KUTCH G U J A R A T - Welcome to Environment · Mandvi and Bhuj (15.1 km, East) SH-49 connecting Bhuj and Naliya (25.8 km, North) SH-48 connecting Bhuj and Mundra (36.5 km, East)

C1101311 RP008, Rev 0

EIA/EMP for Multiproduct SEZ/FTWZ, DTA including Power & Desalination Plants

By

SPPL,ALPL, NLPCL and GIMCOINFRASTRUCTURE LEASING & FINANCIAL SERVICES

LIMITED (IL&FS) - DEVELOPER/PROMOTER

KUTCH G U J A R A T

L&T INFRASTRUCTURE ENGINEERING LIMITED (Formerly Known as L&T-RAMBØLL CONSULTING ENGINEERS LIMITED)

EIA Consultant:

Environmental Appraisal Questionnaire (EAQ) for New Industrial Estates

Table of Contents Page i

TABLE OF CONTENTS

Environmental Appraisal Questionnaire for New Industrial Estates (IE)

LIST OF ANNEXURES

Annexure A Land Purchase Agreement ......................................................................................... A-1

Annexure B Land use/Zoning particulars-relevant portions from the prevailing local Regulations B-1

Annexure C Cost estimates ............................................................................................................ C-1

Annexure D Landscape plans with proposed tree plantation ......................................................... D-1

Annexure E Water Balance ............................................................................................................ E-1

Annexure F Rainwater Harvesting Plan ......................................................................................... F-1

Annexure G Storm water drainage ................................................................................................ G-1

Annexure H Common Effluent Treatment Plant Details ................................................................. H-1

Annexure I Statement on the machinery & manpower during construction ................................... I-1

Annexure J Fire protection measures & approvals obtained ......................................................... J-1

Annexure K Approval of competent authorities- Change of land use ............................................ K-1

Annexure L Construction schedule ................................................................................................ L-1

Annexure M Approval From special bodies - MoCI ...................................................................... M-1

Annexure N Approvals from CWLW/AAI/Department of Geology & Mining/ WRD/GMB etc., ....... N-1

Annexure O Solid waste collection, treatment, storage, transportation and disposal plan ............ O-1

Annexure P Vehicle Parking and Management .............................................................................. P-1

LIST OF APPENDICES

Appendix 1: Inventory of SEZ Air emissions

Appendix 2: Proposed Common Utilities/ Industry Related Facilities

Appendix 3: Risk Mitigations Measures

Environmental Appraisal

Questionnaire (EAQ)


Page 1

QUESTIONNAIRE TO BE SUBMITTED FOR NEW INDUSTRIAL ESTATES (IE) A. GENERAL FEATURES

This information provides a profile of the estate to assist in identifying possible environmental issues. 1. Industrial estate a. Name: Multiproduct SEZ/FTWZ, DTA including

Power & Desalination Plants b. Address: Layja Mota in Kutch District, Gujarat c. Operations to start by Month - Year The entire industrial land within the

processing area of the proposed Layja Mota SEZ can be absorbed within six years starting from 2015-2016 onwards.

2. Contact person for environmental aspects a. Name: Ms. Sumathy Sivaramakrishnan b. Function: Director c. Phone: +91-22-26533333, +91-22-26593694 d. Fax: +91-22-26523979 e. E-mail: [email protected] 3. Ownership a. Public: No b. Private: Yes c. Public/private partnership: No 4. Scale of the project a. Total area of development (in hectares): SEZ/FTWZ&DTA:1405.50

Utility Corridor: 50.18 b. Total number of units/companies

proposed: 160

c. Total number of workers (approximate): ~ 45,000 5. Proposed land uses (Percentage of total area) Area in Hectares

a. Export processing zone 61.65% 866.44 b. General industrial zone 8.98% 126.26 c. Commercial zone 4.26% 59.85 d. Residential zone 1.81% 25.50 e. Landscaped green areas 17.14% 240.95 f. Undeveloped areas 0.00% 0.00 g. Roads 6.15% 86.48 h. Others 0.00% 0.00

Total 100.00% 1405.59

6. Nature of the industries proposed in the IE

No. of Units

Likely No. of Workers

Production Volume

(Tons per year)

a. Petrochemical processing - - - b. Iron and steel processing - - - c. Non-ferrous metal industries - - - d. Chemical manufacturing 14 3825 574000 e. Energy generation 10 1250 39519.65 million

units per year f. Construction industry - - - g. Transportation sector - - - h. Communication technology - - - i. Food processing - - - j. Drinks manufacture - - -

mailto:[email protected]


Page 2

k. Textile manufacturing 7 8125 98000 l. Leather processing - - -

m. Electronic manufacturing - - - n. Pharmaceutical production 4 1680 29000 o. Plastics formulation/processing 35 800 160000 p. Paint manufacture - - - q. Ceramics/glass manufacture - - - r. Pulp and paper production - - - s. Packaging manufacture - - - t. Metal plating - - - u. Others Focus Engineering Goods 41 10460 628000

Non-Metallic Minerals 6 1788 447000 Shipping ancillary & naval offsets 26 5280 317000 FTWZ 17 8670 0 Housing - 2629 0

7. Service industries proposed in the IE a. Transport Yes b. Warehousing Yes c. Chemical storage Yes d. Recycling Yes e. Waste treatment/disposal Yes f. Laboratories Yes g. Information technology No h. Banking, finance and insurance No 8. Details of Environmental features On site Within 25 km radius a. Reserved Forests No Yes

Dhuva Reserve Forest (10.7 km, SE)

b. Vegetation/Tree cover Yes Predominantly Single Crop, Land without Scrub

Yes Scrub forest, single crop and double crop land, land with scrub

c. Wetlands, swamps, mangroves No Yes Small patch of mangroves comprising mainly of Avicinnea sp. (15 km, SE)

d. Lakes No Yes Kharod Dam

13.9 km, NE

Rajada Reservoir

2.0 km, NE

Vengadi Reservoir

0.7 km, West

Don Reservoir

5.5 km, NE

e. Rivers and creeks No Yes


Page 3

Vengadi Nadi

0.7 km, West

Kharod River1

0.3 km, East

Sai Nadi 11.5 km, West

Rukmavati River

11.4 km, East

f. Sea coast No Yes Arabian Sea ~8.0 km, South

g. Protected Areas No No h. Places of tourist interests No Yes

Asharmata Temple at 7.3 km, South

Jain Temple at Mota Layja at 1.6 km, South

Swamy Narayana Temple at 14.0 km, SE

9. List of the human habitations nearby

Rural/urban area Number of inhabitants

Distance (km)

a. Bayath, Bhinsra, Gandhigram, Godhra, Janakpur, LayjaMota, Nagrecha, Padampar, Rajada, Ratadia Mota, Ratadia Nana, Undoth Moti, Undoth Nani, Undoth Brahmanvali

