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Environmental and Social Due Diligence Report

Project Number: 47083-004 December 2019

INDIA: Accelerating Infrastructure Investment

Facility in India – Tranche 3 Freedom Point Expressways 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 Freedom Point Expressways Private Limited

ESDDR NO. IIFCL/ESMU/ADB/2019/118/V2 1

Due Diligence Report on Environment and Social Safeguards

By

India Infrastructure Finance Company Limited (IIFCL)

(A Govt. of India Enterprise)

FOUR LANING (WITH PAVED SHOULDERS) OF MEERUT- BULANDSHAHR

SECTION OF NH 235 (NEW NH-334) FROM KM.8.800 TO KM. 66.482 (APPROX 61.19

KM) IN THE STATE OF UTTAR PRADESH ON DBFOT (HYBRID ANNUITY) BASIS.

November 2019



SUB PROJECT: FOUR LANING (WITH PAVED SHOULDERS) OF MEERUT-

BULANDSHAHR SECTION OF NH 235 (NEW NH-334) FROM KM.8.800 TO KM. 66.482

(APPROX 61.19 KM) IN THE STATE OF UTTAR PRADESH ON DBFOT (HYBRID ANNUITY)

BASIS.

Freedom Point Expressways Private Limited (FPEPL)

Environment and Social Safeguards Due Diligence Report

(ESDDR)

Prepared by Mr. Amit Jain

Environment Consultant

Dr. Rashmi Kadian

Assistant General Manager

(Environmental Specialist)

ESMU, IIFCL

Mr. Krupasindhu Guru

Assistant General Manager

(Social Specialist)

ESMU, IIFCL

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

FIGURE 1: PROJECT LOCATION ON MAP .......................................................................................... 7

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

6. EPC CONTRACTORS ...................................................................................................... 9

7. INDEPENDENT ENGINEER ............................................................................................ 9

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 FPEPL TO THE ESSF OF IIFCL: .................................................... 12

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

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

16. IMPLEMENTATION OF ENVIRONMENTAL MANAGEMENT PLANS ....................... 16

17. HEALTH AND SAFETY ................................................................................................. 21

18. GRIEVANCE REDRESSAL MECHANISM .................................................................... 21

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

20. PROJECT AGAINST THE PROHIBITED INVESTMENT ACTIVITIES LIST ............... 22

21. CATEGORIZATION OF SUB-PROJECT ....................................................................... 22

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

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

DUE DILIGENCE ON SOCIAL SAFEGUARDS ....................................................................... 28

24. PURPOSE OF THE SOCIAL SAFEGUARDS DUE DILIGENCE .................................... 29

25. PROJECT AGAINST THE PROHIBITED INVESTMENT ACTIVITIES LIST ............... 29

26. OBJECTIVE OF SOCIAL SAFEGUARDS DUE DILIGENCE ......................................... 29

27. APPROACH AND METHODOLOGY ............................................................................. 29

28. SOCIAL IMPACT OF THE PROJECT ........................................................................... 30

28.1 LAND ACQUISITION IN THE PROJECT ...................................................................... 30

28.2 IMPACT ON COMMON PROPERTIES ......................................................................... 30

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

28.4 IMPACT ON INDIGENOUS PEOPLE ............................................................................ 31

29. GREIVANCE REDRESSAL MECHANISM FOR THE SUB-PROJECT .......................... 31

30. EMPLOYMENT GENERATION .................................................................................... 31

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

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

33. DISCLOSURE ................................................................................................................ 32

34. SITE VISIT OBSERVATION .......................................................................................... 32

LIST OF FIGURES

Figure 1: Project Location on Map………..……..……………………………………………………7



LIST OF TABLES

Table 1: Salient Features of Freedom Point Expressway Private Limited……………………………8

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

Table 3: Status of EMP Implementation at FPEPL……………………………………………………..16

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

ANNEXURES

Annexure 1 Environmental Clearance

Annexure 2 Environmental Management Plan

Annexure 3 Forest Clearance

Annexure 4 Trees Cutting Permissions and lists

Annexure 5 Consent to Establish RMC Plant from UPPCB

Annexure 6 Letter for Ordinary Earth Procurement

Annexure 7 Permission from HPCB for stone dust

Annexure 8 Labour License

Annexure 9 Labour Insurance

Annexure 10 Permission from Village Panchayat for setting up of camp and borewell

Annexure 11 Environment Analysis report

Annexure 12 Typical Plan for Avenue Plantation

Annexure 13 Details of Median Plantation

Annexure 14 HSD Clearance

Annexure 15 Training Records and Evaluation

Annexure 16 Safety & health Management Plan and Traffic Management Plan



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,

Freedom Point Expressway Private Limited (FPEPL) 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 (With Paved Shoulders) of Meerut- Bulandshahr Section

of NH 235 (New NH-334) from km.8.800 to km. 66.482 (approx 61.19 km) in the State of Uttar

Pradesh on DBFOT (Hybrid Annuity) Basis.

3. SUB-PROJECT BACKGROUND

3. National Highways Authority of India (NHAI) has awarded road stretch project comprising

development of the existing two lane road into four lane with paved shoulder of Meerut-

Bulandshahr section of NH 235 (New NH 334) from Km 8.800 to Km 66.482 (Approx 61.19

Km) in the state of Uttar Pradesh on DBFOT (hybrid annuity) basis for a Concession Period of

17.5 Years which includes construction period of 910 days i.e. 2.5 Years and Operation Period

of 15 Years to M/s Freedom Point Expressways Private Limited as concessionaire. The project

is awarded to M/s APCO Infratech Private Limited (APCO) on the basis of lowest amount of

Bid Project Cost i.e. Rs 868.77 Crores & O&M Cost of Rs 5.76 Crores per year quoted by them

among all the shortlisted bidders for the aforesaid project.

4. M/s Freedom Point Expressways Private Limited is a newly incorporated SPV of M/s APCO

Infratech Private Limited for undertaking the task of four laning (with paved shoulders) of

Meerut- Bulandshahr Section of NH 235 (New NH-334) from Km.8.800 to Km. 66.482

(Approx 61.19 Km) in the state of Uttar Pradesh on DBFOT (hybrid annuity) basis and to do all

necessary and incidental activities in this regard.

5. FPEPL had entered into a Concession Agreement (CA) with the Authority (NHAI) on 4th

March, 2016 for construction, operation and maintenance of the Project. The CA sets out the

scope, rights and obligations of all the parties, overall framework for the development, operation

and maintenance of the Project. The SPV is promoted by M/s Apco Infratech Private Limited.



4. SUB-PROJECT LOCATION & DESCRIPTION

6. The site of the four-lane project highway comprises the section of National Highway-235 (New

NH-334) commencing KM 8+800 to KM 66+482 excluding 3.522 km of existing Bypass of

NH-24 (i.e. the Meerut-Bulandshahr section having total length of 64.712 km including 3.522

km of existing Hapur Bypass of NH-24 in the State of Uttar Pradesh, India. The total design

length of the project road is about 61.19 kms. The alignment of the project is shown in Figure 1

below.

Figure 1: Project Location on Map

7. The alignment will pass through settlements of Meerut, Kharkhauda, Hapur, Gulaothi and

Bulandshahr. Additional land shall be acquired for toll plazas, interchanges, rest areas and truck

parking. The sub-project will provide the widening and strengthening of existing 2 lanes Section

of NH-235 and its Operation and Maintenance (O & M). The paved carriageway shall be 18

meters wide excluding the median. However, the width of carriageway shall be 19 m in the

built-up stretches at Mitthepur and Jainpur. Further width of carriageway at the locations of

Grade Separated Structures and its approaches Vehicular Underpasses and Cattle/Pedestrian

Underpasses and its approaches) shall be 6-lane Divided Highway. The total length of all



bypasses is 29.450 km including 3.522 km of existing Hapur bypass of NH-24 to be used as a

part of this project.

8. The Concessionaire shall widen all the existing culverts so that they are equal to the roadway

width of the approaches in accordance with the provisions of the Manual. Total fifty nine

culverts, 34 of which are structurally distressed or not having sufficient vent/size shall be

reconstructed in accordance with the provisions of the manual and 25 New Culverts have to be

constructed. ROB is proposed at Hapur bypass.

