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Environmental Impact Assessment: Coal Bed Methane (CBM) Project Birbhum District, West Bengal

Executive Summary

June 2008

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EXECUTIVE SUMMARY

A) INTRODUCTION BP has been awarded a CBM exploration concession for a 250 square kilometre CBM Block located in Birbhum District in the State of West Bengal, India. The awarded CBM Block is referred to as BB-CBM-2005/III. The exploration licence was awarded through an international bidding process under the CBM Exploration Policy formulated by Ministry of Petroleum and Natural Gas (MoPNG) on behalf of the Government of India (GoI). As per the Contract agreement with GoI, BP will undertake to execute the CBM Project in the following four phases, with the option to relinquish the CBM Block at end of Phase 1 and 2 should BP deem the Project to be commercially unviable. Phase I Appraisal or exploration stage which is anticipated to last 2 years from the effective date of the Petroleum Exploration License PEL (Nov 2007). Phase II - Pilot Testing to assess the fields sustainable producibility. The duration of this phase is 2.5 years after completion of Phase I. Phase III Implementation of a Development Plan. The duration of this phase is 5 years after completion of Phase II. Phase IV Production and Operation Stage which is planned to last twenty five years or more.

Currently, physical exploratory activity or drilling operations have not commenced at the CBM Block; these will be initiated upon receipt of all necessary regulatory clearances.

B) CBM BLOCK LOCATION The BP CBM Block is located in Birbhum District of the State of West Bengal. The Birbhum District is bounded by Murshidabad and Burdwan Districts to the east and Burdwan District to the south and Dumka district of Jharkhand State to the west and north. The CBM Block is located about 35 km from north-east of Siuri (the administrative headquarters of Birbhum) and about 250 km from Kolkata (the capital of the State of West Bengal). It covers parts of the three administrative blocks of Mohammad Bazar, Rampurhaat 1 and Mayureshwar 1.

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BP EXPLORATION (ALPHA) LTD: EXECUTIVE SUMMARY COAL BED METHANE PROJECT BIRBHUM DISTT., WB

Figure 0.1

CBM Block setting map

C) PRIOR ENVIRONMENTAL CLEARANCE As per the EIA Notification, September 2006, a Coal Bed Methane (CBM) Project is classified as a Category A type project requiring prior environmental clearance (EC) from the Ministry of Environment and Forests (MoEF). The final Terms of Reference (ToR) for the EIA was agreed in April 2008 with the MoEF and covers Phase I and II activities only. D) APPROACH AND METHODOLOGY While the primary object was to follow the MoEF guidelines on conducting EIAs, a phased approach was adopted in the environmental impact
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assessment of the Project. The approach allowed the environmental impact assessment related studies to benefit from critical inputs from initial preparatory studies while giving inputs to the Project planning and design. The EIA followed a five stage approach: Stage 1: Initial studies including field reconnaissance of the site and desk based studies to identify and evaluate potential risks to the Project. Stage 2: Satellite data acquisition and related studies were used to identify initial constraints to development (forests, settlements, water bodies and access roads) and the initial identification of potential issues such as ground and surface water, air, flora, fauna, livestock, land, agriculture and local communities. Stage 3: Regulatory considerations involving the submission of Form 1 and the subsequent agreement of the Terms of Reference (ToR). Stage 4: Environment and Social Baseline (ESB) which was completed in April 2008, and became the basis for predicting the potential environmental and social impacts, providing inputs to the Project design and a benchmark to measure change during and after the Project activities. Stage 5: Environmental and Social Impact Assessment (termed EIA) A key output from the constraints mapping process (Stage 2) was the identification of ten Initial Drilling Areas (IDAs), within which wellsites will be located for the purposes of developing core holes and in some cases, test wells. These IDAs helped focus the environmental and social baseline surveys, and, along with a network of preliminary access roads, formed the basis of the EIA.

