INDIA: Accelerating Infrastructure Investment Facility in India … · 2019. 12. 26. · Ujjain...

Environmental and Social Due Diligence Report

Project Number: 47083-004 December 2019

INDIA: Accelerating Infrastructure Investment

Facility in India – Tranche 3 Dewas Bypass Tollway Private Limited (Part 1 of 5)

Prepared by India Infrastructure Finance Company Limited for the India Infrastructure Finance

Company Limited and the Asian Development Bank.

This environmental and social due diligence report is a document of the borrower. The views expressed herein do not necessarily represent those of ADB's Board of Directors, Management, or staff, and may be preliminary in nature. In preparing any country program or strategy, financing any project, or by making any designation of or reference to a particular territory or geographic area in this document, the Asian Development Bank does not intend to make any judgments as to the legal or other status of any territory or area.

Environment and Social Due Diligence Report Dewas Bypass Tollway Private Limited

ESDDR NO. IIFCL/ESMU/ADB/2019/115/V2 1

Due Diligence Report on Environment and Social Safeguards

By

India Infrastructure Finance Company Limited (IIFCL)

(A Govt. of India Enterprise)

Sub-Project: 4/6 Laning of Dewas Bypass commencing from Km 0+000

(Ujjain-Dewas junction) to Km 19+800 (total length 19.800 km), in the State of

Madhya Pradesh on Build, Operate and Transfer (BOT) basis

November 2019



SUB PROJECT: 4/6 Laning of Dewas Bypass commencing from Km 0+000

(Ujjain-Dewas junction) to Km 19+800 (total length 19.800 km), in the State of

Madhya Pradesh on Build, Operate and Transfer (BOT) basis

Dewas Bypass Tollway Private Limited (DBTPL)

Environment and Social Safeguards Due Diligence Report

(ESDDR)

Prepared by Dr. Rashmi Kadian

Assistant General Manager

(Environmental Specialist)

ESMU, IIFCL

Mr. Krupasindhu Guru

Assistant General Manager

(Social Specialist)

ESMU, IIFCL

Mr. Ashok Suyal

Consultant - Social Safeguards

Reviewed and Approved

by

Dr. S. S. Garg

General Manager & Head, ESMU

IIFCL



CONTENTS

PROJECT BACKGROUND ....................................................................................................... 5

1. PURPOSE OF THE REPORT ........................................................................................... 6

2. SUB-PROJECT TITLE ..................................................................................................... 6

3. SUB-PROJECT BACKGROUND ...................................................................................... 6

4. SUB-PROJECT LOCATION & DESCRIPTION ................................................................ 7

5. CONCESSIONAIRE ......................................................................................................... 8

6. EPC CONTRACTORS ...................................................................................................... 8

7. INDEPENDENT ENGINEER ............................................................................................ 8

8. IIFCL FUNDING .............................................................................................................. 9

9. STATUS OF PROJECT IMPLEMENTATION .................................................................. 9

DUE DILIGENCE ON ENVIRONMENTAL SAFEGUARDS .................................................... 10

10. ENVIRONMENT SAFEGUARDS COMPLIANCE REVIEW .......................................... 11

11. APPLICABILITY OF ENVIRONMENTAL IMPACT ASSESSMENT NOTIFICATION .. 11

12. APPROACH TO THE ENVIRONMENT SAFEGUARDS DUE DILIGENCE REPORT: .. 11

13. COMPLIANCE OF DBTPL TO THE ESSF OF IIFCL: ................................................... 12

14. POLICY, LEGAL AND REGULATORY REQUIREMENT: ............................................ 12

15. IMPACT ASSESSMENT OF SUB-PROJECT .................................................................. 14

16. ENVIRONMENTAL MANAGEMENT PLANS ............................................................... 15

17. HEALTH AND SAFETY ................................................................................................. 16

18. GRIEVANCE REDRESSAL MECHANISM .................................................................... 22

19. ENVIRONMENTAL SENSITIVITY ................................................................................ 22

20. PROJECT AGAINST THE PROHIBITED INVESTMENT ACTIVITIES LIST ............... 23

21. CATEGORIZATION OF SUB-PROJECT ....................................................................... 23

22. SITE VISIT OBSERVATIONS ........................................................................................ 23

23. CONCLUSIONS AND RECOMMENDATIONS .............................................................. 25

DUE DILIGENCE ON SOCIAL SAFEGUARDS ....................................................................... 27

24. PURPOSE OF THE SOCIAL SAFEGUARDS DUE DILIGENCE .................................... 28

25. PROJECT AGAINST THE PROHIBITED INVESTMENT ACTIVITIES LIST ............... 28

26. OBJECTIVE OF SOCIAL SAFEGUARDS DUE DILIGENCE ......................................... 28

27. APPROACH AND METHODOLOGY ............................................................................. 28

28. SOCIAL IMPACT OF THE PROJECT ........................................................................... 29

27.1 LAND ACQUISITION IN THE PROJECT ...................................................................... 29

27.2 IMPACT ON STRUCTURE ............................................................................................ 30

27.3 REHABILITATION AND RESETTLEMENT IMPACT IN THE SUB-PROJECT ............ 30

27.4 IMPACT ON INDIGENOUS PEOPLE ............................................................................ 30

29. GREIVANCE REDRESSAL MECHANISM FOR THE SUB-PROJECT .......................... 30

30. EMPLOYMENT GENERATION .................................................................................... 30

31. THE COMMUNITY ENGAGEMENT ACTIVITIES ....................................................... 31

32. LABOUR LICENSE OBTAINED BY THE SUBPROJECT DEVELOPER ....................... 31

33. DISCLOSURE ................................................................................................................ 31

34. SITE VISIT OBSERVATION .......................................................................................... 31

LIST OF FIGURES

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



LIST OF TABLES

Table 1: Salient Features of Dewas Bypass Tollway Private Limited……………….…………………7

Table 2: Status of Regulatory Permits/ Clearances Obtained related to Environmental Safeguards…..13

Table 3: Proposed EMP and its Implementation status during Construction Phase at DBTPL……......17

Table 4: Proposed EMP for Operation of DBTPL……………………………………………………….20

Table 5: Status of Land available at DBTPL……………………………………………………………...29

ANNEXURES

Annexure I Copy of Tree Implantation Permission

Annexure II A & B Copies of Consent to Establish

Annexure III Consent to Operate

Annexure IV Environmental Clearance for Quarry Area

Annexure V Environmental Clearance for Borrow Area

Annexure VI Labour License

Annexure VII Insurance Copy

Annexure VIII Permission for using water

Annexure IX NOC from Village Panchayat for Camp site

Annexure X License for Explosives

Annexure XI Sample Copy Toll Box Meeting

Annexure XII Sample Copy Safety Training Programme

Annexure XIII Sample Copy On Job Safety Awareness Programme

Annexure XIV Organization chart HSE

Annexure XV Safety Audit Report by Independent Engineer

Annexure XVI Safety Audit Compliance submitted to IE

Annexure XVII CTO Compliance submission to MP PCB

Annexure XVIII Approved Diversion Plan

Annexure XIX ROW Handover Letter

PHOTOPLATE

Photoplate I : Site Visit Photographs



PROJECT BACKGROUND



1. PURPOSE OF THE REPORT

1. This Environmental and Social Due Diligence Report (ESDDR) has been carried out by India

Infrastructure Finance Company Limited (IIFCL) in consultation with the Concessionaire,

Dewas Bypass Tollway Private Limited (DBTPL) to assess the adequacy of the project with the

applicable National, IIFCL’s ESSF and ADB’s safeguard compliance. The report has been

prepared as per the documents/information received from the Concessionaire and on the basis

of site visit observations.