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

Table 1: Salient Features of Freedom Point Expressway Private Limited

Particulars Features

Project Road NH -235 Section from Meerut (km 8.800 ) to

Bulandshahr (km 61.19) New NH-334

State Uttar Pradesh

Concessioning Authority National Highways Authority of India (NHAI)

Concessionaire M/s Freedom Point Expressways Private Limited

(FPEPL)

Length 61.19 km

Service Road on both Sides 4.220 km each side

Major Bridge 1 New and Repair of 1 existing

Minor Bridge 6 New and Repair of 6 existing

ROB 1

Flyovers Nil

VUP 3 New and Repair of 1 existing

Pedestrian/Cattle Underpass Repair of 3 existing

Culverts 25 New and Repair/widening of 34 existing

Track lay-byes 1

Bus Bays & Bus Shelters 8

Toll Plaza 1

By-passes 4

5. CONCESSIONAIRE

10. NHAI has appointed M/s. Freedom Point Expressways Private Limited (FPEPL) as the

concessionaire for this sub-project. FPEPL is a Special Purpose Vehicle (SPV) company

promoted by M/S Apco Infratech Private Limited. FPEPL has entered CA with NHAI on 4th

March, 2016.



6. EPC CONTRACTORS

11. Apco Infratech Private Limited is the turnkey EPC and O&M contractor for the sub-project.

7. INDEPENDENT ENGINEER

12. The contract agreement between NHAI and M/s SAI Consulting Engineers Pvt. Ltd. has been

signed to monitor the sub-project as Independent Engineer (IE).

8. IIFCL FUNDING

13. The total project cost of FPEPL is Rs. 868.77 crores. The project is financed by IIFCL under

Direct Finance Scheme. IIFCL has sanctioned an amount of Rs 155 crores to FPEPL and an

amount of Rs 136.87 has been disbursed till 15.11.2019.

9. STATUS OF PROJECT IMPLEMENTATION

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

which was earlier 25th October 2019 which is now expected to be January 2020. As per IE

report of September 2019, 75.99% of physical progress has been achieved at FPEPL. At the

time of site visit during 31st October 2019, FPEPL staff has informed that 78% physical

progress has been achieved till October 2019.



DUE DILIGENCE ON ENVIRONMENTAL SAFEGUARDS



10. ENVIRONMENT SAFEGUARDS COMPLIANCE REVIEW

15. 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 to the Environmental

Management Plans (EMPs), institutional arrangements for implementation and monitoring of

environmental mitigation measures, EMP planned for operation phase, environment, health &

safety (EHS) related clauses in agreements, health and work safety measures, status of

plantations, safety and emergency preparedness plan. The EDD also reviews the environment &

social management system of the sub-project developer.

11. APPLICABILITY OF ENVIRONMENTAL IMPACT ASSESSMENT NOTIFICATION

16. 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.

17. 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 preview of the Environmental Impact Assessment Notification, 2006 of

Government of India. The total length of the sub-projects is approximately 61.19 Kms,

therefore, FPEPL does not require environmental clearance and is not required to conduct an

Environmental and Social Impact Assessment (ESIA) as a statutory requirement. However,

NHAI had earlier prepared (ESIA) and received environmental clearance from Ministry of

Environment & Forest (IA-III Division), Government of India as per letter F.No.10-24/2011-IA-

III dated 2nd January, 2013. A detailed Environmental Management Plan (EMP) is prepared for

the sub-project, based on the impacts envisaged by the sub-projects and the EMP is being

implemented at the sub-project.

12. APPROACH TO THE ENVIRONMENT SAFEGUARDS DUE DILIGENCE REPORT:

18. 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; EMP implementation; Health,

Safety and Environment (HSE) measures; and categorization of sub-project on the basis of

above review.

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

Diligence Report:

Project Information Memorandum (PIM)

Concession Agreement



Environment Management Plan (EMP) and its implementation

Feasibility Study of FPEPL

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

Project Statutory Approvals/Permits

Project HSE Documents

Labour License & insurance

Contract Documents

Grievance Redressal Mechanism

20. 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.

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

the impacts of the FPEPL 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. The status of EMP implementation is given in Section 16 of the ESDDR.

13. COMPLIANCE OF FPEPL TO THE ESSF OF IIFCL:

22. 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.

23. The environmental due diligence for FPEPL 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. FPEPL is under construction and following

the national regulations and guidelines. There does not seem to be any significant risk for either

IIFCL or DFI involved. The status of environmental measures being implemented at the sub

project is given in Table 3 and EMP for operational phase of sub-project is given in Table 4. It

can be concluded that FPEPL 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:

24. Though FPEPL does not fall under the schedule of EIA Notification, 2006 that lists projects or

activities requiring prior environmental clearance, the project has received environmental

clearance from MOEF&CC, Government of India. FPEPL 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

FPEPL 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 (~61.19 Kms), this is exempted

from obtaining environmental clearance (EC)

and conducting EIA. However, NHAI has

received EC (Annexure 1) and the EMP which

was prepared for FPEPL is being implemented

at the sub-project (Annexure 2). The status of

EMP is reported in the subsequent sections of

the ESDDR.

2. Forest Clearance MoEF&CC and State

Forest Department

The project involves 92.630 ha of protected

forest land in favour of NHAI for widening of

NH-235 Meerut-Bulandshahr Road (24.038 ha

in Meerut from km 7.469 to km 23.00, 29.657

ha in Ghaziabad from km 34.20 to km 44.750

and 38.935 ha in Bulandshahr from km 50.5 to

km 66.523 in the state of Uttar Pradesh. In

principle approval of the diversion of forest land

by Ministry of Environment and Forest (FC

Division), GoI, was given vide letter No. F.No.

8-43/2012-FC dated 5th December 2012.

Subsequently, working permissions were given

by “Samajik Vaniki Division” of Meerut, Hapur & Bulandshahr vide: letter no. 1196/14-1 dated

11th September 2015, No 898/14-1 Bulandshahr

dated 11th September 2015. Copies of these are

given in Annexure 3.

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 cutting

permissions

State Forest

Department, Uttar

Pradesh

Sub-project involves cutting of about 7322 trees

during highway expansion. Tree cutting

permissions have been taken from three district

forest authorities viz., Meerut, Bulandshahr and

Hapur; The list of tree cutting and valuation is




attached in Annexure 4.

5. Consent to Establish Uttar Pradesh Pollution

Control Board

(UPPCB), Uttar

Pradesh State

A Sample of 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 for RMC Plant from Uttar Pradesh

Pollution Control Board on 14.10.17 &

27.12.2017 (Annexure 5).

6. Consent to Operate Uttar Pradesh Pollution

Control Board

(UPPCB), Uttar

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 and Authorization under Rule 6 of the

Hazardous and other Wastes (Management and

Transboundary Movement) Rules, 2016 has

been taken by FPEPL.

7. Borrow Area

Permissions

District Administration

of Meerut, Hapur,

Bulandshahr,

Government of Uttar

Pradesh

FPEPL has obtained permissions for borrow

areas and the borrow area locations were

approved in compliance with MoEF&CC letter

D.O. No. 22-346/2026-1A-111 dated 28th

October, 2016 to NHAI followed by letters from

UP Government dated 23rd

May 2017 and

NHAI’s letter to District Magistrates (Meerut, Hapur and Bulandshahr) dated 26

th May 2017

and district magistrate orders (Meerut, Hapur

and Bulandshahr) dated 18th November 2017

granting permission to allow borrow area

activity while classifying this activity coming

under public good (Janhit). The sample copies

of these permissions are given in Annexure 6.

LIE report (September 2019) mentioned that

crushers will not be operated or installed by

concessionaire. Hence, permissions from state

government for extraction of boulders from

quarry are not required. This was further

confirmed from the concessionaire during site

visit on 31st October 2019. The concessionaire is

sourcing stone dust from the third party based in

Yamuna Nagar, Haryana. The sample of

permission received by the third part based in

Yamuna Nagar, Haryana from Haryana

Pollution Control Board is attached as

Annexure 7.




8. Labour License &

Insurance

Office of the Deputy

Chief Labour

Commissioner(central),

Dehradun (UK) under

Ministry of Labour &

Employment,

Government of India.

FPEPL has taken Labour License under the

Contract Labour (Regulation and Abolition)

Act, 1970 (Annexure 8). The establishment has

valid labour insurance which is enclosed as

Annexure 9.