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BP EXPLORATION (ALPHA) LTD: EXECUTIVE SUMMARY COAL BED METHANE PROJECT BIRBHUM DISTT., WB

Figure 0.2

IDA locations in the CBM Block

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BP EXPLORATION (ALPHA) LTD: EXECUTIVE SUMMARY COAL BED METHANE PROJECT BIRBHUM DISTT., WB

Figure 0.3

One of the Initial Drilling Areas (IDA) and existing features

The well-site locations within the IDAs will be selected based on the identification and understanding of numerous issues associated with both minimizing environmental and social impacts associated with the wellsites as well as access routes to the wellsite locations. Issues considered include: flood potential; ecologically sensitive sites such as forest, community disturbance, areas of cultural / religious significance, land holdings and physical constraints such as power lines. The impact assessment considered the significance of a range of potential impacts following the implementation of various mitigation measures, where significance is determined by its context (geographic extent), duration (short, medium, long term), intensity (magnitude) and type (adverse or beneficial) Figure 0.4 A typical satellite imagery of IDA and its digitized equivalent

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BP EXPLORATION (ALPHA) LTD: EXECUTIVE SUMMARY COAL BED METHANE PROJECT BIRBHUM DISTT., WB

E)

PROJECT DESCRIPTION

E-1) Drilling and Testing of Wells The project will involve the drilling and testing of wells for methane production. Eight IDAs will have a corehole and some will also have a testwell. IDAs have been identified through detailed geological studies. During Phases I and II, 8 exploration coreholes are planned. The average time to complete each corehole is approximately 22 30 days. Coreholes will be drilled with a combination of rotary/percussion and high speed diamond coring technologies. The drilling rigs will be truck mounted. Five testwells are planned during Phase I and up to 15 test wells in Phase II. The average time to complete each well is approximately 16-30 days. Testwells will be drilled with a combination of percussion and rotary drilling technologies. In addition to the drilling rig, a service rig will also be deployed to conduct the well testing program for evaluating the CBM flow potential. A number of tests will be conducted by injecting water and nitrogen into the testwells followed by production testing of these wells, with the aim of assessing the gas producibility of the coal bed. Corehole sites (wellsites) will be approximately 75m x 60m in dimension, and the testwell well pad site will be approximately 115m x 85m. Figure 0.5 Typical truck mounted drilling rig to be used

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BP EXPLORATION (ALPHA) LTD: EXECUTIVE SUMMARY COAL BED METHANE PROJECT BIRBHUM DISTT., WB

E-1.1) Facilities and Resources Required Access to the wellsites within the IDAs will require the use of existing network of roads and where no road exists, new temporary access roads will be constructed. Water will be required both during construction of the wellsites (about 400 m3/well) and access roads and during drilling operations (about 45 m3 and 570 m3 for core hole and test well, respectively). Water will be sourced either from existing surface water, or new tube wells. Chemicals and other substances (such as fuel oil etc) required for drilling and testing of wells will be safely stored at wellsites. E-1.2) Waste Generation Water from the coal horizons will be extracted to liberate the coal bed methane. It is estimated that the extracted water known as Produced Water may be approximately 30 - 80 m3/day/well. Liquid and solid wastes will be generated during the drilling and testing of wells. An inventory of all wastes will be developed and treatment and disposal options will be followed that meet the regulatory requirements. E-1.3) Project Investment The investment during Phase 1 and Phase 2 of the Project is approximately US Dollars 100 million. E-1.4) Project Schedule Phase I of the Project is expected to be completed in two years from the Project commencement date and Phase II is expected to be completed in two and a half years from the completion date of Phase I. E-1.5) Expected Project Benefits BP has several options to market the methane derived from a successful exploration programme in the production phase of the Project, as it is anticipated that the demand for gas will grow significantly in India. As the phased exploration programme is undertaken, BP will assess the feasibility of a number of options to supply potential markets for the gas.