2. SUB-PROJECT TITLE

2. The sub-project includes - Four laning of existing road from Dewas Bypass (km 0.000) to

intersection of NH-3 and Dewas bypass (km 7.000) and six laning of part of bypass from NH-3 and

bypass intersection (km 7.000) until the intersection of the bypass and AB Road (km 19.800) in the

State of Madhya Pradesh on Design, Build, Finance, Operate and Transfer (DBFOT) basis.

3. SUB-PROJECT BACKGROUND

2. Madhya Pradesh Road Development Corporation (MPRDC) in the year 2016, invited detailed bid

proposals for widening and upgradation of Dewas Bypass from km 0.00 to km 19.80 on Build,

Operate and Transfer (Toll) basis. The project envisages four laning of 7.00 km stretch of Dewas

Bypass from Ujjain Dewas Junction (km 0.00) to km 7.00 and six laning of remaining section from

km 7.00 till end of bypass at Indore Dewas Junction (km 19.80).

3. The project stretch, Dewas Bypass, starts from the north western side of Dewas city and ends at AB

Road in south western side of the city. AB Road is a part of Mumbai Agra National Highway which

witnesses a high traffic movement. The existing two lanes forms a vital link in this region connecting

the northern Indian states to the Eastern Indian states and also caters to the Mumbai and Pune bound

traffic. It serves the long distance traffic which is majorly plying from UP, Agra and beyond to

Mumbai and beyond. Apart from long distance traffic, it also serves the short distance traffic which

is mainly generated between Ujjain, Gwalior, Indore, Bhopal and surrounding areas.

4. MPRDC awarded the project to Dewas Bypass Tollway Private Limited, an SPV formed by IJM

Corporation Berhad and the Concession Agreement was signed on February 27, 2017. The

concession period is of twenty five (25) years from Appointed Date (180 days from signing of

Concession Agreement) including construction period of 730 days (2 years).

5. The scope of the project includes performance & execution of all design, engineering, financing,

procurement, construction, completion, operation & maintenance (O&M) of the project corridor as

set out in the Concession Agreement (CA).



4. SUB-PROJECT LOCATION & DESCRIPTION

6. The project road comprises a 19.8 km stretch on State Highway 18 commencing from Ujjain Dewas

junction. The project road would be a rigid pavement. There is one level crossing on the existing

project road. The project scope includes construction of a railway over bridge, three vehicular

underpasses, 2 grade separators and widening of one minor bridge. For the initial 7 km stretch from

Ujjain Dewas Bypass junction, the paved carriage way shall be four lane and balance 12.8 km upto

Dewas bypass - AB road junction will be six lane. The proposed toll plaza will be located at 16.5

kms from Ujjain Dewas bypass junction. The location of DBTPL is given in Figure 1 and salient

features of the sub-project are given in Table 1.

Figure 1: DBTPL road and proposed toll plaza location

Table 1: Salient Features of Dewas Bypass Tollway Private Limited

Particulars Features

Name of Project 4/6 Laning of Dewas Bypass commencing from

Km 0+000 (Ujjain-Dewas junction) to Km 19+800

(Total Length 19.800 km.), in the State of Madhya

Pradesh on Build, Operate and Transfer (BOT) basis. State Madhya Pradesh

District Dewas

Concessioning Authority Madhya Pradesh Road Development Corporation

Concessionaire M/s Dewas Bypass Tollway Private Limited

Terrain Plain

Project Length 19.800 km



5. CONCESSIONAIRE

7. Incorporated in February 2017, Dewas Bypass Tollway Private Limited (DBTPL) is a

special purpose vehicle (SPV) promoted by the Malaysian construction firm IJM

Corporation Berhad and its investment companies to undertake the project of widening &

up-gradation of Dewas Bypass Road from Km 0.00 at Ujjain Dewas Junction and ending at

Km 19.80 at Indore Junction from two-lane to a four/six-lane highway in Madhya Pradesh

on a Design, Build, Operate and Transfer (DBOT) basis. The project was awarded by

Madhya Pradesh Road Development Corporation Limited (MPRDCL) based on

competitive bidding on February 27, 2017, with a concession period of 25 years

commencing from October 10, 2017 including the two year construction period.

6. EPC CONTRACTORS

8. IJM (India) Infrastructure Limited, Hyderabad is the EPC contractor for the sub-project. EPC

agreement has been signed between IJM (India) and DBTPL on April 21, 2017.

7. INDEPENDENT ENGINEER

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

(IE).

Toll Plaza 1 at KM 16+050 Flyover (Nos.) 2 nos.

Vehicular Under Pass (Nos.) 3 nos.

ROB 1

Minor Bridges 1 nos.

Box Culverts 9 nos.

Pipe Culverts 35 nos.

Truck Laybye 1

Bus Shelter (Nos.) 19

Service roads 4 Km X 2



8. IIFCL FUNDING

10. The total project cost of DBTPL is ₹ 280.28 crores. The project is financed by IIFCL under Direct

Lending Scheme. IIFCL has sanctioned an amount of ₹ 56 crore towards DBTPL and disbursed ₹ 39.21 crores as on 31.10.2019.

9. STATUS OF PROJECT IMPLEMENTATION

11. The sub-project is under construction and the Scheduled Commercial Operations Date (SCOD) was

in October 2019. At the time of site visit during 15th October, 2019, DBTPL informed that

approximately 83% physical progress has been achieved. The sub project is expected to achieve

commercial operation by December 2019.



DUE DILIGENCE ON ENVIRONMENTAL SAFEGUARDS



10. ENVIRONMENT SAFEGUARDS COMPLIANCE REVIEW

12. The environmental due diligence (EDD) report focuses on the status and review of the applicable

environmental regulatory requirements, compliance to the regulatory requirements, review of the

environment related sub-project documents, implementation of environmental management

measures at site, institutional arrangements for implementation and monitoring of environmental

measures, environment, health & safety (EHS) related clauses in agreements, health and safety

measures at work place, status of plantations and emergency preparedness.

11. APPLICABILITY OF ENVIRONMENTAL IMPACT ASSESSMENT NOTIFICATION

13. It is required that the project meets the applicable national guidelines / regulations relating to the

environment, occupational health and safety and social issues. The project should have necessary

clearances as well as permits and approvals for project implementation and suitable environmental

management plans.

14. National Highway projects up to 100 Kms involving additional right of way or land acquisition upto

40 meters on existing alignments and 60 meters on re-alignments or by-passes are exempted from

the scope of the Environmental Impact Assessment Notification, 2006 of Government of India. The

total length of the sub-projects is approximately 19.80 Kms; therefore, DBTPL does not require

environmental clearance and is not required to conduct an Environmental Impact Assessment (EIA)

as a statutory requirement. EIA study has not been conducted for the sub-project DBTPL.

