clarifications for the queries raised by eac (infra-2)...

l:\ports\2010\c1101303 - eia for exp of redi port\outputs\reports\moef 4th clarifications\sap-moef-4th clarifications.doc Page 1

Clarifications for the queries raised by EAC (Infra-2) in its 21st meeting held on 22 August, 2017

1 Point wise reply to the complaint made by Conservation Action Trust.

S. No Conservation Action Trust Reply by Proponent 1. ToR validity and forest land

[The project proponent submitted EC application documents within two year ToR of the MoEF&CC. However, by their own adi were granted on 12.05.2e the Final EIA/EMP was MoEF and MCZMA on 29, 21.05.2012. Moreover, we disagree t proponents claim that expansion project, since new site is located at about 2 kms (aerial vie` existing project site. It is not clear if the proj had ever asked for the ToFFF extended in the situation still to be considered before and the MCZMA. In such e would have lapsed and., proponent should apply for The EIA report is not clear of the forest land being int proposed expansion]

Chronology of events is already submitted in the clarifications and MoEF&CC considered the project for appraisal in November, 2013 after MCZMA recommendation on the project for CRZ Clearance. The land for expansion is within the port limits of Redi port. During the process of land possession from Government of Maharashtra, it is informed to obtain the land as per forest act and accordingly application was made for forest clearance in the year 2013. Thereafter, involvement and status of forest land was informed in the MoEF&CC clarifications.

2. Illegal mining [The project proponen responded to the query illegal mining..The prof: may be directed-to-do so.-Also, the expansion prof; destruction of hill of 42.5 the project proponent furnish information on material will be dumped. The project proponent on to mention presence of the study area. in fact proponent has provided information regarding mangroves in the study ar The project proponent m. to furnish information r ancillary activities, roads, r The locals during the p have complaint regardi conditions being miserabl had also suggested altem which the project propo responded, as mentioned public hearing. They are also aggravated pollution due to movement. What is the impact of the it ^ movement by ships/barge are the mitigation measure]

Project does not involve mining activity.

The proposed Redi port expansion is

planned to handle the dry bulk cargo

such as Coal and iron Ore and General

cargo. Necessary pollution control

measures will be adopted and followed

as a part of Environmental Management

Plan. The land identified for expansion

of Redi Port does not entail mangroves.

Therefore no mangroves will be

destroyed by the expansion of the port.

There are no biosphere reserves or

national parks or sanctuaries or other

protected areas within 10 km radius of

core area. There are no Mangroves or

mangrove forests within the core area or

proposed project area. Mangroves and

their associated species are observed

near Keruvada Creek at a distance of 3.6

km towards north and near Terekhol

River at a distance of 3.3 km towards SE.

Except for the presence of a few


S. No Conservation Action Trust Reply by Proponent

mangroves represented by Avicennia

officinalis, Excoecaria agallocha and

Rhizophora mucronata in and along the

banks of the Terekhol River and

Keruvada Creek, there are no mangrove

forests within the study area.

As of now, transportation of mined iron

ore is majorly carried out by road due to

existing redi port can perform only fair

weather operations. Once the Redi port

expansion takes place it will become “All

Weather Deep Water Port” by which

road transportation will be considerably

decreased and air pollution due to

vehicular activity will be decreased. The

trucks will be engaged in road

transportation of port cargo will be

covered and village roads may be

avoided.

The material which is obtained during the cut and fill will be reused for site preparation and levelling.

3. Silt and Dust from open cast mine [However, the project proposes to handle coal The storage and transport would lead to air pollution. The stack yard location duration of coal s transportation is not cle. documents. The mitigation measures document with respons proponent to our earlier inadequate and superfluou it is not clear why the proj intends to plant exotic s green belt. Such practice _undertaken at all]

Present proposal is expansion of Redi port into “All weather deep water port” with mechanised handling of cargo. No mining activity will be involved. The location of coal stack yard is shown in project layout, storage will be dependent on receipt and evacuation from the port.

4. Barge loading at existing port [The project proponent m directed to furnish details of coal that will be ha proposed premises. proponent may also be furnish details regarding studies and source of the . used for the modelling stud; The storage of coal and the air quality and envir area. In the event of any, marine ecosystem woul impacted. The public hearing m reflect that the livelihood being impacted.]

