Post on 23-Dec-2021
Annexure – C2 – English Translation
Vanitaben Masribhai Vansh
Post Alidar, Ta. Kodinar, Dist. Gir Somnath
Date: 24.08.2021
Mob. 9275297093
To,
Additional Collector Competent Authority
Gujarat state Petronet Limited.
Subject: Following point properly consider for Public hearing scheduled on 24.09.221 at Girgadhada
location
The above applicant Alidar village owns agricultural land.
Our area has been declared as a sensitive zone by the Central Government and there are approximately
25 to 30 lions living permanently within the boundaries of our village.
Sugarcane and wheat crops are mainly grown in our area. After harvesting these crops, the farm will
have to be set on fire to dispose of them, which seems to be the cause of a very big accident due to this
gas pipeline.
Due to the fact that the land in our area is divided into small pieces, even the small survey numbers are
fragmented due to coming out of the pipeline so that a very serious situation seems to arise regarding
the distribution of property.
We seem to have to bear the brunt of the damage when it comes to getting a power connection or an
underground water line to our court through this pipeline.
Also provide other facilities so that there is a possibility of severe damage to our agricultural land. This
pipeline comes from Lothpur to Chhara as well as Veraval. But the line is likely to come out at a lower
cost if this line is parallel to the highway which drains from the land acquired from the side of the
Narmada pipeline, the government has an advantage in roads as well as other operations.
Thus, we request you to consider the above and consider it when decision is made by you
Yours faithfully,
Vanitaben Masari Vansh
Annexure – C3 – English Translation
Aam Aadmi Parti, Gujarat
Shri. Bhasinhbhai Samatbhai Gohil
President, Kodinar Taluka
Mob.: 9228724344
Points for Public Hearing Dated 24.08.2021
Subject: Regarding the public hearing
The 200-page report is published in English.
Gir Gadhada sarpanch has not informed.
All farmers should be informed.
Farmers are outraged.
No one was notified before the hearing.
There is also a rule of fire in sugarcane fields
There is complete opposition to farmers
A total of 6 villages are included
Wants to pay according to the price of the land
Construction should not take place in the line
It is stated in this public hearing that farmers get proper compensation.
And all the farmers should be drawn there
Yours faithfully,
Bhavsinhbhai Govindbhai Vala
dua-Hu Us, y.Saus, al.deuan, .ola aiuru titH.OROs-RCUJYY s-.00s-24300
e-mail- collectorgirsomnath@gmail.com
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Annexure – C4 – English Translation
Name: Arjanbhai HIrabhai Banbhaniya
Post: Devali ( Dedani)
Ta: Kodinar
Dist. Girsomnath
Mo.9904032890
To,
Respected Collector,
At Inaj.
Subject: M/s. Gujarat State Petronet Ltd.'s connection of Shapurji Energy Pvt. Ltd. with LNG Terminal at Village Chhara connected with Gujarat State Petronet Ltd.'s Dispatch Terminal at Village Lothpur -Regarding Environmental Impact
To state with Jai Bharat that,
I Shri. Arjanbhai Dhirabhai Bambhaniya requesting that the above subject has been announced in the
Divya Bhaskar newspaper dated 23.04.2021 as per New Delhi Declaration No. 1533, Dated 14.09.2006 of
the Ministry of Environment and Sustainable Change, Government of India. Following are the issues of
impact on human life as well as animals, birds, sea creatures and wildlife due to the spread of the
project.
1. With the advent of small and big industries in the state of Gujarat for the last fifteen to twenty
years, the required amount of oxygen in the air has decreased and if this project comes up, the
current amount of oxygen will be greatly reduced and human life as well as livestock and other
creatures will be affected.
2. This project is to come to the coast. Most of the people here are mainly engaged in fishing as
well as agriculture. People who make a living by fishing are coming here. With the coming of this
project, the amount of pollution will increase. This will push people to a greater extent into
poverty.
3. There are a large number of such industries along the coast of Gujarat and still due to such
industries the people living along the coast will suffer from deadly diseases like cancer, heart
attack, respiratory, asthma, TB and so on and most of the people will die. The truth will come
out if a survey is done about this at present.
4. The agricultural land of Kodinar taluka is fertile and the people of this area are dependent on
agriculture as well as animal husbandry, the livelihood of most of the people is being run by
agriculture and animal husbandry, then it will have a detrimental effect on the farmers.
5. This gas pipeline will pass through the soil of the farmers and there is a danger of damage at any
time and the bacteria that nourish the plants in the soil of the farmers will be destroyed due to
this temperature and gradually the fertile lands will become barren. Due to this, the crops of the
farmers will fail over time and the farmers will sink into the mound of debt. Due to which
farmers will turn to suicide and the suicide rate of farmers in Gujarat will increase.
6. Large numbers of wildlife come to the coast during the summer season to escape the heat and
water scarcity in the forest area. This project will also have an impact on them.
7. So that the line is being passed in the farmer’s field will pass through an area of 30meters which
will result in massive distillation of the trees in the farmer’s land. This is detrimental to the
climate and despite a large number of farmers protesting against this, no response has been
given by you Sir. The peasants are fiercely opposed to your dictatorship. If the issue of farmers is
not taken into consideration then there will be a fierce agitation by the farmers in the coming
time and if necessary all the farmers along with our family will commit suicide or mass suicide.
All the responsibility for that will be with you sir.
My humble request is to take immediate action keeping in view the health of the people, if the above
points need to be taken into consideration for human life as well as animal and bird, to prevent all
diseases related to the effects of pollution in the future. Just expect the same cooperation.
Your faithfully,
Arjanbhai HIrabhai Banbhaniya
Annexure – C5 – English Translation
Advocatee S. J Mer( Ramesh Mer)
At. Kodinar, Vakil House, Office no.7, Ta. Kodinar,
Dist. Gir Somnath, Dated 13/08/2021
Mob.: 7359315215
1. To Hon’ble Collector,
District GirSomnath
At. Inaj, Ta. Veraval
2. To Hon’ble Collector,
Office of Collectorate,
At. Amreli
Subject: Ministry of Environment, Forests and Climate Change, Government of India, New Delhi
Declaration No. SO 1533, Dt.14.09.2020 Matter of making the information related to the project available in
Gujarati language for the information of the proposed affected people and in the meanwhile Matter of
postponing the public hearing to be held on dated 24/08/2021 Gir Gadhada & Dated 01.09.2021
It is requested with Jay Bharat that,
We affected area people representing our demand and objections in respect to public interest that
1. Public hearing scheduled on Dated 24.08.2021 at Girgadhada under the supervision of The Hon’ble
Collector, Gir Somnath for M/s Gujarat State Petronet Limited. laying Natural Gas transportation
pipeline to connect proposed LNG Terminal of HPCL Shapoorji Energy Pvt. Ltd. (HSEPL) from Village–
Chhara (Dist. Gir Somnath) to Gujarat State Petronet Ltd. (GSPL)’s Dispatch terminal at Village-
Lonthpur (Dist. Amreli). As a part of this public hearing Public Notice given by the Member Secretory,
Gujarat Pollution Control Board in the newspaper by 92/21-22 to all affected local people for their kind
attention and to give their present in the public hearing function as well as submission of written
representation before public hearing.