12. APPROACH TO THE ENVIRONMENT SAFEGUARDS DUE DILIGENCE REPORT:

15. The Environmental Due Diligence Report (EDDR) reviews the available documents and assesses the

compliance of the sub-project with respect to environmental safeguards; regulatory clearances;

environmental impacts and management measures; Health, Safety and Environment (HSE)

measures; and categorization of sub-project on the basis of above review.

16. The following documents were referred in order to prepare Environmental Safeguards Due-

Diligence Report:

Project Information Memorandum (PIM)

Concession Agreement

Traffic study report

Independent Engineer Report (September 2019)

Safety Audit Report by Independent Engineer

Lender’s Independent Engineer (LIE) Reports

Project Statutory Approvals/Permits

Project HSE Documents

Labour License & insurance



Contract Documents

Emergency Response Plan

Grievance Redressal Mechanism

17. The environmental safeguard due-diligence study was carried out for the sub-project on the basis of

site visit observations and understanding project scope based on information and documents

provided by Concessionaire. A detailed discussion on the environmental and social safeguards

related issues was also carried out with the team of the sub-project at site.

18. On review of the documents / information related to the sub-project and on the basis of site visit, the

impacts of the DBTPL on environment are envisaged, which are given in section 15 of the ESDDR.

The sub-project is mitigating the environmental impacts at the site with various measures. An EMP

is proposed for DBTPL in concurrence with the developer (Section 16).

13. COMPLIANCE OF DBTPL TO THE ESSF OF IIFCL:

19. The Environmental and Social Safeguard Framework (ESSF) provides the enabling mechanism to

IIFCL to deliver its policy objectives and applies to projects funded by IIFCL throughout the project

cycle. The ESSF defines procedures, roles, and responsibilities, at various project milestones for

managing the adverse environmental impacts.

20. The environmental due diligence for DBTPL has been done as per requirements of direct lending

scheme. The environmental safeguard risks during construction phase have been assessed and risks

during operational phase have been evaluated. DBTPL is under construction and following the

regulations and guidelines. There does not seem to be any significant risk for either IIFCL or DFI

involved. The environmental measures being implemented at the sub project are proposed in the

form of structured EMP with monitoring indicators to DBTPL for both construction and operational

phase of sub-project. It can be concluded that DBTPL is compliant to the requirements of IIFCL’s ESSF under direct lending scheme and has adequate management measures implementation on site.

14. POLICY, LEGAL AND REGULATORY REQUIREMENT:

21. DBTPL does not fall under the schedule of EIA Notification, 2006 that lists projects or activities

requiring prior environmental clearance and hence these are exempt from obtaining environmental

clearance. DBTPL is required to comply with the applicable guidelines relating to the environment,

occupational health and safety in addition to complying with local pollution control board

regulations. The statutory permits/clearances related to environmental aspects obtained/to be

obtained from regulatory authorities as part of DBTPL development were assessed and current status

of availability of such permits/clearances are given in Table 2 below:



Table 2: Status of Regulatory Permits/ Clearances Obtained related to Environmental Safeguards

S.No. Permits/Clearances Statutory Authority Current Status

1. Environmental

Clearance

Ministry of

Environment, Forests &

Climate Change

(MoEF&CC), New

Delhi

Not Applicable. As the sub-project length is below

100 kms (19.8 Kms), this is exempted from

obtaining environmental clearance and conducting

EIA.

2. Forest Clearance MoEF&CC and State

Forest Department

The sub-project does not involve any forest land.

3. Wildlife Clearance MoEF&CC The Project area does not lie within an

ecologically sensitive area and is not located close

to any National Park/Wildlife Sanctuary. The

location of Project does not contravene any

international biodiversity or ecosystem

conservation conventions. Therefore, it does not

require wildlife clearance or permission.

4. Tree permissions Revenue Department,

Madhya Pradesh

Approximately 1354 nos of trees were coming in

ROW. These trees were on revenue land.

Permission from tree transplantation has been

taken from the Collector, District Dewas, Madhya

Pradesh. All the 1354 trees have been transplanted

on the proposed ROW. Copy of tree implantation

permission is attached as Annexure I.

5. Consent to Establish

Madhya Pradesh

Pollution Control Board

(MPPCB), Madhya

Pradesh State

Consent to Establish under section 25 of Water

(Prevention & Control of Pollution) Act, 1974 and

under section 21 of Air (Prevention & Control of

Pollution) Act 1981 was obtained from Madhya

Pradesh Pollution Control Board for RMC plant,

Crusher plant, etc have been obtained. Sample

copies are attached as Annexure II A & B.

6. Consent to Operate Madhya Pradesh

Pollution Control Board

(MPPCB), Madhya

Pradesh State

Consent to Operate under section 25/26 of the

Water (Prevention & Control of Pollution) Act,

1974 and under section 21 of Air (Prevention &

Control of Pollution) Act 1981 and amendments

thereof has been obtained from MPPCB

(Annexure III).

7. Quarry and Borrow

Area Permissions

District level

Environment Impact

Assessment Authority

(DEIAA), Dewas,

Madhya Pradesh

Prior Environmental Clearance has been taken

from DEIAA, Dewas for the quarry/borrow being

used for DBTPL sub-project. Sample copies of

environmental clearances taken by the contractor

are attached as Annexure IV and Annexure V.

8. Labour & Insurance

Licensing Officer,

Dewas, Government of

Madhya Pradesh

DBTPL has taken Labour License under the

Contract Labour (Regulation and Abolition) Act,

1970. The establishment has valid labour license

which is enclosed as Annexure VI. Insurance

policy for DBTPL is enclosed as Annexure VII.

The EPC contractor also has a valid labour license

and insurance.



15. IMPACT ASSESSMENT OF SUB-PROJECT

22. EIA study was not conducted for the sub-project as the project does not fall under the purview of

EIA Notification and subsequent amendments as explained in Section 11 of the EDDR.

23. As the bypass has already been constructed with two lanes, adequate land was acquired along with

original two-lane construction. The width of existing ROW is 60 m and length of the sub project is

19.800 km. Therefore, the impacts of the proposed project are limited because of the land acquisition

during two lane construction. The entire length of the project road runs through plain terrain and

passes across agricultural land and villages. The existing 2 lane pavement is rigid for the entire

stretch.

24. Description of Environment: The project road comprises a 19.8 km stretch on State Highway 18

commencing from Ujjain Dewas junction. It falls under the jurisdiction of Dewas District in the state

of Madhya Pradesh. The project area falls in the Malwa Plateau zone. The major soil group found in

the area is deep medium black soil. Soyabean, wheat and gram are the major crop of the area. The

rainfall in the district is approximately 1000 mm annually. The land use pattern in the sub-project

section is agricultural. The climate of the project area is characterized by hot dry summer, followed

by well distributed rainfall in monsoon and winter. There is no forest land involved in DBTPL. The

sub-project does not pass through any protected area. 1354 number of trees were coming in the

ROW of the project. No archaeological and historical monuments are located along the project road.

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

paragraphs below:

26. Impact on Land Environment: The sub-project involves strengthening and widening of the

existing two to four/six lane bypass. The sub-project involves widening/reconstruction of existing

road within available ROW without any substantial land acquisition, impact on the physiography of

the area is not significant. During construction phase the topography at sub-project location will

9. Tube-well Permissions Commissioner,

Municipal Corporation,

Dewas

The tube wells are located on revenue land, which

are being utilised by DBTPL. DBTPL has taken

permissions for tube wells for drawing water for

construction purpose sample copies are attached as

Annexure VIII.