9. Permission of

setting up of Camp

& borewell

Village Panchayat FPEPL has taken permission from two Village

Panchayats for establishment of two Camps and

Borewells. Sample copy of the permission is

attached as Annexure 10.

15. IMPACT ASSESSMENT OF SUB-PROJECT

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 lanes to four lane highway. During construction phase, the topography at sub-

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

and construction of project related structures. 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. As per the

design no partial / complete loss of water body will take place. Hence no loss in volumetric

capacity of water resources is envisaged. Adverse impact on surface and ground water resources

is envisaged during construction phase due to increased sedimentation load because of

construction activities, waste water discharge from labour camps, fuel/oil from construction

vehicles etc. During the operation stage the leakage or spillage from vehicles damaged,

overturned or just badly maintained may also lead to contamination of water bodies. EMP has

been proposed to manage these impacts.

28. Impact on Air Quality: The setting up of camps and 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 covered with canopy to control the dust

pollution, ready mix concrete plant is well equipped with the cartage filters. All aggregate stock

yards are provided with water sprinkling system. Mitigation measures are in place to manage

these not very significant and temporary impacts.

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

construction and operation phases. The baseline noise levels are below the prescribed limits. In



construction phase, all DG Sets having acoustic attachments to control noise at source. FPEPL

has proactive plant and machinery maintenance schedule to control noise and air pollution.

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 Reserve Forest are located along the project road. About 7322

trees are likely to be affected in up gradation of NH-235 for which permissions from the Forest

Department have been obtained. No significant impacts on fauna are anticipated at the sub-

project. The repair and up gradation of minor bridges will cause some contamination of the

canal water due to spillage of construction material, sediment loading & increased turbidity

downstream of the bridge location. This may impact aquatic flora and fauna temporarily.

Necessary mitigation measures have been recommended at locations of structure where

construction/maintenance is proposed.

16. IMPLEMENTATION OF ENVIRONMENTAL MANAGEMENT PLANS

31. The status of EMP implementation is elaborated in the subsequent paragraphs on the basis of

information received from the developer and on confirmation of the same by site visit. EMP is

being implemented at FPEPL and the status of implementation is being maintained at site and

communicated to FPEPL corporate level. A sample of the environmental parameter testing &

reporting is given in Annexure 11. The EMP implementation status on the basis of

documents/information shared by developer and confirmations at the time of site visit is given

in Table 3. It may be noted that 78% of the construction has already been completed. Therefore,

this EMP is applicable only for the remaining construction work. EMP for the operational phase

of the project will be implemented as per Table 4.

Table 3: Status of EMP Implementation at FPEPL

Issues EMP Status of EMP Implementation

Avenue tree cutting

and

Plantation

A total of 7322 number of trees

have been cut for the sub-

project with permissions.

Avenue plants is proposed

along the project stretches are as

per IRC-SP-21:2011.

Tree felling permissions have been obtained from

Forest department. Sub-project developer has

informed that Avenue plantation has started during

monsoon after September 2019 (Annexure 12).

Median Planation Median planation to be done as

per IRC.

Median plantation has begun after September

2019. Typical plan for median plantation is

attached as Annexure 13.

Borrow pits and

Quarry sites

Borrow areas shall be 15 m

away from the water bodies

identified along the project

corridor.

Developer has confirmed that permissions are

being obtained from respective departments for

extraction from borrow areas as and when

required.



All the conditions of location are being met at all

borrow areas. Resurfacing and landscaping of the

borrow pits utilized in the project will not be

needed as the borrow earth is removed from either

hill or ponds as classified activity under public

good (Janhit).

Site for storage and

construction camp

Storage of HSD, as per the

stipulated guidelines.

Besides these, emergency

response plan will be in

place towards meeting

unforeseen emergencies.

Trained personnel will be

handling such materials

and care will be taken so

that spills are abated and

in case of spills,

immediately they are

contained.

Storage is done at designated areas, with

markings and signboards as per approval

(Annexure 14)

Trainings are imparted to labour and staff and

forms part of the HSE performance indicators

(Annexure 15).

Sewerage and solid

waste disposal.

For sewerage disposal,

septic tanks with soak pits

will be provided at

campsites. Proper

sanitation facilities at the

construction workers

camp to be provided.

Salvage material/

demolition wastes will be

reused to the possible

extent in embankments,

shoulders, slopes,

approach roads and

temporary campsites.

Septic tanks with soak pits are provided at

site. Proper toilets and bathrooms are

provided at site.

Camp haul roads and borrow area haul roads

are maintained with salvage material /

demolition wastes.

Proper solid waste management with

different colour dust bins is being done at the

camp site. Waste disposal from camp site is

being done in association with respective

Municipal departments.

Traffic

management Secure assistance from

local police for traffic

control during

construction

Safety measures to be

undertaken by installing

road signs and markings

for safe and smooth

Secure assistance was provided from local

Police Department for traffic control at

construction zones.

Road signs, solar blinkers and barricades for

construction zone as per IRC standards.

All traffic diversions are approved from IE

and Local Traffic Police.

Sufficient light arrangement has been done at



movement of traffic. construction zone and diverted areas.

Noise level Stationary equipment

shall be placed as far as

possible from residential

areas to minimize noise

impacts on the near

inhabitants.

Construction activities

will be strictly prohibited

between 10.00 PM to

6.00 AM near habitation.

Provision of ear plugs to

workers exposed to high

noise levels in the project

who work in batch mix

plants, quarries etc.

This is ensured at site.

Site work timings are 8 AM to 8 PM.

Workers are provided with personal

protective equipment (PPE).

Noise monitoring is being done and results

are found to be within prescribed limits of

Pollution Control Board (Annexure 11).

Air Quality Trucks will carry

construction material for

which emission of air

pollutants will increase.

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.

Mixing equipment shall

be sealed and equipped

with dust removal

device.

Water will be sprinkled

in morning and evening

hours at the construction

yards and the unpaved

sections of the road.

PUC certificate is checked for all

construction vehicles.

Vehicles are covered to avoid spilling of

construction material.

Mixing equipment is sealed to control dust.

Water sprinkling is done at site to control

dust.

Maintenance schedule is in place to control

further environmental damage in case of

break-down

All belt conveyors are covered with canopy

to control the dust pollution

Air Quality is being monitored at site and

results are found to be within prescribed

limits of Pollution Control Board

(Annexure 11).

Water Quality Water to be sourced from

valid sources

Borewell permissions have been taken at

all sites by the sub-project developer.



During construction it

will be ensured that

contractor does not

dispose off debris in

water bodies.

The majority of the

project stretch is plane &

horizontal land which

will act as water logging

areas during the rainy

seasons and may cause

the breeding of the

vectors in the area.

Uncontrolled digging of

approved Borrow pits in

the areas will be avoided

to prevent water

accumulation which

results in breeding of

disease causing vectors

in the area.

All debris and other unsuitable material are

being reused in haul road making purpose.

The entire project stretch was almost

covered by adequate drainage network

which allows free water flow without

obstructions.

No uncontrolled digging was allowed in

borrow areas.

Water Quality is being monitored at site

and results are found to be within

prescribed limits of Pollution Control

Board (Annexure 11).

Occupational

Health and Safety Labourers shall be

equipped with proper

safety gears like helmets,

gloves and gum boots.

Periodic health check-up

of construction workers.

Training of workers to be

ensured

All workers and labourers are equipped

with all PPE’s like helmets, gloves and gum boots.

Periodical health check-up is being

conducted as per prescribed schedule of

health check-up calendar.

HSE induction trainings are organized for

labour and staff as per plan (Annexure 16).

Prevention of

erosion

and scouring

Stabilizing the embankment

with appropriate technique

immediately after placing.

Embankment work is in progress

Drainage system Adequate care to be

taken for the purpose of

free flow of flood

discharge in the design

stage itself.

There are 2 major and 12

minor bridges which are

to be

constructed/strengthened

along the project corridor

to allow free flow of the

natural drainage water in

the area.

Highway Construction works is in progress

Construction of toe drain along the road on

both the sides is in progress.

Utilization of Fly

Ash Thermal power plants are

located within 500 km of

the sub-project. Fly ash

to be used at FPEPL.

Fly ash is being used from Dadri Super

Thermal Power Station of NTPC Ltd

located within 100 km in Dadri, District

Ghaziabad.