2. As provided in above Govt. Notice, during public hearing affected people get chance to represent their
questions, objections, problems. But the major problem is that the project details provided to affected
area people is not in Gujarati Language( Gujarat Stat local language). As per right to information 2005,
we have provided Draft Environmental Impact Assessment and Environmental Management Plan , Risk
Assessment and Disaster Management Plan report in English for Chhara Lothpur Natural Gas
transportation pipeline through Taluka Develoment officer, Kodinar Office.
3. If Draft report/project proponent report is in Gujarati language then only major people from the affected
area think on it. But as informed by the project official that the report is available in English. It is not
printed in Gujarati Language and its Gujarati copy is not published for public. This matter is serious by
this.
4. We have demanded information for this project to Taluka Development officer, Kodinar and information
received in English. So, we have filed an appeal in the Information Commission, Gandhinagar. The
appeal is currently pending. It is also imperative that the public hearing be adjourned in the interest of
justice until the effect of this appeal is resolved amicably.
Therefore, as a conscious citizen of India, we demand in the public interest that,
A. The above project report should be disseminated in Gujarati language and the local people should be
informed about this project report in the village meetings in the affected villages so that the affected people
can submit their objections and suggestions. Drafting in English makes it clear that fraud has taken place
with the affected.
B. The said project report /project proponent report to be published in Gujarati immediately and if it not
published in Gujarati, our demand is to postponed public hearing Dated 24.08.2021 at Girgadhada and
Dated 01.09.2021 at Motamansa upto people not getting information in Gujarati .
C. It is in the public interest to take into account the provisions of the fundamental rights of citizens in the
Constitution of India.
Place: Kodinar
Date: 13.08.2021 S. J. Mer
Cc to:
1. Chief Justice , Gujarat high Court
2. Governor of Gujarat State, Devvrat Sir
3. Mamlatdar, Kodinar
4. Mamlatdar, Girgadhada
5. Gujarat Pollution Control Board, Gandhinagar
6. Additional Principal Chief Conservator of Forests (C), Government of India, Bhopal
7. Regional office, Gujarat Pollution Control Board, Junagadh
8. Gujarat State Human Right Commission, Gandhinagar
9. National Human Right Commission, New Delhi
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Annexure – C6 – English Translation
Arajanbhai Hirabhai Bambhaniya
P.O.: Devli( Dedani)
Ta.: Kodinar, Dist.: Girsomnath
Date: 06/05/2021
Mob.: 9904032890
To,
Hon’ble Chief Minister
Vijaybhai Rupani,
Gandhinagar.
Subject: Regarding postpone of Environmental public hearing by Gujarat Pollution Control Board with
information Dated 19.04.2021 with /92/21-22 Dated 28.05.2021 .
Dear Sir,
I like to inform you with Jay Bharat that it is kind request from Kodinar, Una & Girgadhada farmers that
at present in our country terrible corona epidemic is going on and hence govt. has given permission only
for 50 person limit for marriage and other function, in spite of this permission granted by Member
Secratory , Gujarat pollution Control Board, Paryavaran Bhavan, Sector – 10A, Gandhinagar, Dated
28.02.2021. In this hearing, a large number of farmers will give their present and there will be a fear of
infections and in reference to above subjected matter, farmer’s demand is to be postponed public
hearing.
Above matter hearing conducted at Village Chhara during 2015/2016, that time also farmers gathered
and protested. If the attention is not given in this matter and if farmers infected then all responsibility
will be yours.
With your all cooperation,
Cc to:
1. Hon’ble Collector, Girsomnath
2. Hon’ble Member Secretary, GPCB
3. Hon’ble, Mamlatdar
4. Kodinar Taluka Khedut Mandal Devli
5. Kisan Ekta Samiti Kodinar
Yours,
On behalf of all farmers
Arjanbhai Hirabhai Bambhaniya
Bharatbhai Rajabhai
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Annexure – C7 – English Translation
Ref. no. 365 Date: 24.08.2021
To,
The Regional officer,
Gujarat Pollution Control Board
Gir Somnath.
Subject: Our objection and questions regarding Gujarat State Petronet Limited public hearing Dated
24.08.2021
It is to inform you with Jay Bharat that our objection and questions regarding Gujarat State Petronet
Limited public hearing is as given below:
1. How many numbers of villages covers in this Pipeline and how many villages has given
application to change the route of pipeline?
2. It is humble request to give the information that which steps to be taken for accident prevention
in this project and where awareness program given by you for accident prevention.
3. How much tress will be cut by this activity and which trees will be planted kindly know us.
4. It is humble request to know us that which steps will be taken to not destroy land fertility where
pipeline layed.
5. It is humble request to give the information that maintenance time after laying of pipeline and
who will do.
6. It is humble request to know us that what compensation will be given to farmers for land
acquisition and how it will be given.
7. It is humble request to know us that what is the life of pipeline and which process does for
replacing pipeline.
8. As per the Forest protection act 1980, for laying of the pipeline in forest area, if forest
permission is required then it will be taken or not.
9. It is humble request to know us that the land in which pipeline layed, for how much space
permission has been given and for how much space permission has not given.
Yours,
Bhavna Vyas
President- Shree Shiv Gau Rakshak Dal
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Annexure – C8 – English Translation
To,
1. Hon’ble Collector
Competent Authority
Gujarat State Petronet Limited
Collector office, Gandhinagar
2. Authorized officer,
Gujarat State Petronet Limited
GSPL Bhavan, E-18,
GIDC Electronic Estate,
Near K-7 Circle, Sector-26,
Gandhinagar.
Subject: Objection to my client regarding acquisition of land and the determination of his
compensation.
Respected Sir,
The land with Survey number 315, Paiki 1 at bodidar Village, Taluka Girgadhada, Dist.
Girsomnath is independent ownership of my client ( Shri. Nathubhai Hajibhai Vala) which has
been acquired based on Right of Use bases by Gujarat State Petronet Limited for transportation
of Natural gas from Lothpur to Chhara LNG.