10. NOC for setting up

camp

Village Panchayat DBTPL has taken NOC from village panchayat for

setting up of camp with RMC and Crusher plant

(Annexure IX).

11. License for Explosives Joint Chief Controller of

Explosives

Central Circle office,

Agra, Government of

India

DBTPL has taken license for explosive transport,

storage and use from the licensing authority - Joint

Chief Controller of Explosives Central Circle

office, Agra (Annexure X)



change due to excavation of borrow areas, cuts and fills for project road and construction of project

related structures. Risk of contamination of soil exists from construction material and oil spills. The

impacts are temporary and are manageable with mitigation measures which are given in Section 16.

27. Impact on Water Resources: The sub project is not crossing any perennial river. Water resources

may be impacted near the construction camp. This can be minimized by proper handling of material

and proper disposal of sewage and proper erosion control. During the operation stage the leakage or

spillage from damaged vehicles or badly maintained vehicles may lead to contamination of water

bodies. EMP has been proposed to manage these impacts.

28. Impact on Air Quality: The setting up of camp including ready mix concrete plant, hot mix plant,

and crusher plant. Up-gradation works at sub-project stretch shall involve generation of dust and

release of other pollutants leading to the localised degradation of air quality. All the belt conveyors

are to be covered with canopy to control the dust pollution. Ready mix concrete plant to be well

equipped with the cartage filters. All aggregate stock yards are provided with water sprinkling

system. Mitigation measures are in place to manage these temporary impacts.

29. Impact on Noise Environment: Impact on noise environment is envisaged during both construction

and operation phases. During construction phase, noise is generated due to use of heavy equipment

and processing facilities. Adequate distance from sensitive sites is to be kept for controlling noise

disturbances.

30. Impact on Biological Environment: No National Park or Wildlife Sanctuary is located within

close proximity of the project road and there is no notified animal corridor/migration route is present

in the project area. No Protected / Reserve Forest are located along the project road. About 1354 trees

falling in revenue land were coming in the ROW expansion. Permission for transplanting these trees

has been obtained from respective authority. All the trees have been transplanted in a scientific

manner in the proposed ROW. No significant impacts on other flora and fauna are anticipated at the

sub-project. Necessary mitigation measures have been recommended where

construction/maintenance is proposed.

16. ENVIRONMENTAL MANAGEMENT PLANS

31. The sub-project does not require EIA as a statutory requirement. The project is being developed on

the existing ROW as far as possible. The sub-project has been implementing various mitigation

measures to minimize risk to environment. A project specific Environment Management Plan (EMP)

has been formulated and proposed to the developer as part of due diligence which consists of a set of

mitigation measures; monitoring and institutional measures applicable to construction and operation

stages of the project. The EMP also defines roles and responsibilities of various parties.



32. The proposed EMP has been formulated on the on the basis of documents/information shared by

developer and site visit. The status of EMP implementation during construction phase is also given in

Table 3 on the basis of site visit observations. The EMP proposed for operation phase is given in

Table 4.

17. HEALTH AND SAFETY

33. DBTPL has deployed route patrolling vehicles, etc with requisite staff for incident management as

per Concession Agreement for maintenance of the project highway during construction and ensures

the project highway is in trafficable & motorable condition.

34. The Traffic Safety Arrangements during execution of works is being carried out by the Contractor

for safe movement of vehicles on the project highway. The Contractor has provided sufficient road

signs, temporary barriers, gunny bags filled with soil with reflective stickers etc. at the construction

sites.

35. DBTPL follows the safety guidelines and conducts safety training programmes for staff at site

including labour. The records for the same are maintained at the sub-project site. Sample copies of

toll box meetings, safety training programmes and on job safety awareness are attached as Annexure

XI, XII and XIII.

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

37. DBTPL has adequate institutional arrangement to look after HSE related aspects. The organizational

chart for HSE is given as Annexure XIV.

38. Safety Consultant has been appointed for the sub-project as per Article 18 of the Concession

Agreement. The consultant conducts road safety audit on periodic basis. Sample report is attached as

Annexure XV. DBTPL submits compliance report to the audit observations to the Safety Consultant

(Annexure XVI).



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

Impact/Issues EMP Responsibility Monitoring

indicators

Status of EMP Implementation

Impact on air environment due

to fugitive emissions and dust

generation due to construction

activities

All the vehicles deployed for

construction of the project will have to

keep “Pollution under Control” (PUC) certificates.

DG sets will also emit air pollutants in

the area during construction period. The

emission generated during construction

will be temporary and localized in

nature.

Vehicles carrying construction material

shall be covered to avoid spilling.

Paved approach roads to be maintained

Water sprinkling in dust prone areas

Personal protective equipment for

workers

RMC and Batching plants to possess

valid CTO

DBTPL Dust pollution

measurements/obser

vations or complaint

of locals

Compliance report

submission to

MPPCB

Approach roads in project area are

paved and water sprinkling is being

done at the sub-project to control

dust

Vehicles have restricted speed in

camp area

All vehicles used for DBTPL have

valid pollution control certificate

Workers are provided with PPEs

Camp site is located away from

settlements

Plants at camp are having CTO

from Madhya Pradesh Pollution

Control Board and compliance to

the conditions of PCB is being

submitted by DBTPL on regular

basis (Sample copy attached as

Annexure XVII).

RMC plant is equipped with dust

collector to control emissions

DBTPL has informed during site

visit that the MP PCB officials

regularly visit project site

Noise from construction

vehicles, machinery and

equipment

Construction equipment to be properly

maintained.

Noisy construction activity to be avoided

during night and close to sensitive

receptors

Traffic management and re-routing during

construction to avoid the accumulation of

noise

Honking restrictions on project vehicles

PPEs to be provided to workers

DBTPL; Contractor;

Sub contractor

Complaint from locals Equipment and vehicles are

properly maintained at site

Vehicles have restricted speed in

camp area

Workers are provided with PPEs

Training is provided to staff




indicators


Borrow Area Management Topsoil to be stockpiled and protected for

use

Borrow areas to be rehabilitated by

levelling or converted to pond in

consultation with the owner

DBTPL; Contractor Rehabilitation records To be done after project construction is

over

Contamination of soil / water Vehicles and equipment to be maintained

at project site

Fuel storage to be kept away from

drainage and on impervious surface

Waste oil to be stored appropriately and

disposed to authorized vendors

Water to be sourced from authorised /

permitted sources

DBTPL; Contractor Records of fuel and

waste oil to be

maintained

During site visit it is informed by

the developer that fuel is not stored

at camp site, as there if a fuelling

station opposite camp site and fuel

is taken from the fuelling station as

per requirement.

Waste oil to be sold to SPCB

authorised vendors as and when

required

Water is sourced from authorised

suppliers through tankers

Impact on water resources Storm water drains in the entire stretch

except service roads at DBTPL is

proposed

Runoff drainage provided at service roads,

flyovers etc.

Rain water harvesting pits are proposed at

culverts

DBTPL Records and

maintenance of

drainage and rain

water harvesting pits

Drainage system is under

construction

Rain water harvesting pits will be

constructed once the alignment is

complete

Avenue trees

1354 number of trees on revenue land

were coming in the ROW up gradation.

Permission was taken by DBTPL for

shifting all trees in the proposed ROW

All 1354 trees have been transplanted in a

scientific manner.

