The company and the sponsor have presented plans to address these impacts to ensure that the proposed project will, upon implementation of the specific agreed measures, comply with the environmental and social requirements - the host country laws and regulations and the IFC Performance Standards and the WBG/IFC environmental, health and safety guidelines, as applicable. The information about how these potential impacts will be addressed by the sponsor/project is summarized in the paragraphs that follow. Further information is provided in the attached documentation.
- PS1: Social and Environmental Assessment And Management Systems
Tata Power has demonstrated stewardship in addressing social, environmental, health and safety (SEHS) aspects associated with its operations. The company is committed to implementing a certified environmental, health and safety management system (EHSMS) based on ISO 14001 and OHSAS 18001 prior to commissioning of the first unit in 2011. In the interim, CGPL will, manage EHS impacts during construction according to Tata Power’s EHSMS, which is certified to ISO 14001 and OHSAS 18001 standards and will ensure adherence to good EHS practices and an environment management plan, through appropriate contractual provisions with various supply and construction contractors.
Further, CGPL will also adopt Tata Group Code of Conduct which addresses aspects relating to: national interest; competition; financial reporting and records; equal opportunities; gifts and donations; government agencies; political non alignment; health, safety and environment; corporate citizenship; quality of products and services; co-operation of Tata companies; third party representation; public representation of the company and the group; use of Tata brand; group policies; shareholders; ethical conduct; regulatory compliance; concurrent employment; conflict of interest; securities transaction and confidential information; protecting company assets; citizenship; integrity of data furnished; and reporting of concerns.
The company has carried out:
- Rapid Environmental Impact Assessment (REIA);
- Comprehensive Environment Impact Assessment (CEIA);
- Rapid Marine Environment Impact Assessment (RMEIA);
- supplemental environmental impact assessment including a cumulative SO2 air quality impact assessment for Mundra UMPP and Adani Power Plant; and
- has developed an Environment Management Plan (EMP).
The RMEIA was prepared by National Institute of Oceanography (NIO), and other assessments above were by TCE Consulting Engineers Limited. The company will undertake a modeling study through a reputed international consultant organization, to assess the impacts of the open seawater intake and discharge channels on the marine environment. The company will, within a timeframe agreed with IFC:
- supplement the RMEIA through more in-depth analysis as more detailed project-related information becomes available;
- make the study available for IFC’s review and incorporate any suggestions recommended by IFC; and
- implement the management plan developed as part of the study, with IFC’s recommendations duly incorporated.
CGPL has commissioned a third party (SAVE: Saline Area Vitalisation Enterprise Limited) to carryout a Social Impact Assessment (SIA) as per IFC''s PS 1 provisions. CGPL completed a BSIA, which has been disclosed with this ESRS. The company will, in consultation with the affected communities, develop and implement measures to mitigate the impacts identified in the BSIA including restoration of livelihood, community development and long-term stakeholders engagement process. The ESRS will be updated to reflect the findings and outcome of the ongoing consultation and implementation of these measures.
The project is expected to commence operations in first half of 2011 and is expected to consume about 10.7 million tonnes of coal per annum at full capacity. CGPL proposes to source coal for the project from several countries including Indonesia, Australia, South Africa, Mozambique and/or other countries. Tata Power (the sponsor) has entered into a coal supply agreement to source coal from an Indonesian mining company, to meet the imported coal requirements of several of its projects including in part or in its entirety, that of the project. The coal mines from which the coal is expected to be sourced have not been considered an associated facility as:
- the project will meet its coal requirements from several sources and their successful operation will not be exclusively dependent on the said mining company; and
- the mining company has already operating mines with several off-takers and its viability is not exclusively dependent on the project.
Imported coal will be received at Mundra Port. Mundra Port currently handles about 5 million tonnes of coal and proposes to augment its coal handling capacity to 33 million tonnes to meet the requirements of:
- the project;
- Adani Power Limited’s 2460 MW imported coal based power plant; and
- the coal needs of existing and other users. Mundra Port or the coal handling capacity augmentation have not been considered an associated facility as: the port already handles coal; and the augmented capacity is not proposed exclusively on account of the project.
As per the current project plan Coal will be transported from the port (approximately 25 km from plant) by rail. A dedicated railway line is proposed from the Mundra Port to the plant. The railway line has been considered an associated facility and an environment assessment has been carried out by the company. About 100 ha of land will be acquired/leased from Mundra SEZ Limited, as the railway line alignment is expected to remain within MSEZ area.