In every stage of acquisition objection represented in spite of that not enough attention has
been given to that objection and have been overlooked under a uniform bureaucratic
framework and thus presented to my client at the cost of destroying his vital productive assets /
assets without adequate financial and economic compensation, thus this whole process of
acquisition is malicious and arbitrary.
First of all, it was introduced, before the period of acquisition plan and you were reminded of
the fact that there is an alternative way of acquisition in which this public purpose project could
be implemented without damaging the property of my client.
Nonetheless, everything is hitting the deaf ear and it seems likely that no serious effort has been
made to find an alternative way to at least damage my client and his property.
Further stating that compensation is defined under Section 10 of the Gujarat Water and Gas
Pipeline (Acquisition of Right of Use of Land) Act 2000 (hereinafter referred to as Act 2000
hereby) which is published under sub-clause (1) of section 3 of the Compensation Act 2000.
Compensation has to be paid as per the market value of the land on the date of publication of
the notification.
Although it was introduced here that this provision should be fully considered and implemented
in the true sense of the word, but it did not happen.
It was also submitted that my client was informed that the amount of compensation would be
paid as per the Jantri of the year 2011, but since then the amount of Jantri has not improved till
today which violating the fundamental, Juristic and other established rights of my client.
It was further submitted that the market price of land in the state of Gujarat is determined on
the basis of jantri or circle rate. Jantri of land is determined by the Revenue Department,
Government of Gujarat and is later published by resolution. Thus Jantri is basically a ready
reckoner (ready calculation) for determining the market price. Therefore, when the State
Legislative Assembly resolves that the amount of compensation should be determined on the
basis of the market value of the land, the rational sub-principle that applies is that the
competent authority / collector should update the market price and declare the compensation
accordingly. In the present circumstances, if this order is to be implemented, when the
competent authority determines the market price on the basis of Jantri, it is necessary to update
and revise the market price and also to follow the necessary sub-principle of revising the Jantri
accordingly.
It was therefore submitted that in the present case the competent authority has not made any
improvement in the market price nor has it taken any concrete steps to improve or change the
market price of land based on the prevailing market rate in the area. Thus, my client's right has
been harmed by not enforcing the Juristic order.
The last amendment of Jantri in the state of Gujarat was made in 2011 and therefore the rate of
Jantri or Circle’s rate is being used by the competent authority as a ready reckoner. Thus relying
on it is tantamount to encroaching on the rights of my client.
It is stated that the purpose of updating and improving the jantri rate in the context of the
Stamp Act, 1958 is to enable the government to generate higher revenue through higher stamp
duty and premium. This is the only reason why the CAG's latest report to the state government
alleges that the state government's failure to revise the annual revenue rate sheet / jantri
(market price) has resulted in a loss of crores of rupees to the state exchequer.
It was introduced and stated that in our welfare states, the market price / jantri should be
scientifically improved / updated from time to time as per the principle of trust and interest as
the objective is to generate maximum revenue. It is the policy of the Government of Gujarat to
revise the rate sheet at the end of each year so that maximum revenue can be generated
through stamp duty and premium collection. Thus when a policy decision is guided from a
business point of view rather than a revision of the market price / jantri and thus the loss of
revenue is a clear violation of Article 14 of the Constitution.
The “public interest” and the “general interest” are the two factors that determine what is
desired under Article 14 of the Constitution, as mandated by the principle of public interest.
Market price / jantri improvement and updating is not directly but indirectly based on the goal
of social welfare and public interest as improvement in jantri / market price can result in
increase in state revenue by collecting stamp duty and premium and thus collected. Growing
fiscal food can be controlled by distributing the revenue generated through welfare policies.
In addition, it has been stated that as per the Gujarat Stamp Act, revision and updating of market price means improvement in the annual rate statement or amendment in the jantri
which is colloquially spoken in Gujarat. The market value of Section 1 (NA) of the Gujarat Stamp
Act 1958, if sold on the open market on the date of implementation of such instrument, defines
the value of the property as such. Thus, the market price should be revised and updated by formulating a solid / basic scientific valuation process to estimate the value of the property with specific, streamlined procedures comprising all factors including sale price comparison, trend analysis and GIS based maps to ensure true market value of the property.
It is also stated that the annual statement / calendar for the year 2011 which is being considered
for determining the market value of the existing property has not been scientifically determined
or even credible. Therefore it is necessary to revise the market price in order to determine the
appropriate and adequate compensation as per the order of Act 200, which means that as per
the Gujarat Stamps Act 1958, the annual statement / jantri of rate has to be amended / updated
and also perform the process consistently as a solid / basic scientific evaluation. And all these
processes have to be completed before the user is informed of the acquisition of the right as the
market price which is prevailing on the date of basic notification is to be considered as the basis.
Thus, the failure of the competent authority to improve the market value is in violation of
Article 14 of the Constitution of India and is arbitrary. It is stated that periodic revision in market
value / jantri not only increases the revenue of the state, but also helps in maintaining the
targets of the 2000 Act to declare adequate compensation to the affected landowners under the
acquisition.
In addition, it was further stated that the determination of market value in the State of Gujarat
is done through Section 32-A of the Gujarat Stamps Act, 1958 and its Rule 5 and the Pet Rules
framed under it and the amendments made therein in 2016. Thus, the market price in the state
of Gujarat is initially determined on the basis of the annual statement of jantri / circle rate / rate
which is generally considered as a ready reckoner for determining the market price. The annual
rate statement itself indicates that it has to be prepared on an annual basis. In addition, as per
the order of amendment made in Rule 6 in the year 2016, the annual statement of rate should
be prepared by the Superintendent of Stamps and Inspector General of Registration, State of
Gujarat, Gandhinagar and they themselves should submit it to the Revenue Department before
31st October every year for approval and consent of Revenue Department. And the
Superintendent shall issue the ASR on the 1st of April every year as per the order.
The provisions of Section 32-A introduced under the Reforms Act, 2004 are as under.
"For the purpose of this subdivision, the calculations made by the State Government,
Central Government, Local Bodies, Gujarat Housing Board, Gujarat Slum Clearance Board
or Gujarat Industrial Development Corporation in the agreement will be considered as the
actual market value of the property.”
The competent authority or the Special Land Acquisition Officer may make a decision on the
basis of all the relevant evidence and material relating to the sale transactions registered by the
State. These factors need to be taken into consideration while determining the market value as
the market value determined as per the statutory order should not be less than the
compensation specified in the contract conducted by the State Government. However, this is
not done even in complete violation of the legal order. This matter completely ignores the
provisions of Section 32-A of the Gujarat Stamps Act, 1958 and shows great prejudice against
the applicant.