Avenue plants are proposed along the

project stretches as per IRC-SP-21:2011.

Approximately 5000 trees are planned to

be planted in avenue plantation, which

will begin in next monsoon.

DBTPL Records of trees

planted and

transplantation to

be maintained at

site

Survival records to

be maintained at

site

Tree transplantation permissions

were obtained

Videography of the tree shifting

activity was done by developer

Survival records are maintained at

site. In first six months the survival

record of implanted trees was about

90%.

Avenue plantation will begin from

the year 2020.




indicators


The avenue plants proposed to be planted

on either side of the road in two rows.

Median Plantation Median planation to be done as per IRC.

Approximately 667 plants will be planted every

km.

DBTPL Survival records to be

maintained at site

Median plantation has been done

on 50% of stretch.

Median plantation is being

maintained at site

Site for storage and

construction camp

Camp to be maintained at minimum

distance of 500 m from habitation

Emergency response plan will be in place

towards meeting unforeseen

emergencies.

Workers to be trained for handling

materials

DBTPL; Contractor Training records to be

maintained at site

Camp site is away from habitation

Storage is done at designated areas,

with markings and signboards.

Emergency response plan is in

place for DBTPL

Trainings are imparted to labour

and staff and records maintained at

site

Sewerage and solid waste

disposal

For sewage disposal, septic tanks with

soak pits will be provided at campsites.

Proper sanitation facilities at the camp to

be provided.

Salvage material/ demolition wastes will

be reused to the possible extent in

embankments, shoulders, slopes,

approach roads and temporary campsites

DBTPL; Contractor On site observation Septic tanks with soak pits are

provided at site.

Proper toilets are provided at camp.

Camp haul roads are maintained

with salvage material / demolition

wastes

There is no labour camp at site, the

labour are staying in rented

accommodation and commuting

from villages nearby

Traffic management & safety Secure traffic control during construction

Safety measures to be undertaken by

installing road signs and markings for

safe and smooth movement of traffic.

DBTPL; Contractor On site observations;

accident incident

records

Contractor has provided sufficient

road signs, temporary barriers,

gunny bags filled with soil with

reflective stickers etc. at the

construction sites

All traffic diversions are approved.

Diversion Plan is attached as




indicators


Annexure XVIII

Sufficient light arrangement has

been done at construction zone and

diverted areas

Marshalls are deployed 24 *6 at all

junctions for traffic management.

Concessionaire has deployed route

patrolling vehicles, etc with

requisite crew for incident

management as per Concession

Agreement for maintenance of the

project highway during

construction and ensures the

project highway is in trafficable &

motorable condition

Occupational Health and

Safety Labourers shall be equipped with

proper safety gears like helmets, gloves

and gum boots.

Training of workers to be ensured

Drinking water to be supplied to

workers

DBTPL; Contractor Training records to

be maintained at site All workers and labourers are

equipped with appropriate PPE’s

HSE induction trainings are

organized for labour and staff.

RO plant is installed at the camp

site for drinking water for staff

and workers

Table 4: Proposed EMP for Operation of DBTPL

Impact/Issues EMP Responsibility Monitoring indicators

Noise Multi layered plantation to serve as mitigation option

for operation phase

Effective traffic management and good road condition

shall be maintained to reduce the noise level

Speed limitation and honking restrictions may be

enforced near sensitive locations.

Create awareness in locals and drivers through

DBTPL On site observations

Records of safety week



Impact/Issues EMP Responsibility Monitoring indicators

programmes

Embankment protection Periodic maintenance of stabilizing measures at

embankments like turfing etc.

DBTPL On site checks & observations

Water logging Regular maintenance and cleaning of drains DBTPL On site checks & observations

Maintenance of Safety Traffic control measures to be enforced strictly

Monitor and ensure that all safety provisions included

in design and construction phase are properly

maintained

2 Highway patrol units for round the clock patrolling to

be available at site

One ambulance to be available at toll plaza

One tow-away facility for the break down vehicles

DBTPL Safety signage to be displayed and

maintained at site

Accident incident reports to be

maintained at site

Avenue / Median Plantation &

Maintenance Avenue plants are proposed along the project stretches as

per IRC-SP-21:2011. Approximately 5000 trees are

planned to be planted in avenue plantation, which will

begin in next monsoon.

The avenue plants proposed to be planted on either side of

the road in two rows.

Planted trees and shrubs in Avenue and Median

Plantation to be properly maintained

Tree survival list to be maintained for planation

effectiveness

DBTPL Records of trees planted and

transplantation to be maintained at

site

Survival records to be maintained

at site

Redressal of public grievances DBTPL shall maintain a complaint register at toll plaza

DBTPL shall define a mechanism to handle and manage

grievances raised by road users, project affected persons

and employees/workers including those of sub-

contractors.

DBTPL shall send copy of the register to Concessioning

Authority and Independent Engineer

DBTPL Complaint Record register



18. GRIEVANCE REDRESSAL MECHANISM

39. Developer has confirmed that they are maintaining a register at site for grievances. Record of

any grievance or demand received from locals is maintained at the site office.

40. Redressal of Public Grievances will be done during operation phase as per Article 46 of the

Concession Agreement. The Concessionaire has to maintain complaint register at the toll

plaza for recording public grievances. The complaint register will be shared with the

Concessioning Authority every 7 days for review.

41. The Grievance Redress Mechanism should outline mechanism to handle and manage

grievances raised by road users, project affected persons and employees/workers including

those of sub-contractors.

19. ENVIRONMENTAL SENSITIVITY

42. The environmental sensitivity of DBTPL has been assessed by reviewing various documents,

supplemented by field visit and consultation with the developer.

43. The environmental sensitivity assessment is given below:

The sub-project is being developed on the existing right of way. At certain places

(vehicle under pass, flyover and administrative block for toll plaza) additional land is

required. Developer has informed that this additional land requirement for toll plaza

building is 1.2 Ha, which is private land and acquisition is in process.

The sub-project sites are not located in any protected area like wildlife sanctuary /

national park or in close proximity of any eco-sensitive area.

During site visit and as per discussions with the sub-project staff, it was informed that

no wild animals are sighted in and around the sub-project area.

No forest area is getting affected due to the sub-project.

1354 trees were coming in the ROW, which are shifted to the proposed ROW.

As informed by the concessionaire, no important cultural or heritage sites are getting

affected due to the sub-project.

The sub-project has the necessary approvals and permits from regulatory authorities.

The impacts of the sub-project are temporary in nature and are manageable with

EMPs.



20. PROJECT AGAINST THE PROHIBITED INVESTMENT ACTIVITIES LIST

44. The sub - project does not involve any prohibited activity as per the Prohibited Investment

Activities List (PIAL) of ADB.

21. CATEGORIZATION OF SUB-PROJECT

45. The sub-project can be classified as Category B based upon ADB’s EA requirements as per their Safeguard Policy Statement (2009). This classification is based on the review of the

available documents and site visit with respect to the environmental sensitivity due to project

activities.

22. SITE VISIT OBSERVATIONS

46. A site visit was undertaken by IIFCL’s Environmental and Social Safeguard Specialists and

Social Safeguard Consultant on 15th October 2019. The site visit was undertaken to review the

implementation of the project’s environmental and social safeguards. During the site visit, following staff were mainly consulted regarding environmental safeguards related measures

implemented at the project site:

(a) Mr N Ramesh Narendra, Team Leader

(b) Mr T Subramanyam, Team Leader, IJM (India) Infrastructure Ltd.