13,995 0-5

b. Bada, Bhada, Bhadai Moti, Bhadai Nani, Bharapar, Bhojay, Dedhia, Dhokda, Don, Durgapur/Nawawas, Gangapar, Hamlo, Kathda, Kokalia, Kotdi, Layja Nana, Manjal, Mapar, Merau, Panchatia, Poldia, Pyaka, Changadai, Sabhrai, Sherdi, Shirva, Vada

31,700 5-10

c. Bambhadai, Godalakh, Halapar, Koday Kotaya, Madanpur, Makda, Mau Moti, Mod Kuba, Nagalpar, Ratnapur, Rayan Moti, Rayan Nani, Vandh, Vindh, Boha, Daha, Karodiya Mota

23,907 10-15

10. Transport links a. Bus National Highway - NH-8A (0.7 km,

Southwest) State Highway - SH-47 connecting

Mandvi and Bhuj (15.1 km, East) SH-49 connecting Bhuj and Naliya (25.8

km, North) SH-48 connecting Bhuj and Mundra

(36.5 km, East) b. Train Railway station at Kothara (meter

gauge) at 32.8 km, NW Railway station at Bhuj (broad gauge) at

~55 km, NE 1 No industrial activities are planned in the area within 500 m from Kharod River. Only Portion of Non Processing Area’s Greenbelt is proposed.


Page 4

c. Others Airport at Bhuj (~52 km), NE Major Port at Kandla (~100 km), East Seaport at Mundra (~51 km), East

B. INFRASTRUCTURE FACILITIES PROPOSED IN THE IE This identifies a number of services and features that may be linked to environmental performance. Who provides or is responsible for the following services, tools or actions?

1. Industrial Estate Authority

1 2 3 4 5 2. Operational Units 3. Government Authority 4. Private Sector 5. Other (Please specify) 1. Energy (also State requirement in K Cal) a. Centralized energy supply b. Individual energy supply c. Supply and recovery of waste heat

(cogeneration)

d. District heating system e. Energy from waste facility f. Energy from renewable resources facility 2. Water (also State requirement in KL) a. Municipal service b. Tube wells c. Treatment facilities d. Waste water disposal e. Liquid waste disposal f. Waste water recycling g. Rainwater harvesting h. Sewage disposal 3. Solid waste (in Metric Tons) a. Solid waste disposal b. Composting of biological waste c. Industrial liquid waste disposal d. Hazardous waste disposal e. Waste exchange clearing house f. Multi-material resource recovery g. Including collection, storage & treatment 4. Transport (attach traffic risk assessment report) a. Traffic and transport management plan 5. Management a. Environmental monitoring b. Effluent monitoring c. Air emission monitoring d. Environmental auditing e. EMP & implementation of risk mitigation

measures

f. Environmental technology assessment g. Environmental training and education h. Emergency preparedness and response

capability

i. Self-regulation and operational standards j. Finance and insurance services 6. Miscellaneous a. Restoring natural features of the site


Page 5

b. Landscaping and gardening c. Analytical and laboratory services d. Protection and security system C. MAIN STAKEHOLDERS 1. List of units requiring individual

environmental clearance (in future) Nil. As per EIA Notification 2006, (as

Amended), IE obtains prior environmental clearance, individual industries including proposed industrial housing within such estates /complexes will not be required to take prior environmental clearance, so long as the Terms and Conditions for the industrial estate/complex are complied with.

The major units such as 4000 MW Thermal Power Plant (TPP) and 2000 MW Gas Based Combined Cycle Power Plant (CCPP) is included in the EIA report and clearance will be obtained for them also along with other industrial sectors proposed.

2. Details of issues raised in the environmental public hearing

Details of public hearing are given in EIA report as Volume III.

D. FINANCE ARRANGEMENTS Yes No

1. Local financial institutions and banks a. If yes, what influence do they have? 3. Owners 4. Conditionalities on investments and

credits

5. Others E. ENVIRONMENTAL IMPACT ASSESSMENT TO COVER 1. Baseline Conditions Covered in Chapter 3 of the EIA Report

(Volume 1) - Description of Environment 2. Impact Assessment including carrying

capacity of the area Covered in Chapter 4 of the EIA Report (Volume 1) - Anticipated Environmental Impacts and Mitigations Measures

3. Social Impact Assessment including Rehabilitation Action Plan (if any)

Covered in Chapter 7 of the EIA Report (Volume 1) – Additional Studies; Section 7.4

4. Risk Assessment and Onsite and offsite Emergency Response Planning

Covered in Chapter 7 of the EIA Report (Volume 1) – Additional Studies; Section 7.1

5. Environmental Management Plan Covered in Chapter 9 of the EIA Report (Volume 1) – Environment Management Plan (EMP)

6. Details of environmental parameters to be monitored (frequency and implementation agency)

Covered in Chapter 6 of the EIA Report (Volume 1) – Environmental Monitoring Programme

F. POTENTIAL ENVIRONMENTAL THREATS This assessment is for the entire estate, not for individual units 1. ‘Imminent threats’ to human health and/or the environment (‘imminent’ means high-

risk threats that require immediate action to reduce risks and liabilities) Threat Actions proposed to be taken

a. IE consists of Red, Orange and green Emissions and discharges from the IE will


Page 6

category industries. Red category industries such as Power Plants etc., may pose threat if emissions and discharges are not controlled.

be within the standards prescribed by GPCB/CPCB/MoEF. Industries will adopt the pollutions control measures such as ESP/Stack with specified height/Low NOX burners/Dust Suppression system, ETP/STP/CETPs etc., Risk Assessment studies were carried out and adequate safety measures were suggested.

2. Likely Environmental ‘trouble spots’ Trouble spot Actions proposed to be taken

a. IE consists of Red, Orange and green category industries. Red category industries such as Power Plants etc., may pose threat if emissions and discharges are not controlled.

Emissions and discharges from the IE will be within the standards prescribed by GPCB/CPCB/MoEF Risk Assessment studies were carried out and adequate safety measures were suggested.