Thus, even independently, the provisions of Section 32-A of the Bombay Stamp Act, 1958 have
been completely disregarded and allowed to determine the market value and hence the process
of determining compensation is illegal, malicious, arbitrary and illegal. Being unconstitutional in
violation of Articles 14, 19 and 21 of the Constitution remains unconstitutional.
It has also been stated that representations / arguments / support / hardening etc. made on
issues like market value compensation etc. are made without prejudice to the logic / argument
of my client that I am sincere to find an alternative way to at least damage my client and his
property. Attempts have not been made and the arguments / representations / statements
made on the issue of compensation and market value to my client to challenge their rights and
remedies / or to challenge the legitimacy of their proceedings and without sufficient thought
work on the matter for their own benefit. Submissions / Objections / Requests are not
considered to have violated their rights for non-compliance and no reason has been given /
provided by your office for non-compliance.
With regard to appropriate representations, it is sincerely requested that ......
A] The claims / representations / objections made by my client for consideration of an
alternative route for laying the pipeline under the Lotpur to Chhara LNG pipeline connection
scheme for transportation of natural gas should be taken into consideration by the appellant.
B] The market price of the land concerned should be revised and then the compensation should
be determined on the basis of such revised market price from the date of initial notification and
ordered to maintain the status quo till the market price correction is completed.
Thanks,
Valmiki Vyas, Advocate
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Annexure – C9 – English Translation
To,
1. Hon’ble Collector
Competent Authority
Gujarat State Petronet Limited
Collector office, Gandhinagar
2. Authorized officer,
Gujarat State Petronet Limited
GSPL Bhavan, E-18,
GIDC Electronic Estate,
Near K-7 Circle, Sector-26,
Gandhinagar.
Subject: Objection to my client regarding acquisition of land and the determination of his
compensation.
Respected Sir,
The land with Survey number 315, Paiki 2 at bodidar Village, Taluka Girgadhada, Dist.
Girsomnath is independent ownership of my client ( Shri. Hareshbhai Rambhai Vala) which has
been acquired based on Right of Use bases by Gujarat State Petronet Limited for transportation
of Natural gas from Lothpur to Chhara LNG.
In every stage of acquisition objection represented in spite of that not enough attention has
been given to that objection and have been overlooked under a uniform bureaucratic
framework and thus presented to my client at the cost of destroying his vital productive assets /
assets without adequate financial and economic compensation, thus this whole process of
acquisition is malicious and arbitrary.
First of all, it was introduced, before the period of acquisition plan and you were reminded of
the fact that there is an alternative way of acquisition in which this public purpose project could
be implemented without damaging the property of my client.
Nonetheless, everything is hitting the deaf ear and it seems likely that no serious effort has been
made to find an alternative way to at least damage my client and his property.
Further stating that compensation is defined under Section 10 of the Gujarat Water and Gas
Pipeline (Acquisition of Right of Use of Land) Act 2000 (hereinafter referred to as Act 2000
hereby) which is published under sub-clause (1) of section 3 of the Compensation Act 2000.
Compensation has to be paid as per the market value of the land on the date of publication of
the notification.
Although it was introduced here that this provision should be fully considered and implemented
in the true sense of the word, but it did not happen.
It was also submitted that my client was informed that the amount of compensation would be
paid as per the Jantri of the year 2011, but since then the amount of Jantri has not improved till
today which violating the fundamental, Juristic and other established rights of my client.
It was further submitted that the market price of land in the state of Gujarat is determined on
the basis of jantri or circle rate. Jantri of land is determined by the Revenue Department,
Government of Gujarat and is later published by resolution. Thus Jantri is basically a ready
reckoner (ready calculation) for determining the market price. Therefore, when the State
Legislative Assembly resolves that the amount of compensation should be determined on the
basis of the market value of the land, the rational sub-principle that applies is that the
competent authority / collector should update the market price and declare the compensation
accordingly. In the present circumstances, if this order is to be implemented, when the
competent authority determines the market price on the basis of Jantri, it is necessary to update
and revise the market price and also to follow the necessary sub-principle of revising the Jantri
accordingly.
It was therefore submitted that in the present case the competent authority has not made any
improvement in the market price nor has it taken any concrete steps to improve or change the
market price of land based on the prevailing market rate in the area. Thus, my client's right has
been harmed by not enforcing the Juristic order.
The last amendment of Jantri in the state of Gujarat was made in 2011 and therefore the rate of
Jantri or Circle’s rate is being used by the competent authority as a ready reckoner. Thus relying
on it is tantamount to encroaching on the rights of my client.
It is stated that the purpose of updating and improving the jantri rate in the context of the
Stamp Act, 1958 is to enable the government to generate higher revenue through higher stamp
duty and premium. This is the only reason why the CAG's latest report to the state government
alleges that the state government's failure to revise the annual revenue rate sheet / jantri
(market price) has resulted in a loss of crores of rupees to the state exchequer.
It was introduced and stated that in our welfare states, the market price / jantri should be
scientifically improved / updated from time to time as per the principle of trust and interest as
the objective is to generate maximum revenue. It is the policy of the Government of Gujarat to
revise the rate sheet at the end of each year so that maximum revenue can be generated
through stamp duty and premium collection. Thus when a policy decision is guided from a
business point of view rather than a revision of the market price / jantri and thus the loss of
revenue is a clear violation of Article 14 of the Constitution.
The “public interest” and the “general interest” are the two factors that determine what is
desired under Article 14 of the Constitution, as mandated by the principle of public interest.
Market price / jantri improvement and updating is not directly but indirectly based on the goal
of social welfare and public interest as improvement in jantri / market price can result in
increase in state revenue by collecting stamp duty and premium and thus collected. Growing
fiscal food can be controlled by distributing the revenue generated through welfare policies.
In addition, it has been stated that as per the Gujarat Stamp Act, revision and updating of market price means improvement in the annual rate statement or amendment in the jantri
which is colloquially spoken in Gujarat. The market value of Section 1 (NA) of the Gujarat Stamp
Act 1958, if sold on the open market on the date of implementation of such instrument, defines
the value of the property as such. Thus, the market price should be revised and updated by formulating a solid / basic scientific valuation process to estimate the value of the property with specific, streamlined procedures comprising all factors including sale price comparison, trend analysis and GIS based maps to ensure true market value of the property.