(c) Mr Mahesh Chandra, Senior Vice President, IJM (India) Infrastructure Ltd.

(d) Mr Shekh Josaif Hussain, EHS Officer

47. The sub-project is under construction and more than 83% works are complete at the site. Based

on the discussions with above mentioned officials and visit, the site observations are given below:

The sub-project has obtained necessary clearances/permits from the State Pollution

Control Board and other regulatory organizations and is complying with the

reporting / monitoring requirements.

The sub-project is involves strengthening and widening of highway in the existing

ROW.

Tree shifting is complete at site. The trees are maintained and in the initial six

months survival of 90% was recorded. Avenue plantation will begin during

monsoon of 2020. Median plantation in about 50% of the stretch is complete and is

being maintained. Developer has been informed to keep a record of plantations and

survival rate.



Utility shifting at site is almost complete. 100% of land is available for highway

up-gradation.

The workers and staff at the site were seen wearing personal protective equipment

such as helmets, jackets, boots, gloves etc.

Regulatory signs, warning signs and direction signs were available at all relevant

places at site.

Traffic marshals could be seen at all junctions.

There is one camp site at the sub-project.

There is no labour camp at sub project. Developer has informed that most labour is

local and are commuting from nearby villages. The other workers are also housed

in rented accommodations. Good standards of health and hygiene were maintained

at camp. Dust bins were placed at different locations. Toilets were available at the

camp site for staff with continuous water supply. Good housekeeping was

maintained at the site.

Pantry is being run at the camp site.

All waste water being generated at the sub-project premises is disposed in septic

tanks/soak pits.

RO water purifier of large capacity is available at camp for drinking water purpose.

Adequate EHS staff was present at the site and understood their commitments.

On discussions with the site staff, it was observed that tool box talk, safety

induction trainings are done for labour as well as staff.

Vehicle movement in the administrative premises was very limited and control by

Security at entrance of camp.

No oil spillage was observed at the site. Developer has informed that they are not

storing fuel at the camp site as a fuelling station is available across the road and

fuel is procured as and when required.

Concrete demolition waste is kept at secured and identified location and is being

utilized for low laying area development and leveling purpose by local community.

The permits and NOCs required for the project are in place.

Fire extinguishers and first aid kits were available at camp site.

Emergency contact numbers have been displayed at appropriate locations.

Records of safety trainings, mock drills and various inspections/audits are

maintained at site office.



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

23. CONCLUSIONS AND RECOMMENDATIONS

49. It is concluded on the basis of review of the available information, reconnaissance site visit and

interaction with sub-project staff it can be concluded that the concessionaire DBTPL is

complying with the requirements as per the national and state guidelines and regulations. The

19.8 km road strengthening and widening project in the State of Madhya Pradesh is unlikely to

pose any adverse environmental risks given the nature of the activities.

50. There are no legally protected areas, cultural heritage sites and forest land located within and/or

in close proximity to the sub-project. However, the sub-project activities have reversible

environmental impacts which have been managed.

51. Based upon the available documents and site visit, it is concluded that the concessionaire has

undertaken adequate environmental safeguard measures. The conclusions for the sub-project are

given below:

The sub-project has been planned as per the National and State Government

requirement and not in anticipation to ADB operation.

The project site is not located in an ecologically sensitive area.

The sub-project is being developed in the existing ROW and some additional land

is being acquired for administrative block, flyovers etc. which is agriculture land.

The project does not involve diversion of forest land. However, approximately

1354 trees were coming in ROW which have been shifted to proposed ROW. The

concessionaire will be doing avenue and median plantation on the entire stretch.

The sub-project has the required national and local level permits and approvals for

project implementation.

Concessionaire has confirmed continuous compliance with the terms and conditions

stipulated while according statutory clearances /approvals /consents. Concessionaire

was implementing environment management measures at site and a structured EMP

has been proposed for the sub project. The EMP implementation will be monitored by

IIFCL.

The institutional arrangement available for the implementation of environment, health

& safety appears to be adequate.

The concessionaire is maintaining adequate safety at the site. The EMPs will

minimize any significant negative impact on environment.



During site visit and discussion with the project developer, the implementation of

management measures was found to be adequate.

After approval from the ADB the ESDDR will be uploaded on website for public

disclosure.

52. Based on the site visit and due diligence findings, it can be deduced that the sub-project has no

significant environmental safeguard issues. The sub-project, therefore, does not appear to

involve any kind of reputational risk to ADB funding on environmental safeguards.



DUE DILIGENCE ON SOCIAL SAFEGUARDS



24. PURPOSE OF THE SOCIAL SAFEGUARDS DUE DILIGENCE

53. The Social Safeguards Due Diligence Report (SSDDR) has been carried out by India

Infrastructure Finance Company Limited (IIFCL) in consultation with the Concessionaire, Dewas

Bypass Tollway Pvt. Ltd. (DBTPL) to assess the Social safeguards compliances of the project

with the applicable National Policies. The report has been prepared as per the

documents/information received from the concessionaire and subsequent to the site visit on 15th

October 2019. The information given in the SSDDR is agreed and confirmed by the

Concessionaire.

25. PROJECT AGAINST THE PROHIBITED INVESTMENT ACTIVITIES LIST

54. The sub project does not involve any prohibited activity as per the Prohibited Investment

Activities List (PIAL) of ADB.

26. OBJECTIVE OF SOCIAL SAFEGUARDS DUE DILIGENCE

55. Social Safeguards due diligence study is carried out to assess the social safeguards monitoring

compliance status of the project as per the applicable National policies/procedures as observed

during the site visit as well as the information received. The main objective of this Social

Safeguard Due Diligence Report (SSDDR) is:

To assess the likely social impacts and its minimization/mitigation majors adopted

for the project with respect to land acquisition, compensation , Indigenous people

affected, involuntary resettlement and common properties resources affected, if any,

in terms of displacement, loss of incomes, and community links:

To ascertain, in case of any adverse impact, if appropriate mitigation measures have

been taken during the project planning, designing and frameworks established for

carrying out safeguard measures during the construction stage to minimize and

mitigate such if any adverse impacts.

27. APPROACH AND METHODOLOGY

56. The Social safeguard due diligence study for Dewas Bypass Tollways Pvt Ltd (DBTPL) has been

carried out after reviewing the documents made available by the subproject developer. On site

visit to the project location by the Environment and Social Safeguards Specialist and Social

Consultant, discussion with the project developer and various permits and approvals relating to

the project to understand the salient features of the project and social concerns. The following



documents/Reports/Licenses/permits and notifications were referred in order to prepare the

Social Safeguard Due Diligence Report:

Project Information Memorandum (PIM);

Right of Way (RoW) handover letter

Concession Agreement

Lender’s Independent Engineer (LIE) Reports Independent Engineer Report

Labour License & insurance

28. SOCIAL IMPACT OF THE PROJECT

27.1 Land Acquisition in the Project

57. Land acquisition is not in the scope of the project developer and it is under the purview of

the Concessioning Authority, Madhya Pradesh Road Development Corporation (MPRDC).