Present proposal is expansion of Redi port into “All weather deep water port” with mechanised handling of cargo. Cargo handling and storage operations: A fully mechanized ship loading/unloading system is planned at the berths. The major components of the mechanised ship loading/unloading system are: Ship Gantry type unloaders, loaders Telescopic chutes, Wagon loaders, Wagon Tipplers, and connected covered conveyor system. The impact of air quality due to fugitive emissions from dry bulk cargo such as Iron Ore and Coal handling has been studied using the Industrial Source


S. No Conservation Action Trust Reply by Proponent Complex, Short Term (ISCST3) dispersion model based on Steady State Gaussian Plume Dispersion, developed by US Environmental Protection Agency (US EPA). Site specific meteorology and emission data of coal and iron ore has been used for model studies. The resultant concentrations PM10 and PM2.5 at all monitoring stations are found to be well within the National Ambient Air Quality Standards (NAAQS), 2009. From the predicted GLCs and the corresponding resultant concentrations, it can be concluded that there is no significant increase over the baseline levels.

5. Forest Clearance Status [The EIA report does n forest land being invol. proposed expansion. It is still not clear if the for has been obtained. The pr' to be considered in totality Expert Committees need to project, simultaneously. The public hearing cor!~' reflect that the land grabbed by proponent]

Chief conservator of forests (CCF), Mantralaya has recommended the proposal to Additional Principal Chief Conservator of Forest, MoEF&CC, Nagpur for diversion of forest land to non-forestry purpose. Stage I approval is in advanced stage. Difficulties faced in identifying the compensatory afforestation land was explained earlier and present location of compensatory afforestation was approved by Forest department

6. Compensatory afforestation [As stated earlier, the compensatory afforestation km which is not acceptable should be ground for rej proposal]

7. Master Plan-EC [Despite our earlier the que proponent has yet ag provide details of all th comprising of ten berths, e Such piecemealing of t should not be allowed by as it leads to fragmentatio area and repetitive im proposal on the environment. The project needs to be its totality. A cumulative assessment should also be]

The present expansion of port is planned in two phases i.e., Phase I (5.16 MTPA) and Phase II (13.74) MTPA development of Redi Port comprises of Three (3) berths Port expansion is planned on phased manner based on the business demand and requirements, further expansion and line of cargo will be decided and appropriate statutory clearances along with cumulative impact assessment will be taken up.

8. Reclamation - effect on marine biodiversity [We reiterate that the recla gravely impact the marine the area. the project p again fails to consider the mangroves, mudflats, cr study area. As mentioned by the proje the reclamation bunds to b to act as barrier towar. Creek, will block the natur; waters and waves. The

Reclamation is proposed towards

seaward side. Predominantly the port

land proposed to be reclaimed is an

intertidal zone towards sea.

The area proposed to be reclaimed does

not contain corals, mangroves and any

other sensitive species. Reclamation will

be carried out judicial planning.

Reclamation bunds shall be constructed


S. No Conservation Action Trust Reply by Proponent breakwaters will also of the tide and waves. Th erosion and change in gE of the area. the proposal a, rock bund which would al geomorphology of the area Moreover, Vengurla beach turtle nesting. The geomorphology, increase movement, etc will impact this area. In fact one of the articlr conservation in Sindhudii Maharashtra" lists Redi as for conservation of sea turtle. The expansion project sl allowed in an area which i' sensitive and geom. important. We reiterate that the bre alter the flow of the tide an( This will lead to erosion a geomorphology of the area` observed at numerous othF The Bandra-Worli Sea lint the classic example wh modelling studies have fail erosion along Dadar area. The proposal also envisag which would also geomorphology of the are

which will act as barrier towards

Keruvada Creek located at 3.6 km, north

and southern breakwater will act barrier

towards Terekhol river located at 3.3 km

towards south. Also minimum required

retention time of return water in the

reclamation area will be ensured.

There are no biosphere reserves or national parks or sanctuaries or other protected areas within 10 km radius of core area. There are no Mangroves or mangrove forests within the core area or proposed project area. Sedimenation and shoreline changes were already carried out and results doesn’t indicate any major changes and closure of river and creek mouth.

9. Shoreline changes [We reiterate that the breakwater alter the flow of the tide. This will lead to erosion a geomorphology of the area observed at numerous othF The Bandra-Worli Sea lint the classic example wh modelling studies have fail erosion along Dadar area. The proposal also envisag which would also geomorphology of the area]

The simulated results show that the shoreline towards south of south breakwater has an annual depositional trend in the range of 2 – 2.3 m/year (five year average) in the immediate vicinity which diminishes over 600m and the shoreline towards the north has a negligible erosion. It is observed from the simulated results that there is no influence of breakwater on the Terekhol river mouth. If at all sand by passing is required, it will be sourced from accreted areas.

