KATTUPALLI PORT CHENNAI’s NEW...

Marine Infrastructure Developer Pvt Ltd (Kattupalli Port) Kattupalli Village, Ponneri Taluk, Tirivalluvar District 600 120, Tamil Nadu, India

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Registered Office: Ramcon Fortuna Towers, 4th floor No 1/2, Kodambakkam High RoadNungambakkam, Chennai 600034

KATTUPALLI PORT CHENNAI’s NEW GATEWAY

Date: 19th Feb 2019 Ministry of Environment , Forest and Climate Change, IA Division, Indira Paryavaran Bhavan, Jor Bagh Road, Aliganj, New Delhi – 110 003

Kind Attn: Dr.Vinod K Singh, Scientist D Sub : Revised Master Plan (RMP) Development of Kattupalli Port by Marine

Infrastructure Developer Pvt Ltd (MIDPL) – Reply to the representation of CAG (Citizen consumer and civic action group) – Reg.

Ref : Additional details sought vide Final Minutes of 38th EAC Infra-2 meeting held

on 6-8 Feb. 2019 Sir, This has reference to the captioned subject and cited reference above; we hereby submit our response to the key representation of CAG (Citizen consumer and civic Action Group) for your kind consideration.

Sr. No

Key representation from CAG

MIDPL’s Response

1 No other Site selection criterion has been considered for the project

It is pertinent to mention that the proposed project under discussion is Expansion of Existing Kattupalli Port Only and not a new Port creation.

Kattupalli port has already been established and is operational, and current proposal is for expansion of the port.

Following (Environment & Social) considerations were taken for finalising the master plan. - Existing port is bifurcated from Shipyard and

therefore there is scope for expansion in southern side. Port expansion is being done mostly towards North, North west & Westward side

- As a part of our expansion plan, ~ 33% of the total area is being proposed under reclamation to avoid R&R and other related issues

- Further government and private land, as proposed are free from human settlements.


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2 Ennore creek is already under severe anthropogenic pressure due to existing industrial establishments

Ennore creek is located on the southern side at a distance of ~ 4.0 kms from proposed project.

Port expansion is planed mostly towards North, North west & Westward side of the existing port area and will not have direct impact on Ennore creek.

Proposed expansion is planned with adequate Environmental management facilities such as - Part of the cargo transportation through rail

and Pipelines - Covered Conveyor and Transfer Points - Dust Suppression System at stockyard,

Transfer towers, at berth/Unloaders, at wagon (Un)loading, at Track Hoppers, at Truck loading Silos, Discharge and feeding points of Conveyors etc.,

- Use of specialised ship loaders/unloaders, wagon tippler, track Hopper, covered conveyors and rapid loading system through silos

- Proper house keeping - Trucks before leaving the loading area shall

be covered with tarpaulin and also the railway wagons

- Greenbelt Development - STP of 240 KLD - ETP of 1.5 MLD - Storm Water Drainage System for Inside and

some portion of outside port area - Proper Collection, handling and Transport

System for Solid Waste Management

Additional measures if any will be provided based on the EIA Studies and suggestions of MoEF&CC/TNPCB/TNCZMA etc.,

However, as part of EIA, detailed studies will be carried out as per ToR with respect to impact of proposed activity on the 10 km radius of the project area and the proposed mitigation measures will be implemented as a part of Environment Management Plan.

3 Conversion of Ennore creek and its associated wetlands into industrial real estate. Activities like reclamation in prohibited

Ennore creek is located on the southern side at a distance of ~ 4.0 kms from proposed project.

No activities are proposed as part of Ennore Creek.

Port expansion is being done mostly towards


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activity in this areas North, North west & Westward side of the existing port area and will not have direct impact on Ennore creek.

As per the Coastal Zone Management plan, published by Dept. of Environment, Tamil Nadu, the area proposed under Revised Master Plan development falls under CRZ I(B), CRZ III, CRZ IV(A) & CRZ IV(B).

Proposal for Revised Master Plan is submitted to MoEF&CC for consideration of ToR. As a part of draft ToR Proposed by MIDPL, the impact due to proposed activities including the sea reclamation and raising of low lying area has been committed. Based on the approved ToR, Environment Impact Assessment will be carried out including hydro dynamic modelling studies for the study area and mitigation measures will be identified and implemented as part of EMP.

Land use proposed as a part of Revised Master plan is in-line to the permissible activities, as per CRZ notification 2011, amended till date.

However all activities will be carried out, only after obtaining required permission from the concerned authorities.

4 Ennore creek is a protected wetland under “Wetland Conservation and Management Rules, 2010 & reclamation, setting up of new industries or expanding existing industries on protected wetland is prohibited.

Ennore creek is located on the southern side at a distance of ~ 4.0 kms from proposed project. Ennore creek is not listed under wetlands/Ramsar sites under Ramsar Convention of Wetlands.

No activities are proposed as part of Ennore creek. The proposed project under discussion is Expansion of Existing Kattupalli Port Only not a new Port creation. Port expansion is being done mostly towards North, North west & Westward side of the existing port area and will not have direct impact on Ennore creek.

5 Increase in Vehicular movement will further deteriorate the air quality in this region.

As a part of our proposed project, apart from road evacuations, it is also proposed to evacuate cargo through Railway which is proposed on North and South side of the project, which will help reduce the impact on the surrounding region. However, proper traffic management plan will be prepared and covered as a part of EIA & EMP, which will be implemented during execution of the project.


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Impacts on air environment during operation phase during Bulk cargo handling/storage and transportation, Cryogenic Gases (Upto -162 degree Celsius, Pressurized Gases) regasification process and emissions from ships etc. Build-up of pollutant levels due to these emissions will be arrived through modelling studies using Gaussian Dispersion Models (ISCST3/ AERMOD). Mitigation measures will be accordingly suggested and implemented.

6 Location of critical – high investment infrastructure like ports in areas degrade/damaged by climate change needs to be looked at critically

The project is not located in any declared critically polluted area. Present proposal is expansion of existing Kattupalli port facilities.Port infrastructure will be developed, with all safety consideration, considering proneness to natural hazards. Disaster Management Plan is available with respect to existing infrastructure and operations and same will be upgraded in line to the proposed Revised Master Plan and same will be submitted to District administration.