Power will be evacuated from the project through three double circuit 400kV high-voltage transmission lines to be built, operated and maintained by Power Grid Corporation of India Limited (PGCIL), a public sector entity. Two additional transmission lines are proposed to enhance connectivity within the grid. The length of each of the transmission lines proposed is in the range of 134km – 405km. These five transmission lines have been considered an associated facility. Power Grid Corporation adheres to its own Corporate Environmental and Social Policy and Procedures (ESPP), which is consistent with The World Bank and Asian Development Bank social and environmental safeguard requirements. CGPL will share IFC’s Performance Standards on Social and Environmental Sustainability (Performance Standards and PSs) with PGCIL, to construct, operate and maintain the above transmission lines in accordance with IFC’s Performance Standards.
CGPL has deployed a full time appropriately qualified environment management professional at site. Further, the company is in the process of deploying a fulltime occupational health and safety professional at site. CGPL’s EHS team is actively supported by Tata Power’s corporate EHS team. CGPL has deployed a two member team to engage with the affected communities. Further, Tata Power has hired a corporate resource person on social responsibility, who will support the team on community development initiatives. CGPL’s Social and EHS operations will be further strengthened by implementation of the EHSMS certified to ISO 14001 and OHSAS 18001 standards.
The EMP proposes a detailed monitoring program for:
- emissions and discharges;
- impacts on ambient air quality; and
- impacts on marine environment both during construction and operation.
The company will, within a timeframe agreed with IFC, implement an EHS monitoring program, which is consistent with IFC’s EHS guidelines both for construction and operation phases. The company will, as part of the ISO 14001 and OHSAS 18001 certified EHSMS, implement an appropriate internal and third party EHS audit program. Further, CGPL will detail a program to:
- monitor the progress/status of implementation and outcomes of the mitigation measures and also the CDP; and
- implement an appropriate third party social audit program to be undertaken two years after finalization of the mitigation measures proposed in the BSIA.
In addition to the local disclosure of assessment documents as detailed here-above, CGPL will, as part of its Social and EHS Management System, implement a reporting program on site management and corporate Social and EHS management for Tata Power senior management and for Tata Power’s Board of Directors. CGPL will on a six monthly cycle submit compliance reports to regulators. The company will implement a program to share Social and EHS performance information with communities resident in the vicinity of the plant. Further, Tata Power prepares a Corporate Sustainability Report (CSR) and within a timeframe agreed with IFC, Tata Power will:
- incorporate CGPL’s Social and EHS performance in its CSR; and
- disclose the CSR on its website.
- PS2: Labor and Working Conditions
The project will likely employ approximately 5000 people during construction and approximately 700 people during operation. CGPL plans to construct employee housing and contract labor camps to house all non-locally recruited workers. The company fully recognizes the importance of labor influx management to minimize adverse environmental and social impacts on local communities. More details are provided in PS4 section below.
The CGPL Human Resources Management governing all permanent employees will be integrated into the larger Tata Power HR management system which is governed by a policy that is consistent with the ILO declaration on fundamental principles and rights at work. Tata Power’s HR policy includes components related to:
- guidelines for recruitment, selection and continuity in service;
- standardized skill competencies;
- performance appraisal;
- career progression;
- professional development and financial assistance of self education;
- rewards and recognition;
- retirement benefits;
- leaves and holiday policy;
- accident, injury and compensation; and
- professional ethics.
IFC will require CGPL to review IFC’s PS 2 provisions and ensure that its policies and practices are consistent with PS2 requirements.
CGPL will implement procedures to ensure that contractors engaged at the project site adhere to applicable contract labor laws. CGPL will implement a contract labor grievance management plan in accordance with Tata Power corporate policies, applicable labor laws and PS2 provisions. IFC will obtain assurance that labor relations and conditions for contract laborers are consistent with PS2 requirements throughout the construction period.
The company will implement an OHSAS 18001 certified health and safety management system prior to plant commissioning. In the Construction stage, the company will deploy a safety officer for ensuring that contractors adhere to EHS provisions in the various supply and construction contracts. The safety officer will also conduct EHS training program for contract labor.