3. Major sources & quantities of wastes (solid, air, liquid) likely to be generated in the IE

Sources Inventory Actions proposed to be taken

a. Solid Waste

i. Hazardous Waste 44.2 TPD Will be sent to common hazardous facility/TSDF nearby

ii. Non-hazardous Waste

Biodegradable Waste 17.5 TPD

Composting and Greenbelt application/To engineered sanitary landfill/Vermi composting/RDF, etc.

Total Recyclable Waste

24.1 TPD Will be given to GPCB approved recycling units/vendors

Inert material 12046.5 TPD

To ash pond and fly ash utilization; inert waste will be sent to proposed landfill

b. Air Inventory of Air emissions from the SEZ and Actions proposed to be taken is given as Appendix 1

c. Liquid wastes Total Sewage and Effluent Generation in SEZ/FTWZ and DTA – 5.97 MLD (including NPA generated sewage) and 26.045 MLD of Effluents. Sewage/Effluent from 4000 MW TPP:

0.384 MLD/4.68 MLD Sewage/Effluent from 2000 MW

CCPP: 0.084/0.468 MLD Sewage/Effluent from Other

SEZ/FTWZ and DTA Units: 5.502 MLD/20.897 MLD

Total Return Cooling (Sea) Water: 780.9 MLD From 4000 MW TPP: 612.7 MLD From 2000 MW CCPP: 168.2 MLD. Reject Brine from Desalination Plant: 111 MLD Discharge from the TPP and desalination plant will be 891.9 MLD. The outfall discharge of 19.4 MLD of SEZ CETP treated effluent is mixed in the guard pond


Page 7

along with TPP and desalination plant discharge and during rainy season 7.04 MLD of treated sewage from SEZ and both the power plants will also be mixed. In addition 3 MLD of treated wastewater from shipyard cum captive jetties will be discharged through marine outfall system. The combined outfall quantity of ~921.4 MLD will be discharged into sea through outfall pipes.

4. Habitat/wildlife Issues of concern Actions proposed to be taken

a. Impact on Flora The detailed flora fauna has been carried out by engaging a reputed wild lift scientist with working experience from Gujarat Ecological and Education, Research Foundation (GEER). None of the plant species recorded from the core area belongs to the Rare/Endangered / Endemic / Threatened category. However, in Project influence area Plants having medicinal values Commiphora wightii and Tribulus terrestris were observed.

Since patches of forest plantation are located in buffer area, it will be taken utmost precautions not to further degrade these areas by constructing temporary roads, dumping materials, solid wastes, garbage or any other form of material in to the surrounding grasslands. Rest of the project activities may not have any significant impacts on the vegetation of project area and surrounding area, in general, and on the plant species of higher conservation significance, in particular. Plantation of Commiphora wightii by involving local forest department or community

b. Impact on Fauna None of the Faunal species recorded from the core area belongs to the Rare/Endangered / Endemic / Threatened category. However in Project influence area, the species such as Olive Ridely Seaturtle (Lepidochelys olivacea) (VU), Green Seaturtle (Chelonia mydas) (EN), Long-billed Vulture (Gyps indicus) (CR), White-rumped Vulture (Gyps bengalensis) (CR), Indian Wolf (Canis lupus pallipes) (EN) were reported.

Terrestrial Reptiles: Rehabilitation of Terrestrial Reptiles. Local biologist or trackers can be consulted in rehabilitating these individuals from their burrows. Birds: Laying of transmission lines for evacuation of the power to the SEZ and associated structures and facilities shall be planned carefully. The power lines shall be kept at a safe distances from sensitive bird habitats such as water bodies and forest plantation areas in order to avoid bird mortalities due to collisions. It will be ensured that no pollutants discharged into the nearby water bodies. Mammals: Maximum precautions will be taken so that the waterholes/water bodies and forest nursery and other forest areas in the study area are also not disturbed. Sea Turtles: In Kutch coast sporadic nesting is reported. The Wildlife Conservation Plan has provided some mitigations measures to conserve sea turtles though the nesting is reported to be very sporadic in the project area;


Page 8

The artificial beachfront lighting problem may be the most manageable of the human-caused sea turtle disturbances. Although some lighting is necessary for safety and security, light management measures can help prevent interference with sea turtle nesting habitat while still addressing human safety concerns. These measures include following: Using lamps with a narrow area of

focus i.e. lamps with a narrow field of scattering light

Turning off unnecessary lights during the nesting season.

Using a smaller number or lower wattage of lights; repositioning, shielding, redirecting, lowering, or recessing fixtures so light does not reach the beach;

Moreover, sea turtles are less affected by red, yellow, and low-pressure sodium-vapor lights, which can be substituted for ordinary lights.

Construction activities shall be avoided in peak breeding/nesting season of sea turtles (December, Venkatesan et al. 2004).

Intake and outfall system shall be designed keeping in view of avoiding the entanglement issues of turtles.

Wild life conservation were prepared and authentication from CWLW were also obtained. Some of the Species specific recommendations are

Name Recommendations

Green Seaturtle/ Olive Ridley

Monitor beach for sea turtle nesting, No disturbance shall be caused to nesting sites during construction and operation, Contribute towards conservation activities

Rat Snake/Saw Scaled Viper

Common throughout India no special measures suggested

White–rumped Vulture/ Long-billed Vulture

No large trees or feeding sites present in core area so no impact envisaged by project activities

Indian Peafowl

Common throughout India no special measures suggested


Page 9

Black-tailed Godwit/ Eurasian Curlew/ Oriental White Ibis/ Painted Stork

Ensure no pollutants discharged into water bodies, No power lines be laid near or over water bodies

Hyena/ Indian Wolf/ Chinkara

Do not cause any direct disturbances to forest plantation and water bodies located in buffer areas

5. Potential sources of industrial accidents, explosions and fires, health and safety issues Potential sources Actions proposed to be taken

a. Accidents during Construction Phase o Mechanical Accidents o Transportation Accidents o Physical Accidents o Storage and Handling of

Hazardous Materials Accidents during Operation Phase

o Material Accidents o Mechanical Accidents o Handling, Storage and

Transportation Accidents o Plant Accidents

Accidents due to Natural Calamities o Earthquake o Tsunami o Cyclone/Flood

Risk Assessment studies were carried out for the potential industries causing accidents, explosions and fires, health and safety issues and present in the EIA report.