7 Villages like Goongankuppan, Vairavan Kuppam, Korai Kuppan, Lighthouse Nadu Kuppam, Kadal Kanniyur, Kattupalli, Kalanji, Karungali, Arangankuppan and Thirumalai Nagar are likely to be displaced by erosion and privatising for the port.

As per the Status of Shoreline change maps, published by Institute of Ocean Management (IOM), Anna University, Chennai and Ministry of Environment Forest & Climate Change, New Delhi, the shoreline where the water front development as a part of Kattupalli port Revised Master Plan is proposed, is subjected to Low accretion to Stable Coast to Low erosion.

In general, the net littoral drift in this region is noted towards north and hence erosion on north side and accretion on south side of proposed marine structures are envisaged. The extent erosion/ has to be studied and accordingly available proven measures such as sand trap/bypassing, shoreline protection by using geo membranes/rocks/groins, etc., shall need to carried out to protect the shoreline.

As part of EIA Study detailed shoreline assessment will be conducted considering


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Revised Master Plan Layout to understand the impact on shoreline within 10 Km radius from the Project boundary and necessary Shoreline Management Plan will be proposed as part of mitigation measures which will be also considered as part of Environment Management Plan for the project.

Under CSR and CER program, sustainable livelihood projects will also be carried out in consultation with local communities that exists within project impact area.

Hope you find our above submissions are in order. Thanking You For Marine Infrastructure Developer Private Ltd Authorized Signatory.


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Kind Attn: Dr.Vinod K Singh, Scientist D Sub : Revised Master Plan (RMP) for the Development of Kattupalli Port- Reply to

the representation of Mr. Rahul Sridharan, Concerned Youth for People – Reg.


on 6-8 Feb. 2019 Sir, This has reference to the captioned subject above; we are submitting our pointwise response to the representation of Mr. Rahul Sridharan for your kind consideration.

Sl.No. Representation from Mr. Rahul Sridharan

MIDPL Reply

1. The proposed expansion of the Kattupalli Port by Adani and the proposed rail and road links from Thatchur to Kattupalli, lay claim to almost all the commons – Including the Kosasthalayar river – that have been used for centuries and continue to be in use by the entire community in Uranambedu. The same holds true for the river commons and associated lands north of those tended to by the people of Uranambedu, where the customary rights of the communities from Sengenimedu, Rajanthoppu, Ebrahampuram, Kaatupalli, Kalaanji, Kaattur, Chindamanipuram and Karungali to these landscapes are threatened by the proposed port expansion.

The land identified for the project abutting Kosasthaliyar river/ Buckingham Canal including rail/ road corridor belongs to TIDCO and Department of Salt. Transfer of lands in this region by the Salt Department in favour of TIDCO was duly considered and in progress. MIDPL is already in touch with GoTN/ TIDCO for the use of the same land for Port purpose. All the project activities will be carried out only after obtaining required permissions from the concerned authorities. MIDPL is also committed to carry out comprehensive CSR and CER programs in the areas of Education, Community Health, Sustainable Livelihood opportunities and Rural Infrastructure Development in the region. The aim is to walk with the communities, help people


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look ahead, make the right choices and secure a bright and beautiful future, together. Other than government land, there are private land which are forming a part of proposed port area as well as rail/road corridor. MIDPL is proposing the direct negotiated purchase of these areas from the land owners. Proposed expansion will not hamper any customary rights of the concern Communities.

2. The construction of port facilities including infrastructure for producing power, desalination, storage of petrochemicals and ores, cryogenic facilities and warehousing in the Ennore Creek and estuary of the Kosathalayar river, its flood plains, mud flats, mangroves and salt pans – all landscapes below sea level – and in some 1800 acres reclaimed from the Bay of Bangal – by dumping earth dredged from the sea or carted in from further inland to protect the port facilities from the naturally flood prone estuarine region – and by flattening the sand dunes in Kattupalli, will inevitably obstruct the flood drainage of the lands to the west of the proposed port expansion via the Kosasthalayar river and inundate thousands of acres of agricultural land and river commons besides several villages.

No activities are proposed in the Ennore Creek area. Proposed project facilities doesn’t include any Ecological Sensitive Areas such as Mud Flat/sand dunes/ mangroves as defined in the Approved CZMP (attached as Annexure 1). It is pertinent to mention that the mangroves are already excluded in the Master Plan during the planning stage itself. Proposal for Revised Master Plan is submitted to MoEF&CC for consideration of ToR.. Based on the approved ToR, Environment Impact Assessment will be carried out including hydro dynamic modelling studies for the study area and mitigation measures will be identified and implemented as part of EMP. In addition, Drainage study of the study area is also proposed as a part of draft ToR by MIDPL. Drainage pattern of the study area will be studied and adequate measures will be ensured to carry the runoff generated safely by deepening/widening and desilting if required based on the scientific study. Storm water drainage network will be designed considering the proposed level rising near these areas, the drain in and around project site area will be designed


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to safely carry the runoff generated due to rainfall. Outlets will be developed for the storm water towards natural sloping which can be used during monsoon and will be connected to existing drainage network if any. The details of the same shall be studied and covered as a part of EIA studies. Land use proposed as a part of Revised Master plan is in line with the permissible activities, as per CRZ notification 2011, amended till date.

3. The exclusion of a narrow north-south channel from the proposed project boundary surrounding it, for the Kosasthalayar river and the Buckingham Canal to connect with the Karungali estuary and the Pulicat lake, is nothing but a miserly and extremely short sighted ‘concession’ to a major river draining the better part of thiruvallur District and known to have carried over 100,000 cusecs of flood waters during the Chennai Floods of 2015.

The drainage pattern of the study area is mainly governed by Araniyar, Korattalayar, The drainage pattern, in general, is dendritic. All the rivers are seasonal and carry flood water during monsoon period. The drainage pattern of the region is given as Annexure 3. It is pertinent to mention that Korattaliar river empties into the Ennore creek which is located 4.4 km South from the proposed expansion boundary. Aranai river empties into the Pulicat lake which is located 7.2 km North from the proposed expansion boundary. The Kosasthaliyar stream and Buckinham Canal is connecting these Ennore Creek and Pulicat lake which is passing between the proposed expansion plan facilities. Drainage study of the study area is also proposed as a part of draft ToR by MIDPL. Drainage pattern of the study area will be studied and adequate measures will be ensured to carry the runoff generated safely by deepening/widening and desilting if required based on the scientific study. Land use proposed as a part of Revised Master plan is in line with the permissible activities, as per CRZ notification 2011, amended till date.


