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S.B. ASSOCIATES

Environmental Impact Assessment (EIA) Study

Sumya Northern Industrial Zone

March 2021 Ref: EIA/06/03/21

EMC PVT. LTD. 503, Anum Estate, Opp. Duty Free Shop, Main Shahrah-e-Faisal, . Phones(+) 9221- 34311466, 34382860, Fax: (+) 9221-34311467. E-mail: [email protected], [email protected] Website: www.emc.com.pk

Disclaimer:

This report has Attorney – Client Privilege. EMC Pakistan Pvt. Ltd. has prepared this report in accordance with the instructions of S.B. Associates for their sole and specific use. Any other persons who use any information contained herein do so at their own risk. This report cannot be used in the court of law for any negotiation or standardization. © EMC Pakistan Pvt. Ltd. 2021 Environmental Impact Assessment (EIA) Study Sumya Northern Industrial Zone

EXECUTIVE SUMMARY

Project Sumya Northern Industrial Zone Proponent S.B. Associates

This report represents the study of Environmental Impact Assessment (EIA) of Sumya Northern Industrial Zone. The project site is situated at Survey No. 371, 372 & 373/1, Deh Bund Murad Khan, Town, , Karachi West (site coordinates 25°01'51.46"N and 67°01'15.92"E).

The facility will comprise heavy, medium and light engineering industries including textile, automobile manufacturing units, and process plants and covers an area of about 36.50 acres (176660 SQ YDS). The project is directly facing 200’’-0’ ft wide Hum Dam Road which leads to Karachi Northern Bypass when moving northwards; and in the south, Hum Dam Road connects the project site with main Manghopir Road.

Figure ES.1: Project Location

The (EIA) study has been prepared by EMC for the compliance of the requirement under section 17 of Environmental Protection Act, 2014 and IEE/EIA Regulations 2014. The study has taken into consideration all the relevant national legislations and regulations. Environmental and socio-economic baseline has been taken from previous reports, books and other literature available specifically to the project area. The baseline has been further investigated and confirmed during site visit. Accordingly, this Environmental Assessment has been conducted by EMC Pakistan Private Limited to provide an assessment of the environmental concerns that need to be taken into account with regard to the construction and operation of proposed facility. This assessment report has attempted to fulfill the objectives of study as given below:

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 To provide detailed description of the project area  To establish baseline environmental and social profile of the project area  To outline applicable legislative requirements for the project  To carry out thorough assessment of the project in order to identify and evaluate the likely project impacts on the environmental and social components of the micro and macro environment  To prepare Environmental Management Plan (EMP) for the project to control the anticipated impacts at manageable level Site surveys were conducted to develop the environmental baseline. No endangered flora or fauna exists at the project site. Detailed analysis of major environmental and social impacts was performed and their corresponding mitigation measures are discussed in the report. The assessment is primarily focused on the construction activities and later operations of the building. The major areas covered in the impact analysis include wastewater, air emissions, solid waste, occupational safety and socio-economic factors.

Screening and assessment of potential environmental impacts for the project finds that:

 The project site has no protected areas such as wildlife, game reserves or national park, or any archaeological, historical or cultural heritage in its neighborhood; no impact is therefore envisaged.  Sources of air emissions include mainly the manufacturing process and the generators operated for backup power supply in case of power failure from grid. Key constituents of

these stack emissions include smoke, Particulates, SOx, NOx, CO, and CO2.  Project activities during operation phase are not environmentally intensive predominantly, as the major process effluent discharge is from the textile based units only.  An Effluent Treatment Plant is suggested to be constructed and to make it operational before commencing the textile and automobile units operations at the proposed site. Assessment of impact associated with project finds that the impacts from the project operations are not of such scale so as to cause adverse environmental impact on the ambient environment and where potential impact arises, proportional mitigation measures have been provided to eliminate or keep the impacts within acceptable and permissible limits.