Proper wiring of the electrical appliances like lights, exhausts, etc., would be made to ensure that there are no live wires causing short circuits to ignite materials.

Layout of equipment/machinery is being done in accordance to factory and electrical inspectorate.

All electrical fittings and cables are to be provided as per the specified standards.

HC leak detectors are to be provided. Spillages are to be collected and

neutralized for toxic contents before disposal.

Extra care shall be taken by providing rupture disc, pressure release valve and temperature controller

All the chemicals will be provided with identification labels

Eye wash/Drench shower is to be provided at a strategic location for emergency purpose

Chemical Safety Data Sheets and handling procedure, First Aid measures are to be prepared and displayed for information and safety of the working personnel.

Other Risk mitigation measures are given in Appendix 3.

6. Sources of environmental threats in adjacent areas Sources Actions proposed to be taken

a. None -


Page 10

LIST OF ENCLOSURES

1. Land purchase agreement

Details of land parcel purchased for the project use / purpose and Sample sale deed agreement copy are given in Annexure-A

2. Land use/Zoning particulars-relevant portions from the prevailing local Regulations Annexure-B

3. Cost estimates inclusive of land cost Annexure-C 4. Landscape plans with proposed tree plantation Annexure-D 5. Water balance statement Annexure-E 6. Rainwater harvesting plan Annexure-F 7. Storm water drainage Annexure-G 8. Material balance studies, if carried out - 9. Common effluent treatment plant-details with a write up Annexure-H 10. Statement on the machinery & manpower during construction Annexure-I 11. Fire protection measures & approvals obtained Annexure-J

12. Proceedings of Environmental Public Hearing also provide response to points raised in the public hearing

Proceedings of Public Hearing are given as a part of EIA i.e, Volume III.

13. Approval of competent authorities in case of conversion of agricultural land, change of land use, DC rules Annexure-K

14. Construction schedule (CPM/PERT chart) Annexure-L

15. Approval from special bodies (State Industries Commissioner/SIDC/financial institutions) Annexure-M

16. Approvals if applicable from ASI, Civil Aviation, ecologically sensitive areas, coastal development regulations, etc Annexure-N

17. Solid waste collection, treatment, storage, transportation and disposal plan Annexure-O

18. Vehicle parking and management Annexure-P

19. Environment Impact Assessment Study (including Executive summary)

Standalone Documents given as Volume I and II

20. Schedule-II Application Form for EC - 21. Questionnaire for IE This Document

22. Inventory of Air emissions from the SEZ and Actions proposed to be taken Appendix 1

23. Proposed Common Utilities/ Industry Related Facilities Appendix 2

L&T INFRASTRUCTURE ENGINEERING LIMITED (Formerly Known as L&T-RAMBØLL CONSULTING ENGINEERS LIMITED)

6-3-1192/1/1, 5th Floor, Block No.3,

White House, Kundan Bagh, Begumpet, Hyderabad – 500 016

Ph: 91-040-40354444; Fax: 91-040-40354430

As the file size for uploading is limited to 20

MB, therefore, all Annexure/Appendices were

deleted.

Entire report along with necessary

Appendices/Annexure is submitted in both

hard and soft (CD) copy to MoEF.

DEMARCATION OF HTL, LTL AND CRZ BOUNDARIES FOR THE PROPOSED MULTI PRODUCT

SEZ/FTWZ & DTA INCLUDING POWER AND DESALINATION PLANTS AT LAYJA MOTA,

MANDVI TALUK, KUTCH DISTRICT, GUJARAT.

1

DISTRIBUTION RESTRICTED NIO/SP-22/2014

(SSP-2514)

DEMARCATION OF HTL, LTL AND CRZ BOUNDARIES FOR THE PROPOSED

MULTIPRODUCT SEZ/FTWZ & DTA INCLUDING POWER AND

DESALINATION PLANTS AT LAYJA MOTA, MANDVI TALUK, KUTCH

DISTRICT, GUJARAT.

PART-II

For

M/s. Sealand Ports Private Limited,

M/s. Avash Logistic Park Private Limited,

M/s. Nana Layja Power Company Limited.

December 2014

– CSIR-NATIONAL INSTITUTE OF OCEANOGRAPHY

( ) (COUNCIL OF SCIENTIFIC & INDUSTRIAL RESEARCH)

, / DONA PAULA, GOA - 403004

India /Tel : 91(0)832-2450450/ 2450327

/Fax: 91(0)832-2450602 - /e-mail : [email protected]

http:// www.nio.org




2

DEMARCATION OF HTL, LTL AND CRZ BOUNDARIES FOR THE PROPOSED

MULTI PRODUCT SEZ/FTWZ & DTA INCLUDING POWER AND

DESALINATION PLANTS AT LAYJA MOTA, MANDVI TALUK, KUTCH

DISTRICT, GUJARAT.

PART - II

For

M/s. Sealand Ports Private Limited, M/s. Avash Logistic Park Private Limited & M/s.

Nana Layja Power Company Limited, promoted by ILFS.

Scientist-In-Charge: Dr. V.S.N. Murty Project Leader: Dr. B. Prabhakara Rao

NATIONAL INSTITUTE OF OCEANOGRAPHY

Council of Scientific & Industrial Research

Regional Centre, Visakhapatnam – 530 017

INDIA

NOVEMBER 2014




3

CONTENTS

Description of the Item Page No.

PREFACE 4

PROJECT PERSONNAL 5

LIST OF FIGURES 5

LIST OF PLATES 5

1.0 NTRODUCTION 6

1.1 Background 6

1.2 Project Description 7

1.3 Tide 9

1.4 Objective 10

1.5 Approach 10

1.6 Data Source 11

2.0 MATERIALS AND METHODS 12

2.1 Definition of LTL and HTL 12

2.2 The Projection system 12

2.2.1 Differential Global Positioning System (DGPS) 13

2.2.2 Electronic Total Station 14

3.0 RESULTS 17

3.1 CRZ General Rules 17

3.2 Survey Details 18

3.3 Presentation of maps 18

3.4 Salient observations from the CRZ map 19

4.0 SUMMARY AND CONCLUSIONS 20

ACKNOWLEDGEMENTS 21




5

Project Personnel

Dr. V.S.N. Murthy Scientist-In-Charge

Dr. B. Prabhakara Rao Principal Investigator

Mr. Y.S.N. Raju Sr. Technical Officer

Mr.Ch. Jawahar Kumar Sr. Technical Officer

Mr. B. Prasad Project Assistant

Miss.M.Swapna Project Assistant

List of Figures

Figure

No.