- PS3: Pollution prevention and abatement
Management of resources including energy, water, hazardous and other materials:
The project will use supercritical coal technology, which is more energy efficient than subcritical technology currently used in the existing thermal power plants as well as mid-sized unit based new thermal power projects in India. Gross heat rate of the plant is 15 - 20 % better than the Central Electricity Regulatory Commission (CERC) recommended heat rate for new plants. Towards water conservation, the company will not draw groundwater or draw upon surface water resources both during construction and operation. The project envisages setting up a sea water desalination plant to meet its entire boiler make-up and other process and domestic water needs both during construction and operation. The Environmental Management Plan (EMP) provisions for storage and handling of hazardous and other materials will meet IFC requirements. The company will ensure that PCB containing transformer oils is not used and no asbestos containing material is used in the project.
Management of emission and discharges:
The project is designed to meet The World Bank Group/IFC’s EHS Guidelines for New Thermal Power Plants (1998 Pollution Prevention and Abatement Handbook) and General EHS Guidelines dated April 30, 2007. The CEIA states that the particulate matter emission levels will be limited to 100 mg/Nm3 and sulfur in fuel will be 1%. However, the ESP (Electrostatic Precipitator) is designed to ensure that particulate matter emissions are limited to 50 mg/Nm3 at 6% excess oxygen to meet IFC guideline requirements. The project proposes to use a low NOx burner technology enabling plant NOx emissions to meet IFC’s NOx emissions standards (750 mg/Nm3 at 6% excess oxygen). The company carried out a comparative analysis on the project’s sulfur control options – using Flue Gas Desulfurization (FGD) or procuring lower sulfur coal, and determined that the latter be more cost effective. The company will limit sulfur content of coal to 0.6% or less and will meet IFC SO2 emission guidelines of 2,000 mg/Nm3 (at 6% excess oxygen) and 450 ton SO2 per day, without using FGD. The Supplemental Environmental Impact Assessment, attached to this ESRS, includes air quality impact predictions at IFC Guideline limits. The company has made a space provision as per Ministry of Environment and Forests (MoEF) clearance condition for retrofitting an FGD unit in case it is required in the future. The project envisages a once through sea water cooling system with designed seawater intake capacity of 620,000 m3/hr (including the amount required for desalination plant) and 594,200 m3/hr of thermal discharge with elevated temperature. The balance will be used in the desalination plant for other plant uses. The condenser cooling discharge water temperature is expected to meet IFC’s thermal discharge guidelines (3 Celsius at the edge of the mixing zone). Various mitigation measures were proposed in the Rapid Marine EIA to minimize impacts on the marine environment and fishery resources. A further study (physical modeling) was required as one of the MoEF clearance conditions, before the intake and outfall locations and mode for withdrawal of water are finalized. The company will ensure that residual chlorine and/or other biocides used to treat sea water, remain within IFC EHS guideline levels. Treated waste water will be reused in the process or discharged on-land for irrigation of green belt. A suitably designed ash pond is proposed, to mitigate risk of ground water contamination. Also, sea water intake and outfall open channels will be lined on the onland stretches, to prevent groundwater salinity increase. The EMP details appropriate measures for storage, handling and disposal of hazardous wastes, other wastes and for prevention of leachates (from coal yard and ash pond) contaminating ground water. Further, the EMP details measures to minimize fugitive emissions both during construction and operation. Total ash pond area is 241 ha. Unutilized fly ash and bottom ash will be disposed in slurry form to the ash pond, which is located within the plant boundary. The company has outlined a plan for ensuring 100% fly ash utilization within 9 years of commissioning including through use in cement and FAL-G brick manufacture and possibly other applications. CGPL will, include appropriate contractual provisions, requiring the ships carrying coal for the project meet all applicable host country laws, IMO conventions and MARPOL requirements.
Management of impact on ambient conditions:
The existing ambient air quality levels of the proposed project site and its surrounding villages are good. The project’s impacts at 8 surrounding villages were assessed, and the resultant levels are predicted to be within the National Ambient Air Quality Standards (NAAQS) of India. The incremental impacts of NO2 and SPM are well below the relevant NAAQS. The incremental impacts of SO2 (24-h Max) are also small, maximum 30 µg/m3 at two of the eight villages, whereas at other six villages the impacts are predicted to be in the range of 0 to 19 µg/m3 as compared with the NAAQS limit of 80 µg/m3. Annual average SO2 incremental impact in all the villages is between 0 – 3.2 µg/m3, much smaller than the NAAQS limit of 60 µg/m3. Ambient noise levels are predicted to meet IFC’s ambient noise level standards.