For the effective implementation and management of the mitigation measures and monitoring requirements an Environmental Managements Plan (EMP) has been prepared. The EMP satisfies the requirements of the Sindh Environmental Protection Agency (Review of EIA/IEE) Regulations- 2014, and the Pakistan Environmental Assessment Procedures, 1997.

Based on the findings of the environmental assessment, and the suggested mitigation measures it is reasonable to suggest that the environmental impacts of construction and operation of proposed project are minor to moderate and can be mitigated by effective implementation of the Environmental Management Plan (EMP), which forms an integral part of the EIA report.

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Table of Contents

EXECUTIVE SUMMARY ...... i

Chapter 1 INTRODUCTION ...... 1

1.1. General ...... 1 1.1. Overview of Project ...... 2 1.2. Project Location ...... 2 1.3. Brief Description of Project ...... 2 1.4. Objectives of Environmental Assessment ...... 4 1.5. Methodology for Environmental Assessment ...... 4 1.5.1. Scoping ...... 5 1.5.2. Acquiring Project Specific Data ...... 6 1.5.3. Literature Review ...... 6 1.5.4. Stakeholder Consultation ...... 6 1.5.5. Reconnaissance and Detailed Surveys ...... 7 1.5.6. Aspects Identification ...... 7 1.5.7. Impact Assessment and Mitigation Measures ...... 7 1.5.8. Environmental Management and Monitoring Plan ...... 7 1.5.9. Documentation Review and Conclusion ...... 8 1.6. Structure of EIA Report ...... 8 1.7. EIA Study Team ...... 8

Chapter 2 REGULATORY FRAMEWORK ...... 9

2.1. Administrative and Statutory Framework ...... 9 2.1.1. Sindh Environmental Protection Act, 2014 ...... 10 2.1.2. Sindh EPA (Review of IEE/EIA) Regulations 2014 ...... 12 2.1.3. Guidelines for Public Consultation ...... 13 2.1.4. Sindh Environmental Quality Standards (SEQS) ...... 14 2.2. Other Relevant Laws & Regulations ...... 18 2.2.1. Sindh Prohibition of Child Employment Act, 2017 ...... 18 2.2.2. The Sindh Occupational Safety and Health Act, 2017 ...... 19 2.2.3. Pakistan Penal Code 1860 ...... 19 2.2.4. Sindh Factories Act, 2015 ...... 19 2.2.5. Hazardous Substances Rules, 2014 ...... 20 2.2.6. Land Acquisition Act, 1894 ...... 20 2.2.7. Self-Monitoring and Reporting by Industry Rules, 2014 ...... 20 2.2.8. Sindh Solid Waste Management Board Act, 2014 ...... 20 2.2.9. Archaeological Relics ...... 20 2.3. National Environmental Guidelines ...... 21 2.3.1. Pakistan Environmental Assessment Procedures ...... 21 2.4. International Environmental Guidelines ...... 23 2.4.1. IFC General EHS Guidelines ...... 23

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Chapter 3 PROJECT DESCRIPTION ...... 24

3.1. The Project ...... 24 3.2. Project Location ...... 24 3.3. Project Details ...... 24 3.4. Construction Activities ...... 26 3.5. Utilities during Construction Phase ...... 29 3.5.1. Electricity ...... 29 3.5.2. Workforce ...... 29 3.6. Utilities during Operation Phase ...... 29 3.6.1. Electricity ...... 29 3.6.2. Water ...... 29 3.6.3. Workforce ...... 29 3.7. Health, Safety and Environment ...... 29 3.8. Solid Waste Management ...... 30 3.9. Fire Protection System ...... 30 3.10. Approvals ...... 30