Description

1 Location Map of the survey area.

2 Demarcation of LTL, HTL and CRZ areas (covering 7km radius) near

project site, Kharod nadi and open coast in 1: 25,000 scale.

3 Demarcation of LTL, HTL and CRZ boundaries for project site in 1: 4,000

scale.

4 Demarcation of LTL, HTL and CRZ boundaries for project site in 1: 4,000

scale.

5 Land use features from the satellite imagery

List of Table

Plat No Description

1 to 4 Photographs showing the land use pattern of the SEZ project area.




6

Chapter 1

INTRODUCTION

1.1 Background:

M/s. Sealand Ports Private Limited (SPPL) & Avash Logistic Park Private Limited

(ALPL) propose to develop a Multi-Product Special Economic Zone (SEZ), a Free Trade

and Warehousing Zone (FTWZ) and a Domestic Tariff Area (DTA) at Layja Mota in Kutch

District, Gujarat. Infrastructure Leasing & Financial Services Limited (IL&FS) is promoter

of this project. M/s. Nana Layja Power Company Limited (NLPCL), a Special Purpose

Vehicle (SPV) of IL&FS Energy Development Company Limited (IEDCL) proposed to

develop 4000 MW TPP, 60 MLD Desalination Plant and 2000 MW CCPP in the proposed

Multiproduct SEZ/FTWZ.

IL&FS Maritime Infrastructure Company Limited (IMICL), a subsidiary of IL&FS is co-

developing a Shipyard cum Captive Jetties including LNG Terminal at Nana Layja in

Mandvi Taluka, Kutch District, Gujarat through its subsidiary Gujarat Integrated

Maritime Complex Private Limited (GIMCO) and SPPL. This proposed Shipyard cum

Captive Jetties including LNG Terminal is located about 8.0 km south of proposed

Multiproduct SEZ/FTWZ. The requirements of SEZ/FTWZ such as Coal for 4000 MW TPP,

Gas for the 2000 MW CCPP and other import/exports of SEZ industries are proposed to be

met from the Captive Jetties and LNG Terminal proposed at Nana Layja.

In this context, project proponents had approached National Institute of Oceanography

(NIO), which is one of the authorized agencies by MoEF for carrying out the HTL, LTL, CRZ

demarcation and mapping in the Project area near Layja Mota and open coast near Nana

Laya Villages of Mandvi taluk, Kutch district. Regional Centre of NIO, Visakhapatnam has

carried out the required surveys and field measurements for the demarcation of HTL, LTL

and CRZ during the period from 01.12.2010 to 05.12.2010 and 06.02.2013 to 10.02.2013

and 27.02.2013 to 02.03.2013.




7

The present report details the methodology followed in physical demarcation of High Tide

Line (HTL), Low Tide Line (LTL) and delineation of CRZ boundaries along the coastline

near Nana Layja in Mandvi Taluka, Kutch District of Gujarat. While demarcating various

aspects like HTL, LTL and CRZ boundaries, the procedures given in the guidelines of MoEF

were followed. After mapping, the locations of HTL (identified to be associated with

shoreline morphological features), LTL and the locations have been transferred on to a

map. Various designated boundaries of Coastal Regulation Zone were delineated and

marked on the map.

National Institute of Oceanography Regional Centre (NIO-RC) has conducted the

necessary field works and submitted the report in two parts.

Part I Demarcation of High Tide Line (HTL), Low Tide Line (LTL) and CRZ

boundaries for the proposed Shipyard cum Captive jetties including

LNG terminal at Nana Layja village of Mandvi Taluk, Kutch District,

Gujarat.

Part II

Demarcation of HTL,LTL and CRZ boundaries for the proposed

Multiproduct SEZ/FTWZ & DTA including Power and Desalination

Plants at Layja Mota, Mandvi Taluk, Kutch District, Gujarat

This report forms as the Part II report on CRZ Studies for the Multiproduct SEZ/FTWZ &

DTA including Power and Desalination Plants of ILFS Group.

1.2 Project Description :

M/s. Sealand Ports Private Limited (SPPL) & Avash Logistic Park Private Limited

(ALPL) propose to develop a Multi-Product Special Economic Zone (SEZ), a Free Trade and

Warehousing Zone (FTWZ) and a Domestic Tariff Area (DTA) at Layja Mota in Kutch

District, Gujarat. Infrastructure Leasing & Financial Services Limited (IL&FS) is promoter

of this project. SEZ Section of Department of Commerce, Ministry of Commerce and

Industries (MoCI) has granted in-principle approval for the project. The Industries

Commissioner, GoG has issued a Bonafide Certificate to use the identified land for

industrial purpose.




8

A 4000 MW Thermal Power Plant (TPP) supplemented with a 60 MLD Desalination

Plant and a 2000 MW Gas Based Combined Cycle Power Plant (CCPP) are planned to be

developed within the proposed SEZ/FTWZ and DTA. In addition, other potential sectors

identified for investment in the proposed SEZ and FTWZ include Logistics, Focus

Engineering Goods, Textiles & Handicrafts, Shipping Ancillary and Naval Offsets. Plastic

industry, Pharmaceuticals & Medicinal Products, Basic Chemicals, Polymer Products, Allied

and Speciality Chemicals, Textiles and Handicrafts and Non Metallic Minerals are the

industrial sectors proposed in the DTA. This project shall also have Non-Processing Area

(NPA) and associated infrastructure facilities to cater the requirements of industries

proposed within SEZ/FTWZ and DTA.

M/s. Nana Layja Power Company Limited (NLPCL), a Special Purpose Vehicle

(SPV) of IL&FS Energy Development Company Limited (IEDCL) proposed to develop

4000 MW TPP, 60 MLD Desalination Plant and 2000 MW CCPP in the proposed Multiproduct

SEZ/FTWZ.

IL&FS Maritime Infrastructure Company Limited (IMICL), a subsidiary of IL&FS

is co-developing a Shipyard cum Captive Jetties including LNG Terminal at Nana Layja in

Mandvi Taluka, Kutch District, Gujarat through its subsidiary Gujarat Integrated

Maritime Complex Private Limited (GIMCO) and SPPL. This proposed Shipyard cum

Captive Jetties including LNG Terminal is located about 8.0 km south of proposed

Multiproduct SEZ/FTWZ. The requirements of SEZ/FTWZ such as Coal for 4000 MW TPP,

Gas for the 2000 MW CCPP and other import/exports of SEZ industries are proposed to be

met from the Captive Jetties and LNG Terminal proposed at Nana Layja.