Land acquisition for the project DBTPL for 4/6-laning of Dewas Bypass from Km. 0+000

(Ujjain-Dews Junction) to Km. 19+800 (Total Length 19.800) in the state of Madhya

Pradesh on Build, Operate and Transfer (BOT) basis has been completed by MPRDC.

During the discussion and subsequent to the mail received from the project developer it was

informed that the land acquisition including the present right of way was acquired by the

authority MPRDC in the year 2009.

58. As per provision of the Concession Agreement, 100% the Right of Way (RoW)

encumbrance free for 4/6 laning of Dewas Bypass to the extent of 60m has been handed over

to the Concessionaire by MPRDC. At the time of two laning of the project, the land was

acquired in the year 2009 and handed over in one phase to the project developer after

awarding the work in 2017. The RoW hand over letter is attached as Annexure XIX.

59. During the discussion it was told that the total land including the present right of way was

acquired at the time of two laning of project and the additional right of way for

accommodating the future widening of the existing road for 4/6 laning was kept on median.

As per the information provided by the project developer the purpose wise land for 4/6

laning of Dewas Bypass is given in Table 5:

Table 5: Status of Land available at DBTPL

Sl. No. Purpose Land in Hectare (Ha.)

1. Widening of the existing road for 4/6 laning 118.8

2. Realignment Nil

3. Toll Plaza & Truck lay bye 1.20

Total 120



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

ADB financing.

27.2 Impact on Structure

61. The sub-project stretch falls in Dewas district in the state of Madhya Pradesh. The entire section

of project road is passing through plain terrain. As informed by the concessionaire and noted

during the site visit, that no structure is getting affected due to the project.

27.3 Rehabilitation and Resettlement impact in the sub-project

62. During the site visit it was informed that there was no involuntary resettlement because of land

acquisition for the project. Further during the site visit it was observed that there was no

rehabilitation and resettlement in the project.

27.4 Impact on Indigenous people

63. As information provided by the concessionaire the project does not disturb indigenous people in

the project and does not have adverse impact or create any threat to the survival of any

indigenous community along the alignment, hence no indigenous people affected in this sub-

project.

29. GREIVANCE REDRESSAL MECHANISM FOR THE SUB-PROJECT

64. The Grievance Redressal Register is maintained at project site to ensure that any affected person’s grievances are adequately addressed and to facilitate timely project implementation. During the

site visit it was observed that the project authority has formed their own institutional

arrangements to deal with complaints on site resolve of the issues concerns.

30. EMPLOYMENT GENERATION

65. As informed by the concessionaire, the project land acquisition was completed during 2 to 4-

laning of project in the year 2009, so the project does not impact the livelihood of the local

people. It has been confirmed by the concessionaire that employment opportunities are being

provided to the local people for various unskilled and semi-skilled activities like security guards

and office assistants, drivers.

66. During the discussions it was informed that the employment opportunity is being given to more

than 70 local people belongs to the nearby areas during the project construction period. Further it

was also informed that during the operation of toll plaza as much as possible local people will be

given employment opportunity at toll plaza location.



31. THE COMMUNITY ENGAGEMENT ACTIVITIES

67. As information provided by the concessionaire, to reach the local people, DBTPL has under taken

few of community development activates to reach the local people during the construction stage

of the project. The subproject developer celebrated its road safety week, blood donation camp,

free medical check-up camp, health and hygiene awareness camps has also been under taken

under community development initiatives as per the demands made by the local community /

nearby village/Panchayats.

32. LABOUR LICENSE OBTAINED BY THE SUBPROJECT DEVELOPER

68. The Labour license has been granted to the subproject developer Dewas Bypass Tollway Pvt.

Ltd. (DBTPL) under Section 12 (1) of the Contract Labour (Regulation and Abolition), Act,

1970. The Labour Commissioner, Government of Madhya Pradesh, Dewas has issued the

license for construction of Dewas Bypass. As per the labour licenses the subproject developer

can employ as contract labour in the establishment shall not, on any day, exceed 300 Nos. The

labour license is attached as Annexure VI.

33. DISCLOSURE

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

IIFCL’s website.

34. SITE VISIT OBSERVATION

70. A site visit was undertaken by IIFCL’s Environment and Social Safeguard Specialists and Social

Safeguards Consultant on15th October, 2019. The site visit was undertaken to review the

implementation of the project’s environmental and social safeguards parameters at the project

site. . The sub-project at the time of site visit was in the stage of construction, and more than 83%

of construction activity was completed and the Concessionaire is hopeful to achieve the COD in

the month of December 2019.

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

The sub-project has been prepared by Madhya Pradesh Road Development Corporation

Ltd. (MPRDC) as per its own funding requirement and not anticipation to ADB

operation;

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



Land acquisition to the extent of 60m Right of Way (RoW) for 6-laning of this project

was completed during 2 laning of project in the year 2009.

There is no Rehabilitation and Resettlement in the project.

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

Construction workers are provided with ready access to on- or off-site health care check-

up facilities and are being provided with first aid facilities for minor injuries;

As informed during the site visit it was confirmed that no fatal accident happened in the

project till date.

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

During the site visit it was observed that, workers and staffs at the site were seen wearing

personal protective equipment such as helmets, jackets, boots, gloves etc.

As informed by the project developer, after discussions with the local people, the

affected cultural properties are being relocated by the concessionaire;

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

unskilled activities;

It seems that the sub-project does not appear to involve reputational risk to Asian

Development Bank funding on social safeguards and recommended for funding under

the proposed project.

Concessionaire has undertaken community development activities based on the demands

raised by the local people.

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

negative significant social safeguard issue.

Collector Court — District Dewas (M.P.)

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

■-■ ugust-2017

Case no. 09/v-69/2016-2017

:: Permission Letter::

Divisional Manger, Madhya Pradesh Road Development Corporation Limited

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

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

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

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

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

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

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

stated above permission for implantation of 1300 trees is given with the condition

that during implantation Madhya Pradesh Road Development Corporation Ujjain will

be totally responsible for life of trees (keep the trees alive).

As stated above during implantation Madhya Pradesh Road Development

Corporation Ujjain will be totally responsible to pay the claim amount for any kind of

life/animal loss.

Sd/-

Collector

Distrcit — Dewas (M.P.)

Pg. no./1530/Reader/2017 Dewas, dated 22-August-2017

cc to :-

Divisional manager, Madhya Pradesh Road Development Corporation Limited,

Ujjain for information and compliance.