Table 4: Proposed EMP for Operation of FPEPL

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 programmes

FPEPL On site observations

Records of safety week

Embankment

protection Periodic maintenance of

stabilizing measures at

embankments like turfing etc.

FPEPL On site checks & observations

Water logging Regular maintenance and

cleaning of drains

FPEPL 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

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

FPEPL 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.

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

FPEPL Records of trees planted

to be maintained at site

Survival records to be

maintained at site

Fly ash is being used at FPEPL, thereby

reducing the requirement of earth for dyke

height. Ash has better compacting factor

than earth.



Impact/Issues EMP Responsibility Monitoring indicators

Tree survival list to be

maintained for planation

effectiveness

Redressal of

public

grievances

FPEPL shall maintain a

complaint register at toll plaza

FPEPL shall define a mechanism

to handle and manage grievances

raised by road users, project

affected persons and

employees/workers including

those of sub-contractors.

FPEPL shall send copy of the

register to Concessioning

Authority and Independent

Engineer

FPEPL Complaint Record register

17. HEALTH AND SAFETY

32. FPEPL has a Traffic Safety Management Plan (Annexure 16), which elaborates the

organizational structure roles and responsibilities of HSE staff; traffic safety and management

practices; work place safety etc. FPEPL follows the safety guidelines and conducts safety

training programmes as defined in the procedures and records for the same are maintained at the

sub-project site.

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

34. FPEPL has adequate institutional arrangement to look after HSE related aspects. The

organizational chart for HSE is given in Annexure 16.

18. GRIEVANCE REDRESSAL MECHANISM

35. FPEPL has devised guideline for Grievance Redressal Mechanism (GRM).

36. 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.

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

Concession Agreement. The Concessionaire has to maintain complaint register for recording

public grievances. The complaint register will be shared with the Concessioning Authority

every 7 days for review.



19. ENVIRONMENTAL SENSITIVITY

38. The environmental sensitivity of FPEPL has been assessed by reviewing various documents,

supplemented by field visit and consultation with the developer.

39. The environmental sensitivity assessment is given below:

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

(intersections and lay byes) additional land is required. Developer has informed that this

additional land is forest land and private land and it was confirmed during site visit.

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.

Approximately 7322 numbers trees are cut at the sub-project and tree cutting permissions

were taken from Forest Department.

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

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

Activities List (PIAL) of ADB.

21. CATEGORIZATION OF SUB-PROJECT

41. 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

42. A site visit was undertaken by Environmental Consultant and Social Safeguard Specialists on

31st October, 2019. The site visit was undertaken to review the implementation of the project’s

environmental and social safeguards. During the site visit and follow on, following staff were

mainly consulted regarding environmental safeguards related measures implemented at the

project site:

Name Designation

Mr. GR Saraswat Senior project manager

Mr. J. K. Srivastava AGM QA/QC

Mr. Bharat Singh AGM Structure

Mr. Sandeep Sharma Manager Planning

Mr. Pavan Kaushik Dy. Manager Planning

Mr. Sanjeev Sharma Sr. manager Accounts

Mr. S.K. Mishra Dy. Manager Admin

Mr. Upadhyay Vsist Dy. Manager Safety

Mr. Kailash Sharma Safety officer

Mr. Nitin Sr. officer Purchase

Mr. Ankit Singh Engineer

43. The sub-project is under construction; more than 78% 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 to the reporting /

monitoring requirements.

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

Avenue and median plantation has begun after September (Monsoon season) of 2019.

Developer has been informed to keep a record of plantations and survival rate.

Utility shifting at site is 100% complete.

100 % (345.28 Ha) of land is already 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. FPEPL has devised innovative ways for signages for diversion. Life size dummy

with red flag can be seen at sites where diversions signages were required.

Fly ash is being used to create dykes for flyovers and other purpose instead of earth

filling.

Developer informed during site visit that during road diversion, HSE Officers and local

traffic police is doing consultation and conveying the update related to road construction

and risk to locals in concerned area.

There are two camp sites at the sub-project. Camp 1 at Ch 22+800 is the main camp

which has stone WMM, block casting yard, office, laboratory, labour camp etc. Camp 2

at Ch 57+200 is other camp.

Labour camp is located at the two camp sites. The labour camp has dormitories for labour

which are well-maintained and hygienic conditions. Approximately maximum of 250

labours are residing at the camp. The dormitories were having fans and coolers. 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 labour with continuous

water supply. Good housekeeping was maintained at the site.

Kitchen/mess is being run at the camp site where food is prepared and served to all labour

and staff. LPG is being used in the kitchen for cooking purpose.

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 labour 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.

Concrete waste generated from demolished structure has been kept at secured and

identified location and is being utilized for low laying area development and leveling

purpose by local community.

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.

The sub-project has a proper grievance handling mechanism and records are maintained

at site.

23. CONCLUSIONS AND RECOMMENDATIONS

44. 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 FPEPL is

complying with the statutory requirements as per the national and state guidelines and

regulations. FPEPL is committed to protection of the environment while performing its

activities. The 61.19 km road strengthening and widening project in the State of Uttar Pradesh is

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

45. There are no legally protected areas or cultural heritage sites located within and/or in close

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

impacts which have been managed.



46. 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 has

been acquired.

The project involves diversion of forest land. Approximately 7322 numbers of trees have

been cut for widening and the concessionaire has paid forest department to develop an

elaborate plantation scheme to compensate for the tree cutting.

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 has been informed

to implement the EMP and maintain a record of status of implementation.

The institutional arrangement available for the implementation of environment, health &

safety appears to be adequate.

The concessionaire is maintaining safety at the site as per the management plans. The

EMPs are undertaken to minimize any significant negative impact on environment.

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

found to be adequate.

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



47. 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

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

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

Freedom Point Expressway Private Limited (FPEPL) 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 organized during 31st October 2019. The information given in the SSDDR is agreed and

confirmed by the Concessionaire.

25. PROJECT AGAINST THE PROHIBITED INVESTMENT ACTIVITIES LIST

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

Activities List (PIAL) of ADB.

26. OBJECTIVE OF SOCIAL SAFEGUARDS DUE DILIGENCE

50. 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

51. The Social safeguard due diligence study for FPEPL has been carried out after reviewing the

documents made available by the subproject developer. On site visit to the project location by the

Environmental and Social Safeguards Specialist, 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)

Concession Agreement

Feasibility Study of FPEPL

Independent Engineer’s (IE) Report Lender’s Independent Engineer (LIE) Reports Project Statutory Approvals/Permits

Labour License & insurance

28. SOCIAL IMPACT OF THE PROJECT

28.1 Land Acquisition in the Project

52. Land acquisition for the project FPEPL for 2/4-laning of section NH-235 (New NH-334) from km

8.800 to km 66.482 (approx 61.19 km) in the State of Uttar Pradesh by two / Four laning on

DBFOT (Hybrid Annuity) Basis has been completed by NHAI as per NH Act 1956. During the

discussion it was informed that the land acquisition to the extent of 40m Right of Way (RoW) for 4-

laning of this project was completed during 2 laning of project in the year 2011. As per the the

information provided in the LIE –July 2019, 100% of land was made available to the project

developer. The total land required in the project is 345.28 Ha.

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

financing.

28.2 Impact on Common Properties

54. As informed by the concessionaire during the project design phase, efforts have been made to avoid

acquisition of common properties. However, in some section of the projects a few of common

properties comes within the RoW which need to be acquired for the project. As informed by the

concessionaire there are 47 No’s of religious structures are being affected due to the widening of the project road. Out of which cost of rehabilitation is being borne by the Authority in consultation with

the Concessionaire. The affected structures are being relocated after consultation with the local

people.

28.3 Rehabilitation and Resettlement impact in the sub-project

55. Land acquisition to the extent of 40m Right of Way (RoW) for 4-laning of this project was initiated

during 2 -laning of project in the year 2011. During the site visit it was informed that there was no

rehabilitation and resettlement in the project because of land acquisition.



28.4 Impact on Indigenous people

56. As information provided by the concessionaire the project does not have indigenous people in the

project.

29. GREIVANCE REDRESSAL MECHANISM FOR THE SUB-PROJECT

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

arrangements to deal with any issues/concerns in the site. Grievance Redressal Mechanism with the

help of project site official has in place which comprises of the following members:

Project In charge;

EHS Head

Project Manager

Site In charge

58. The Grievance Redressal Committee (GRC) was formed at the project site to ensure that any

affected person’s grievances are adequately addressed and to facilitate timely project implementation. At project level the GRC is headed by the Project Head.

