| File Note: |
It is submitted that during examination of the observations raised and the replies furnished by the Regional Office, certain issues require further clarification, particularly with respect to compliance of the mandatory 15-metre-wide green belt towards the existing poultry farms, as stipulated in the Consent to Establish (CTE) dated 19.12.2023. As per Special Conditions No. 4 and 5 of the CTE, the project proponent was required to develop a 15 m wide green belt of broad-leaf trees towards the poultry farms and to incorporate the same in the layout plan approved by the competent authority. Further, it was clearly provided that the green belt must be part of the approved layout. However, on perusal of the approved layout plan submitted by the project proponent, it is observed that the layout shows only a 10 m wide green belt towards the highway side, while the remaining 5 m has been marked merely as a “No Construction Zone” without any indication of plantation or green belt development. In this regard, the RO has stated that the “15 m green belt area has been retained.” The said statement appears to be inconsistent with the approved layout, which does not show a continuous 15 m wide plantation-based green belt as originally mandated. Further, the CTE was granted based on a conceptual layout plan submitted by the project proponent at the time of application, wherein a full 15 m green belt with plantation towards the poultry farms was proposed. The current approved layout differs from the conceptual layout in terms of the width, composition, and treatment of the green belt area and it is required to be clarified by RO whether the mandated 15 m green belt has been provided towards the existing poultry farm as proposed at the time of CTE in the conceptual layout provided at that time comparing it with the approved layout provided.
Reply: The current status drawing, Aks-Chajra Naksha of green buffer and registry of green buffer is submitted herewith. It is pertinent to mention here that the 15 m green buffer was provided by the project during the initial consent to establish which was not in the part of CLU of the project. The project has submitted the separate ownership documents and Aks-chajra Naksha to comply with the green buffer requirement. As the CLU has not been carried out for 15 m green buffer provided by the project. The inclusion of the land in layout plan was not possible. Further, it is mentioned that as CLU has not been carried out for 15 m green buffer land, the plotting of that land will attract unauthorized development.
It is also noted from the RO’s report that the green area and green belt dimensions have changed from the original proposal of 3036 sqm green area and 5060 sqm green belt to 4162 sqm green area and 4014 sqm green belt. These changes appear to be significant. As per Special Condition No. 6 of the CTE, in case of any change in the conceptual plan submitted at the time of approval, the project proponent is required to apply for a revised / fresh CTE before proceeding with development activities. In this context, the RO has not clarified whether the present changes in green belt configuration and area requires a revised CTE.
Reply: The disposal area has been changed from original proposal of 3036 sqm green area and 5060 sqm green belt to 4162 sqm green area and 4014 sqm green belt. However, the total area has been changed from 8096 sqm to 8176 sqm. As such, the project has provided additional 80 sqm of area for disposal. The major differences is only the change of the plotting. However, the proposed wastewater generation, treatment and disposal arrangement are same as approved in ‘consent to establish’ expansion.
In view of the above; if approved, the application be sent back to RO to clarify the following:
1. Whether the approved layout plan truly complies with the requirement of a 15 m wide green belt with plantation towards the poultry farms, as mandated under the CTE.
Reply: Yes, the project is complying with the requirement and has subsequently obtained the CTE due to compliance of providing the green belt of plantation towards the poultry farm.
2. Whether the mandated 15 m green belt has been provided towards the existing poultry farm as proposed at the time of CTE in the conceptual layout provided at that time comparing it with the approved layout provided.
Reply: As per above.
3. On what basis the 5 m no-construction zone has been considered part of the 15 m green belt.
Reply: The 5 m no construction zone has not been considered part from the 15 m green belt as the green belt is at the opposite site of the plot comparing to the no construction zone.
4. Whether the differences between the conceptual layout submitted at the CTE stage and the approved layout constitute a change in project components and Whether the project proponent is required to obtain a revised / fresh CTE in view of the changes in green belt and green area dimensions.
Reply: The changes are primarily due to replotting, which is conceptually approved during the CTE expansion case. There is no change in wastewater generation, treatment and disposal and any other pollution control arrangement, which attracts the revised or fresh CTE.
In view of above, the CTE extension may be granted with appropriate conditions, please.
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