((c11't-1,ittM 22-31 4 Ikcf-2017

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gra-P6-ft !;it Erm. , Trviii.-st

Consent Order Regional office

M.P. Pollt.ition Control Board

Devoe::

Tole 07272251170

CTE-Fresh

VALID UP TO: CTE

CONSENT NO: **"

GREEN-SMALL

PCB ID: 111548

NO: /MPPCB/DEW

M/s. I,—( Ind ,e) Infrastructure Ltd,

Survey No. 384/2/2,403/2/2,405/2/2,384/4/4,405/3,384/2/3 & 403/2/1, Shankarghad,

De., Dist : Dewas,

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

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

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

in any way, this is to inform you that this Board grants Consent to Establish for setting up of an industrial plant/activities at

• nkarghad, Dewas, Phone No. 7702200185

SUBJECT TO THE FOLLOWING CONDITIONS

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

b. The capital investment in lakhs: Rs. 90

c. Product & Production Capacity:

Product

CTE Qty/y

RMC Plant

238200Mater cube/year

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

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

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

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

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

Enclosures:-

* C

•

onditions under Water Act

* C

•

onditions under Air Act

* G

•

eneral conditions

e seelthaftom LIDALR ANNEX , NEAR BIMA NAGAR , VIJAY NAGAR , INDORE - 452010 , MADHYA PRADESH SS g MILIT Regional Officer

e-Signed On 31/05/2017 16:39:15 (Organic Authentication on AADHAR from UIDAI Server)

PvitaNy Sign with Aulhatar TPAV # U2DM7D1J6D

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

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

Consent Order

To'.: 07272251170

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

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

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

2. Trade Effluent Treatment: -

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

maintain the same properly to achieve following standards -

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

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

BOD 3 Deye 270C Not exceed 30

COD Not exceed 250

10

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

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

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

,—

1.1M11.11111111111 )! WC : 68.000 VVWG : 1.000 1 Domestic Purpose 2. 000 1.000

Waite: Source .1

Borew.,,

Borewo,

2 Mnrg Process 66.000 0.000

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

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

be discharged outside of industry/unit premises.

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

for category wise consumption of water as per Water (Prevention and Control of Pollution) Cass Act 1977 For Industrial

cooling/boiler feed, mine spray, process & domestic purposes and data shall be submitted online through XGN monthly

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

monthly patrak/statements.

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

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

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

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

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

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

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

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

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

above conditions.

10. Compilation of Monitoring '

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

volume and nature of monitored discharge.

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

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

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

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


a -Sigrieb (Physical Signature NOT reguires) Page: 2 /5 111 I

0H Between 5.5 — 9.0

Suspended SOl,ds Not exceed 100

BOD 3 D., 27° C N. exceed 100 moll.

COD Not exceed 250 rng/i

Oe end grease Not exceed 10 rag/.

•


Dewey

Tc,le : 07272251170

,.../#'4•000"%esior -esso"ftssiegoft...... -.6110keisolfiis.r

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

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

through XGN the same to the Board.

11. Recording of Monitoring -

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

Consent.

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

followS:

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

(II) The dates on which analysis were performed

(iii)Who performed the analysis?

(iv)The analytical techniques or methods used and

(v)The result of all required analysis

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

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

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

iv. The applicant shall retain for a minimum of 3 years all records of monitoring activities including all records of

Calibration and maintenance of instrumentation and original strip chart regarding continuous monitoring instrumentation.

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

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

12. Reporting of Monitoring Results: -

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

report on line to the Board.

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

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

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

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

14. Limitation of visible floating solids and foam:

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

15. Disposal of Collected Sol id -

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

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

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

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

16. Provision for Electric Power Failure -

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

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

conditions of the Consent.

17. Prohibition of By pass system -

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

and conditions of this Consent in prohibited except

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

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

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

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

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

consent conditions.

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

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

Consent Order RCIf_110 fl a I office

M.P. Pollution /

Regional

ootrol BoOrc.1

Dewar

T010 07272251170

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

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

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

achieve the level or pollutants to the following Standards: -

2 . Ambient air quality at the boundary of the industry/unit premises shall be monitored and reported to the Board regularly

on quarterly basis: The Ambient air quality norms are prescribed in M0EF gazette notification no. GSR/826(E). dated: 16/11/09. Some of the parameters are as follows:

a. Particulate Matter (less than 10 micron) - 100 pg/m3 (PM10 pg/m3 24 hrs. basis)

b. Particulate Matter (less than 2.5 micron) - 60 p0/0,3 (PM2.5 pg/r03 24 hrs. basis)

c. Sulphur Dioxide [S02] (24 hrs. Basis) - 80 ps/0,3

0. Nitrogen Oxides [Na<] (24 hrs. Basis) - 80 Ng/m3

e. Carbon Monoxide [CO] (8 hrs. Basis) 2000 pg/m3

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

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

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

erniSSion/section/activities.

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

made airtight to avoid the public nuisance.

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

process within premises

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

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

etc..

Additional Air condition:-

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

Improvement of environmental conditions.

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

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

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


4 / 5 III I II

Consent Order ReglonAl orrice

M.P. Pollution Control Board

Dowas

Tele : 07272251170

■••■•■•04AMMIN.INOVIII

•■••••—•Norall"-•%.,e ■4111110111.werar....

"414.1gir-

GENERAL CONDITIONS:

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

upon the representation of credentials:

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

Board.

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

be Kept under the terms and conditions of this Consent.

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

Consent.

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

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

3. This consent/authorisation is transferable, in case of change of ownership/management and addresses of new

Owner/partner/Directors/proprietor should Immediately apply For the same.

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

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

'egulatiOn5.

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

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

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

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

every month

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

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

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

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

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

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

date of expiration of this consent/authorisation

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

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

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

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

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

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

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

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

necessary action will be initiated against the industry.

srtimfroaklili dl.R ANNEX , NEAR BIMA NAGAR , VUAY NAGAR , INDORE - 452010 , MADHYA PRADESH i S

WSW ( PRegionarbfficet) e-Signed On 31/05/2017 16:39:15

(Organic Authentication on AADHAR from UIDAI Server) Dlitaivr.i Sign w4h AChiktaf TPAV # U2DM7D1J6D


Signed (Physical Signature NOT 5 / 5 ill I ■

O


NI.P. Pollution Control Board

Dewas

Tele : 07272-251170

GREEN-SMALL

CCA-Renewal Validity (A/W) 31/5/2020

CONSENT NO: ***

PCB ID: 1115481

)" &ik-ttn)5/2 )19

Consent No:AW-65109

To, The Occupier,

M/s. Ijm(India) Infrastructure Ltd,

Survey No.384/2/2,403/2/2,405/2/2,384/4/4,405/3,384/2/3 & 403/2/1, Shankarghad, Tehsil & District Dewas (M.P.)

Subject: Renewal of Consent under section 25 of the Water (Prevention & Control of Pollution) Act,I 974 under section 21 of the Air (Prevention & Control of Pollution) Act,1981

Ref: Your renewal of Consent Application Receipt No. 823746 Dt. 27/04/2019

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

SUBJECT TO THE FOLLOWING CONDITIONS :-

a. Location: Survey No.384/2/2,403/2/2,405/2/2,384/4/4,405/3,384/2/3 & 403/2/1, Shankarghad, Tehsil & District Dewas.

b. The capital investment in lakhs: Rs. 90

c. Product & Production Capacity:

S.No. Products Qty/y

1. RMC Plant 238200Meter cube/year (Two lakh thirty eight thousand two hundred meter cube per year)

Note:- For any change in above industry Mall obtain _fresh consent from the hoard .

The Validity of the consent is up to 31/05/2020 and has to be renewed before expiry of consent validity. Online application

through XGN with annual license fees inthisregard shall be submitted to this office 6 months before expiry of the consent/Authorization. Board reserves the right to amend/cancel / revoke the above condition in part or whole as and when required.

Enclosures:-

* Conditions under Water Act * Conditions under Air Act

* General conditions

e cue LEW

90 MTN'

D.O.Pro, for. we V* ...Law..

e-Signed On 09/05/2019 17:28:28 (Organic Authentication on AADHAR from UIDAI Server) TPAV # 947786ENF4

ALOK KUMAR JAIN

Regional Officer

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

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