30. EMPLOYMENT GENERATION

59. As informed by the concessionaire, the project’s land acquisition was completed during 2 to 4-laning

of project in the year 2011. 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.

60. During the site visit it was told by the concessionaire that they have given job opportunity to more

than 200 local labours, have employed as per the available skill and qualification.

31. THE COMMUNITY ENGAGEMENT ACTIVITIES

61. As information provided by the concessionaire, to reach the local people, FPEPL 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.

62. The concessionaire has carried out community development activities based on the demands made

by the local community / nearby village/Panchayats as below:

Construction and maintenance of village temples.



Construction and maintenance of village road in the project affected villages as per the

requirement of the villagers.

32. LABOUR LICENSE OBTAINED BY THE SUBPROJECT DEVELOPER

63. The subproject developer FPEPL has received the Labour license from the Licensing Officer and

Asstt. Labour Commissioner, (Central), Dehradun, Govt. of India, Ministry of Labour &

Employment for doing the work of 4 laning of Meerut Bulandshahar section of NH-235 in the state

of UP, under Section 12(1) of the Contract Labour (Regulation & Abolition) Act, 1970. As per the

labour licenses the subproject developer can employed as contract labour in the establishment will

not exceeding 300 Nos. The detail of labour license is attached as Annexure 8.

64. The subproject developer has taken insurance policy for the project FPEPL including contractors &

sub-contractors workers are covered under policy. The detail of accident insurance is given in

Annexure 9.

33. DISCLOSURE

65. The ESDDR report, after approval from ADB, will be uploaded for public disclosure in IIFCL

website and ADB website.

34. SITE VISIT OBSERVATION

66. A site visit was undertaken by IIFCL’s Environmental and Social Safeguard Specialists during 31st

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 construction stage and has achieved 78% physical progress.

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

The sub-project has been prepared by NHAI 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 was completed during the 2 -laning of project in the year 2011;

Land acquisition has been done by NHAI under NH Act-1956 and the compensation for

land acquisition was paid to the affected families before handing over the land to the

concessionaire;



There is no Rehabilitation and Resettlement in the project.

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

Local people’s view have been given due consideration during the project planning and designing of 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;

Concessionaire has undertaken various community development activities to benefit the

local people;

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.

Employment opportunities have been provided to the local people

Concessionaire has undertaken community development activities based on the demands

raised by the local people.

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

significant social safeguard issue.

Annexure - 1

1

4 Laning of Meerut – Bulandshahar section of NH-235 from Km 8.800 (design

Chainage Km 8.800) to Km 66.482 (design Chainage Km 73.512) in the state of

Uttar Pradesh on Hybrid Annuity Mode

NATIONAL HIGHWAYS AUTHORITY OF INDIA

Environment Management Plan

FREEDOMPOINTEXPRESSWAY (Pvt.) Limited(An SPV for Development of Meerut - Bulandshahar Section of NH – 235; NEW NH – 334)

CIN: U45400UP2016PTC076383

EPC Contractor

(Apco Infratech Pvt.

Ltd.)

Checked By:

(Concessionaire:

Freedompoint

Expressway Pvt

Ltd.)

Reviewed By:

(Concessionaire:

Freedompoint

Expressway Pvt.

Ltd.)

Approved By:

(IE: SAI

consulting

Engineers Pvt.

Ltd.)

Name

Designation

Signature

Date

Annexure - 2

2

Table of Content

Sl.No Description Page No.

1 Introduction 3

2 Purpose & Scope 4

3 Description of Project 5

4 Management Commitment 7

5 Roles & responsibilities 8

6 Mitigation & environmental management programme 11

7 Personal Protective equipment 18

8 Appendix-1 Environmental Laws & regulations 19

9 Appendix-2 Environmental Control Checklist 21

10 Appendix-3 Organizational Structure for implementation 22

3

1.0 INTRODUCTION

This Project Environmental Management Plan (PEMP) will establish relevant environmental standards or objectives for each element of the project to be executed. It outlines management strategies and actions to meet the project's environmental objectives and also details how the adverse environmental impacts generated from the various stages of the construction and related activities would be minimized or controlled during development, operation & maintenance of 4-laning of Meerut-Bulandshahr section of NH-235 (New NH-334) Project

4

2.0 PURPOSE AND SCOPE OF THE PEMP

The principal purpose of the PEMP is to be a reference manual for the site managers and site personnel. This project specific PEMP explains the various environmental aspects & impacts associated with the construction activities of FEPL and its subcontractor’s. For an effective implementation of this PEMP, the reference materials such as documents/plans mentioned in the various chapters of this plan shall be referred and followed. This PEMP also explains the possible mitigation measures requires to be taken for minimizing and controlling the potential environmental significant impacts that arises during the execution of the project through appropriately laid down action plans. During developing this PEMP, as per General condition of contract, the brief scope of works listed out here.

The Environmental Management Plan reflects the high priority that FEPL Management place upon the

environmental management at construction zone to. It also demonstrates FEPL’s commitment to

ensure that all reasonably practicable measures are taken to:

Comply with the relevant statutory and Contractual traffic management requirements.

Ensure that impact to existing environment is kept to minimum by the construction work.

Provide and maintain plant, places and systems of work that are maintained to keep the impact

level as low as reasonably practicable.

Ensure that the wastes generated during construction phase are disposed off in an

environmental friendly manner.

Ensure that noise generation from plant & equipment are kept within limit.

Ensure that the waste water generated from construction activities are not discharge to any

natural/community water bodies like river ,canal .ponds etc.

Effective control, Co-ordinate and monitor the activities of all to keep the adverse impact level

as low as reasonably practicable.

5

3.0 DESCRIPTION OF PROJECT 3.1 The scope of work involves:

Four Laning of Meerut-Bulandshahr Section of NH-235 (New NH-334) in the State of Uttar Pradesh

under NHDP Phase-IV on Hybrid Annuity Mode.

3.2 Details of Highways as per CA:

Four Lane Carriageway – Reconstruction: 61.19 Km

(Rigid Pavement – 59.962 Km. & Flexible Pavement – 1.228 Km.)

Service Road/Slip Road: 4.22 Km (At 3 Locations)

Design Chainage Proposed

Length* (m)

Carriageway

Side From To Width in m

27+770 28+530 2 x 760 7.0m Both

51+340 51+940 2 x 600 7.0m Both

54+350 55+100 2 x 750 7.0m Both

Bypass: 29.450 Km (04 Nos.)

3.3. Details of structures as per CA: List of structures are given below.

Sl.

No.

Design Chainage

Length in km Type of Pavement

From To

LHS RHS

1 8+800 23+400 14.600 Rigid Rigid

2 23+400 34+600 11.200 Rigid Rigid

3 34+600 35+456 0.856 Flexible Flexible

4 35+456 38+978 3.522 Out of Scope

5 38+978 39+350 0.372 Flexible Flexible

6 39+350 73+512 34.162 Rigid Rigid

Sl. No. Bypass

Location

Design Chainage (km) Length

From To (Km)

1 Phapunda

Bypass

12+100 14+800 2.70

2 Kharkhuda

Bypass

17+700 20+900 3.20

3 Hapur

Bypass

23+400 34+600 11.20

34+600 35+456 0.86

35+456 38+978 3.52

38+978 39+350 0.37

4 Gulaothi

Bypass

49+700 57+300 7.60

Total Length 29.45

6

Type of Culvert New Re-

Construct Repair/

Widening Total

Culverts 25 19 15 59

Minor Bridges 05 04 02 11

Major Bridges 01 01 01

Vehicular Underpass

(VUP) 03 - 01 04

Pedestrian Underpasses

(PUP) 04 - - 04

Subway 01 - - 01

ROB 01 - - 01

3.4 Details of Project Facilities as per CA: Toll Plaza: One Toll Plaza is proposed at Design Ch. 47+900 of Project.

Truck Lay-byes: One Truck Lay-Byes is proposed at Design Ch. 46+400 in Village Padao.