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BP EXPLORATION (ALPHA) LTD: EXECUTIVE SUMMARY COAL BED METHANE PROJECT BIRBHUM DISTT., WB

F) PRIOR PERMITS REQUIRED FOR THE PROPOSED PROJECT The relevant regulatory approval/permit requirements for the CBM India Project have been assessed as part of a Project regulatory review. A Project Permits register has been developed and is currently being implemented. G) ENVIRONMENTAL AND SOCIAL BASELINE G-1) Environmental Baseline G-1.1) Physical environment The western part of the CBM Block comprises low hills, gradually descending to the alluvial plains in the eastern part of the CBM Block. The eastern part is more suitable for agriculture. The geology of the region shows the occurrence of diverse rock units ranging from Archaean hard rocks, Gondwana sediments (Permian to Jurassic in age) to sub-recent laterites and recent to sub-recent alluvium. Coal is found in the Permian Barakar Formation. The CBM Block area is largely drained by Dwarka and Brahmini Rivers. The Dwarka flows close to the southern boundary of the CBM Block and briefly enters in to the CBM Block at the south east corner. The CBM Block area has a network of irrigation canals in form of main and branch canals. These canals are linked to the Dwarka and Brahmini Barrages. Approximately 70% of the land in the Project area is classified as agricultural land, which supports the main crops such as rice (paddy), wheat, and maize. Designated forest covers 3.5% of the CBM Block area. The remaining proportion is covered by settlements, stone mining and crushing areas and water bodies. Soil within the CBM Block is mostly sandy clay loam and loamy sand. Samples have been analysed across the CBM Block. Surface water quality of the major rivers and water bodies has been observed to be moderate to good (at the sampling point). COD and BOD were well within the desirable limits (IS Limits). Groundwater quality at some places in the CBM Block is slightly alkaline. Total Dissolved Solids (TDS) in the groundwater was observed within the desirable limit of 500mg/l at all the sampled locations except in an open well located in middle of the CBM Block. Fluoride in the CBM Block area was observed below 1.0mg/l (IS Limit for Drinking) except in an artesian well which reported elevated fluoride concentrations of 1.81mg/l. Iron concentration at some of the locations (middle and north of the CBM Block) was observed to be elevated above the desirable limit of 0.3 mg/l. All heavy metals, except zinc were observed below detection limits.

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BP EXPLORATION (ALPHA) LTD: EXECUTIVE SUMMARY COAL BED METHANE PROJECT BIRBHUM DISTT., WB

Figure 0.6 A typical rice field

Figure 0.7 A stone crusher in the block

G-1.2) Ecology No national parks or wildlife sanctuaries exist within the CBM Block. The forest within the CBM Block and surrounding region are mainly identified as Dry Deciduous Forest (Sal dominated) type. The CBM Block has both the Reserved Forests (RF) and Protected Forests (PF). Masra, Jatla, Bhatina, Ghaga are the reserve forests and Ganpur, Damra, Chandpur, Ranipur, Kasthagora, Chanda, Chandpur, Radipur, Kalaipahari, Maubelia are the protected forests. In the entire study area there were no records of rare and
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endangered plant species. Most of the observed plants were widely distributed. Most of the fauna species are common. Some of the mammalian fauna species are included in endangered and rare categories but none of them belonged to endemic categories. Of these three species belong to endangered category, and eight species to threatened category. Figure 0.8 Sal forest in the CBM Block