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All the activities will be carried out, only after obtaining required permission from the concerned authorities.

4. It will also destroy the region’s capacity to absorb storm surges from the seaward side and expose the proposed facilities to extensive damage from extreme climate events. The proposed breakwater and land reclamation stretching from Kattupalli and Karungali, will push coastal erosion due to littoral drift further north and risk the loss of Pulicat Lake and Sriharikota to the Sea.

As per the Status of Shoreline change maps, published by Institute of Ocean Management (IOM), Anna University, Chennai and Ministry of Environment Forest & Climate Change, New Delhi, the shoreline where the water front development as a part of Kattupalli port Revised Master Plan is proposed, is subjected to Low accretion to Stable Coast to Low erosion. In addition, shoreline changes map prepared by IOM, AU for Andhra Pradesh based on LISS III 2010 imagery reveals that the shore line north of Pulicat lake mouth subjected to Low/Meduim/High Erosion and south of Pulicat lake mouth is subjected to Stable, Low/Medium/High accretion. It is observed that proposed Revised Master Plan Breakwater is located about 7.2 km south of Pulicat Lake and 11.0 km South from lake mouth opening to bay of Bengal. These maps are provided as Annexure 1. Further, Revised Master Plan is submitted to MoEF&CC for consideration of ToR. As per the standard ToR, Environment Impact Assessment will cover various modelling studies, include shoreline assessment, to study the impact near the vicinity and the proposed mitigation measures as a part of Environment Management Plan. Inline to the EIA notification 2006, amended till date, final EIA will be submitted to EAC for consideration for final Environment & CRZ Clearance. Only after obtaining final clearance from MoEF&CC, further development activities


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inline to Revised master plan will be carried out. In general, the net littoral drift in this region is noted towards north and hence erosion on north side and accretion on south side of proposed marine structures are envisaged. The extent erosion/ has to be studied and accordingly available proven measures such as sand trap/bypassing, shoreline protection by using geo membranes/rocks/groins, etc., shall need to carried out to protect the shoreline.

5. The Proposed road and rail links from the west will cut through Maamuni eri while the elevated facilities referred to above will cut through all the east flowing channels from the tank into the river. The obstruction to flood drainage will not only inundate the lands to the west during the monsoons and spells of heavy rain but prevent the continuous recharge of ground water at a scale that will invite the salt water from the sea to take over the aquifer already threatened by salinity, along the coast from North Chennai up to Pulicat lake.

Rail/Road corridor will be developed by taking cognizance of the drainage pattern of the region. Water Body/ Drain crossing if any shall be duly considered in the design and accordingly Culverts/ corridor on stills will be provided as appropriate to ensure the drainage pattern of the region is undisturbed. Drainage pattern of the study area will be studied and adequate measures will be ensured to carry the runoff generated safely by deepening/widening and desilting if required based on the scientific study. All measures will be taken The details of the same shall be studied and covered as a part of EIA studies Proposal for Revised Master Plan is submitted to MoEF&CC for consideration of ToR. Based on ToR, Environment Impact Assessment will be carried out including hydro dynamic modelling studies & flood discharge scenarios inline to the proposed development and the mitigation measures will be identified suggested and implemented as part of EMP. All the activities will be carried out, only after obtaining required permission from the concerned authorities.


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6. The experience of the coastal and inland fishing communities in the Ennore Creek and those from Kattupalli, Sepakkam, Uranambedu and Senganimedu point to the distinct possibility that the construction and operation of mega-facilities like those proposed in the Revised Master Plan for the tenfold expansion of the Kattupalli port, will result in the endemic contamination of air, water and soil to the degree that it will make it impossible for thousands of families in the surrounding villages to continue to live and work here.

Proposed expansion is planned with adequate Environmental management facilities such as

Part of the cargo transportation through rail and Pipelines

Covered Conveyor and Transfer Points

Dust Suppression System at stockyard, Transfer towers, at berth/Unloaders, at wagon (Un)loading, at Track Hoppers, at Truck loading Silos, Discharge and feeding points of Conveyors etc.,

Use of specialised ship loaders/unloaders, wagon tippler, track Hopper, covered conveyors and rapid loading system through silos

Proper house keeping

Trucks before leaving the loading area shall be covered with tarpaulin and also the railway wagons

Trucks Tyres and areas susceptible for coal dust before leaving premises shall be cleansed washed to remove coal particles.

Use of -low sulphur diesel fuel is proposed.

Greenbelt Development

Use of Eco friendly regasification technology such as Seawater based/ Ambient Air Based for LNG Regasification.

STP of 240 KLD

ETP of 1.5 MLD

Settling Pond

Storm Water Drainage System for Inside and some portion of outside port area

Proper Collection, handling and Transport System for Solid Waste Management

Additional measures if any will be provided based on the EIA Studies and suggestions of MoEF&CC/TNPCB/TNCZMA etc.,


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As a part of proposed expansion, all the required studies based on Terms of Reference granted by MoEF & CC will be carried out as part of EIA and mitigation plan will be proposed and implemented accordingly.

7. Whatever the merits of the proposed port expansion project, it is clear that in appropriating and privatizing thousands of acres of ecologically fragile wetlands and estuarine – coastal commons, it will snatch away the very basis for the sustenance of all those engaged in sea and inland fishing, farming, animal husbandry and forestry in the Ennore Creek and Kosasthalayar estuarine region and related coastal environments, destabilize beyond repair the precarious hydrological balance by creating and promoting conditions for extreme flood, drought and salt water intrusion, drive to extinction several endemic species of flora and fauna – many yet to be identified – and right the death kneel for thousands of people representing several village communities in the vicinity while irreversibly compromising the potential of the commons enclosed to support future generations either directly or indirectly.