It is also stated that the annual statement / calendar for the year 2011 which is being considered
for determining the market value of the existing property has not been scientifically determined
or even credible. Therefore it is necessary to revise the market price in order to determine the
appropriate and adequate compensation as per the order of Act 200, which means that as per
the Gujarat Stamps Act 1958, the annual statement / jantri of rate has to be amended / updated
and also perform the process consistently as a solid / basic scientific evaluation. And all these
processes have to be completed before the user is informed of the acquisition of the right as the
market price which is prevailing on the date of basic notification is to be considered as the basis.
Thus, the failure of the competent authority to improve the market value is in violation of
Article 14 of the Constitution of India and is arbitrary. It is stated that periodic revision in market
value / jantri not only increases the revenue of the state, but also helps in maintaining the
targets of the 2000 Act to declare adequate compensation to the affected landowners under the
acquisition.
In addition, it was further stated that the determination of market value in the State of Gujarat
is done through Section 32-A of the Gujarat Stamps Act, 1958 and its Rule 5 and the Pet Rules
framed under it and the amendments made therein in 2016. Thus, the market price in the state
of Gujarat is initially determined on the basis of the annual statement of jantri / circle rate / rate
which is generally considered as a ready reckoner for determining the market price. The annual
rate statement itself indicates that it has to be prepared on an annual basis. In addition, as per
the order of amendment made in Rule 6 in the year 2016, the annual statement of rate should
be prepared by the Superintendent of Stamps and Inspector General of Registration, State of
Gujarat, Gandhinagar and they themselves should submit it to the Revenue Department before
31st October every year for approval and consent of Revenue Department. And the
Superintendent shall issue the ASR on the 1st of April every year as per the order.
The provisions of Section 32-A introduced under the Reforms Act, 2004 are as under.
"For the purpose of this subdivision, the calculations made by the State Government,
Central Government, Local Bodies, Gujarat Housing Board, Gujarat Slum Clearance Board
or Gujarat Industrial Development Corporation in the agreement will be considered as the
actual market value of the property.”
The competent authority or the Special Land Acquisition Officer may make a decision on the
basis of all the relevant evidence and material relating to the sale transactions registered by the
State. These factors need to be taken into consideration while determining the market value as
the market value determined as per the statutory order should not be less than the
compensation specified in the contract conducted by the State Government. However, this is
not done even in complete violation of the legal order. This matter completely ignores the
provisions of Section 32-A of the Gujarat Stamps Act, 1958 and shows great prejudice against
the applicant.
Thus, even independently, the provisions of Section 32-A of the Bombay Stamp Act, 1958 have
been completely disregarded and allowed to determine the market value and hence the process
of determining compensation is illegal, malicious, arbitrary and illegal. Being unconstitutional in
violation of Articles 14, 19 and 21 of the Constitution remains unconstitutional.
It has also been stated that representations / arguments / support / hardening etc. made on
issues like market value compensation etc. are made without prejudice to the logic / argument
of my client that I am sincere to find an alternative way to at least damage my client and his
property. Attempts have not been made and the arguments / representations / statements
made on the issue of compensation and market value to my client to challenge their rights and
remedies / or to challenge the legitimacy of their proceedings and without sufficient thought
work on the matter for their own benefit. Submissions / Objections / Requests are not
considered to have violated their rights for non-compliance and no reason has been given /
provided by your office for non-compliance.
With regard to appropriate representations, it is sincerely requested that ......
A] The claims / representations / objections made by my client for consideration of an
alternative route for laying the pipeline under the Lotpur to Chhara LNG pipeline connection
scheme for transportation of natural gas should be taken into consideration by the appellant.
B] The market price of the land concerned should be revised and then the compensation should
be determined on the basis of such revised market price from the date of initial notification and
ordered to maintain the status quo till the market price correction is completed.
Thanks,
Valmiki Vyas, Advocate
Annexure – C10 – English Translation
1. To Hon’ble Collector,
District GirSomnath
At. Inaj, Ta. Veraval
2. To Hon’ble Collector,
Office of Collectorate,
At. Amreli
Subject: Ministry of Environment, Forests and Climate Change, Government of India, New Delhi
Declaration No. SO 1533, Dt.14.09.2020 Matter of making the information related to the project available in
Gujarati language for the information of the proposed affected people and in the meanwhile Matter of
postponing the public hearing to be held on dated 24/08/2021 Gir Gadhada & Dated 01.09.2021
It is requested with Jay Bharat that,
We affected area people representing our demand and objections in respect to public interest that
1. Public hearing scheduled on Dated 24.08.2021 at Girgadhada under the supervision of The Hon’ble
Collector, Gir Somnath for M/s Gujarat State Petronet Limited. laying Natural Gas transportation
pipeline to connect proposed LNG Terminal of HPCL Shapoorji Energy Pvt. Ltd. (HSEPL) from Village–
Chhara (Dist. Gir Somnath) to Gujarat State Petronet Ltd. (GSPL)’s Dispatch terminal at Village-
Lonthpur (Dist. Amreli). As a part of this public hearing Public Notice given by the Member Secretory,
Gujarat Pollution Control Board in the newspaper by 92/21-22 to all affected local people for their kind
attention and to give their present in the public hearing function as well as submission of written
representation before public hearing.
2. As provided in above Govt. Notice, during public hearing affected people get chance to represent their
questions, objections, problems. But the major problem is that the project details provided to affected
area people is not in Gujarati Language( Gujarat Stat local language). As per right to information 2005,
we have provided Draft Environmental Impact Assessment and Environmental Management Plan , Risk
Assessment and Disaster Management Plan report in English for Chhara Lothpur Natural Gas
transportation pipeline through Taluka Develoment officer, Kodinar Office.
3. If Draft report/project proponent report is in Gujarati language then only major people from the affected
area think on it. But as informed by the project official that the report is available in English. It is not
printed in Gujarati Language and its Gujarati copy is not published for public. This matter is serious by
this.
4. We have demanded information for this project to Taluka Development officer, Kodinar and information
received in English. So, we have filed an appeal in the Information Commission, Gandhinagar. The
appeal is currently pending. It is also imperative that the public hearing be adjourned in the interest of
justice until the effect of this appeal is resolved amicably.
Therefore, as a conscious citizen of India, we demand in the public interest that,
A. The above project report should be disseminated in Gujarati language and the local people should be
informed about this project report in the village meetings in the affected villages so that the affected people
can submit their objections and suggestions. Drafting in English makes it clear that fraud has taken place
with the affected.
B. The said project report /project proponent report to be published in Gujarati immediately and if it not
published in Gujarati, our demand is to postponed public hearing Dated 24.08.2021 at Girgadhada and
Dated 01.09.2021 at Motamansa upto people not getting information in Gujarati .