10. Sand bypassing-source [The project proponent whether there would be erc As the project proponent nt the "In case of sand bypass sand will be bypassed stretches"]

11. Sedimentation [We reiterate and are apl the erosion the breakwa rock bunds would use in The project proponent ma to give an undertaking tha be no erosion and in ca: being observed or reporte activities will stop and the' and the rock bund deconstructed and the ar, restored]

12. Dredging- impact on biodiversity [The project proponent ha; the loss of biodiversity proposal. The project proponent ma to explain on what basis ar that the turbidity will

Centre for Advanced Studies in Marine Biology (CASMB), Annamalai University has prepared Biodiversity Impact Assessment Report and Management Plan and in order to mitigate the impacts


S. No Conservation Action Trust Reply by Proponent diversity in the adjoining are The mitigation measures inadequate. The project p be directed to furnish d mitigation measures such of equipment and environmental monitoring activities based on-monitor]

mitigation measures and management plan will be adhered.

13. Form 1 is not uploaded on the MoEFCC website [The Project proponent is expansionon basis of project. Fresh Form I submitted along with other]

Online uploading of Form-1 was initiated from year 2014 onwards and Form-1 application for Redi Port Expansion was submitted in the year 2010.

14. Mangroves- CRZ IA [The project proponent. admitted presence of man kms and 2 kms and they part of the study area. The project proponent understand that mangroves are ecologically geomorphologically import]

Project site doesn’t contain mangroves and mangrove presence in the study area was already declared and the model studies carried out does not reveal any impact on these areas.

15. Employment [The Additional information dated 23 June 2016 states developed will give a huge opportunities andthat eagerly awaited by the peo However, bare perusal proceedings, which recon and concerns of only 13 and no more, clearly states people to be employed will The PP may be asked and shed light on the act& locals to be employed [operation phase] /1500]

There will be a demand for skilled, semi-skilled and unskilled work force during the construction and operational phase of the Port expansion and it is imperative that mostly local people would be employed based on their skills and educational qualifications. The employment potential from the construction phase of the proposed port is estimated as 1500 persons. The expected direct employment will be 300 persons during operation phase. The proposed project will have positive impact on socio-economic condition of the region overall. With the addition of this employment potential, the indirect employment will be increased by many folds

16. Mining [Be it so, the project h+c envisage transport and st and iron ore cargo, among The storage, transportatio impact the health and envisaged. A cumulative impact asse to be conducted to study t all the projects in this area]

Project does not involve mining activity. To carry out cumulative impact, there are no proposal of similar projects at the time EIA preparation.

17. Coal storage and dust [The transport of coal, thrc or barges, would be or closed. The coal dust will be the land as well as marine of this area]

The impact of air quality due to fugitive emissions from dry bulk cargo such as Iron Ore and Coal handling has been studied using the Industrial Source Complex, Short Term (ISCST3) dispersion model based on Steady State Gaussian Plume Dispersion, developed by US Environmental Protection Agency (US EPA). Site specific meteorology and


S. No Conservation Action Trust Reply by Proponent emission data of coal and iron ore has been used for model studies. The resultant concentrations PM10 and PM2.5 at all monitoring stations are found to be well within the National Ambient Air Quality Standards (NAAQS), 2009. From the predicted GLCs and the corresponding resultant concentrations, it can be concluded that there is no significant increase over the baseline levels.

2 Affidavit regarding No violation and No court case

Affidavit as required is enclosed.

3 Submit the set of following documents required as per para 4.2 (i) of CRZ Notification, 2011

S. No Details Remarks 18. Form-1 (Annexure-IV of the notification) Soft Copy in a CD will be submitted

along with this clarification hard copy submission.

19. Rapid EIA Report including marine and terrestrial component except for construction projects listed under 4(c) and (d)

EIA Report including marine and terrestrial component has already submitted and same is available in MOEF&CC web portal. However EIA report in a CD will be submitted along with this clarification hard copy submission.

20. Comprehensive EIA with cumulative studies for projects in the stretches classified as low and medium eroding by MoEF based on scientific studies and in consultation with the State Governments and Union territory Administration

Not Applicable

21. Disaster Management Report, Risk Assessment Report and Management Plan

The Disaster Management Report, Risk Assessment Report and Management Plan are part of the EIA Report (Section 7.3 and 7.2 of Chapter 7).

22. CRZ map indicating HTL and LTL demarcated by one of the authorized agency (as indicated in para 2) in 1:4000 scale

The CRZ map indicating HTL and LTL demarcated by one of the authorized agency was submitted along with the documents for CRZ/EC Clearance and same is available in MOEF&CC web portal. However, the same will be submitted in a CD along with this clarification hard copy submission.

23. Project layout superimposed on the above map indicated at (e) above

24. The CRZ map normally covering 7km radius around the project site

25. The CRZ map indicating the CRZ-I, II, III and IV areas including other notified ecologically sensitive areas


S. No Details Remarks 26. No Objection Certificate from the

concerned State Pollution Control Boards or Union territory Pollution Control Committees for the projects involving discharge of effluents, solid wastes, sewage and the like.

No objection certificate is not applicable as discharge of effluent/ Sewage and the like are not involved in the project.

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