Bus Bays: There are 04 (Four) Bus Bays are proposed at following locations:

Sl. No. Existing

Chainage (km)

Design Chainage

(km)

Location/ Village

1 8+900 8+900 Meerut

2 22+900 23+600 Hapur

3 44+380 49+425 Gulaothi

4 64+000 71+000 Bulandshahr

Bus Shelters: There are 11 (Eleven) Bus Shelters are proposed at following locations

At Grade Intersections: There are 11 (Eleven) at Grade Intersections (Major Junctions) are proposed

in the project stretches.

Sl. No.

Existing Chainage(Km)

Design Chainage(Km)

Location

1 11+600 11+600 Alipur

2 13+900 13+900 Phaphuda

3 17+800 17+800 Kharkhoda

4 20+500 20+500 Lalpur

5 22+800 22+800 Kaili

6 On Proposed Hapur Bypass

26+900 Jogipura

7 28+400 Dastoi

8 36+200 41+200 Hadikpur

9 38+100 43+100 Padao

10 50+540 57+400 Mithipur

11 61+600 68+600 Jainpur

7

4.0 MANAGEMENT COMMITMENT

4.1 Health, safety & Environment Policy

We, the management of FEPL are committed to the safe and efficient operation of our facilities. The

highest standards of equipment integrity and reliability are maintained to avoid risk to people and the

environment.

We are committed to:

The elimination of accidents and work-related ill health and the protection of the environment.

The management of Health, Safety and Environment (HSE) in the same way as any other critical business activity.

The efficient and responsible use of energy and materials.

The promotion of HSE management in all our sites.

The development of a culture -supported by publicity, training and education -which will result in sharing this commitment at all levels within the FEPL

We will pursue this commitment with a policy based upon

A well-structured HSE organisation in which competencies and responsibilities are clearly

defined to provide instruction to all employees in compliance with all applicable laws,

regulations and ethical standards.

The principles of prevention where measures will be taken to avoid, prevent, control and

restrict HSE related risks.

The development of action plans and the setting of targets which will be monitored measured

and reported to achieve continuous improvement.

A requirement that all contractors manage HSE consistent with this policy.

The recognition of employees' contributions to HSE management in their performance

appraisal when appropriate.

The management will visibly and rigorously support the implementation of this policy. We

expect the support of all employees and contractors in order to make FEPL HSE performance

one which will earn us the continuing confidence of our customers and the community at large.

We, the management of FEPL are committed to the safe and efficient operation of our facilities.

The highest standards of equipment integrity and reliability are maintained to avoid risk to

people and the environment

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5. ROLES AND RESPONSIBILITIES

Implementation of this PEMP along with other project requirements would be the responsibility of e v e r y i n d i v i d u a l w o r k i n g i n t h e p r o j e c t s i t e . It w i l l a l s o b e t h e responsibility of FEPL personnel to educate his partners / suppliers / sub-contractors etc in successful implementation of this PEMP. It shall be the collective responsibility that no unavoidable disturbance shall be caused to local communities or the environment within the project area.

5.1 Project Manager

Allocate r e s o u r c e s ( man, material, machine and financial resources) f o r t he successful implementation of this plan. Ensure compliance to HSE legal and other requirements like contractual requirements. Ensure adherences to HSE standards Review progress of objective, target and programme (s), environment awareness about aspect and impact among staff members, third party environment monitoring report, evaluate compliance of legal and other requirements, monitor non- conformity and observation raised by HO team/ site and any compliant on environment issues from legal, client or from nearby resident. Promote environ-friendly practices and awareness. Participate in environment awareness

5.2 Department Head:

Ensure that HSE norms are complied with during project execution in accordance of FEPL’s procedure, guidelines, HSE legal and other requirement as contractual requirements. Interact with Client and all external stakeholders in the project as required and resolve issues if any. Implementation of objective, target and programme. Ensure management review meeting, i.e. project HSE committee meeting shall be conducted on regular basis. He shall participate and motivate for active participation in the meeting by all members. Time to time review environmental aspect and impact, especially consideration of all activity which is planned or is being carried out.

5.3 Project HSE Head

Implementation of Environment Management System in the Project Site Advice the project management and line management in planning and organizing preventive measures necessary for HSE and HSE Legal issues. Coordinate with store and procurement team to plan and procure for HSE gadgets, compliance of hazardous waste rule.

Prepare project specific Environmental Aspect Identification, Impact assessment and control, objective, target and programme with involvement of respective site in charge

Conduct environmental monitoring at an interval as agreed by the engineer with approved agency I n case of any deviation from permissible limits then efforts shall be taken by making objective, target and programme to control the pollution.

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Monitor performance of pollution control system for waste water generation at sewage waste water, batching plant, vehicle washing area, etc. for air pollution control at traffic area, crusher area, etc 5.4 Project HSE Officers/Personnel Implementation of Environment Management System in the Project Site. Raise the environment observation and check its compliance Conduct and/ or organize environment related training. Conduct environment awareness campaign. It shall be ensure that the staff/ officer level of shall be at least aware about requirement, environmental aspect, impact, impact assessment, objective, target and programme(s), environmental legal requirement and other requirement

Advice the project management and line management in planning and organizing preventive measures necessary for HSE and Legal issues. Co-ordinate with store and procurement team to plan and procure for HSE gadgets, compliance of hazardous waste rule.

5.5 Store in charge- Manage handling, storage, transport, record keeping and annual return considerations especially for hazardous waste and substances as per requirement of procedure, legal and other requirements. . Maintain storage area as a spill free condition with proper housekeeping. Shall keep a copy of related authorisation and comply the relevant conditions of the authorisation and consent

5.5 Mechanical In-Charge

Manage handling, storage, transport and record keeping considerations especially for hazardous waste and substances as per requirement of procedure, legal and other requirements. He shall keep a copy of related authorisation and comply the relevant conditions of the authorisation and consent.

Prevent and control dust pollution, water pollution, water losses, oil spillage, noise pollution at site. Noise level of DG set shall be below 85 dB (A) from one meter distance.

Noise level of vehicle and other equipment shall be low as low as reasonably practicable. Maintain PUC record for vehicle and ensure periodically checked. Maintain workshop area as oil spill free condition with proper housekeeping. 5.6 Employee

Shall not litter the work area. Shall use toilet for natural calls Shall not waste water or pollute the water bodies.

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Shall not use music system at high volume Shall report any oil leakage from equipment if noticed to supervisors. Put the protective guards like noise reducing silencer/enclosure in its place after carrying out maintenance of equipment. Dispose oil soaked cloths in environmental friendly manner.

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6.0 MITIGATION & ENVIRONMENTAL MANAGEMENT PROGRAMME The two phases of project identified are construction phase & operational phase The EMP is prepared separately for two phases. Each phase has specific issues unique to that period of development and operation of the proposed project and associated infrastructure. Considering the extent, duration, intensity of the impact under each phase the environmental management plan is designed and developed taking into account of the mitigation measures for both phases as identified and other statutory requirement as described in appendix-1 The present Environment Management Plan (EMP) aims to delineate the mitigate measures requires for restoration& conservation the environment as well as minimization & prevention of the possible adverse impacts, if any, due to proposed project. The environmental management plan for the proposed project is designed for the following targeted environmental attributes & aspects:

1. Geophysical environment a. Land environment and solid waste management b. Water environment c. Air environment d. Noise environment 2. Ecological environment (Flora & Fauna) 3. Health and safety management. 4. Cleaner Production Approaches 5. Other administrative activities The activities being carried out during construction phase may also require adequately planned environment management plan. The construction activities will be restricted to the time allotted and therefore no considerable impacts are envisaged but the EMP must be laid down to ensure that the environmental impacts are remaining within acceptable limit. Further, during the operational phase there will be many activities which may pose some impact upon various components of the environment.

The operational phase will impose impacts upon the environment mainly due to the accidental spillage

or leakage of chemicals/materials. The Present chapter described the well planned Environmental Management Plan which will be proven very efficient in managing it effectively and efficiently. The details of the formulated action plan for pollution prevention and environmental protection & conservation has been presented in subsequent sections under respective heading.