A dedicated Utility Corridor is proposed to connect the Shipyard cum Captive Jetties

and the SEZ/FTWZ project site. The utility corridor will have coal conveyor, gas pipeline,

seawater intake/outfall pipelines, potable water supply pipelines, 66 KV D/C power

transmission line and access road.

The project site is located in Kutch district of Gujarat at a distance of 1.5 km North

of Layja Mota village and 18 km NW of Mandvi town (Taluk headquarters). The other

major towns near the project site are Mundra, Bhuj and Kandla at a distance of 52 km (SE),




9

55 km (NE) and 100 km (East) respectively. Geographical co-ordinates of the site are 22º

56’ 11” North Latitude and 69º 14’ 20” East Longitude.

For the project development, associated facilities such as Coal conveyor, gas

pipeline, seawater intake/outfall pipelines, potable water supply pipelines, 66 KV D/C

power transmission line and access road connecting SEZ/FTWZ & DTA and shipyard cum

captive jetties including LNG terminal will pass through Coastal Regulation Zone (CRZ)

area. The project attracts the CRZ notification, 2011 and Coastal Regulation Zone (CRZ)

demarcation studies are required to be carried out for obtaining necessary permission

from Ministry of Environment and Forests (MoEF).

Keeping in view the stipulations in the Coastal Regulation Zone legislation, National

Institute of Oceanography has undertaken the project with the following scope of work.

• To demarcate of HTL and LTL and CRZ boundaries near Kharod nadi,

backwaters, if any and along the open coast near Nana Layja village of

Mandvi taluk, Gujarat as per the prescribed policy, practice and procedure of

MoEF.

• To delineate the set back lines of 500 m and 200 m from the HTL boundary

on open coast.

• To delineate the set back lines of 100 m along the Kharod nadi and other

creeks/back waters.

• Identification of sensitive areas such as mangroves if any, in the proposed

project site, along the utility corridor and open coast.

Based on the above objectives, studies were made about land use pattern,

morphological features and environmentally sensitive areas, to predict the impact of the

proposed development within CRZ. The results are presented in the form of this report and

the physical demarcation of HTL and restricted development boundaries are presented in

the form of a CRZ map annexed to this report (Figs. 2, 3&4).

1.3 Tide

The spring and neap tidal ranges in the region are about 3.2 m and 1.8 m

respectively. The various tide levels with respect to Chart Datum as presented in Naval

Hydro graphical Chart (No. 203) published by Surveyor General of India.




10

Tide Levels at Mandvi

Height (m) above Chart Datum (CD)

Mean Low Water Spring 0.9

Mean Low Water Neap 1.7

Mean Sea Level 2.6

Mean High Water Neap 3.5

Mean High Water Spring 4.1

1.4 Objective

The objective of the study is to delineate the HTL, LTL and Coastal Regulation Zone

(CRZ) boundaries as notified by the Ministry of Environment and Forest (MoEF),

Government of India, along the open coast and creeks, if any in the 7 km radius and

superimposition of the project layout with power plants and desalination plant on

HTL/LTL, CRZ map.

1.5 Approach

Based on the above objective, studies have been made on the land use pattern,

morphological features and environmentally sensitive areas to predict the response of the

proposed development within CRZ. The key elements of the approach are as follows:

1. To delineate the HTL, LTL and CRZ boundaries along open coast, Kharod nadi and

nearby creeks .

2. To conduct the primary field inventory and transfer the data on large scale base

map

3. To gather information on the status of eco-system (such as mangroves, tidal flats,

saltpans etc) prevalent in the study area.

4. To compile the CRZ map delineating the HTL, LTL and the CRZ boundaries.

5. To interpret and demarcate CRZ setbacks using AutoCAD

6. Superimposition of project layout on HTL, LTL and CRZ map.




11

1.6 Data Source

The following data sources were used in the compilation of the final map and

preparation of the CRZ report.

i. Project layout with intake and outfall facilities.

ii. Field mapping.

iii. Satellite imagery and land use map of study area.




12

Chapter 2

Materials and Methods

2.1 Definition of LTL and HTL

For the purpose of meeting the requirement of the CRZ notification, the High Tide

Line (HTL) means the line on the land up to which the highest water line reaches during

the spring tide. Here the word “highest water line reaches during the spring tide” refers to

the mean high water spring (19 years average of spring water) that is the regular water level

fluctuations caused by changes in relative position of Sun, Moon and the Earth.

Coastal stretches of sea, bays, estuaries, creeks, rivers and back waters which are

influenced by tidal action (on land ward side) are included in Coastal Regulation Zone

(CRZ). Highest range of spring tide and its horizontal run up on the land was identified by

way of morphological features, permanent vegetation line, monsoonal crest and flotsam

along the open sea and along the creek as per the existing guideline of MoEF. Delineation

of HTL was carried out by using the Differential Global Positioning System techniques

(Hemisphere) and Total Station, the data were collected by following the established

principles in survey of this nature. For demarcation of Low Tide Line (LTL), we have

considered surf zone spot bathymetry observations at low tide time.

2.2 The Projection System

The WGS-84 Datum and Transverse Mercator Projection have been used for

presenting the HTL, LTL on the map and also for preparing the CRZ classification map.

Finally the positions of HTL, LTL and CRZ boundary lines were marked on the CRZ maps in

1:25000 and 1: 4000 scale (Figs. 2 &3&4).




13

2.2.1 Differential Global Positioning System (DGPS)

The horizontal positioning of the mobile unit was

carried out using Hemisphere R100 Series DGPS Beacon

Receiver. It combines high-performance GPS reception with

a DGPS-capable receiver in a lightweight, durable housing and comes with a separate

antenna. It gives the horizontal position to an accuracy of close to 1 m. The GPS receiver

also contains technology enabling WAAS/EGNOS, OmniSTAR or Beacon real time

differential capabilities. When used with a Real- time Kinematic (RTK) Base station, the

GPS receiver provides RTK positioning for high-accuracy, centimeter-level applications. A

standard GPS receiver provides the following features:

• 10 Hz (10 positions per second) output rate

• 12 GPS (C/A-code L1, C/A code L2 (for the OmniSTAR XP/HP and RTK models))

tracking channels, code carrier channels

• Sub meter differential accuracy (RMS), assuming at least five satellites and a PDOP

(Position Dilution of Precision)of less than four (when used with Satellite Based

Augmentation Systems (SBAS) correction).