G-1.3) Climate, air and noise The temperature of the area ranges from a minimum of 5.6C in December to 47.8C in May and June. The average annual rainfall observed is 1388 mm. About 92% of the rainfall is received during the south-west monsoon from May to October. Ambient air quality monitoring within the CBM Block was carried out at eleven locations during December March 2008. The results showed that most parameters were within the National Ambient Air Quality Standards except Suspended Particulate Matter (SPM), Respirable Particulate Matter (RPM), and NOx. SPM was high at all sampling locations, while NOx was observed to be high in areas close to stone crushing units. Day and night noise level measurements were taken at locations within the CBM Block. Ambient noise levels in the CBM Block are within the prescribed limits, which is 55 dB (A) for day time and 45 dB (A) for night time. G-1.4) Traffic The main NH-60 crossing the CBM Block carries heavy traffic mainly comprised of heavy motor vehicles (HMV). HMVs comprised over 60% of all vehicles on the Rampurhaat Dumka road and a similar trend was observed on the road connecting Pachami stone crusher area. Trucks primarily carrying crushed stone material use this road. Non-motorised vehicles also ply in significant numbers.
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G-2) Socio-economic Baseline The District of Birbhum accounts for about 5 percent of the total area and about 15 percent of the total population of the state of West Bengal. There are 19 Community Development blocks in the district covering 2478 villages, five statutory towns and one census town. As per the Backward District Initiative in the 10th five year plan prepared by the Planning Commission of India, the District of Birbhum has been classified as a Backward Area. Most (more than 95 percent) of the population in the CBM Block is rural and lives in settlements located close to water bodies and agricultural fields. The Project area has an average household size of five and an average population density of around 530 individuals per square kilometer. This population density however is mostly concentrated in nucleated and densely populated pockets in villages/ areas close to administrative block headquarters/ markets. There are approximately 70 revenue1 villages within the CBM Block. The Project area has a diverse religion profile, though Hindus are in a majority. The three administrative blocks have a high percentage of Scheduled Castes (SCs) and Schedule Tribes (STs) population. These groups comprise at least 35-45 percent of the total population in the area. In terms of gender development, the district/area is a poor performer, being ranked 14 out of 17 districts on GDI. The primary survey came across very few women who hold influential positions in the villages of the Project area, like elected leaders, teachers, and medical staff etc. G-2.1) Land Land holding patterns in the Project area are fairly similar across the mouza/villages. Large landowners are very few, and most households own less than one hectare of land and fall in the marginal land holding category. Typically the villages in the Project area are spread over an area ranging from 80 to 700 hectares. Most of this area is dominated by privately owned agricultural practices. The actual habitation area is small, constituting about five to ten per cent of the total village area and is usually located in the centre close to the paddy fields or water bodies. The Project area has a complex pattern of land ownership and use. The system of sharecropping referred to as bargadari2 exists in the area. There are both registered as well as unregistered bargadars.
The census uses the term village in regard to 'revenue village'. According to the census definition a village represents a parcel of land, the boundaries of which are defined and settled by revenue survey or by cadastral survey. A revenue village may consist of one compact habitation (distinct cluster of houses with a local name where people live in compact and contiguous manner) or a number of habitations. One of the habitations may bear the name of the village itself. These habitations may be separated from each other by a long distance (sometimes over a number of kilometres). (1) 2 A Bargdar is a person who cultivates the land of other person (generally an absentee landlord) and in lieu gives a certain proportion of yield to the land owner (move this note to next page)
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G-1.3) Occupation and Livelihoods Agriculture is the mainstay of the economy of the Project area, the three administrative blocks as well as the district. The farm sector employs approximately 80 percent of the active and productive work force. The overall Work Participation Rate1 (WPR) is around 50 percent. The WPR was found to be higher among males as compared to the females. In terms of primary occupation, the majority of the households is engaged in agriculture and related activities. A typical family in the Project area grows one/ two rice crops during the year and has one/two members who are engaged in other activities (farm and non farm for example agricultural labour, work in mines/ quarry either in Chanda/Pachami or in Masra/Salbhadra area or in some local business unit for example shops or other business enterprise). The average yield of rice is estimated at approximately 24 to 36 quintal (1 quintal = 100 kilograms) per hectare for winter rice (paddy) and 48-60 quintal per hectare for summer rice (paddy) depending upon the quality of land, availability of water, cost and labour inputs etc. Non farm-based livelihoods primarily consists of work in the stone crushing and quarrying sector with other employment being provided by government and temporary, seasonal or permanent employment in garages, shops, rice mills etc. Fishing is practiced on a small scale either in the small fish ponds/ water bodies (locally termed daab, pukur) in the village area or in the nearby river/ streams/ canals and was reportedly used mostly for household consumption. Rearing livestock plays a very important role in the rural economy and is another subsidiary source of household income in the Project area. A typical household in the Project villages has livestock including cow, ox, goat, pigs, buffalo and poultry which are used both for generating subsidiary income and to a lesser extent for household consumption. Forest based livelihood exits, though it is largely limited to collecting fuelwood and fodder. G-1.4) Infrastructure The health facilities in the villages in the Project area are thinly spread and even the existing facilities suffer from poor equipment, accommodation, staff and medicines. Malaria had the highest prevalence across all the villages surveyed. Other diseases reported from the survey villages (in decreasing order) include tuberculosis, kala azar (black fever), respiratory diseases (including Asthma), jaundice and occupation linked diseases like skin

(2) 1 Workers Participation Rate (WPR) depicts the engagement of main and marginal workers in different occupations at household, commercial or agricultural level.