Nearest declared Ecological sensitive area is Pulicat Sanctuary which is located at about 14.5 NW of proposed port expansion boundary. The proposed expansion site is superimposed on the approved CZMP which reveals that the proposed expansion area is not a part of any CRZ I A (i.e. Ecologically Sensitive Areas) Only few patches of mangroves are observed in and around the vicinity which are already excluded with sufficient buffer as per CRZ notification 2011. As part of proposed project detailed study will be carried out with respect Changes in Hydrodynamics Impacts on Marine water quality, Shoreline/Coastline, Marine ecology, Pulicat Lake, fishing communities and animal husbandry etc. Under CSR and CER program, sustainable livelihood projects will also be carried out in consultation with local communities that exists within project impact area. Proposal for Revised Master Plan is submitted to MoEF&CC for consideration of ToR. Based on ToR, Environment Impact Assessment will be carried out using appropriate available models for dredge spoil disposal, various discharges, shoreline changes, hydro dynamic modelling studies and flood discharge scenarios for the study area and mitigation measures will be identified and implemented as part of EMP.


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All the activities will be carried out, after obtaining required permission from the concerned authorities.



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Kind Attn: Dr.Vinod K Singh, Scientist D Sub : Revised Master Plan (RMP) Development of Kattupalli Port by Marine

Infrastructure Developer Pvt Ltd (MIDPL)– Reply to the representation of Fishermen Panchayat Sabha, Kattupallikupan, Ponneri Taluk, Thiruvallur District, Tamil Nadu – Reg.

Ref: Additional details sought vide Final Minutes of 38th EAC Infra-2 meeting

held on 6-8 Feb. 2019 Sir, This has reference to the captioned subject and cited reference above; we are submitting our response to the representation of Fishermen Panchayat Sabha, Kattupallikupan for your kind consideration.

Sl.No. Representation from Fishermen Panchayat Sabha, Kattupallikupan

MIDPL Reply

1 It has come to our notice that ministry is in receipt of revised Master plan (RMP) for development of Katuapalli port by Adani / Marine Infrastructure Development Private limited for Tor in Ponneri taluka, thiruvallur district, Tamilnadu. We would like to bring to your notice that this port is being proposed just north of the existing Kamarajar Port and L&T shipbuilding yard. Already, due to these two operation ports, the coastline on the northern parts towards pulicat has been subject to direct to wide spread beach erosion, greatly affecting our fish livelihood. Now another mega project in the area will prove disastrous as the rate of erosion toward pulicat lake will increase significantly. There is a risk

It is pertinent to mention that the proposed project under discussion is Expansion of Existing Kattupalli Port and not a new Port creation. Kamarajar Port is operating since 2001 and LTSB started its operation after obtaining required approvals, from Jan 2013. Bifurcation of EC and CRZ Clearance between MIDPL & LTSB obtained from MoEf & CC on 9th February 2018. As per the Status of Shoreline change maps, published by Institute of Ocean Management (IOM), Anna University, Chennai and Ministry of Environment Forest & Climate Change, New Delhi, the shoreline where the water front development as a part of Kattupalli port


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of the sand bar separating Pulicat lake and bay of Bengal eroding, resulting in massive sea level raise that will swallow the islands of pulicat lake where many habitants are situated. It is not only habitations in Pulicat that will be affected. Allowing the sea to move inland into the Pulicat lake will greatly affect inland fresh water aquifiers that will lead to collapse of fresh water resources in the district.

Revised Master Plan is proposed, is subjected to Low accretion to Stable Coast to Low erosion. In addition, shoreline changes map prepared by IOM, AU for Andhra Pradesh based on LISS III 2010 imagery reveals that the shore line north of Pulicat lake mouth subjected to Low/Meduim/High Erosion and south of Pulicat lake mouth is subjected to Stable, Low/Medium/High accretion. It is observed that proposed Revised Master Plan Breakwater is located about 7.2 km south of Pulicat Lake and 11.0 km South from lake mouth opening to bay of Bengal. These maps are provided as Annexure 1. Further, Revised Master Plan is submitted to MoEF&CC for consideration of ToR. As per the standard ToR, Environment Impact Assessment will cover various modelling studies, include shoreline assessment, to study the impact near the vicinity and the proposed mitigation measures as a part of Environment Management Plan. Inline to the EIA notification 2006, amended till date, final EIA will be submitted to EAC for consideration for final Environment & CRZ Clearance. Only after obtaining final clearance from MoEF&CC, further development activities inline to Revised master plan will be carried out. In general, the net littoral drift in this region is noted towards north and hence erosion on north side and accretion on south side of proposed marine structures are envisaged. The extent erosion/ will be studied as a part of EIA and accordingly available proven measures such as sand trap/bypassing,


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shoreline protection by using geo membranes/rocks/groins, etc., will be implemented. It is to be noted that Pulicat lake is a brackish water system which is being fed by two rain fed rivers namely Kalangi and Arani. The salinity levels lowers during Monsoon season and will be carrying from brackish to Saline for the remaining period. During the execution of the proposed project all the required support will be given to Government Authorities as part of CER for their efforts on protection and conservation of Pulicat lake.

2 The plan also propose to take over Karungali Estuary that will lead to obstructing drainage - causing floods not only in these areas but also upstream areas

Proposed master plan will not be obstructing Karungali Estuary.

3 We are at the point, where many report and scientific studies, have proven variety of risk, due to climate change induces sea level rise. The sand dune in Katupalli and Kalanji village act as buffer, protecting, the area and groundwater inland. Now, the port proposes to flatten many areas of sand dunes, exposing the habitants here to the extreme effects of natural weather events like cyclones, tsunami, etc. Blocking of drainage and extreme land use changes in the backwater will result in the effect of these disaster being felt by areas even inland.

As per the Coastal Zone Management plan, published by Dept. of Environment, Tamil Nadu, the area proposed under Revised Master Plan development does not contain any sand dunes. The approved CZMP is attached as Annexure 2. Land use proposed as a part of Revised Master plan is in line to the permissible activities, as per CRZ notification 2011, amended till date. Various studies will be carried out to understand the impact of the proposed project in the vicinity areas. However all the activities will be carried out only, after obtaining required permission from the concerned authorities.