The system configuration is enabled with:

• LED display and keypad

• Outputs a 1 PPS (pulse per second) strobe signal on both ports. This signal enables

an external instrument to synchronize its internal time with a time derived from the

very accurate GPS system time.

• SBAS such as WAAS (Wide Area Augmentation System) differential correction 1

• Beacon differential correction

• Omni STAR VBS capability

• Omni STAR XP/HP capability in the XP/HP and RTK models (also available as an

upgrade)

• RTK positioning capability, In the RTK model only (also available as an upgrade)




14

• EVEREST ™ multipath rejection technology

• Two connectors that support both CAN 2.0B and RS-232:

• –CAN: J1939 and NMEA 2000 messages

• –RS-232:

• NMEA-0183 output: GGA, GLL, GRS, GST, GSA, GSV, MSS, RMC, VTG, ZDA (the default

NMEA messages are GGA, GSA, VTG, and RMC).

2.2.2 ELECTRONIC TOTAL STATION

In the improved method, to obtain the geographical

positions of baseline points “A” and “B”, “HEMISPHERE”

differential global positioning system was used. This

instrument computes geographical position of any point

using the raw data collected from four satellites in the

horizon. Also, it receives transit time error corrections from nearby land based marine

beacons. After applying these corrections, the final position is obtained which has an

accuracy within a meter. These positions can be entered in electronic total station to get

the azimuth of the baseline “AB”. Electronic Total Station of “TOPCON” make and “GPT-

3002N” model was used for obtaining geographical co-ordinates and elevation of every

point sighted with respect to G.T.S. benchmark “A”. Electronic Total Station uses both an

invisible Pulse Laser Diode for distance measurement and a visible Red Laser Beam as a

laser pointer to identify the measurement point at the center of the cross hair lines of the

telescope. The instrument has a keyboard containing 24 keys, which makes it easier and

quicker to key in codes and other alphanumeric characters. The output contains several

displays based on user’s choice. The output contains measured field data display listing

horizontal angle, vertical angle and laser measured slant distance, computed co-ordinate

data display listing geographical location of the point surveyed (Easting, Northing) and

elevation of the surveyed point with respect to the instrument station elevation and so on.

A dual axis compensator sensor is included in this model, which automatically corrects the




15

horizontal and vertical angle compensation for leveling error, thereby ensuring accurate

and reliable reading.

The specifications of the instrument are as follows:

1) Maximum distance measurable using single prism: 3000 meters.

2) Accuracy in distance measurements: ± (2 mm. + 2 ppm. × D) where “D”

Denotes measured distance (mm)

3) Least Count in measurement: I) Fine measurement mode: 1mm.

ii) Coarse measurement mode: 10mm.

4) Accuracy in angle measurements: 2″ (2seconds).

5) Optical Plummet magnification: 3X

6) Weight of the instrument (including battery): 5.3 Kgs.

7) Operating temperature: --20° to +50° C

8) Maximum operating time including distance measurement: 4.2 hrs.

(Rechargeable battery)

9) Battery charger recharging time: 1.8 hrs.

10) External battery: Input voltage: DC 7.0 to 9.8 V.

11) Display: Graphic LCD Display 160 Χ 64 Dots with backlight.

12) Internal memory: has a large internal memory to store upto 24,000 points for

field data collection and layout works.




16

METHOD OF SURVEY:

First, the geographical positions of both “A” and “B” were obtained accurately in

WGS-1984 UTM co-ordinates using DGPS instrument. Electronic Total Station was set up

over Point “A” and all initial settings such as leveling, etc. were done very accurately. The

U.T.M. (Universal Transverse Mercator) co-ordinates and elevations of both “A” and “B”

were entered through the keyboard of the Total station. The height of the optical centre of

the instrument with respect to mean sea level of Point “A” and the height of the reflector

prism were measured accurately and entered. The reflector prism was exactly placed over

Point “B” and measurement was taken to compare the DGPS values of Point “B” with that of

Total station’s computed values of “B”. After confirming the position matches, the HTL and

LTL surveys were commenced using Total station. By aiming the survey points accurately

and releasing the laser pulse, geographical positions (in UTM) as well as the elevation

values of all survey points were computed by the instrument and recorded into the

memory. The data thus collected was downloaded from the memory to a computer using

data transfer cable, for further processing and preparation of CRZ maps.




17

Chapter 3

Results 3.1 CRZ GENERAL RULES

The Central Government, with a view to ensure livelihood security to the fishing

communities and other local communities living in the coastal areas; to conserve and

protect coastal stretches, its unique environment and its marine area and to promote

development in sustainable manner based on scientific principles taking into account the

dangers of natural hazards in the coastal areas including sea level rise due to global

warming, has declared the coastal stretches of the Country and the water area upto its

territorial water limit, excluding the islands of Andaman and Nicobar and Lakshadweep

and the marine areas surrounding these islands upto its territorial limit, as the Coastal

Regulation Zone. Setting up and expansion of any industry, operations or processes and

manufacture or handling or storage or disposal of hazardous substances are restricted in

the CRZ. The following areas are declared as CRZ:

(i) The land area from High Tide Line (HTL) to 500 m on the landward side along the

sea front.

(ii) Land area between HTL to 100 m or width of the creek whichever is less on the

landward side along the tidal influenced water bodies.

(iii) The land area falling between the hazard line and 500 m from HTL on the landward

side, in case of seafront and between the hazard line and 100 m line in case of tidal

influenced water body.

(iv) Land area between HTL and Low Tide Line which is termed as the intertidal zone.

(v) The water and the bed area between the LTL to the territorial water limit (12 Nm)

in case of sea and the water and the bed area between LTL at the bank to the LTL on the

opposite side of the bank, of tidal influenced water bodies.

A key component of the coastal regulation zone is the setback lines measured from the high

tide line through which coastal development is regulated in a protected zone contiguous to

HTL. These setback lines are with reference to the HTL and act as buffer zones between the




18

ocean and the upland property. Thus precision is required in delineating the HTL which

forms the base to define the setback.

