to increased health hazards and risks due to pollutive industries?

Not envisaged. Though the Reddiarpatti resettlement site is located on a small hillock, it is free from industrial activities and hence exposure to increased health hazards is not envisaged. There are no low-lying lands, floodplains, or polluting industries near the resettlement site. The water bodies will be regenerated after the relocation of encroachment and it will be protected by fencing to prevent further encroachment.

Water resource problems (e.g. depletion/degradation of available water supply, deterioration for surface and ground water quality, and pollution of receiving waters?

Yes, the proposed resettlement project in Reddiarpatti shall have an impact on the water resources, especially during project construction and operation. During project construction, significant quantity of surface water (municipal water supply) shall be used for construction purposes and during operation, municipal water supply shall be provided for drinking and other domestic purposes. Due to this a considerable quantity of waste water will be generated and it shall be disposed properly after treatment and

2 Appendix 4

Screening Questions Yes No Remarks

hence no major water resource problems are anticipated.

air pollution due to urban emissions?

Yes, there may be increased urban emissions due to travel as people may still need to access previous livelihoods or services. However, resettled location has been chosen to be close to economic opportunities and infrastructure, including existing transport routes so this should be minimised.

risks and vulnerabilities related to occupational health and safety due to physical, chemical and biological hazards during project construction and operation?

Yes, generation of Asbestos materials/ sheets, which are used as roofing/ celling purposes from the 9 encroachment sites will have hazardous risks, hence it should be disposed as per the hazardous waste management rules 2016 with assistance from Asbestos expert, who will assess the site and will guide in handling the asbestos. For fire accidents, fire extinguisher has been proposed on each floor. Other OHS related impacts are also anticipated, however, they shall be mitigated through provision of appropriate PPEs to the labours and hence the risks and vulnerability shall be reduced to acceptable levels.

road blocking and temporary flooding due to land excavation during rainy season?

No, not envisaged, the proposed project is located far from the city centre (boundary of Tirunelveli Corporation) and it does not have roads with heavy traffic to become blocked during the project construction. Construction activities shall be put on hold during the rainy seasons to avoid flooding or any other issues

noise and dust from construction activities?

Yes, noise and air quality impacts are anticipated due to the movement of construction materials through transportation, noise and vibration regenerated from the construction activities including piling works/ vehicle/ machineries etc. Piling works will be prohibited at night and appropriate noise monitoring will be implemented.

traffic disturbances due to construction material transport and wastes?

The project site is in the outskirts of Tirunelveli corporation limit, with very little traffic and hence the proposed construction activities (transportation of construction materials and disposal of construction wastes) will not have any major impacts

temporary silt runoff due to construction?

No, construction activities (at resettlement site, demolishing sites and water body regeneration sites) shall be put on hold during the rainy seasons, however, appropriate mitigation measures including silt fencing shall be provided for controlling silt runoff from the site

hazards to public health due to ambient, household and occupational pollution, thermal inversion, and smog formation?

Not envisaged

water depletion and/or degradation?

Yes, during the project construction and operation, there is a moderate negative impact anticipated on the water resource. However, providing rain water harvesting structures within

Appendix 4 3

Screening Questions Yes No Remarks

the project area will help to recharge the groundwater system. A water source sustainability study is being conducted for the resettlement site, the findings/ observations and suggestions from the study shall be implemented to maintain groundwater sustainability in the project area

overpaying of ground water, leading to land subsidence, lowered ground water table, and salinization?

The use of groundwater is totally prohibited for construction and operation stages of the project and hence impact on the groundwater sources are not envisaged

contamination of surface and ground waters due to improper waste disposal?

No, there is no surface water body near to the project site and hence contamination of the surface water is not envisaged. However, construction waste and Municipal Solid Waste (from labour camp) are likely to be generated during the project construction and Municipal Solid Waste (from residential units) are likely to generate during operation stages and hence, if waste disposal is not implemented properly (from collection to disposal), it may affect the groundwater resources through generation of leachate. Hence disposal of the MSW will occur on a daily bases.

pollution of receiving waters resulting in amenity losses, fisheries and marine resource depletion, and health problems?

No, as indicated there is no surface water body near the project site. Moreover the treated water from the STP shall be utilised for gardening and for water recharge proposes, the excess treated water will be used for watering trees and shrubs around Pallavarayan pond

large population influx during project construction and operation that causes increased burden on social infrastructure and services (such as water supply and sanitation systems)?

Yes, during the construction activity, there will be influx of people from local areas and other states and will include those who would be migrating as labours. However, it will be temporary which will last up to the completion of the project. To avoid increased burden on social infrastructure and services such as water supply and sanitation systems, the Contractor shall provide labour camps with all required amenities including water and sanitation facilities.

social conflicts if workers from other regions or countries are hired?