Cumulative Impact:
The company also conducted a cumulative air quality impact assessment of the project and the Adani Power Project (Phase I: 2 x 330MW). The results show that the resultant levels considering the two projects will be in compliance with the NAAQS. Adani Power Project (Phase II: 2 x 330MW+ 2 x 660MW = 1,980MW) is being proposed to start environmental assessment and the cumulative impacts of the same is likely to be reviewed by Ministry of Environment and Forests, GoI.
Management of GHG emission:
Project will be the first private sector supercritical technology plant; and plant with 800 MW unit size in India. Due to the use of this technology and choice of unit sizes, the thermal efficiency of the project (LHV, gross) will be higher by about 70%, 30% and 20% as compared to the average thermal efficiency (LHV, gross) of coal based power plants in India, across the globe and OECD respectively. The project likely will be amongst the most energy efficient coal fired power plant of the country. While the CO2 emission of the project is estimated at 24 million ton CO2 per year (assuming 87% plant load factor), the project’s GHG emission intensity (gCO2 emitted per kWh of energy generated) will be amongst the lowest in India at 750 gCO2/kWh, as compared to 1259 gCO2/kWh (national average India for coal based power plants, 2005), 919 gCO2/kWh (world average for coal based power plants, 2005) and 888 gCO2/kWh (OECD average for coal based power plants, 2005). The project will have a GHG emission intensity which is lower by 40%, 18% and 15% as compared to the average GHG emission intensity of coal based power plants in India, across the globe and OECD respectively (based on the latest International Energy Agency statistics of 2007 Edition). Due to its high energy efficiency of supercritical technology, the Clean Development Mechanism (CDM) Executive Board meeting (under UNFCCC’s Kyoto Protocol) of September 2007 approved the eligibility of supercritical coal-fired plants for carbon credit in developing countries, and the company is exploring an opportunity for the project to be registered under CDM.
Monitoring and reporting:
The EMP proposes detailed ambient monitoring programs including for ambient air quality, surface water quality, ground water quality, noise and for marine impacts through which the project’s direct impacts as well as potential cumulative impacts from other industrial sources will be monitored by the company. Further, CGPL will install online stack emission monitoring and continuous ambient air quality monitoring stations, in addition to twice a week monitoring programs to collect more robust monitoring data. The EMP will be updated with more details as the project design will be finalized.
- PS4: Community health, safety and security
CGPL will construct infrastructure and use equipment that meet good industry practices. The company will design, construct, operate, maintain and monitor the power plant, to ensure minimal community, environment, health and safety impacts.
Most of the construction work will be within the project site except for construction of roads and the open channels for intake and discharge of sea water. The company will ensure through appropriate contractual provisions that impacts on community environment, health and safety are minimized. Further, the company will ensure, through appropriate risk assessment, engineering and management measures, that risks associated with the plant are contained within the plant premises and societal risks are within international criteria/best practice norms.
CGPL will ensure that the supply and construction contractors adopt good SEHS practices during construction and in particular ensure that its employees and contractor train equipment operators and drivers in safe driving techniques; develop a materials movement plan to ensure that vehicle movement during construction has minimal impact on daily life patterns of nearby communities; undertake appropriate measures to reduce fugitive emissions from storage and transport of excavated earth and other construction material; and periodically monitor ambient air quality as also noise levels in potentially affected communities/villages, and implement mitigation measures where required.
While local labor will be used for semi-skilled and unskilled work, an influx of laborers is expected during the peak construction period. The company will provide appropriate amenities/facilities for labor during construction. In this regard the company will provide, or require its contractors to ensure that, to the extent possible, members of local community are employed as construction laborers; labor camps have appropriate facilities and amenities including housing, toilets, washing and cleaning water, potable drinking water and cooking fuel; treated sanitary waste water meets IFC/WBG requirements prior to discharge; and potential host community impacts on account of influx of labor are assessed and managed. The company will, within a timeframe agreed with IFC, develop a labor influx management plan.
The project is not expected to exacerbate community exposure to disease due to changes in land/hydrologic or other terrestrial/air quality/hydrologic regimes. However, impacts of influx of labor will be assessed and CGPL will implement measures to minimize risk of community exposure to disease due to influx of laborers including: ensuring that appropriate medical facilities are available for its labor, employees and contract labor; that all its employees and laborers undergo periodic health check up including for HIV/AIDS; and other measures to control disease vectors.