4 The project envisages massive take over of backwater and river flood plains that will affect the livelihood of thousands of people making a living

As per the Coastal Zone Management plan, published by Dept. of Environment, Tamil Nadu, the area proposed under Revised Master Plan


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by fishing and allied activities, salt farming, fish farming, hand picking of shells, grazing livestock and agriculture.

development falls under CRZ IB, CRZIII, CRZ IVA & CRZ IVB Land use proposed as a part of Revised Master plan is in line to the permissible activities, as per CRZ notification 2011, amended till date. No such activities like fishing, salt farming, fish farming, hand picking of the shells has been observed in the proposed project areas. Proposal for Revised Master Plan is submitted to MoEF&CC for consideration of ToR. As per the standard ToR, Environment Impact Assessment will be prepared. Inline to the EIA notification 2006, amended till date, final EIA will be submitted to EAC for consideration for final Environment & CRZ Clearance. Only after obtaining final clearance from MoEF&CC, further development activities inline to Revised master plan will be carried out. Further, Social Impact assessment will be carried out as a part EIA studies to identify the impact on locals and CSR plan will be developed accordingly.



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Kind Attn: Dr.Vinod K Singh, Scientist D Sub : Revised Master Plan (RMP) for the Development of Kattupalli Port – Agenda

Item No. 38.3.2 EAC (Infra 2) – Kattupalli Port, MIDPL – Thiruvallur District, Tamil Nadu - Reply to the representation of Mr. Nityanand Jeyaraman – Reg.


on 6-8 Feb. 2019 Sir, This has reference to the captioned subject above; we are submitting our pointwise response to the representation of Mr. Nityanand Jeyaraman for your kind consideration.

Sl.No. Representation from Mr. Nityanand Jeyaraman

MIDPL Reply

8. The Port is set to come up into erosion – prone zone, in close proximity to the Kamarajar Port Ltd., which has already triggered harmful shoreline dynamics.

It is pertinent to mention that the proposed project under discussion is Expansion of Existing Kattupalli Port

As per the Status of Shoreline change maps, published by Institute of Ocean Management, Anna University, Chennai and Ministry of Environment Forest & Climate Change, New Delhi, the shoreline where the water front development as a part of Kattupalli port Revised Master Plan is proposed, is subjected to Low accretion to Stable Coast to Low erosion.

In general, the net littoral drift in this region is noted towards north and hence erosion on north side and accretion on south side of proposed marine structures are envisaged. The extent erosion will be studied as a part of EIA and accordingly available


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proven measures such as sand trap/bypassing, shoreline protection by using geo membranes/rocks/groins, etc., will be implemented to protect the shoreline.

As per CRZ Notification 2011 and subsequent amendments, ports are permissible activity in such classified area for which Comprehensive EIA is to be done.

MIDPL will comply with all the requirements as per the EIA notifications 2006 as well as CRZ notifications 2011 and subsequent amendments till date.

As part of EIA Study detailed shoreline assessment will be conducted considering Revised Master Plan Layout to understand the impact on shoreline within 10 Km radius from the Project boundary and necessary Shoreline Management Plan will be proposed as part of mitigation measures which will be also considered as part of Environment Management Plan for the project.

9. Erosion triggered by the Port can harm fisher villages like Koraikuppam to the North.

The habitation of Koraikuppam village is located at 1.5 km north of proposed Northern boundary of the Revised Master Plan.

As per the Status of Shoreline change maps, published by Institute of Ocean Management (IOM), Anna University, Chennai and Ministry of Environment Forest & Climate Change, New Delhi, the existing status of shoreline near Koriakuppam is under low erosion under natural phenomenon.

As part of EIA Study detailed shoreline assessment will be conducted considering Revised Master Plan Layout to understand the impact on shoreline within 10 Km


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radius from the Project boundary and necessary Shoreline Management Plan will be proposed as part of mitigation measures to prevent erosion along the coast of fishing villages

Under CSR and CER program, sustainable livelihood projects will also be carried out in consultation with local communities that exists within project impact area.

10. Erosion triggered by the Port can breach the narrow strip of sand separating the Bay of Bengal from the Lake Pulicat irreversibly altering the brackish water system and causing salinity intrusion deep inland.

It is to be noted that Pulicat lake is a brackish water system which is being fed by two rain fed rivers namely Kalangi and Arani. The salinity levels lowers during Monsoon season and will be carrying from brackish to Saline for the remaining period.

As per shoreline changes map prepared by IOM, AU for Andhra Pradesh based on LISS III 2010 imagery reveals that the shore line north of Pulicat lake mouth subjected to Low/Meduim/High Erosion and south of Pulicat lake mouth is subjected to Stable, Low/Medium/High accretion. It is observed that proposed Revised Master Plan Breakwater is located about 7.2 km south of Pulicat Lake and 11.0 km South from lake mouth opening to bay of Bengal. These maps are provided as Annexure 1.

As a part of EIA Study detailed shoreline assessment will be conducted considering Revised Master Plan Layout to understand the impact on shoreline within 10 Km radius from the Project boundary and necessary Shoreline Management Plan will be proposed as part of mitigation measures which will be also considered as part of Environment Management Plan for the project.


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All the developments will be carried out only after obtaining required permissions from the Concerned Authorities.

During the execution of the proposed project all the required support will be given to Government Authorities as part of CER for their efforts on protection and conservation of Pulicat lake.

11. The approach channel to the proposed port will disturb the Ennore Shoals which are the sole reason why the eroding effects of the Kamarajar Port are not as pronounced as otherwise.

Ennore Shoals are tentatively located towards eastern side of the North break waters of Kamarajar Port and south break waters of Kattupalli Port

As per the data available, Ennore shoals are located about 5 km North-Northeast direction of the Ennore creek.

The stated Ennore shoals are located south of existing Kattupalli port approach channel.

As a part of Revised Master Plan, existing navigation channel will be used with some widening and deepening of the channel without changing the orientation of the channel which is located perpendicular to coast i.e., eastern side.

Further, As per the standard ToR, Environment Impact Assessment will be carried out, covering various modelling studies, including shoreline assessment, to study the impact near the vicinity and the proposed mitigation measures as a part of Environment Management Plan.

12. The harbor within the breakwaters encloses the richest fishing grounds, characterized by a muddy seabed ideal as a prawn habitat.


No such activities like fishing, salt farming, fish farming, hand picking of the shells has been observed in the proposed project areas.


Tel +91 44 2824 3062 CIN: U74999TN2016PTC103769



The fish landing centres in the study area are Ennore 3.15 km S and Pulicat 7.2 km N.