Yes, social conflicts mays arise with respect to competition for jobs, dispute with wages, attitude issues etc. Hence, the contractor has to adopt a Code of Conduct for the migrant labours to sort out any issues with the locals. However, preference shall be given to the local labour.

risks to community health and safety due to the transport, storage, and use and/or disposal of materials such as explosives, fuel and other chemicals during operation and construction?

Yes, though the stored construction materials are not toxic or hazardous in nature and hence explosion, fires are not anticipated. However, the removal of asbestos from the demolition sites during construction and disposal of STP sludge during operation are considered to be hazardous. With the help/ assistance from the asbestos expert, the asbestos waste shall be handled and disposed as per hazardous waste management rules 2016. The sludge from the STP will be treated prior to disposal. The prepared CEMP

4 Appendix 4

Screening Questions Yes No Remarks

shall have mitigation measure for managing the same.

Community safety risks due to both accidental and natural hazards, especially where the structural elements or components of the project are accessible to members of the affected community or where their failure could result in injury to the community throughout project construction, operation and decommissioning?

There may be a minimal risk during demolition at the encroachment sites, however this area will be fenced and access will be restricted. So no risks are envisaged.

Appendix 4 5

A Checklist for Preliminary Climate Risk Screening

Country/Project Title : IND: Proposed Inclusive, Resilient and Sustainable Housing for

the Urban Poor Project in Tamil Nadu – Reddiarpatti, Tirunelveli

Sector : Urban Development and Water

Subsector : Housing

Division/ Department:

Screening Questions Score Remarks31

Location and Design of project

Is siting and/or routing of the project (or its components) likely to be affected by climate conditions including extreme weather related events such as floods, droughts, storms, landslides?

1

The Reddiarpatti resettlement site have not experienced flooding or worst climate impacts however the encroachment areas have witnessed seasonal flooding.

Would the project design (e.g. the clearance for bridges) need to consider any hydro-meteorological parameters (e.g., sea-level, peak river flow, reliable water level, peak wind speed etc)?

1

The project site is located in a hilly area and the project design is provided with sufficient drain to prevent storm surges.

Materials and Maintenance

Would weather, current and likely future climate conditions (e.g. prevailing humidity level, temperature contrast between hot summer days and cold winter days, exposure to wind and humidity hydro-meteorological parameters likely affect the selection of project inputs over the life of project outputs (e.g. construction material)?

1

The apartment blocks have been designed considering the hot climate of the area to reduce temperature. Weather proof construction materials are proposed to withstand extreme heat and humid weather conditions.

Would weather, current and likely future climate conditions, and related extreme events likely affect the maintenance (scheduling and cost) of project output(s) ?

1

Likely the maintenance of housing will depend on how degraded it becomes due to weather and extreme events. The site has been chosen to ensure it is not in a hazard zone.

Performance of project outputs

Would weather/climate conditions, and related extreme events likely affect the performance (e.g. annual power production) of project output(s) (e.g. hydro-power generation facilities) throughout their design life time?

0

Weather/climate conditions and related extreme events are not likely to affect the residential units since they have been designed to withstand them.

Options for answers and corresponding score are provided below:

Response Score

Not Likely 0

Likely 1

Very Likely 2

Responses when added that provide a score of 0 will be considered low risk project. If adding all

responses will result to a score of 1-4 and that no score of 2 was given to any single response, the

project will be assigned a medium risk category. A total score of 5 or more (which include providing a

score of 1 in all responses) or a 2 in any single response, will be categorized as high risk project.

31 If possible, provide details on the sensitivity of project components to climate conditions, such as how climate parameters are

considered in design standards for infrastructure components, how changes in key climate parameters and sea level might affect the siting/routing of project, the selection of construction material and/or scheduling, performances and/or the maintenance cost/scheduling of project outputs.

6 Appendix 4

Result of Initial Screening (Low, Medium, High): Medium

Other Comments: The proposed Resettlement Project site in Reddiarpatti shall not have any significant

environmental / climate change impacts. The proposed rainwater harvesting, harnessing solar energy

and landscaping shall have a positive impact on the environment and the climate change. It is also

proposed to use environmental friendly construction materials as to safeguard the surrounding

environment.

Prepared by: Tamil Nadu Slum Clearance Board, Chennai

Appendix 5 7

Environmental Clearance from SEIAA

8 Appendix 6

Salient Features of Major Labor Laws Applicable to Establishments Engaged in Construction of Civil Works

(i) Workmen Compensation Act, 1923 - The Act provides for compensation in case of injury

by accident arising out of and during the course of employment.