3.2 Survey Details

The HTL and LTL were demarcated by physical survey in the study area as per the

MoEF guidelines. The horizontal position of HTL, associated with wave run up at preceding

high tides and forming geomorphic features and the features such as boundary of

perennial natural terrestrial vegetation, flotsam, drift wood and embankments have been

considered. The identification of these markings enabled a reasonably accurate assessment

of High Tide Line. Low Tide line was demarcated from the surf zone bathymetry. On

demarcation of High Tide Line, Low tide line and CRZ boundaries, the plan annexed to this

report was prepared in the scales of 1: 25000 (Fig. 2), and 1: 4000 (Fig. 3&4). Physical

demarcation of HTL, LTL and the delineation of CRZ boundaries relevant to the project site

was carried out. Approved CZMP plan of Gujarat Government was referred. Land use map

(Fig 5) was prepared based on the satellite imagery.

3.3 Presentation of maps

The observations in respect of HTL, LTL and other setback lines are presented on

the maps of 1: 25000 (Fig. 2), 1: 4000 (Fig.3&4) scale. The legend for different

demarcations like HTL, LTL and project facilities are also given in the CRZ map. Along the

open coast the setback lines of 200 m and 500 m from the HTL and 100 m setback line for

Kharod nadi and creeks were demarcated as per CRZ notification.




19

3.4 Salient observations from the CRZ map

Figure 2 and 3 shows the demarcation of HTL, LTL and CRZ areas with proposed

project layout. Land use map of the area (Fig. 4) shows the existing land use features of the

study area. Physical demarcation of HTL, LTL was carried out along the open coast near

Nana Layja and Kharod Nadi and creeks in the study area. The proposed project site is

located at 8.0 km north of coastal area of Nana Layja. The project site does not fall under

CRZ area, whereas utility corridor will be passing the CRZ area and seawater intake and

marine outfall facilities will fall under CRZ area. The project site and utility corridor area

comprises of mostly land without scrub, single crop agriculture land, gullied and ravenous

land comprises of barren lands and stony waste area (Plates 1 to 4). The proposed project

site is in Non CRZ area as the distance between HTL and project site is about 8 km and

about 6 km away from tidal influenced (CRZ) area of Kharod nadi.

Seawater intake and marine outfall facilities will fall in CRZ IV and the utility corridor

containing seawater, marine outfall pipelines, coal conveyor, gas pipelines, transmission

lines and road etc., will pass through CRZ I (B), CRZ IV and CRZ III zones as per CRZ

notification, 2011. The project site and proposed seawater intake, marine outfall facilities

and utility corridor does not fall under any environmentally sensitive areas like Natural

Parks, Sanctuaries, Coral reefs or areas rich in genetic diversity and Mangroves.




20

Chapter 4

Summery and Conclusions

Based on the observations made during the field visits and also as per the policy,

practice and procedure of MoEF, the following conclusions have been drawn.

• Physical demarcation of HTL, LTL and CRZ boundaries relevant to the project site

were carried during the period from 01.12.2010 to 05.12.2010 and 06.02.2013 to

10.02.2013 and 27.02.2013 to 02.03.2013.

• Land use mapping using the Satellite imagery was prepared.

• The whole stretch of relevant High Tide Line (HTL) is supported by the

geographical features such as terrestrial vegetation and sandy coast.

• The position of HTL, LTL and CRZ boundaries are demarcated in the scales of 1:

25000 (Fig. 2), 1: 4000 (Fig. 3&4) respectively.

• Approved CZMP of Government of Gujarat was referred for the preparation of this

report.

• Land use map of the area (Fig. 5) shows the existing land use features in 15 km

radius. The area mapped is a coastal strip on either side of Kharod nadi near Nana

Lajya village of Mandvi Taluk in Gujarat.

• The project site and utility corridor area comprises of mostly land without scrub,

single crop, gullied and ravenous land and stoney waste area.

• The area between HTL and 500 m set back line near the utility corridor is comprises

of thorny bushes.

• On either side of Kharodi nadi, CRZ area is comprises of tidal flats and thorny

bushes.

• The area in the 7 Km radius of the study area comprises of thorny bushes, creeks,

land with scrub, single crop agriculture lands, stoney waste area and settlements.

• The proposed project site falls under non CRZ area as the distance between HTL

and project site is about 8 km and about 6 km away from tidal influenced (CRZ) area

of Kharod nadi.

• The proposed utility corridor containing seawater, marine outfall pipelines, coal

conveyor, gas pipelines, transmission lines and road etc., will pass through CRZ I(B)

and CRZ III zones.

• The project site and proposed seawater intake, marine outfall facilities and utility

corridor will not fall under any environmentally sensitive areas like Natural Parks,

Sanctuaries, Coral reefs or areas rich in genetic diversity and Mangroves.

• The proposed fuel transportation system and wastewater conveyance system etc.,

in the utility corridor is a permissible activity as per the CRZ Notification, 2011.




21

Details of facilities attracting the CRZ Notification 2011 from the CRZ map and their

permissibility.

S.

No. Infrastructure Facility

Falling in CRZ

Area with

Classification

Permissible/

Not

Permissible

as per CRZ

notification,

2011

Applicable

Clause no. of

CRZ

notification,

2011

1. SEZ NON CRZ Area Permissible CRZ not

applicable

2. Seawater intake CRZ IV Permissible 4(ii)(f)

3. Seawater Intake Pump house CRZ III Permissible 4(ii)(f)

4.

Marine outfall for discharge of

treated wastewater and return

cooling water

CRZ IV Permissible 4(ii)(f)

5.

Utility Corridor (coal

conveyor, gas pipeline, sea

water intake/ marine outfall

pipelines, transmission lines,

road etc.)

CRZ I (B) &

CRZ III Permissible

4(ii)(d) &

8(III)(A)(iii)(h)

6.

Outfall pipeline within

Shipyard cum captive jetties

including LNG terminal

premises

Pipe length of 2132 m



CRZ IV

CRZ I(B)

CRZ III

Permissible

4(ii)(d),

8(I)(i)(b) &

8(III)(A)(i)

7.

Seawater intake pipeline

within Shipyard cum captive

jetties including LNG terminal

premises



CRZ IV

CRZ I (B)

Permissible 4(ii)(d) &

8(I)(i)(b)

ACKNOWLEDGEMENTS

We express our grateful thanks to the Director, NIO, Goa for his permission to take

up this work and to Shri. K.Mohan Rao for reviewing the report.




22




23




24

Plate 1

Plate 2




25

Plate 3

Plate 4