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ailments. Tuberculosis continues to be the major health problem in the area despite attempts to limit its spread for over four decades. Most villages have a primary school or a Sishu Shiksha Kendra (pre-primary school). Secondary schools are located in Gram Panchayats or larger villages, while colleges are concentrated in towns. Generally brick and mud paved/unpaved road connects the villages to the main road. Many of these roads are not accessible by motor vehicle in the monsoon season. The study area and the surrounding villages have inadequate infrastructure available for sanitation and no sewerage system is present. None of the villages covered as a part of the field visit had a proper interconnecting drainage/ sewer network. Household electricity connections are common in the main village especially on the dense, nucleated and concentration settlements. Tube well, hand pumps, ponds and open wells serve mostly to the needs of household water consumption. There are no designated archaeological and heritage sites within the CBM Block. However as is typical of rural Indian settlements, each village in the CBM Block has a number of cultural sites or sites of religious significance, like temples, mosques, cremation ground, graveyard, revered trees etc. that are scattered across the CBM Block.

H) STAKEHOLDER MAPPING The EIA process identified, mapped and consulted with a range of stakeholders on which the Project could possibly have impacts, and who in turn could influence the Project. The objective was to understand stakeholder concerns and opinions and, , to the extent possible, address this feedback in the EIA as well as the relevant management plans. Key stakeholders identified and consulted with included: Land owners, sharecroppers and other formal and informal users. Vulnerable groups including women, marginal farmers and landless families; Village institutional stakeholders like the Gram Panchayat; Sansad; Gram Unnayan Samiti; Panchayat Samiti, Political parties and others; Administrative district and block level officials; Other influential groups like NGOs, media, local business groups like the stone crusher owners etc.

A detailed stakeholder consultation log is attached as Annex B of the EIA report.

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Figure 0.9

Consultation with the stakeholder groups

I)

IMPACT ASSESSMENT AND MITIGATION

The EIA report presents an assessment of potential environmental and social impacts due to the proposed CBM Project. The CBM Project is separated into the following four stages: a) Site Preparation, b) Construction, c) Drilling, and d) Decommissioning. The identified potential impacts then formed the basis for the development of mitigations and management plans. I-1) Air Quality Potential emission sources include fugitive dust from earth works associated with site preparation and wellsite construction activities as well as from construction traffic using local roads for site access; other sources include air emissions from power generators, flaring of gases and other activities during drilling and well testing; air emissions from vehicles; and heat radiation due to test flaring. All the anticipated air emissions other than fugitive dust would be from the combustion of hydrocarbons. The parameters of concern are NOx, SO2, CO, particulates and non-methane hydrocarbons. Owing to prevailing high particulate matter concentrations associated with stone quarrying and crushing operations (mainly in the western half of the CBM Block), potential impacts to ambient air quality include particulate matter. A number of mitigation measures will be employed to minimize the effects of the Project on ambient air quality. Water sprinkling will be used where necessary to minimize the generation of dust along the access roads to the wellsites as well as at the wellsites themselves. This effort will concentrate on areas near settlements, isolated yet occupied dwellings, and areas holding livestock. Other proposed measures will include appropriate stack heights for emissions-emitting equipment, as prescribed by regulatory requirements. Equipment will only be used on an as-needed basis and will not be left idling unnecessarily. All vehicles will be maintained properly and compliance with Pollution Under Control (PUC) certificate will be observed.