(ii) Payment of Gratuity Act, 1972 - Gratuity is payable to an employee under the Act on

satisfaction of certain conditions on separation if an employee has completed 5 years’ service

or more or on death at the rate of 15 days wages for every completed year of service. The Act

is applicable to all establishments employing 10 or more employees.

(iii) Employees’ PF and Miscellaneous Provisions Act, 1952 - The Act provides for monthly

contributions by the employer plus workers @10 % or 8.33 %. The benefits payable under the

Act are: (a) Pension or family pension on retirement or death as the case may be; (b) deposit

linked insurance on the death in harness of the worker; (c) payment of PF accumulation on

retirement/death etc.

(iv) Maternity Benefit (Amendment) Act 2017- The Act provides for leave and some other

benefits to women employees in case of confinement or miscarriage etc.

(v) Contract Labour (Regulation and Abolition) Act, 1970 - The Act provides for certain

welfare measures to be provided by the Contractor to contract labor and in case the Contractor

fails to provide, the same are required to be provided by the Principal Employer by Law. The

principal employer is required to take Certificate of Registration and the Contractor is required

to take a License from the designated Officer. The Act is applicable to the establishments or

Contractor of principal employer if they employ 20 or more contract labor.

(vi) Minimum Wages Act, 1948 - The employer is supposed to pay not less than the

Minimum Wages fixed by appropriate Government as per provisions of the Act if the

employment is a scheduled employment. Construction of Buildings, Roads, Runways are

scheduled employment.

(vii) Payment of Wages Act, 1936 - It lays down as to by what date the wages are to be paid,

when it will be paid and what deductions can be made from the wages of the workers.

(viii) Equal Remuneration Act, 1979 - The Act provides for payment of equal wages for work

of equal nature to Male and Female workers and not for making discrimination against Female

employees in the matters of transfers, training and promotions etc.

(ix) Payment of Bonus Act, 1965 - The Act is applicable to all establishments employing 20

or more workmen. The Act provides for payments of annual bonus subject to a minimum of

8.33 % of wages and maximum of 20 % of wages to employees drawing Rs. 3,500/- per month

or less. The bonus to be paid to employees getting Rs. 2,500/- per month or above up to

Rs.3,500/- per month shall be worked out by taking wages as Rs.2,500/- per month only. The

Act does not apply to certain establishments. The newly set up establishments are exempted

for five years in certain circumstances. Some of the State Governments have reduced the

employment size from 20 to 10 for the purpose of applicability of the Act.

(x) Industrial Disputes Act, 1947 - The Act lays down the machinery and procedure for

resolution of industrial disputes, in what situations a strike or lock-out becomes illegal and

what are the requirements for laying off or retrenching the employees or closing down the

establishment.

Appendix 6 9

(xi) Industrial Employment (Standing Orders) Act, 1946 - It is applicable to all establishments

employing 100 or more workmen (employment size reduced by some of the States and Central

Government to 50). The Act provides for laying down rules governing the conditions of

employment by the employer on matters provided in the Act and get the same certified by the

designated Authority.

(xii) Trade Unions Act, 1926 - The Act lays down the procedure for registration of trade

unions of workmen and employees. The trade unions registered under the Act have been

given certain immunities from civil and criminal liabilities.

(xiii) Child Labor (Prohibition and Regulation) Act, 1986 - The Act prohibits employment of

children below 14 years of age in certain occupations and processes and provides for

regulation of employment of children in all other occupations and processes. Employment of

child labor is prohibited in Building and Construction Industry.

(xiv) Inter-State Migrant Workmen's (Regulation of Employment and Conditions of Service)

Act, 1979 - The Act is applicable to an establishment which employs 5 or more inter-state

migrant workmen through an intermediary (who has recruited workmen in one state for

employment in the establishment situated in another state). The inter-state migrant workmen,

in an establishment to which this Act becomes applicable, are required to be provided certain

facilities such as housing, medical aid, traveling expenses from home up to the establishment

and back, etc

(xv) The Building and Other Construction Workers (Regulation of Employment and

Conditions of Service) Act, 1996 and the Cess Act of 1996 - All the establishments who carry

on any building or other construction work and employ 10 or more workers are covered under

this Act. All such establishments are required to pay Cess at rate not exceeding 2% of the cost

of construction as may be notified by the Government. The employer of the establishment is

required to provide safety measures at the building or construction work and other welfare

measures, such as canteens, first-aid facilities, ambulance, housing accommodation for

workers near the workplace etc. The employer to whom the Act applies has to obtain a

registration certificate from the Registering Officer appointed by the Government.