6.1 Construction Phase

The impact of the construction phase will not be significant as not passing through or nearby any reserve forest land, not fall under any protected area, no wild life sanctuary within 15 KM distance on either side from the project road, no archaeological and historical monument is located within the project alignment. Further, all impacts of the construction phase will be well within acceptable limit in case of all environmental attribute with the necessary mitigation measures for the operations are implemented. During the construction phase FEPL shall ensure implementation of the following mitigation measures. 6.1.1-PreConstruction & site preparation operations-

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The concern authorities like must be informed of the starting date of construction as well as the phases in which the construction shall take place Adherence to all conditions of contract including the Environmental Management Program and other applicable special conditions Adequate planning of the construction program to allow for disruptions due to rain and other worst weather conditions. Where existing roads are in a bad state of repair, such road’s condition shall be documented before they are used for construction purposes. This will allow for easy assessment of any damage to the roads which may result from the construction process. If necessary some repairs should be done to prevent damage to equipment traffic delay. All manmade as well as natural (vegetation) resources &structures outside the boundary of the ROW hall be protected against damage at all times and any damage shall be rectified immediately Regular site inspections by the HSE Department along with concerned section head or Project Manager or appointed Site Official of FEPL shall be carried out and good control over the construction process throughout the construction period. FEPL must ensure compliance with conditions described in the construction related permissions & clearances All maintenance &servicing works for construction machineries & vehicles must take place within the premises in a designated area Where possible all unskilled labourers should be drawn from the local market& hutment for the labour hired from outside area shall be provided with in the premises only. The camp shall also be provided with adequate facilities for water, fuel & sanitation. Site clearing must take place in a phased manner, as and when required. The area to be cleared must be clearly demarcated and this demarcation shall be strictly maintained. Topsoil from the premises must be neatly stockpiled / windrowed adjacent to the construction site for backfill when required. FEPL shall inform all site staff to make use of provided facilities for sanitation & other domestic activities and haphazard sanitary activities by any of the construction staff shall not be allowed under any circumstances FEPL shall supply waste collection bins and all solid waste collected shall be disposed off through the proper disposal method as required to comply with the statutory requirement. All earthworks for site preparation must be adequately controlled and managed. Stockpiles should not be situated such that they obstruct natural water pathways. 6.1.2 Construction Operations Construction should be preferred to be done in daylight hours only. Concrete mixing must only take place within designated areas. Ready mixed concrete must be utilised where possible. No vehicles transporting concrete to the site may be washed on site. If a batching

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plant is necessary, run-off should be managed effectively to avoid contamination of other areas of the site. Runoff from the batch plant must not be allowed to get into the storm water system Wherever possible locally available construction materials shall be sourced for the proposed construction work to reduce transportation activities. All measures suggested for prevention of runoff, contamination of land & water as well as prevention of air contamination due to construction activities shall be implemented as described in other sections of EMP for construction phase. Where new access roads are constructed, this must be done according to design and approved plans of the site development. Drainage channels shall be suitably designed to ensure erosion does not occur, especially at the outflow points. The new access road shall be designed to allow for the natural flow of water where applicable. 6.1.3 Construction Vehicle & Traffic Management Construction routes and required access roads must be clearly defined prior to construction works. Delivery of equipment must be undertaken with the minimum amount of trips. Access of all construction and material delivery vehicles should be strictly controlled.

Vehicles and equipment shall be serviced regularly to avoid the contamination of soil from oil and hydraulic fluid leaks etc. Servicing must be done in designated service areas on site or at preapproved service location/station. Oil changes must take place on a concrete platform and over a drip tray to avoid pollution Contractors should ensure that access roads are maintained in good condition all the time of construction phase. If necessary, staff must be employed to clean surfaced roads adjacent to construction sites where materials have spilt. 6.1.4 Storage of materials Choice of location for storage areas must take into account prevailing winds, distances to water bodies, general onsite topography and water erosion potential of the soil. Impervious surfaces must be provided where necessary. Storage areas must be designated, demarcated and fenced if necessary. Fire prevention facilities must be present at all storage facilities. Proper storage facilities for the storage of oils, paints, grease, fuels, chemicals and any hazardous materials to be used must be provided to prevent the migration of spillage into the ground and groundwater regime around the temporary storage area(s). These pollution prevention measures for storage should include a bund wall high enough to contain at least 110% of any stored volume, and this should be sited away from drainage lines in a site with the approval of the Project Manager. These storage facilities (including any tanks) must be on an impermeable surface that is protected from the ingress of storm water from surrounding areas in order to ensure that accidental spillage does not pollute local soil or water resources.

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Material Safety Data Sheets (MSDSs) shall be readily available on site for all chemicals and hazardous substances to be used on site. Where possible the available, MSDSs should additionally include information on ecological impacts and measures to minimise negative environmental impacts during accidental releases or escapes. Storage areas containing hazardous substances / materials must be clearly signed. Staff dealing with these materials / substances must be aware of their potential impacts and follow the appropriate safety measures. An approved recycler must be employed to remove waste oil. These wastes should only be disposed off through the authorised recyclers designed to handle waste/used oil. All such disposal must be done by authorised person appointed by proponent and necessary documents & record shall be kept for each waste transaction.

All excess cement and concrete mixes are to be contained on the construction site and such unused construction wastes shall be reused for filling if approved by engineers. Any spillage, which may occur, shall be investigated and immediate action must be taken. This must also be reported immediately to the Management of Proponent, and local authorities, where necessary Any spillage, which may occur, shall be investigated and immediate action must be taken. This must also be reported immediately to the Management of Proponent, and local authorities, where necessary Proper implementation mitigation measures & suggestion for hazardous material storage, handling & transportation must be ensured throughout the construction phase. 6.1.5 Air Pollution Control Water sprinkling and damping down of un-surfaced and un-vegetated areas as well as earthen/unpaved roads. Retention of vegetation where possible to reduce dust travel. Excavations and other clearing activities must only be done during agreed working times and permitting weather conditions to avoid drifting of sand and dust into neighbouring areas. Damping down of all exposed soil surfaces with a water bowser or sprinklers when necessary to reduce dust. Dust control on site to shall be given utmost importance ensure no nuisance is caused to the neighbouring communities . A speed limit of 30km/h must not be exceeded by any vehicle. Any complaints or claims emanating from the lack of dust control shall be attended to immediately by the Contractor& Designated Environmental Officer appointed at site. Regular servicing of vehicles in order to limit gaseous emissions (to be done off-site) All ideal vehicles & construction machineries having air pollution potential due to exhaust/emission shall be turn off when not in used.

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Regular maintenance of such construction vehicles & machineries shall be ensured to reduce the emission rate . DG set, if required during construction work, shall be provided with adequate stack and other necessary infrastructure to prevent issue of air pollution. The DG set installed in site must confirm the CPCB standards. Burning of any kind of waste shall be prohibited to avoid air pollution issues. Wherever required, air quality monitoring by the help of approved environmental laboratory shall be done and necessary mitigation as suggested by the agency shall be ensured. 6.1.6 Water Conservation & Pollution Control Correct drainage of the site should ensure that contaminants do not impact upon surface water. No sensitive surface water features are present on the site or in vicinity of the site. The storm water system on the proposed work site needs to be regularly maintained to ensure effective working. FEPL must ensure that solid waste collection and sanitation is managed effectively in order to avoid any chances of ground and surface water pollution Water usage shall be supervised and strictly controlled to avoid wastage. Necessary checking & maintenance for prevention of water leakage from pipelines & tap/valves shall be done immediately upon notice of leak. Separate provision of water supply for labour camp, if develop within site, shall be made for domestic activities of workers. Proper sanitation facilities with septic tank &/or soak pit must be provided in labour camp area & construction site. 6.1.7 Noise Control The construction phase must aim to adhere to the relevant noise regulations and limit noise to within standard working hours in order to reduce disturbance of residential areas in close proximity to the development

Construction site yards, workshops, concrete batching plants, and other noisy fixed facilities should be located well away from noise sensitive areas. Once the proposed final layouts are made available by the contractor(s), the sites must be evaluated in detail and specific measures designed in to the system. Construction traffic should be routed away from noise sensitive areas, where possible. Noise levels must be kept within acceptable limits. All noise and sounds generated must adhere to CPCB Standards for maximum allowable noise levels for residential & industrial areas as well as vehicular noise. Construction activities are to be contained to reasonable hours during the day and early evening. Night-time activities near noise sensitive areas should not be allowed Noise suppression measures must be applied to all construction equipment. Construction equipment must be kept in good working order and where appropriate fitted with silencers which are kept in good working order.