As part of proposed project detailed study will be carried out with respect to Shoreline/Coastline, Marine ecology, Pulicat Lake, fishing grounds/prawn habitats/fishing communities and animal husbandry etc.

Under CSR and CER program, fishermen livelihood projects will also be carried out in consultation with Fishermen group that exists within project impact area.

All the activities will be carried out, after obtaining required permission from the concerned authorities.

13. The economic necessity of a third mega port within the same city of Chennai is not made out.

The state of Tamil Nadu contributes 17% of the total number of factories and 11% to the industrial output of the country which requires infrastructure for speedy cargo evacuation for trade.

The expansion proposal is important because it can serve several purposes like alternative gateway for Chennai and Kamarajar Ports, potential for container traffic due to vicinity of Chennai and Ennore SEZ, the cargo potential exists due to the presence of number of industries including Power plants and refineries.

14. The port’s land-side facilities will necessitate the conversion of more than 2000 acres of wetlands, and the takeover of Ennore Creek. This will have the following effects;

Salinity intrusion

Impact on biodiversity due to land-use change

Increased risk of flooding in Araniyar and Kosasthalaiyar basins. More than 10 Lakh people will be at increased risk of


Ennore creek is located on the southern side at a distance of ~ 4.0 km from proposed project.

Port expansion is being done mostly towards North, North west & Westward side that has no direct impact on Ennore creek.

As per the Coastal Zone


Tel +91 44 2824 3062 CIN: U74999TN2016PTC103769



disastrous flooding if the Creek is encroached upon.

Impact on fishing, agriculture and the cattle economy

Impact due to land-use changes caused by roads and other infrastructure associated with ports.

Management plan, published by Dept. of Environment, Tamil Nadu, the area proposed under Revised Master Plan development falls under CRZ IB, CRZIII, CRZ IVA & CRZ IVB.

It is to be noted that Pulicat lake and Ennore creek are brackish water systems which are being fed by rain fed rivers namely Nagari, Araniar, Korathalayar. The salinity levels lower during Monsoon season and will be carrying from brackish to Saline for the remaining period.

There are no declared areas protected under international conventions, national or local legislation for their ecological, landscape, cultural or other related value.

In addition, Drainage study of the study area is also proposed as a part of draft ToR by MIDPL. Drainage pattern of the study area will be studied and adequate measures will be ensured to carry the runoff generated safely by deepening/widening and desilting if required based on the scientific study. Storm water drainage network will be designed considering the proposed level rising near these areas, the drain in and around project site area will be designed to safely carry the runoff generated due to rainfall. Outlets will be developed for the storm water towards natural sloping which can be used during monsoon and will be connected to existing drainage network if any. The details of the same shall be studied and covered as a part of EIA studies.

Activities like fishing, salt farming, fish farming, hand picking of the shells has not been observed in the proposed project areas.


Tel +91 44 2824 3062 CIN: U74999TN2016PTC103769



Land use proposed as a part of Revised Master plan is inline to the permissible activities, as per CRZ notification 2011, amended till date.


15. The Ennore region is already well past its environmental carrying capacity with two ports, a coal yard, more than 3000 MW of coal fired power plants, coal ash ponds spread over 1700 acres, the Manali Petrochemical region and high traffic of heavy vehicles.

The expansion proposal is for port and related infrastructure facilities.

As a part of our proposed project, apart from road evacuations, it is also proposed to evacuate cargo through Railway which is proposed on North and South side of the project, which will help reduce the impact on the surrounding region. However, proper traffic management plan will be prepared and covered as a part of EIA & EMP, which will be implemented during execution of the project.

However, as part of EIA, detailed studies will be carried out as per ToR with respect to impact of proposed activity in the 10 km radius of the project area and the proposed mitigation measures will be implemented as a part of Environment Management Plan.

All the developments will be carried out only after obtaining required permissions from the Concerned Authorities.

16. The Ennore Creek and the air shed in the vicinity are heavily polluted, and further intensification of polluting activities in the region is not justified.

Ennore creek is located on the southern side at a distance of ~ 4.0 km from the project.

Port expansion is being done mostly towards North, North west & Westward side that has no direct impact on Ennore creek.


Tel +91 44 2824 3062 CIN: U74999TN2016PTC103769



Impacts on air environment during operation phase during Bulk cargo handling/storage and transportation, Cryogenic Gases (Upto -162 degree Celsius, Pressurized Gases) regasification process and emissions from ships etc. Build-up of pollutant levels due to these emissions will be arrived through modelling studies using Gaussian Dispersion Models (ISCST3/ AERMOD). Mitigation measures will be accordingly suggested and implemented.


17. The proposed site was the landfall point for Cyclone Vardah and is disaster prone. The flattening of coastal sand dunes for the purposes of constructing the port will further expose the inland areas to the wrath of the sea.

Port infrastructure will be developed, with all safety consideration, considering proneness to natural hazards. Disaster Management Plan is available with respect to existing infrastructure and operations and same will be upgraded in line to the proposed Revised Master Plan and same will be submitted to District administration.

As per the Coastal Zone Management plan, published by Dept. of Environment, Tamilnadu, the area proposed under Revised Master Plan development does not contain any sand dunes.

Land use proposed as a part of Revised Master plan is in line to the permissible activities, as per CRZ notification, 2011 amended till date.

However all activities will be carried out, after obtaining required permission from the concerned authorities.


Tel +91 44 2824 3062 CIN: U74999TN2016PTC103769



18. The proposed developments are set to come up within the Hazard Line demarcated by Survey of India for this region.

As per the Coastal Zone Management plan, published by Dept. of Environment, Tamil Nadu, the area proposed under Revised Master Plan development falls under CRZ IB, CRZIII, CRZ IVA & CRZ IVB which is a permissible activity as per CRZ Notification, 2019.

Proposal for Revised Master Plan is submitted to MoEF&CC for consideration of ToR. Based on ToR, Environment Impact Assessment will be carried out and DMP will be prepared and implemented. All the activities will be carried out, only after obtaining required permission from the concerned authorities.

19. The proposed developments, particularly those encroaching upon the Creek, are likely to be submerged due to sea level rise, if modelling studies, including by the Space Application Centre, ISRO, are to be believed.