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With the implementation of the above mitigations the impact of the Project on ambient air quality is predicted to be minor in the vicinity of the wellsites. For minimizing impact along the access roads, vehicle speeds will be restricted and dust suppression measures will be followed. I-2) Noise Quality Activities that have a potential impact on noise quality include operations of construction equipment, vehicular movement to and from the wellsite sites, and drilling activities. It is expected that site preparation and wellsite construction activities will generate elevated noise levels locally for short durations. Also, drilling operations include the routine running of equipment that will generate elevated noise levels locally. In addition, the passage of construction traffic through local villages will also contribute to noise levels in the vicinity. This will be minimised by imposing speed restrictions on all project vehicles. Mitigations such as acoustic enclosures on equipment and the use of soil berms to help attenuate noise sources will be implemented at wellsites to reduce the impact. With the mitigations measures proposed, the impact significance on noise quality due to site preparation and wellsite construction and drilling activities is considered to be minor and no significant adverse environmental effects due to noise are expected. I-3) Land and soil Activities that impact land and soil include site preparation and wellsite construction, off site road movement of project vehicles, drilling activities and decommissioning of the Project site. Potential impacts related to the above activities include soil compaction, soil erosion and run-off, and the local alteration of flood plain hydrodynamics; overflow and runoff of drilling mud from the containment pits over the wellsite to adjacent land. Mitigation measures such as avoidance or minimization to the extent possible of project activities during monsoon season (to the extent possible), forest areas, flood plains and sites near water bodies, provision of drains along the selected sites and proper management of construction and drilling wastes at sites will be implemented to minimise these potential impacts. The significance of impacts on soil compaction and soil erosion have been assessed to be minor, mainly due to the short term and localised nature of the disturbances, as well as the fact that if any adverse effects do materialise, they can be reversed. The impact of site preparation activities on flood plain hydrodynamics is predicted to be insignificant due to the small size of the
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construction footprint and the preferred timing of the construction activities (during the dry season). Equally, the nature and quantities of waste generated are such viable options for safe disposal are available and hence the residual impacts of waste disposal are predicted to be insignificant. I-4) Groundwater Potential impacts that could affect groundwater include drilling through shallow and deep aquifers, pumping of produced water from coal seams, onsite storage and disposal of wastes, disposal of produced water and closing of wells and decommissioning. Mitigations such as operational control and monitoring of Project activities will be executed to ensure impacts are minimised. The impact of site preparation and construction activities on groundwater quality and quantity is assessed to be insignificant due to the proposal to only use sustainable sources of supply and the very low likelihood that site activities will lead to any uncontained, subsurface contamination. The impact of drilling on local water quality is predicted to be insignificant due to the nature and quantities of materials that will be used on site, the proposed storage and handling procedures, and spill response measures that will be enforced. The effects on water availability are predicted to be minor for the reasons noted above for site preparation. Owing to the deep-seated origin of produced water, it is considered unlikely that surface aquifer sources will be affected as a result of well testing. Proposed monitoring activities will ensure that any unexpected variations to this prediction will be detected and actions modified accordingly. I-5) Surface Water Potential impacts on surface water include change in local drainage pattern and hydrology and deterioration of quality due to disturbance to soil layers, mobilising of heavy vehicles, onsite spillage and disposal of waste and produced water. Mitigations such as operational control and monitoring of Project activities will be executed to ensure impacts are minimised. Impacts on surface water quality are predicted to be minor and changes in drainage pattern and hydrology to be insignificant. This is due to the initial site considerations, including the design and operation of on-site waste storage , the use of disposal facilities such as mud pits and waste water treatment systems, and to maximise beneficial use of the water where possible.