10 Appendix 7

Confirmation letter from Tamil Nadu Electricity Board

Appendix 8 11

Certificate Indicating Reddiarpatti Resettlement site is not Vulnerable for Flooding

12 Appendix 9

Acceptance Letter for Collection of Municipal Solid Waste

Appendix 9 13

14 Appendix 10

Permission letter for Discharge of Treated Sewage Water

Appendix 10 15

16 Appendix 11

Tamil Nadu Water Supply and Drainage Board (TWAD) Acceptance/ Acknowledge for the Supply of Water to Reddiarpatti Resettlement Site

Appendix 12 17

Confirmation Letter for Collection and Disposal of Sludge Generated from the STP installed at Reddiarpatti Resettlement Site

18 Appendix 13

Compliance matrix for the Environmental Clearance Conditions

Appendix 14 19

Groundwater Quality Test Result for Reddiarpatti Resettlement Site

20 Appendix 15

IBAT Study for the Subproject Area

Appendix 15 21

22 Appendix 15

Appendix 15 23

24 Appendix 15

Appendix 15 25

26 Appendix 15

Appendix 15 27

28 Appendix 15

Appendix 15 29

30 Appendix 15

Appendix 15 31

32 Appendix 15

Appendix 15 33

34 Appendix 15

Appendix 15 35

36 Appendix 15

Appendix 16 37

Health and Safety Plan/ Response and Measures for COVID-19

‘To Do’ List / Protocol

Daily Drill:

All workers to report some time earlier before the start of the shift. An attendance register is to be maintained for each shift. Masks are mandatory and social distancing32 of at least 1m to be followed in the holding area. The focal point to provide information update.

The workers need to wash their hands thoroughly (for at least 20-30 seconds) with soap or use sanitizers just before reporting screening. Adequate provision for hand washing, soaps, sanitizers needs to be made at the reporting location. Hand gloves mandatory for teams who are screening workmen, conducting medical checkup, disinfection

Health screening to be done for all workers in the shift - including temperature monitoring using a non-contact thermometer. Any worker reporting with temperature higher than 37.3oC shall be sent to the isolation quarters and periodic observation be made.

o In case the worker shows symptoms of the pandemic (including COVID-19), the procedures as laid down by the national and state laws need to be followed for testing, quarantine of at least 14 days or hospitalization, depending upon individual case.

o All the co-workers in the shift, and other persons with known contact history in the construction site should be quarantined for a period of at least 14 days, followed by regular checkups/ observation/ examinations as laid down by the national and state laws.

The workers found fit need to proceed to work with all required personal protective equipment, e.g. masks, gloves, goggles, boots, helmets, harness, etc.

The workers be encouraged to avoid contact with co-workers as far as possible and wash their hands at regular intervals.

Lunch/meal break be staggered into two so that workers proceed for lunch/meal at different times.

There needs to be a provision of separate drinking bottles/cups for each worker, and these need to be cleaned thoroughly after meals.

Proper hand washing arrangement (water/soaps/sanitizers) needs to be ensured at eating locations. Hand washing facilities are ideally to be located within 5m of toilets and at close range of eating space.

The workers returning to the shift after lunch/meal break need to thoroughly wash their hands and follow the same procedure as that followed at the start of the shift.

At the close of shift, the workers need to thoroughly wash their hands with soap/sanitizers etc.

The PPE should be thoroughly washed/cleaned/sanitized (depending upon the type of PPE) after the shift ends.

The meal timings should be phased in each shift. There should be a difference of about 1 hour between two shifts and the sensitive areas of the workplace should be cleaned / sanitized as far as possible.

The time between two shifts should be used for cleaning and sanitizing machines, hand tools and areas of regular contact – grab handles, control levers, steering wheels,

32 https://www.mohfw.gov.in/pdf/SocialDistancingAdvisorybyMOHFW.pdf

38 Appendix 16

control panels, etc. shall be regularly cleaned, and at the end of shifts used across shifts (or continuous operations) where operators/helpers change.

General Guidance for Contractors:

Site specific risk assessment needs to be undertaken and emergency preparedness plan be prepared for all sites, including camp sites and construction sites.

Protocols for medical treatment, etc. should be prepared/followed, including for reporting, referral, treatment and discharge as per national and state laws and other guidelines.

A health and safety officer to be deployed as the focal point at all project sites, and wherever, the same is not in place, urgent action needs to be taken by the contractor to recruit someone.

Register for all the workers needs to be maintained, along with their health records. Prepare a profile of the workforce considering the following: i) Total number of workers who live in the labor camps; ii) Total number of workers who commute from their houses; iii) Number of male and female workers.

Limit the number of workers on site at any one time to minimize contact, including exploring operations for multi-shift working rotation.