Ennore creek is located on the southern side at a distance of ~ 4.0 kms from Proposed project.

Port expansion is being done mostly towards North, North west & Westward side that has no direct impact on Ennore creek

Further, Revised Master Plan is submitted to MoEF&CC for consideration of ToR. As per the standard ToR, Environment Impact Assessment will cover various modelling studies, include shoreline assessment, to study the impact near the vicinity and the proposed mitigation measures as a part of Environment Management Plan.



Tel +91 44 2824 3062 CIN: U74999TN2016PTC103769




Kind Attn: Dr.Vinod K Singh, Scientist D Sub : Consideration of Revised Master Plan (RMP) Development of Kattupalli Port

by Marine Infrastructure Developer Pvt Ltd (MIDPL)– Reply to the representation of Thirumalai Nagar Fishermen Panchayat Sabha, Palaverkadu, Ponneri Taluk, Thiruvallur District, Tamil Nadu – Reg.


held on 6-8 Feb. 2019 Sir, This has reference to the captioned subject and cited reference above; we are submitting our response to the representation of Thirumalai Nagar Fishermen Panchayat Sabha, Palaverkadu for your kind consideration.

Sl.No. Representation from Thirumalai Nagar Fishermen Panchayat

Sabha, Palaverkadu

MIDPL Reply

1 It has come to our notice that ministry is in receipt of revised Master plan (RMP) for development of Katuapalli port by Adani / Marine Infrastructure Development Private limited for Tor in Ponneri taluka, thiruvallur district, Tamilnadu. We would like to bring to your notice that this port is being proposed just north of the existing Kamarajar Port and L&T shipbuilding yard. Already, due to these two operation ports, the coastline on the northern parts towards pulicat has been subject to direct to wide spread beach erosion, greatly affecting our fish livelihood. Now another mega project in the area will prove disastrous as the rate of erosion toward pulicat lake will

It is pertinent to mention that the proposed project under discussion is Expansion of Existing Kattupalli Port and not a new Port creation. Kamarajar Port is operating since 2001 and LTSB started its operation after obtaining required approvals, from Jan 2013. Bifurcation of EC and CRZ Clearance between MIDPL & LTSB obtained from MoEf & CC on 9th February 2018. As per the Status of Shoreline change maps, published by Institute of Ocean Management (IOM), Anna University, Chennai and Ministry of Environment Forest & Climate Change, New Delhi, the shoreline where the water front


Tel +91 44 2824 3062 CIN: U74999TN2016PTC103769



increase significantly. There is a risk of the sand bar separating Pulicat lake and bay of Bengal eroding, resulting in massive sea level raise that will swallow the islands of pulicat lake where many habitants are situated. It is not only habitations in Pulicat that will be affected. Allowing the sea to move inland into the Pulicat lake will greatly affect inland fresh water aquifiers that will lead to collapse of fresh water resources in the district.

development as a part of Kattupalli port Revised Master Plan is proposed, is subjected to Low accretion to Stable Coast to Low erosion. In addition, shoreline changes map prepared by IOM, AU for Andhra Pradesh based on LISS III 2010 imagery reveals that the shore line north of Pulicat lake mouth subjected to Low/Meduim/High Erosion and south of Pulicat lake mouth is subjected to Stable, Low/Medium/High accretion. It is observed that proposed Revised Master Plan Breakwater is located about 7.2 km south of Pulicat Lake and 11.0 km South from lake mouth opening to bay of Bengal. These maps are provided as Annexure 1. Further, Revised Master Plan is submitted to MoEF&CC for consideration of ToR. As per the standard ToR, Environment Impact Assessment will cover various modelling studies, include shoreline assessment, to study the impact near the vicinity and the proposed mitigation measures as a part of Environment Management Plan. Inline to the EIA notification 2006, amended till date, final EIA will be submitted to EAC for consideration for final Environment & CRZ Clearance. Only after obtaining final clearance from MoEF&CC, further development activities inline to Revised master plan will be carried out. In general, the net littoral drift in this region is noted towards north and hence erosion on north side and accretion on south side of proposed marine structures are envisaged. The extent erosion/ will be studied as a part of EIA and accordingly available proven measures such as sand trap/bypassing, shoreline protection by


Tel +91 44 2824 3062 CIN: U74999TN2016PTC103769



using geo membranes/rocks/groins, etc., will be implemented. It is to be noted that Pulicat lake is a brackish water system which is being fed by two rain fed rivers namely Kalngi and Arani. The salinity levels lowers during Monsoon season and will be carrying from brackish to Saline for the remaining period. During the execution of the proposed project all the required support will be given to Government Authorities as part of CER for their efforts on protection and conservation of Pulicat lake.




As per the Coastal Zone Management plan, published by Dept. of Environment, Tamil Nadu, the area proposed under Revised Master Plan development does not contain any sand dunes. The approved CZMP is attached as Annexure 2. Land use proposed as a part of Revised Master plan is inline to the permissible activities, as per CRZ notification 2011, amended till date. Various studies will be carried out to understand the impact of the proposed project in the vicinity areas. However all the activities will be carried out only, after obtaining required permission from the concerned authorities.

4 The project envisages massive take over of backwater and river flood plains that will affect the livelihood of thousands of people making a living by fishing and allied activities, salt

As per the Coastal Zone Management plan, published by Dept. of Environment, Tamilnadu, the area proposed under Revised Master Plan development falls under CRZ IB, CRZIII, CRZ IVA & CRZ


Tel +91 44 2824 3062 CIN: U74999TN2016PTC103769



farming, fish farming, hand picking of shells, grazing livestock and agriculture.

IVB Land use proposed as a part of Revised Master plan is inline to the permissible activities, as per CRZ notification 2011, amended till date. No such activities like fishing, salt farming, fish farming, hand picking of the shells has been observed in the proposed project areas. Proposal for Revised Master Plan is submitted to MoEF&CC for consideration of ToR. As per the standard ToR, Environment Impact Assessment will be prepared. Inline to the EIA notification 2006, amended till date, final EIA will be submitted to EAC for consideration for final Environment & CRZ Clearance. Only after obtaining final clearance from MoEF&CC, further development activities inline to Revised master plan will be carried out. Further, Social Impact assessment will be carried out as a part EIA studies to identify the impact on locals and CSR plan will be developed accordingly.