Chapter 4 DESCRIPTION OF ENVIRONMENT ...... 31

4.1. Project Location and Geography ...... 31 4.2. Description of Physical Environment ...... 33 4.2.1. Geology, Geomorphology and Soil ...... 33 4.2.2. Seismicity...... 35 4.2.3. Liquefaction Features Caused by Earthquake ...... 39 4.2.4. Meteorology and Climate ...... 39 4.2.5. Impact of Climate Change - Karachi ...... 46 4.2.6. Ambient Air Quality ...... 50 4.2.7. Noise Quality ...... 51 4.2.8. Water Resources, Water Quality and Drainage ...... 51 4.2.9. Water Quality ...... 58 4.2.10. Storm Water Drainage ...... 60 4.3. Ecological Baseline ...... 62 4.3.1. The Ecology of Project Area ...... 62 4.3.2. Vegetation ...... 62 4.3.3. Fauna of Macro-environment ...... 64 4.4. Socioeconomic Environment ...... 64 4.5. Macro Environment ...... 64 4.5.1. Administrative Context ...... 64 4.5.2. Demography ...... 65 4.5.3. Transportation ...... 66 4.5.4. Economy ...... 67 4.5.5. Education Sector ...... 67 4.5.6. Public Health Sector ...... 68 4.6. Description of Microenvironment...... 69 4.6.1. Education Facilities...... 70

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4.6.2. Healthcare Facilities ...... 70 4.6.3. Utilities ...... 70 4.6.4. Transportation ...... 70

Chapter 5 INFORMATION DISCLOSURE, CONSULTATION & PARTICIPATION ...... 71

5.1. Stakeholder Mapping ...... 71 5.1.1. Local People/Neighborhood ...... 71 5.1.2. Proponent ...... 71 5.1.3. Government Agencies ...... 72 5.1.4. NGOs/Interest groups ...... 72 5.2. Primary and Secondary Stakeholders ...... 72 5.3. Consultation Approach & Methodology ...... 73 5.3.1. Consultation with Primary Stakeholders ...... 73 5.4. Consultation Feedback ...... 74

Chapter 6 SCREENING OF POTENTIAL ENVIRONMENTAL AND SOCIAL IMPACTS AND APPROPRIATE MITIGATION MEASURES ...... 77

6.1. Methodology for Impact Assessment ...... 78 6.1.1. Environmental & Social screening checklist ...... 79 6.2. Screening of Potential Impacts at Siting / Planning & Designing (Pre-Construction) Phase ...... 81 6.2.1. Structural Stability ...... 81 6.2.2. Threat to Biodiversity ...... 82 6.2.3. Archaeological / Cultural / Protected Areas ...... 82 6.2.4. Land Acquisition ...... 82 6.3. Screening of Potential Environmental Impacts at Construction Phase and their Mitigation Measures ...... 83 6.3.1. Erosion of Soil ...... 83 6.3.2. Soil Contamination ...... 84 6.3.3. Construction Waste ...... 85 6.3.4. Ambient Air Quality ...... 86 6.3.5. Impact on Ambient Noise Levels ...... 88 6.3.6. Water Consumption ...... 90 6.3.7. Impacts of Wastewater Generation ...... 91 6.3.8. Operation of Vehicular Traffic ...... 91 6.3.9. Materials Selection ...... 92 6.3.10. Occupational Health and Safety ...... 93 6.3.11. Energy Use ...... 97 6.3.12. Community Health and Safety ...... 97 6.4. Impact Associated with the Operations of Project ...... 98 6.4.1. Soil Contamination ...... 98 6.4.2. Groundwater Contamination ...... 99 6.4.3. Solid and Hazardous Waste: Generation and Disposal ...... 99 6.4.4. Water Consumption and Quality Assurance ...... 101 6.4.5. Wastewater and its Disposal ...... 102

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6.4.6. Fire Hazard ...... 103 6.4.7. Air Quality ...... 104 6.4.8. Noise ...... 104 6.4.9. Energy Consumption ...... 105 6.4.10. Illumination...... 105 6.4.11. Traffic Flow and Congestion ...... 106 6.4.12. Land Use and Aesthetics ...... 106 6.4.13. Socio-Economic Impacts...... 107