The company employs security guards. The company will, within a timeframe agreed with IFC, develop and implement procedures for ensuring that: past records of security personnel employed are screened; security personnel have clear objectives and permissible actions laid out; security personnel are trained in avoidance of human rights violations, use of fire arms and handling various situations with clear procedures; security incidents are recorded, investigated and corrective action implemented; bona fide complaints against security personnel are investigated/disciplinary actions implemented; and there is a grievance mechanism for aggrieved members of community or employees in the event of a violation of the code for security personnel. The company will evaluate adoption of the UK Voluntary Principles on the Use of Security Forces as suggested in the Guidance Note for PS4.
The project is located in earthquake zone 5 with risk of high intensity earthquakes. The risk is exacerbated since there are communities resident in the immediate vicinity of the plant site. CGPL will prepare an emergency preparedness and response plan (EPRP) both for onsite and offsite emergencies; communicate the EPRP to stakeholders and also link the EPRP to the district EPRP; undertake drills on emergency response including participation of nearby communities; and continually improve the EPRP based on outcome of the drills.
Further, the company will implement procedures, on an ongoing basis, to identify and remediate potentially adverse impacts on community environment, health and safety.
- PS5: Land Acquisition and Involuntary Resettlement
Total land to be acquired for the project is 1052 ha. This includes 182 ha of private land and 870 ha of public land. No physical displacement/resettlement is anticipated on account of the project.
This entire 182 ha of private land is being acquired from one village Tunda, and Tundawand, which is a hamlet forming part of Tunda village. Private land is being acquired under The Land Acquisition Act of India, 1894 on behalf of CGPL, by the local administration. However, CGPL and the land owners have arrived at a negotiated settlement on compensation amount for private land. 62 of the 76 private land owners have signed a consent letter to sell the land for a negotiated price of INR 600,000 per acre. However, 14 private land owners have not formally consented to the negotiated price. BSIA indicates that some of these land owners may consider seeking a review of the offered land price in a court of law. The price of land offered by CGPL is higher than the government LA price awarded for this land acquisition. The company has paid 75% of the compensation amount to the Land Acquisition Officer and expects formal transfer of land soon. Private land acquisition will meet PS 5 provisions.
The 870 ha of public land is comprised of: 730 ha government wasteland (including 320 ha of MSEZ land, which was acquired by government and given to MSEZ, and has now been re-acquired from MSEZ by the government and given to the project); 130 ha of forest land (open scrub type vegetation); and 12 ha of grazing land. However, the BSIA indicates that the 85 ha of 320 ha of MSEZ land that has been made available to the project was public grazing land, prior to its acquisition for MSEZ. Hence, in effect, the project has acquired, 97 ha of grazing land in all.
While CGPL adopted the plant layout to avoid any physical displacement, there is economic displacement of 76 families/households (PAH), from whom land has been acquired, 45 households have lost their entire landholding of which 21 households are women headed. In all, 4 households are left with unviable parcels of land and no land was acquired from indigenous peoples (i.e. Scheduled Tribes) households.
In addition to the economic displacement of private land owners who have lost land, livelihoods (grazing, and charcoal making) of communities dependent on government land is also expected to be impacted since the land acquisition for the project has resulted in a 37% (870 ha from 2330 ha available) reduction in total government land availability in the affected villages.
Livestock rearing and milk production are important livelihood sources in the affected villages. The BSIA indicates that an estimated 330 households (with apprx. 9000 heads of livestock) in the affected villages are involved in this activity. While 97 ha of grazing land has been acquired for the project, the potential impact of project related land acquisition is higher since forest land and also government wasteland is used for grazing. Government of Gujarat has carried out a survey to assess the impact on cattle herders and proposes to provide alternate grazing land. Grazing, forest and some wasteland acquired under the project have open scrub type vegetation with Prosopis julliflora as a major species. About 100 households are involved in charcoal making as a source of livelihood, which use Prosopis julliflora to make charcoal. These households also used government wasteland for carrying out their charcoal making activities; and
500 persons in the affected villages are involved in agricultural labor. Opportunities for finding agriculture labor work will be partially impacted due to private land acquisition.
Structures, other assets (bore wells, pump house, wells and cattle shed) and trees, impacted due to land acquisition, will be compensated based on valuation methodologies provided by Horticulture Department and Public Works Department.