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Labourers shall be discouraged from loitering in the noise sensitive area and causing noise disturbance. 6.1.8 Existing indigenous vegetation must be retained where possible. Existing indigenous vegetation must be retained where possible. A survey should be conducted before site clearing along with forest officials to demarcate vegetation that should remain and remove and relocate any plants of botanical or ecological significance. MOEF /CPCB guidelines shall be followed for the greenbelt development. Vegetation shall be removed only when it becomes necessary. No vegetation shall be used for firewood. 6.1.9 Borrow Area Management No borrowing of earth shall be permitted in case the area of borrowing/ excavation is within I km of boundary of national parks and wild life sanctuaries.

A minimum safe distance of 15 m from any civil structure shall be kept from the periphery of any excavation area. No blasting activity to be carried out for extraction of soil. No altercation to natural drainage pattern of the area. Borrowing activity shall be restricted to 2 meters above the ground water table. 6.2 OPERATION PHASE MANAGEMENT PLAN As mentioned earlier, the impact of the operation phase will not be significant as not passing through or nearby any reserve forest land, not fall under any protected area, no wild life sanctuary within 15 KM distance on either side from the project road, no archaeological and historical monument is located within the project alignment. No adverse impact is anticipated on the flora and fauna of the area during operation phase. Plantation along the road on available space shall be done to enhance the flora in the area. Compensatory afforestation shall be done along the project corridor during operation phase where ever it is possible as per MOEF/CPCB guidelines. Monitoring of survival of trees shall be done at regular interval and suitable mitigation measures shall be taken to protect the trees. 6.3 TRAINING AND ENVIRONMENTAL AWARENESS Training is an important tool in bringing the behaviour change and modification in thinking processes of employees, for an effective implementation of EMP. Training is an important tool in bringing the behaviour change and modification in thinking processes of employees, for an effective implementation of EMP.

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The following training topics shall be considered.

Air Pollution & its impact

Water Pollution & its impact

Noise Pollution & its impact

Control measures to prevent environmental impact

Reduce, reuse recycle

6.4 MONITORING AND MEASUREMENT Monitoring and Measurement is carried out for (i) tracking of project-wide environmental parameters with respect to ambient air, water & effluent, noise, (ii) tracking of resource consumption such as water, energy, raw materials, (iii) tracking of environmental control measures such as operation of treatment plants, (iv) monitoring progress of objectives and targets, (v) monitoring legal compliance. There is no specific requirement on the frequency of monitoring and this is decided on a case- to-case basis based on the issue or parameter to be monitored. Monitoring and measurement enables the project to Evaluate environmental performance Analyse root causes of problems Assess compliance with legal or contractual requirements Identify areas requiring corrective action Improve performance and increase efficiency (or) productivity. If required a third party environmental monitoring shall be carried out as per contractual requirement. The frequency shall be revised as per contractual requirement and as mentioned by statutory government body like mentioned in consent. The monitored data shall be evaluated with legal requirements (e.g. As per The Environment (Protection) Rule), as per requirement of consent, contractual requirement. 6.5 CHECKING AND CORRECTIVE ACTION

The checking findings are recorded as non-conformance and/ or suggestions for the improvement. Recorded audit findings are closed by taking the corrective measures along with preventive action. Corrective action amends the non-conformance, need not tackle the root cause of the problem and is generally in the immediate-term. On the other hand, the preventive action ensures non-recurrence of the non-conformance necessarily tackles the root cause of the problem and is generally undertaken in the short-to-medium term.

A non-conformance is not necessarily identified through audits; it can also be identified through day-to-day observations. If aware, mark the observations along with the suggested measures.

In relation to non-conformance and corrective and preventive action, FEPL has defined the responsibilities and authorities for handling, investigation, mitigation of impacts caused, completing corrective and preventive action, verifying its appropriateness with regards to its elimination, magnitude and commensurateness.

Project HSE team shall maintain record of environmental observation on m o n t h l y basis, if any. This observation may give either by project HSE team, other department, and client or stake holders.

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7.0 PERSONAL PROTECTIVE EQUIPMENTS All workmen will be provided with necessary PPE for protection against work related risks as per exposure at site. In general Hard Hat, Fluorescent Colour Vest and foot protection shall be used. For noisy work area-Earmuff/ear plug shall be provided to the workmen involved. For cement handling workmen, respiratory protection shall be provided.

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Appendix-1 ENVIRONMENTAL LAWS & REGULATIONS Sl.No

Law/Regulations/ Guidelines

Relevance Applicable Yes/No

Reason for application

Implementing/Responsible

Agency 1 The Environmental

(Protection) Act. 1986, and the Environmental (Protection) Rules, 1987-2002 (various amendments)

Umbrella Act. Protection and Improvement of the environment. Establishes the standards for emission of noise in the atmosphere

Yes All environmental notifications, rules and schedules are issued under the act

MOEF, CPCB and

SPCB

2 The EIA Notification, 14th September 2006

Identifies expansion of National & State highways greater than 30 Km involving additional ROW greater than 20m involving Land Acquisition (item 7 (f) of schedule) as one of the projects requiring prior clearance.

Yes Length of the road is more than 30 Km and LA more than 20m

MOEF / SPCB

3 The Water (Prevention and Control of Pollution) Act, 1974

Central and State Pollution Control Board to establish/enforce water quality and effluent standards, monitor water quality, prosecute offenders, and issue licenses for Construction/operation of certain facilities.

Yes Consent required for not polluting ground and surface water during construction

SPCB

4 The Air (Prevention and Control of Pollution) Act. 1981

Empowers SPCB to set and monitor air quality standards and to prosecute offenders, excluding Vehicular air and noise emission.

Yes Consent required for establishing and operation of plants and crushers

SPCB

5 Noise Pollution (Regulation And Control) Act, 1990

Standards for noise emission for various land uses

Yes Construction machineries and vehicles to conform to the standards for construction

SPCB

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6 Hazardous Wastes (Management and Handling) Rules, 1989

Protection to the general public against improper handling and disposal of hazardous wastes

Yes Hazardous wastes shall be generated due to maintenance & repair activities on vehicles & equipment’s

SPCB

7 The Motor Vehicle Act. 1988

Empowers State Transport Authority to enforce standards for Vehicular pollution. From August 1997 the "Pollution Under Control Certificate is issued to reduce Vehicular emissions.

Yes All vehicles used for construction will need to comply with the provisions of this Act.

State Motor Vehicles Department

8 Forest (Conservation) Act, 1980

Conservation and definition of forest areas. Diversion of forest land follows the process as laid by the act

No No involvement of forest land diversion for the project

State Forest Department, MoEF

9 Wild Life Protection Act, 1972

Protection of wild life in sanctuaries and National Park

No No sanctuaries / national park in the project area

State Forest Department, MoEF

10 Ancient Monuments and Archaeological sites and Remains Act 1958

To protect and conserve cultural and historical remains found.

No No archaeological monuments, area in the project area

Archaeological Survey of India, Dept. of Archaeology

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Appendix-2

ENVIRONMENTAL CONTROL CHECKLIST

LOCATION_____________________________ DATE____________________

DETAILS YES NO REMARKS

Environmental regulations and other requirements complied with

Environmental Management Programs (EMPs)

Preventive Maintenance Plan for equipment and vehicles for control of leakage , noise & smoke

Conveyer belt s provided with cover to minimise dust emission during material transfer to plant.

Appropriate containment bund walls/trays provided for control of spillage at equipment installation/oil storage areas

Appropriate washout area provided for concrete batch mix plant, transit mixer

Environmental signs posted

Waste and garbage skips available

Skips and bins marked and waste properly segregated

Hazardous materials stored and disposed properly

Barrel pump is used for decanting/refuelling of oil to avoid spillage.

Workmen provided with appropriate PPE For protection against dust, noise

Checked By : Name :_____________________ Designation :_____________________ Signature :_____________________

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Appendix- 3 ORGANISATION STRUCTURE FOR ENVIRONMENT MANAGEMENT IMPLEMENTATION

PROJECT

HEAD

HSE HEAD MGR/OFCR

MANAGEMENT REPRESENTATIVE

CONTRACTOR REPRESENTATIVE

EMPLOYEE REPRESENTATIVE

HEAD P&M

HEAD PLANNING

HEAD HIGHWAY

HEAD STRUCTURE

ENGINEER/ SUPERVISOR STRUCTURE

ADMIN OFFICER

ENGINEER/ SUPERVISOR HIGHWAY

ENGINEER/ SUPERVISOR P&M

Annexure -3

Annexure - 4