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I-6) Ecology Potential impacts on ecology include clearing ground cover at wellsite locations and construction of new access roads, air and noise emissions at local levels, construction traffic and restoration of sites. The proposed project activities are planned to be kept outside the identified reserve and protected forests, therefore, loss of forest by virtue of conversion of forest land for non forest purposes is not envisaged. Predicted impacts from site preparation and construction activities as well as drilling are assessed to be insignificant. J-1- Land and land use Land will be either temporarily accessed or purchased from willing owners. For phase I and II, up to approx 20 hectares of land will be required for all project activities. Potential impacts on land may arise out of a temporary change in land use, loss of land for landowners and reduction of land value in the long term. Some of these could potentially have impacts on livelihoods. The scale of these impacts is however limited as the duration of project activities will be short and area of land required is small. Compensation to land owners and users will take into account loss of income due to CBM operations. Impacts on land use and holding patterns are assessed to be of minor significance. J-2) Livelihoods Potential impacts on livelihood due to loss of land and crops (even though temporary) during the drilling period, may arise. In the case of testwells becoming viable for future phases of the Project the potential impacts on the land owners could be long term. Compensation to land owners and existing users will then be made on the basis of replacement value. J-3) Community The rural communities living in and around the construction and wellsites may face the impacts of an influx of outsiders looking for employment and better wages. This can have socio-cultural impacts as well as community health impacts. However the scale of the Phase I and II operation is relatively small and is unlikely to result in significant immigration. Additionally, the Project will encourage contractors to deploy local staff where practicable. Information on the Project feedback mechanism will be disseminated in the local communities.
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K) RISK ASSESSMENT The risk assessment associated with initial planning of CBM Project identified well blow out during drilling/coring operations to be a potential major hazard. However, the well blow out frequency was determined to be low and the event out come is confined to within the wellsite (as established by modelling) and would not therefore impact the community (outside the fenceline). Other hazards are associated with lifting equipment and vehicle and driving safety. The risks from these events will be mitigated by strict adherence to safety rules and procedures. The key principles of emergency response and disaster management are outlined. A fully developed emergency response plan and disaster management plan will be available prior to start of the Project for necessary actions in case of any emergency. L) MANAGEMENT AND MONITORING The purpose of developing and implementing an E&S management system is to ensure that the principles, standards and requirements (collectively referred to as project E&S commitments) are met. The impacts and associated mitigation measures identified through the EIA process will be implemented and managed through two distinct phases: Design Findings and recommendations from the EIA process (and associated assessments) are captured in the design process. Where possible, identified mitigation measures are incorporated directly into the design plans. Where it is not possible to design out impacts, the requirements for mitigating the impacts are carried through to the Project management plans. For the CBM Project this primarily consists of optimising the wellsite location and access road route selection to minimise overall environmental and social impact Project Execution BP will develop a HSE management system and Contractor(s) will develop HSE plan(s) that incorporates the mitigation measures required to manage the impacts of their activities. Mitigation measures will be taken from the Management Plans included in this document.

A set of eleven specific Management Plans (MPs) have been developed to manage key issues that have been identified through the environmental and social assessment process: pollution prevention, waste,
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produced water, traffic, cultural heritage and chance finds, construction and decommissioning, ecology, land, employment and procurement, community feedback, stakeholder engagement

The overall responsibilities for the proposed CBM project will be with BP (the Project proponent). BP will ensure that all project personnel and contractors representatives understand BPs policies, programmes and contractual terms, management and monitoring requirements and ERP (emergency response plan) and DMP (disaster management plan). Environmental and social awareness programmes will be implemented to ensure that personnel are aware of environmental and social issues and their responsibilities related to these issues. Coordination of project activities will be undertaken as required with authorities such as Birbhum district authority, CBM Block and Village Administration, Land and Land Reforms department, Irrigation department, Ground water authority, Department of Forest and Environment, West Bengal Pollution Control Board, Ministry of Environment and Forests, Directorate General of Hydrocarbon (DGH), and Director General of Mines and Safety (DGMS). The Project will implement a monitoring plan to ensure that all sites will comply with the commitments in accordance with the MPs. Monitoring of the environmental and social effects of the Project will enable the effectiveness of the mitigation measures to be determined by identifying the gap and taking preventative and corrective action. Project reporting will be undertaken to agencies like WBPCB and MoEF as per the regulatory requirements. BP will ensure that the CBM Project is operated in a manner that conforms to the legal, regulatory and policy objectives. All the necessary permits and licenses will be taken prior to Project operations. CONCLUSION The draft EIA study has concluded that the main issues are related to ground and surface water quality, air quality and vehicular movement. These issues have been appropriately addressed in the various management plans. In addition, input from the public consultation exercise will be taken into account in the preparation of the final EIA report. Upon finalization of EIA report, Project will seek environmental clearance from MoEF.
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