Tel +91 44 2824 3062 CIN: U74999TN2016PTC103769




Kind Attn: Dr.Vinod K Singh, Scientist D Sub : Consideration of Revised Master Plan (RMP) Development of Kattupalli Port

by Marine Infrastructure Developer Pvt Ltd (MIDPL)– Reply to the representation of Vairavankuppam Fishermen Panchayat Sabha, Ponneri Taluk, Thiruvallur District, Tamil Nadu – Reg.


held on 6-8 Feb. 2019 Sir, This has reference to the captioned subject and cited reference above; we are submitting our response to the representation of Vairavankuppam Fishermen Panchayat Sabha for your kind consideration.

Sl.No. Representation from Vairavankuppam Fishermen

Panchayat Sabha

MIDPL Reply

1 It has come to our notice that ministry is in receipt of revised Master plan (RMP) for development of Katuapalli port by Adani / Marine Infrastructure Development Private limited for Tor in Ponneri taluka, thiruvallur district, Tamilnadu. We would like to bring to your notice that this port is being proposed just north of the existing Kamarajar Port and L&T shipbuilding yard. Already, due to these two operation ports, the coastline on the northern parts towards pulicat has been subject to direct to wide spread beach erosion, greatly affecting our fish livelihood. Now another mega project in the area will prove disastrous as the rate of erosion toward pulicat lake will

It is pertinent to mention that the proposed project under discussion is Expansion of Existing Kattupalli Port and not a new Port creation. Kamarajar Port is operating since 2001 and LTSB started its operation after obtaining required approvals, from Jan 2013. Bifurcation of EC and CRZ Clearance between MIDPL & LTSB obtained from MoEf & CC on 9th February 2018. As per the Status of Shoreline change maps, published by Institute of Ocean Management (IOM), Anna University, Chennai and Ministry of Environment Forest & Climate Change, New Delhi, the shoreline where the water front


Tel +91 44 2824 3062 CIN: U74999TN2016PTC103769



increase significantly. There is a risk of the sand bar separating Pulicat lake and bay of Bengal eroding, resulting in massive sea level raise that will swallow the islands of pulicat lake where many habitants are situated. It is not only habitations in Pulicat that will be affected. Allowing the sea to move inland into the Pulicat lake will greatly affect inland fresh water aquifiers that will lead to collapse of fresh water resources in the district.

development as a part of Kattupalli port Revised Master Plan is proposed, is subjected to Low accretion to Stable Coast to Low erosion. In addition, shoreline changes map prepared by IOM, AU for Andhra Pradesh based on LISS III 2010 imagery reveals that the shore line north of Pulicat lake mouth subjected to Low/Medium/High Erosion and south of Pulicat lake mouth is subjected to Stable, Low/Medium/High accretion. It is observed that proposed Revised Master Plan Breakwater is located about 7.2 km south of Pulicat Lake and 11.0 km South from lake mouth opening to bay of Bengal. These maps are provided as Annexure 1. Further, Revised Master Plan is submitted to MoEF&CC for consideration of ToR. As per the standard ToR, Environment Impact Assessment will cover various modelling studies, include shoreline assessment, to study the impact near the vicinity and the proposed mitigation measures as a part of Environment Management Plan. Inline to the EIA notification 2006, amended till date, final EIA will be submitted to EAC for consideration for final Environment & CRZ Clearance. Only after obtaining final clearance from MoEF&CC, further development activities inline to Revised master plan will be carried out. In general, the net littoral drift in this region is noted towards north and hence erosion on north side and accretion on south side of proposed marine structures are envisaged. The extent erosion/ will be studied as a part of EIA and accordingly available proven measures such as sand trap/bypassing, shoreline protection by


Tel +91 44 2824 3062 CIN: U74999TN2016PTC103769



using geo membranes/rocks/groins, etc., will be implemented. It is to be noted that Pulicat lake is a brackish water system which is being fed by two rain fed rivers namely Kalngi and Arani. The salinity levels lowers during Monsoon season and will be carrying from brackish to Saline for the remaining period. During the execution of the proposed project all the required support will be given to Government Authorities as part of CER for their efforts on protection and conservation of Pulicat lake.




As per the Coastal Zone Management plan, published by Dept. of Environment, Tamil Nadu, the area proposed under Revised Master Plan development does not contain any sand dunes. The approved CZMP is attached as Annexure 2. Land use proposed as a part of Revised Master plan is inline to the permissible activities, as per CRZ notification 2011, amended till date. Various studies will be carried out to understand the impact of the proposed project in the vicinity areas. However all the activities will be carried out only, after obtaining required permission from the concerned authorities.

4 The project envisages massive take over of backwater and river flood plains that will affect the livelihood of thousands of people making a living by fishing and allied activities, salt

As per the Coastal Zone Management plan, published by Dept. of Environment, Tamilnadu, the area proposed under Revised Master Plan development falls under CRZ IB, CRZIII, CRZ IVA & CRZ


Tel +91 44 2824 3062 CIN: U74999TN2016PTC103769



farming, fish farming, hand picking of shells, grazing livestock and agriculture.

IVB Land use proposed as a part of Revised Master plan is inline to the permissible activities, as per CRZ notification 2011, amended till date. No such activities like fishing, salt farming, fish farming, hand picking of the shells has been observed in the proposed project areas. Proposal for Revised Master Plan is submitted to MoEF&CC for consideration of ToR. As per the standard ToR, Environment Impact Assessment will be prepared. Inline to the EIA notification 2006, amended till date, final EIA will be submitted to EAC for consideration for final Environment & CRZ Clearance. Only after obtaining final clearance from MoEF&CC, further development activities inline to Revised master plan will be carried out. Further, Social Impact assessment will be carried out as a part EIA studies to identify the impact on locals and CSR plan will be developed accordingly.


ANNEXURE 1

ANNEXURE 2

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Turning Circle

700m Ø

-20.5 m CD

Existing 580Ø TURNING

CIRCLE DREDGED TO (-)14.0 M

Proposed 650m Ø

TURNING CIRCLE

DREDGED TO (-)20.5 M

Proposed 700m Ø TURNING CIRCLE

DREDGED TO (-)25.0 M

ANNEXURE 3

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