C. It is in the public interest to take into account the provisions of the fundamental rights of citizens in the
Constitution of India.
Place: Kodinar
Date: 13.08.2021 Vaja Tapubhai Rajabhai
Former Sarpanch Sarkhadi & Advocate Kodinar
Mob.: 9276158807
Cc to:
1. Chief Justice , Gujarat high Court
2. Governor of Gujarat State, Devvrat Sir
3. Mamlatdar, Kodinar
4. Mamlatdar, Girgadhada
5. Gujarat Pollution Control Board, Gandhinagar
6. Additional Principal Chief Conservator of Forests (C), Government of India, Bhopal
7. Regional office, Gujarat Pollution Control Board, Junagadh
8. Gujarat State Human Right Commission, Gandhinagar
9. National Human Right Commission, New Delhi
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S2CLASSIFIE
Annexure – C11 – English Translation
Rohitkumar Pratapsinh Vala and effected farmers
Post Sarkhadi, Ta. Kodinar, Dist. Gir Somnath
Date: 04.05.2021
To,
The Memeber Sacratory,
Gujarat Pollution Control Board,
Paryavaran Bhavan, Sector-10 A,
Gandhinagar.
Subject: M/s Gujarat State Petronet Limited. (For a Part of Dist. Gir Somnath) for laying Natural Gas
transportation pipeline of approx. length 86.615 km & 36” Dia. to connect proposed LNG Terminal of
HPCL Shapoorji Energy Pvt. Ltd. (HSEPL) from Village–Chhara (Dist. Gir Somnath) to Gujarat State
Petronet Ltd. (GSPL)’s Dispatch terminal at Village-Lonthpur (Dist. Amreli) – Regarding postponed of
public hearing
Ref.: Divyabhaskar Daily Dated : 23.04.2021 Public Notice.
Dear Sir,
This is to inform you that M/s Gujarat State Petronet Limited planned (For a Part of Dist. Gir Somnath)
for laying Natural Gas transportation pipeline of approx. length 86.615 km & 36” Dia. to connect
proposed LNG Terminal of HPCL Shapoorji Energy Pvt. Ltd. (HSEPL) from Village–Chhara (Dist. Gir
Somnath) to Gujarat State Petronet Ltd. (GSPL)’s Dispatch terminal at Village-Lonthpur (Dist. Amreli) and
public hearing scheduled as per referenced Daily Newspaper.
As per the public notice public heareing scheduled on 28.05.2021 at 11:00 am at Revenu Staff quarter
Garden, near to Mamlatdar office, Girgadhada, Ta. Girgadhada in Girsomnath District.
But at present the Corona epidemic in Gir Somnath district has taken a terrible turn and no one can say
when the Koro epidemic will come under control. It does not seem appropriate to hold a public hearing
at that time. This is because as per the guideline, a declaration of section 144 has been published in Gir
Somnath district at present and any public function is prohibited. In view of the situation in Corona at
the present time, it is requested to cancel the said public hearing and publish a public notice in this
regard in all the daily papers.
As well for this, objections have been given by the affected farmers during hearing at Kodinar for 3(1)
Article notice issued by Additional Collector and Competent Authority, Gujarat State Petronet Limited,
GSPL Bhavan, E-18, GIDC Electronic Estate, Near K-7 Circle, Sector-26, Gandhinagar as per The Gujarat
Water and Gas Pipelines (Acquisition of Right of User in Land) Act, 2000. But still today, we have not
replied and change in proposed pipeline alignment not processed. So, still the affected farmers
complaints not disposed and we strongly oppose Environmental public hearing. We request you to not
conducting public hearing until affected farmers complaints disposed.
Yours faithfully,
Rohitkumar Pratapsinh Vala
Bharatbhai G Vala
Kuldeep G Vala
Bhartiben Dhirsinh
Valiben Dhirubhai
Vala Sanjay R
Vala Ashvin R
Cc to:
1. Respected Shri. Pujabhai Vansh,
Dharasabhyashri, Una
2. District Collector,
Gir Somnath, Post Inaj Ta. Veraval
3. Superintendent of Police,
Gir Somnath District
Post Inaj Ta. Veraval
From: Arpit Patel [mailto:arpit.patel.envt@gmail.com]
Sent: 23 August 2021 09:22 To: info@gccipl.com; secon.baroda@secon.in
Cc: kanika singh Subject: Draft Queries - GSPL (Gir & Amreli)
**This mail has been sent from an external source. Please treat hyperlinks and attachments in
this mail with caution**
Draft attached,
Regards,
Dr. Arpit Patel
9601895929
1
Date: 09-08-2021
To,
1) Member Secretary.
GPCB, Gandhinagar.
ms-gpcb@gujarat.gov.in
2) Regional Officer,
G.P.C.B Junagadh
ro-gpcb-juna@gujarat.gov.in
3) Public Hearing Cell,
GPCB, Gandhinagar
uh-gpcb-ph@gujarat.gov.in
4) Prakash Karnik
GM (Projects), GSPL
kanika@gspc.in
5) Dr. Pawan Kr. Singh,
Assistant Director, NABET
pawan.nabet@qcin.org
6) Dr. A.K Jha
Sr. Director, NABET
akjha.nabet@qcin.org
Subject: My objection and suggestion regarding Public Hearing of M/s. GSPL dated 24th
August 2021
Respected Sir/Madam,
With due respect, this to inform you that for above mentioned subject, below are my queries
/ suggestions & highlights on false or incomplete or misleading information which must be
updated in the EIA report:
S.
No.
Reference Page
in EIA report
(Q) Query / (S) Suggestion / (F) False or Incomplete or
Misleading Information
1 6 – 9
(Declaration
Page – Made by
Secon & GCI
(F) It is not clear that EIA team members of SECON PVT. LTD.
are approved experts or not? If yes, in which Functional
Area? Nothing is mentioned in the declaration page.
As per the NABET’s requirement as mentioned below:
Following FAEs were not utilized for EIA study:
a) EB (Core)
b) AP
c) SC
Why such negligence has occurred by the consultant?
Without EB expert (Study area consists of Gir National
Park), what is the authenticity of the entire report?
Response from the Consultants (both) on their respective
letter heads must be given as a response to this query.
2 6 – 9
(Declaration
Page – Made by
Secon & GCI
(F) In spite of being warned many times, consultants are still
copying and pasting the signatures of the experts. Why?
It is evident that none of the signatures were done in person.
MoEF/NABET to take serious note of this.
3 9 (Q) Team member’s names are given without their respective
sector, involvement period and specific task as mandated by
NABET’s standard declaration page. Why?