Entry/exit to the site should be documented. Transport vehicles used during construction activities to carry construction materials should be sanitized on regular basis (at least once a day).

Hygienic living conditions need to be ensured in the camp sites with regular/daily cleaning, adequate hand washing facilities. Adequate provision for solid waste management needs to be provided.

Provide health and safety training/orientation on COVID19, or any other pandemic, to all workers and staff. Some initiatives could be like training family members of construction workers to stitch masks and gloves to augment PPE.

Ensure adequacy of necessary supplies of energy, water, food, medical supplies, cleaning equipment, PPE (both for regular use and those for medical exigencies) etc.

Quarantine and isolation facilities should be established in the camps (WHO Guidelines). The isolation facilities should have separate and dedicated toilets with proper arrangement for cleaning and removal of faeces.

Any medical waste produced during the care of ill workers should be disposed as per the national and state laws or relevant guidelines (e.g. WHO guidelines from time to time). PPE used for medical treatment/care purposes should be stored securely and kept separate from other waste. Current WHO recommendations are to clean utility gloves or heavy duty, reusable plastic aprons with soap and water and then decontaminate them with 0.5% sodium hypochlorite solution after each use. Single-use gloves (nitrile or latex) and gowns should be discarded after each use and not reused;

Incentivize workers lodging in the local community to move to site accommodation.

The community should be made aware, through posters etc., of procedures put in place at site to address issues related to COVID-19. This should include all measures being implemented to limit or prohibit contact between workers and the community.

Additional guidance for good practice for Contractors:

o Follow national orders/circulars/guidelines issued from time to time

o Apply the guidelines/guidance notes referred in the document

o Practice the Daily Drill and General Guidance above.

Appendix 16 39

o Camp sites and construction sites may require different approaches to avoid spread of COVID-19. Special care to be taken for supply chain related vehicles, personnel and material.

o Provide Contactless attendance system

The various guidelines / interim notes for construction sites have been prepared by several

institutions and organizations, some of which are listed below:

a. The Ministry of Home Affairs and Ministry of Health and Family Welfare, Government of

India issued several Orders/Circulars/Guidelines from time to time to be followed by the

State governments, sectors and individuals :-

(https://www.mha.gov.in/notifications/circulars-covid-19,

https://www.mha.gov.in/sites/default/files/PR_ConsolidatedGuidelinesofMHA_28032020_

0.pdf , https://www.mohfw.gov.in/. Further, amendments to these orders are updated from

time to time on https://www.mha.gov.in/media/whats-new,

b. ILO’s Guidance: Considerations for employment intensive works in response to COVID 19

(April 12, 2020): https://www.ilo.org/wcmsp5/groups/public/---

ed_emp/documents/publication/wcms_741669.pdf

c. WB’s ESF/Safeguards interim note: COVID-19 considerations in construction/civil works

projects (April 7, 2020)

d. WHO’s guidelines: Getting your workplace ready for COVID-19 (March 03, 2020)

https://www.who.int/docs/default-source/coronaviruse/getting-workplace-ready-for-covid-

19.pdf; Water, sanitation, hygiene, and waste management for the COVID-19 virus (March

19, 2020) https://www.who.int/publications-detail/water-sanitation-hygiene-and-waste-

management-for-covid-19; Rational use of personal protective equipment (PPE) for

coronavirus disease (March 19, 2020):

https://apps.who.int/iris/bitstream/handle/10665/331695/WHO-2019-nCov-IPC_PPE_use-

2020.3-eng.pdf .

e. IASC Interim Guidance: Scaling-Up Covid-19 Outbreak Readiness and Response

Operations in Humanitarian Situations, Including Camps and Camp-Like Settings (March

17, 2020) https://interagencystandingcommittee.org/other/interim-guidance-scaling-covid-

19-outbreak-readiness-and-response-operations-camps-and-camp

f. IDB’s Guidance for infrastructure projects on COVID-19

https://www.idbinvest.org/en/download/9625

g. IFC Guidance: Workers’ accommodation: processes and standards (2009)

http://documents.worldbank.org/curated/en/604561468170043490/pdf/602530WP0worke

10Box358316B01PUBLIC1.pdf

40 Appendix 17

Date Place of Registration

Contact Information/Personal Details Name: Gender: Male Female Age: Home Address Village/Town District Phone no. E-mail Complaint/Suggestion/Comment/Question Please provide the details (who, what, where and how) of your

Grievance below:

If included as an attachment/note/letter, please mention here:

How do you want us to reach you for feedback on your comment/grievance?

