Annexure C

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

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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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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