2
S.
No.
Reference Page
in EIA report
(Q) Query / (S) Suggestion / (F) False or Incomplete or
Misleading Information
(Declaration
Page – Made by
Secon & GCI
This must be updated.
4 General (F) Plagiarism certificate as mandated by NABET is missing.
MoEF / NABET to take a serious note of this.
5 Executive
Summaries
(F) The executive summary mentioned in EIA report of 6
pages (Ref. Page 10 – 16) and the one uploaded separately
(which would probably have distributed in villages) having
13 pages are different.
Why different executive summaries are provided by the
consultant?
It is not clear, whether locals were given mis-leading
information by having two separate Executive
Summaries?
MoEF / NABET to take a serious note of this.
6 11 (Q) It is noted that Land will be required for SV1 at Pati Mansa
(~2500 sq. mt.) and at SV3 at Bodidar (~5800 sq. mt.).
Please provide the land possession documents for these
plots.
7 14
(Executive
summary in
EIA report -
Description of
Environment)
(F) It is noted baseline monitoring was done during October to
December, 2020.
Consultant was not accredited with NABET certificate
during the period of June 05, 2020 to December 06, 2020.
This makes them unauthorized to do the sampling during
this period.
This indicates EIA study was not done in the right sprit by
the consultant. Why?
8 18 (S) It is noted NBWL clearance is not yet obtained for the project.
I request MoEF&CC to grant EC after receiving the NBWL
clearance for the said project.
9 46 (F) Schedule for approval & implementation is baseless without
timeframe. Moreover, it seems to be a Flowchart of getting
Environment Clearance rather than implementation
schedule.
Throw some light towards the implementation schedule for
locals to be well aware in advance of when the work will start
and when will it end.
10 50
(Section 2.7.6)
(Q) How is this section (Telecommunication, SCADA, electrical
and instrumentation system) relevant to the proposed
project?
3
S.
No.
Reference Page
in EIA report
(Q) Query / (S) Suggestion / (F) False or Incomplete or
Misleading Information
10 57
(Section 2.8.1)
(F) Last line states “These impacts shall be temporary in nature
and shall be mitigated or eliminated by implementing a well-
organized Environmental Management Plan (EMP) during
the construction and operational phases of the project as
described below”.
But, it is noted no EMP is provided under this section.
Why such misleading sentences are used in the EIA report?
11 68
(Windrose
Diagram)
(F) On Page 3 of EIA report, TOR 16’s compliance is written as
“Site-specific micro-meteorological data for temperature,
relative humidity, hourly wind speed and direction and
rainfall for ONE season at one location is as given in Chapter
3 as para no. 3.3, Pg. 66 to 68”
But, it is noted the windrose was made for only 1 month.
Thus, incomplete data was collected at site by the
consultant.
Thus, EIA is incomplete. Kindly update the EIA report and
resubmit for Public Hearing.
12 72
(Section 3.6.3)
(F) It is mentioned that “The detailed on-site 24/8-hourly
monitoring results….)”. But, on Page 73 & 74, results of CO
are compared with NAAQM standard which is for 1 Hour.
Thus, a misleading information provided by the consultant.
Which statement / data is correct?
Kindly, corrections are required in EIA report.
13 75
(Table 3.8)
(F) It is amazing to see Benzo(a)Pyrene (BaP), Arsenic (As) &
Nickle (Ni) are reported by the consultant.
But, unit for these parameters are shown as µg/m3,
whereas the NAAQS are in ng/m3.
What is the minimum detection limit as approved by
NABL for these parameters to GCI’s laboratory? Proof of the
NABL letter must be updated in EIA report as a reply to this
query.
Laboratories test method, SOPs must be also provided in EIA
report for verifying the authenticity of such data which is
clearly misleading.
14 104 –
(Socio
Economic
Profile)
(F) It is astonishing to see no primary data were collected for
socio economic study. The core of the EIA for such pipeline
project is the socio-economic impact assessment. If the
baseline data in chapter 3 is missing, then how the impact
assessment was carried out in chapter 4 by the consultant?
The report does not indicate number of villages, details of
habitants whose land will be used for the project, etc. in the
study area. This is unacceptable.
4
S.
No.
Reference Page
in EIA report
(Q) Query / (S) Suggestion / (F) False or Incomplete or
Misleading Information
Only on the basis of secondary data, how assessors will
be able to take fare decision to grant EC or not?
Proper studies must be redone, EIA should be updated
accordingly.
15 117 – 118
(Impact on
Ambient Air)
(F) Against requirement of TOR 18 (Ref. Page. 3), which states
“Determination of Atmospheric Inversion Level and
assessment of Ground Level concentration of air
pollutants. Air quality modelling for proposed project.”,
nothing is given in the EIA report especially in Chapter
4.
It is noted in EIA report, Pg. 57, Section 2.8.2 mentions “The
emissions to the atmosphere shall be from construction
equipments / vehicles or activities during construction
phase and DG sets/ diesel engines during operation phase.”
Why modelling was not carried out? Why Atmospheric
Inversion Levels were not reported in the baseline data?
Thus, this it is incomplete TOR compliance. EIA must be
updated and resubmitted.
16 118 – 119 (Q) Similarly, no incremental noise levels were predicted in the
EIA report.
17 120
(c. Impacts due
to wastewater
generation)
(Q) During construction
Last line of 1st para states “If required, it will be collected and
disposed off suitably in near by municipal drain.”
It is noted that no villages were reported by the consultant
earlier in the report. If, this is true, which municipal drain is
being referred to in the statement as mentioned above?
Also, it is noted that Table shown on Pg. 58, shows disposal
of domestic waste water will be done in soak pit only. Why
different data are being shown in different sections of EIA
report?
This seems to be a misleading information.
1st line of 2nd para states “The water used during hydro test
will be a temporary activity used for leak test and same water
will be used in multiple test of other section of pipeline.”
Inspite of using the word “used” multiple times, it is still not
clear, what exactly is being proposed by this sentence.
Please, reframe it for better understanding.
Why the quantity of waste water due to such activities not
provided in EIA?
During operation
5
S.
No.
Reference Page
in EIA report
(Q) Query / (S) Suggestion / (F) False or Incomplete or
Misleading Information
Last line states “Wastewater generation during operational
phase due to cleaning, washing, mopping, bathing, toilet,
and sanitization will be approx. 200 liter per day at each
station and it will be disposed to nearby municipal drains.”
Please clarify the details of such municipal drain.
Include the permission / interim letter for disposal of waste
water in municipal drain by the concerned authority for 200
liter per day.