Registered by: (Name of Official registering grievance)

Verified through:

Note/Letter

E-mail

Verbal/Telephonic Reviewed by: (Names/Position of Official(s)reviewing grievance)

Action Taken:

Whether Action Taken Disclosed:

Yes

No Means of Disclosure:

Sample Grievance Form

(To be available in Tamil)

The Proposed Inclusive, Resilient and Sustainable Housing for the Urban Poor Project

welcomes complaints, suggestions, queries, and comments regarding program

implementation. We encourage persons with a grievance to provide their name and contact

information to enable us to get in touch with you for clarification and feedback.

In case you want to include your personal details but want information to remain confidential,

please type CONFIDENTIAL above your name.

FOR OFFICIAL USE ONLY

Appendix 18 41

Sample Environmental Site Inspection Report

Project Name Contract Number

NAME: _____________________________________ DATE: __________________________ TITLE: _______________________________________ DMA: ___________________________ LOCATION: __________________________________ GROUP: ________________________ WEATHER CONDITION:______________________________________________________________________ INITIAL SITE CONDITION:___________________________________________________________ CONCLUDING SITE CONDITION: Satisfactory ______Unsatisfactory ______Incident ______Resolved _______ Unresolved ______ INCIDENT: Nature of incident:__________________________________________________________________ Intervention Steps:__________________________________________________________________ Incident Issues

Project Activity Stage

Survey

Design

Implementation

Pre-Commissioning

Guarantee Period

Inspection

Emissions Waste Minimization

Air Quality Reuse and Recycling

Noise pollution Dust and Litter Control

Hazardous Substances Trees and Vegetation

Site Restored to Original Condition Yes No Signature _______________________________________ Sign off Name Position

Name Position

Resolution

42 Appendix 19

Quarterly Environmental Monitoring Template

Introduction

Overall project description and objectives

Environmental categorization of each subproject as per ADB Safeguard Policy Statement, (SPS 2009)

Project Safeguards Team

Identify the role/s of Safeguards Team including schedule of on-site verification of reports submitted by consultants and contractors.

Name Designation/Office Email Address Contact Number Roles

1. PMU

2. PIDs

3. Consultants

Overall project and subproject/package progress and status

Description of Sub-projects and Indicate o Status of design – preliminary design or final design, o Status of implementation - under bidding, contract awarded but no works yet,

contract awarded with works (on-going construction), civil works completed, and/or Operation & Maintenance (O&M)

Package

Number

Subproject

Name / List

of Works

Type of

Contract

(specify if

DBO, DB

or civil

works)

Status of

Design

(specify if

Preliminary

Design,

Final

Detailed

Design

Contract

Status

(specify if

under

bidding or

contract

awarded)

Status of

Implementation

(specify if

Contract

awarded with

works (On-going

Construction),

Completed

Works, or O&M

phase)33

If On-going Construction

%Physical

Progress

Expected

Completion

Date

o For package with “Contract Awarded”, provide name/s and contact details of contractor/s’ nodal person/s for environmental safeguards.

Package-wise Contractor/s’ Nodal Persons for Environmental Safeguards

33 If on-going construction, include %physical progress and expected date of completion

Appendix 19 43

Package

Name

IEE Cleared

by ADB

(provide

date)

Contractor EHS Nodal

Person

Email

Address

Contact

Number

Status of IEE per Subproject/Package

Provide status of updated/final IEE34 per package.

Package-wise Implementation Status

Package Number

Final IEE based on Detailed Design Site-specific EMP or

Construction (C-EMP)

approved by Chief

Engineer?35 (Yes/No)

Remarks

Not yet due

(detailed design not

yet completed)

Submitted to ADB (provide date of

submission)

Disclosed on

project website (provide

link)

Final IEE provided to Contractor/s

(Yes/No)

Compliance status with National/State/Local statutory environmental requirements36

Package Number

Statutory Environmental Requirements37

Status of Compliance (Specify if obtained,

submitted and awaiting approval,

application not yet submitted )

Validity Date(s)

(if already

obtained)

Action Required

Specific Conditions that

will require environmental

monitoring as per environmental

clearance, consent / permit

to establish38

Compliance status with environmental loan covenants

Schedule No. and Item

(see Project Loan Agreement and list

Covenant Status of Compliance

Action Required

34 IEE prepared based on preliminary design and cleared by ADB with condition that updated/Final IEE based on detailed design will be submitted. 35 Works will not be allowed until C-EMP is approved by the PMU and/or PID. 36 All statutory clearance/s, no-objection certificates, permit/s, etc. should be obtained prior to award of contract/s. Attach as Appendix all clearances obtained during the reporting period. If already reported, specify in the “remarks” column. 37 Specify statutory requirements: environmental clearance? Permit/consent to establish? Forest clearance? Workers/Labor permit, etc. 38 Example: Environmental Clearance requires ambient air quality monitoring, Forest Clearance/Tree-cutting Permit requires 2 trees for every tree, etc.