The company will implement measures to facilitate members of the affected households in getting contract employment during the construction phase. Further, the company will, in consultation with affected communities, develop and implement measures to mitigate identified impacts to ensure that no affected household is left worse off on account of the project.
_CGPL will, to mitigate the impacts on account of private and public land acquisition:
- work with Government of Gujarat (GoG) and the affected communities, to develop and implement solutions to ensure that livelihood of project affected communities is not adversely affected. This may include (but may not be limited to) working with GoG to facilitate making available alternate and suitable equivalent grazing and other land for the project affected villages;
- work with affected communities to enhance productivity of and yield from the balance grazing and wasteland available in the project affected villages; and productivity of and yield from balance private agricultural land in the project affected villages.
The company is planning suitable measures for temporary and permanent livelihood restoration. Further, the company will, through skill development training, enhance employability and enable affected households seek alternate sources of livelihood/income enhancement.
A BSIA (appended to this ESRS) has been completed, which identifies:
- project affected households;
- the key impacts of land acquisition;
- assessment of compensation for acquired land;
- framework for mitigation of identified impacts;
- key grievances of PAHs; and
- actions being implemented by the company to address these grievances.
The company will ensure that impacts on account of land acquisition are managed in accordance with PS5 provisions.
- PS6: Biodiversity Conservation and Sustainable Natural Resource Management
A seawater (for once through condenser cooling) intake open channel (80 m width at base at 3 m below chart datum) is proposed in the Kotdi creek and an outfall/discharge channel (60 m base width at 1 m below chart datum) is proposed in the Mudhwa creek. The seawater intake required is a maximum of 594,200 m3/hr, and the channel is designed for 620,000 m3/hr.
Construction of the channel and regular upkeep will involve capital and maintenance dredging. Capital dredging is expected to generate as much as 4.1 million m3 of dredge spoil. The company will, within a timeframe agreed with IFC, based on recommendations of a reputed independent consultant and with approval of Gujarat Maritime Board and other regulators:
- identify a site for disposal of dredge spoil; and
- develop a dredge spoil disposal plan both for capital and maintenance dredging.
CGPL has carried out a Rapid Marine Impact assessment to assess the impacts of sea water intake and thermal discharge from/into the creeks. The RMEIA indicates that material adverse impacts may not be expected on account of the project, if a management plan suggested in the RMEIA (appended to this ESRS) is appropriately implemented.
The Rapid Marine EIA was undertaken on the assumption that the temperature difference between intake and outfall points will be 7 degree Celsius. However, CGPL proposes to maintain the temperature difference between intake and discharge points below 4 Celsius, and will meet World Bank environmental guideline of 3 degree Celsius at the edge of the mixing zone.
The RMEIA indicates that high tidal movements, uneven topography and unusually strong currents make trawling or gill-netting for fish difficult and risky in the creeks. No large scale commercial fishing operations prevail in these shallow creeks except for minor shore based hand-net and gill-net operations. Further, RMEIA indicates that mangroves are not likely to be impacted on account of the open channels.
RMEIA recommends:
- placement of suitable nets across the intake channel and moving screen at the intake with suitable washing mechanism,
- wide and deep channel causing only weak currents, both to reduce impingement and entrainment, and
- allowing the local fishing community to fish in the channel.
CGPL will carryout additional modeling through reputed independent expert organization with the following objectives:
- the activity does not affect the flow regime (of the creeks/gulf);
- to determine the intake and outfall locations;
- to determine the mode for drawl of water;
- hydraulic and thermal regime is not affected; and
- Sensitive areas such as mangroves, corals and aquatic flora and fauna are not affected.
IFC will require the company to implement a management plan based on the outcome of the Rapid Marine EIA and the additional studies referred to above.
Further, the project land acquisition includes 130 ha of forest land. The forest was mostly open scrub type vegetation. CGPL has already made available an equivalent area in Bacchau district for compensatory afforestation. The company will also undertake mangrove plantations and implement measures to conserve mangroves in the vicinity of the project site.
- PS8: Cultural Heritage
The BSIA indicates that the public land acquisition may result in loss of access to a village fair site and a playground. CGPL will implement procedures, in accordance with PS8 provisions so as to mitigate the impact on such sites of cultural/community importance to the affected communities.
CGPL will, in accordance with PS8 provisions, implement a chance find procedure including for finds of archaeological (prehistoric), paleontological, historical, cultural, artistic, and religious values, as well as unique natural environmental features that embody cultural values, such as sacred groves.