18 121
(Section 4.1.6,
a)
(Q) Second para states “The other minor impacts on land
environment, due to these operations could be due to
vegetation loss during access cutting and site preparation.
These impacts can be mitigated by simply considering
adequate afforestation in near-by wastelands.”
Quantification of such vegetation loss in terms of atleast
area (m2) is not shown by the consultant?
19 121
(Section 4.1.6,
b)
(Q) Last line of 1st para states “The project requires extensive
work on the excavation and removal of soil ..”.
Quantification of excavated soil, its resuse, left over soil for
dumping, dumping location, route of truck movement for
such activities, its impact due to vehicular emissions are
missing in the EIA report. Hence, impact assessment is not
carried out properly. Kindly respond and update the EIA
report accordingly.
20 136 – 138
(Chapter 6)
(F) Nowhere in the entire chapter, monitoring plan is provided
for the environmental parameters. Why?
Does this mean there will not be any environment
monitoring during construction phase or during operation
phase?
Without Environment Monitoring Plan, how will one be able
to know the effectiveness of the proposed mitigation
measures?
This chapter is thus incomplete and needs to be revised.
21 152 (Q) It is reported the maximum distance for overpressure level
due to failure of pipeline will be upto 871 m for 0.0206 bar.
What will be actual pressure in the pipeline? Is it justified
with the scenarios taken by the modeler?
It is noted Risk assessment was not carried out with FN
Curves with UK HSE standards (covering Individual Risk &
Societal Risk curves). Only the consequence analysis was
carried out by the consultant which is inconclusive w.r.t to
the risk for the nearby habitants of Mota Mansa (Pg. 153) &
Pipalva Bavana (Pg. 158).
6
S.
No.
Reference Page
in EIA report
(Q) Query / (S) Suggestion / (F) False or Incomplete or
Misleading Information
Thus, Risk assessment chapter is also incomplete and needs
to be revised.
22 168 (Q) It is reported that Damage Contour for VCE in case of
Catastrophic Rupture of Diesel Storage Tank is going outside
the project premises. Why risk assessment was not carried
out for this scenarios also as mentioned above?
EIA report must be updated accordingly.
23 200
(Section 7.3.35)
(Q) It is noted that Off-site emergency plan write up is very
generic and not project specific.
This must be given as a part of EIA document having local
administrative phone numbers and other important contact
details for locals to contact in case of emergency.
Why such important document is not updated in EIA report?
EIA report must be updated accordingly.
24 218
(Chapter 9)
(F) Not a single cost is mentioned in the chapter called
Environmental Cost Benefit Analysis.
Why such mis-leading / incomplete information is provided?
Is it really ased during the scoping?
25 219 – 233
(Chapter 10)
(Q) What exactly the management (Directors / Site Incharges) of
GSPL will do is unclear from this chapter?
How will they know if there is breach in environmental
monitoring plan (which apparently is also missed out as
mentioned earlier)?
Whether there will be any system which can assure that
management are aware of environmental issues happening
at the site? No-where in the report it is mentioned about its
hierarchy. Does that mean, nobody bothers about the
environment in the GSPL organization?
26 234 – 236
(Summary &
Conclusion)
(F) Without proper impact assessment and baseline collection,
the writeup seems to be baseless of actual summary of EIA
report (which also differs as two executive summaries are
already provided at different locations).
Thus, it is not clear which document is correct to refer.
27 246
(Annexure II)
(Q) Map shown is not clear. No tags/name of village are visible
on map. Is it done purposefully to hide information?
28 251
(Annexure VII)
(Q) Letter for recognition of Environmental Laboratory provided
by MoEF is almost 11 years old. What is the current status
of the recognition?
7
S.
No.
Reference Page
in EIA report
(Q) Query / (S) Suggestion / (F) False or Incomplete or
Misleading Information
It is believed that the approved parameters for analysis of
ambient air, ground water, surface water & soil were
mentioned in the EIA report by the consultant.
Any misleading information found at later stage may attract
to debar / issue show cause notice to the consultant by
MoEF&CC / NABET.
29 252 – 257
(Annexure VIII)
(Q) Why only the general write up for Rainwater harvesting &
Use of Solar Energy is given (copied from the internet)?
Why no project specific calculations provided by the
consultant to know the actual positive impact due to the
project?
30 270 – 271
(Annexure XII)
(F) Images doesn’t show the power supply lines (especially
Gundala Village), thus proving that the photos were taken
for the sake of showing it in EIA, with instant tag of A4 size
prints sticked on the old machines.
Covid-19 norms as mandated by GOI were breached by the
monitoring team (i.e. to have mask) in Photographs shown
on Pg. No. 270, 272 – 277.
Why the locals/team members were risking their lives?
Since this document will remain on the public portal forever,
an apology is sought from the Consultant and Project
Proponent.
31 274 & 275
(Annexure XII)
(F) Noise monitoring equipment used is a spot reading machine,
which cannot gather Leq measurements for 24 hours. Thus,
proving the data shown in baseline chapter are incorrect.
Revised monitoring must be done with authentic baseline
data captured by the Accredited FAE-NV having sound
knowledge.
32 276
(Annexure XII)
(F) Images were copied pasted as it does not match with the
Name given in the table.
Why such negligence is shown by the EIA coordinator?
Also the guidelines for collecting soil sample is from at least
0.5 m from the top soil. All photographs show that hardly 5
to 10 cm was dug. Thus, the results shown are of the top soil
and not the actual representative sample of the soil to be
monitored.
Revised monitoring must be done with authentic baseline
data captured by the Accredited FAE-SC having sound
knowledge
33 280 (Q) Why area covering under Eco-Sensitive Zone was not
marked out in the Land Use map?
8
S.
No.
Reference Page
in EIA report
(Q) Query / (S) Suggestion / (F) False or Incomplete or
Misleading Information
(Land use Map)
Above queries / suggestions must be addressed appropriately in Final EIA report as a part of
improvement.
Final EIA report will also be checked for the compliance of the above mentioned points. This
will further help EAC-Industry 2 to take necessary actions while recommending the case of
Environmental Clearance.
Yours sincerely,
Dr. Arpit Patel
9601895929
CC:
1) Secon Pvt. Ltd - secon.baroda@secon.in
2) Green Circle Inc. - info@gccipl.com
3) Prakash Karnik - GM (Projects), GSPL - kanika@gspc.in
4) EAC – Industry 2 members: ak.pateshwary@gov.in, m.phulwaria@gov.in,
kanaka.teja@gov.in, moefccmeetikagupta@gmail.com