44 Appendix 19

provisions / paragraph relevant to environmental safeguards, core labor standards,

occupational EHS, community health

and safety)

Compliance status with the environmental management plan (refer to EMP tables in

approved IEE/s)

Confirm in IEE/s if contractors are required to submit construction EMPs (C-EMP). If not, describe the methodology of monitoring each package under implementation.

Provide over-all compliance of the contractors with C-EMP. This should be supported by contractors’ monthly monitoring reports to PID(s) and/or verification reports of PID(s) or project consultants. Include as an Appendix supporting documents such as signed monthly environmental site inspection reports prepared by consultants and/or contractors.

Overall Compliance with C-EMP

Package Number

Status of C-EMP Implementation (Excellent/ Satisfactory/ Partially Satisfactory/ Below Satisfactory)

Action Proposed and Additional Measures

Required

Provide description based on site observations and records: o Confirm if any dust was noted to escape the site boundaries and identify dust

suppression techniques followed for site/s. o Identify muddy water was escaping site boundaries or muddy tracks were seen on

adjacent roads. o Identify type of erosion and sediment control measures installed on site/s, condition

of erosion and sediment control measures including if these were intact following heavy rain.

o Identify designated areas for concrete works, chemical storage, construction materials, and re-fueling. Attach photographs of each area.

o Confirm spill kits on site and site procedure for handling emergencies. o Identify any chemical stored on site and provide information on storage condition.

Attach photograph. o Describe management of stockpiles in each work site (construction materials,

excavated soils, spoils, etc.). Provide photographs. o Describe management of solid and liquid wastes on-site (quantity generated,

transport, storage and disposal). Provide photographs. o Provide information on barricades, signages, and on-site boards. Provide

photographs. o Provide information on construction / workers camp(s). Provide photographs. o Provide information on work-related accidents and incidents. Describe actions

implemented. o Provide information on if there are any activities being under taken out of working

hours and how that is being managed.

Appendix 19 45

Provide list of trainings on environmental safeguards, core labor standards, and Occupational environment, health and safety conducted during the reporting period. Include ADB-organized workshop, trainings, seminars, etc)

Trainings, Workshops and Seminars Conducted

Date Topic Conducted by

No. of Participants

(Total)

No. of Participants

(Female)

Remarks

Provide the monitoring results as per the parameters outlined in the approved EMP (or C-EMP when applicable).

Summary of Environmental Monitoring Activities (for the Reporting Period)39

Impacts (List

from C-EMP)

Mitigation Measures (List from C-EMP)

Parameters Monitored

(As identified in

the C-EMP)

Method of Monitoring

(Visual, Actual

Sampling, etc.)

Location of Monitoring

(Provide GPS Coordinates)40

Date of Monitoring Conducted

Person Who

Conducted the

Monitoring

Design Phase

Pre-Construction Phase

Construction Phase

Operational Phase

Monitoring of environmental Impacts on Project Surroundings

Confirm records of pre-work condition of roads, agricultural land or other infrastructure prior to starting to transport materials and construction.

Package Number. Status of Pre-Work Conditions

(Recorded / Not Recorded)

Baseline Environmental Conditions (air, water, noise) Documented

(Yes / No)

Action Proposed and Additional

Measures Required

39 Attach Laboratory Results and Sampling Map/Locations 40 If GPS coordinate is not available, provide landmark(s) and/or chainage.

46 Appendix 19

Provide information on monitoring activities conducted during reporting period. If not conducted, provide justification. Compare results with baseline and internationally recognized standards.41

Air Quality Monitoring Results

Site No. Date of Testing Site Location (Provide GPS Coordinates)42

Parameters (as required by statutory

clearances or as mentioned in the IEE)

Remarks

PM10 µg/m3

SO2 µg/m3

NO2 µg/m3

Water Quality Monitoring Results

Site

No.

Date of

Sampling

Site

Location

Parameters (as required by statutory

clearances or as mentioned in the IEE)

Remarks

pH Conductivity

µS/cm

BOD

mg/L

TSS

mg/L

TN

mg/L

TP

mg/L

Noise Quality Monitoring Results

Site No. Date of Testing

Site Location

LAeq (dBA) (as required by statutory clearances or as mentioned in the IEE)

Remarks

Day Time Night Time

Information Disclosure, Participation and Consultations

Confirm PMU/PID/contractors provide project-related information to stakeholders, communities and/or affected people before and during construction works.43

41 ADB Safeguard Policy Statement (SPS) Appendix 1, para 33: During the design, construction, and operation of the project the borrower/client will apply pollution prevention and control technologies and practices consistent with international good practice, as reflected in internationally recognized standards such as the World Bank Group’s Environment, Health and Safety Guidelines. These standards contain performance levels and measures that are normally acceptable and applicable to projects. When host country regulations differ from these levels and measures, the borrower/client will achieve whichever is more stringent. If less stringent levels or measures are appropriate in view of specific project circumstances, the borrower/client will provide full and detailed justification for any proposed alternatives that are consistent with the requirements presented in the SPS. 42 If GPS coordinate is not available, provide landmark(s) and/or chainage. 43 Check EMP requirement on information disclosure. At a minimum, PID through the contractor should notify communities/affected persons/sensitive receptors 7 days and again 1 day before start of works.

Appendix 19 47

Provide information on consultations conducted during reporting period such dates, topics discussed, type of consultation, issues/concerns raised, safeguards team member present. Attach minutes of meetings (ensure English translation is provided), attendance sheet, and photos.

Date of Consultation

Location Number of Participants (specify total, male and

female)

Issues/Concerns Raised

Response to issues/concerns

Grievance Redress Mechanism

Grievance Redress Mechanism. Provide information on establishment of grievance redress mechanism and capacity of grievance redress committee to address project-related issues/complaints. Include as an Appendix Notification of the GRM (package-wise if applicable).

Complaints Received during the Reporting Period. Provide information on number, nature, and resolution of complaints received during reporting period. Attach records as per GRM in the approved IEE. Identify safeguards team member/s involved in the GRM process. Attach minutes of meetings (ensure English translation is provided).

Summary of Key issues/concerns identified during the Reporting Period and Remedial

Actions

Provide corrective action plan which should include all issues/concerns, actions required to be implemented, responsible entities, and target dates.

Status of Corrective Actions from Previous Monitoring Report(S)

Provide information on corrective actions to be implemented as reported in the previous Monitoring Report(s). Include status of implementation of feedbacks/comments/suggestions as provided by ADB, if any.

Corrective Action Plan Status

Issues/Concerns Corrective Action Status Remarks

Appendixes

Photos

Records of consultations

Copies of environmental clearances and permits (if not provided in the previous Monitoring Reports)

Environmental site inspection report (if not provided in the previous Monitoring Reports)

Other

48 Appendix 20

Outline of Daily Monitoring Sheet for Contractors

Contractor Monitoring Sheet Name of Subproject:

Location of Subproject: Supervising PID: Contractor: Contractor EHS Supervisor (or equivalent): Date of monitoring:

Summary of Findings

Monitoring Item Status Remarks

1. Compliance with Local Permit (Secured / Application

Requirements Submitted / Not Applicable)

Location/zoning permits

Permit to construct

Building permit

Transport / hauling permits

2. Compliance with IEE Requirements (Approved / Under

Preparation / Submitted to PID for Approval)

Construction EMP (C-EMP)

Corrective Action Plan, if any

3. Compliance with C-EMP

Construction Site (Satisfactory / Needs

Improvement / Not Implemented)

- Conduct of toolbox talk

- Use of PPE

- Rest areas for male and female workers

- Toilets for male and female workers

- Medical kits

- Drinking water supply

- Dust control

- Noise control

- Solid waste management

- Wastewater management

- Chemicals storage (fuel, oil, etc.)

- Siltation or erosion control

- Heavy equipment staging / parking area

- Barricades around excavation sites

- Access to residential

houses/shops/businesses

- Traffic routing signages

- Lightings at night

- Trench shoring / landslide protection

Construction Workers’ Camp Site (Available / Needs

Improvement / Not

Available)

- Quarters for male and female workers

Appendix 20 49

Monitoring Item Status Remarks

- Sleeping utilities (e.g. beds, pillows,

blankets, mosquito nets, etc.)

- Power/Electricity supply

- Drinking water supply

- Toilets for male and female workers

- General purpose water supply (cooking,

washing, bathing)

- Cooking facilities and areas

- Solid waste management

- Wastewater management

- Pest control

4. Implementation of GRM (Yes / No or None / Under

Resolution)

Complaints

Complaints resolution

5. Environmental Quality Measurement (Passed / Failed / Not

Applicable)

Ambient air quality sampling

Noise level measurement

Receiving water quality sampling

Other Issues:

Attachments:

1. Copies of permits secured, if any. 2. Photos taken at worksites, if any.

(photos attached in previous monitoring sheets should not be used again). 3. Laboratory results of environmental quality measurements, if any.

Prepared by:

Name, Designation and Signature

50 Appendix 21

Source sustainability study for supply of water to the Reddiarpatti

Resettlement Site