Chapter 7 ENVIRONMENTAL MANAGEMENT PLAN ...... 108

7.1. Introduction ...... 108 7.2. Need for EMP ...... 109 7.3. EMP Process ...... 109 7.4. Management Approach ...... 110 7.5. Maintenance of the EMP ...... 110 7.6. Health Safety and Environment Management System ...... 110 7.7. Risk Assessment ...... 111 7.7.1. Identification of Environmental and Social Aspects of Project ...... 111 7.8. Legislation and Guidelines ...... 112 7.9. Roles and Responsibilities ...... 112 7.9.1. Top Management ...... 113 7.9.2. Construction Manager ...... 113 7.9.3. HSE Officer ...... 113 7.9.4. Construction Contractor ...... 114 7.9.5. Independent Monitoring Consultants ...... 114 7.10. Regulatory Requirements ...... 114 7.10.1. Approvals, Authorizations and Permits ...... 114 7.10.2. Compliance Monitoring ...... 114 7.11. Audits ...... 115 7.11.1. Site Internal Environmental Audit ...... 115 7.11.2. Environmental Management Systems Audit ...... 115 7.12. Implementation Stages of EMP ...... 115 7.12.1. Planning and Design of Proposed Project ...... 115 7.12.2. Construction and Operation Phase ...... 116 7.12.3. Mitigation Plan ...... 118 7.12.4. Monitoring and Review ...... 118 7.12.5. Training ...... 119 7.12.6. Communications ...... 119 7.12.7. Emergency Procedures ...... 120 7.12.8. Change Management ...... 122

Chapter 8 CONCLUSION ...... 139

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List of Tables

Table 1.1: Contact Details ...... 1 Table 1.2: Salient Features of the Project ...... 2 Table 1.3: List of EIA Team Members ...... 8 Table 2.1: Sindh Environmental Quality Standard for Ambient Air ...... 15 Table 2.2: The Motor Vehicle Noise ...... 16 Table 2.3: Sindh Environmental Quality Standard for Noise ...... 16 Table 2.4: Sindh Environmental Quality Standard for Municipal & Liquid Industrial Effluents ..... 16 Table 2.5: Sindh Environmental Quality Standards for Drinking Waters (mg/l) ...... 17 Table 2.6: Sindh Environmental Quality Standards for Selected Gaseous Pollutants from Industrial Sources ...... 18 Table 3.1: Salient Features of the Project ...... 24 Table 3.2: Area Schedule of Project Features ...... 25 Table 4.1: List of Earthquake in Indus Deltaic Region and surrounding within Latitude 23.0-25.0N and Longitude 67.5-71.0E ...... 37 Table 4.2: Seasonal Characteristics of the Climate of Karachi ...... 40 Table 4.3: Mean Monthly Maximum Temperature °C ...... 41 Table 4.4: Monthly Amount of Precipitation (mm) at Karachi Airport ...... 43 Table 4.5: Mean Monthly Relative Humidity (Mean) at 1200 UTC (%) ...... 44 Table 4.6: Wind Speed (m/s) at 12:00UTS ...... 45 Table 4.7: Wind Direction at 12:00UTS ...... 45 Table 4.8: Ambient Air Quality SEQS Parameters ...... 50 Table 4.9: Noise Level Test Result ...... 51 Table 4.10: Present Water Supply Capacity ...... 55 Table 4.11: Blockage in Malir River and its Tributaries based on Satellite Data ...... 58 Table 4.12: Descriptive statistics of physical, chemical and microbiological analysis of Ground water of Macro-environment ...... 60 Table 4.13: Town-wise Storm water Drainage/Nallah Length ...... 60 Table 4.14: Covered Area of District & Sub-Division ...... 65 Table 4.15: Demographic Change in District West and Manghopir Sub-Division (1998-2017) ... 65 Table 4.16: District wise Number of Schools, Enrollment and Staff in Karachi (2016-17) ...... 67 Table 4.17: District-wise Basic and Advance Facilities in Schools of Karachi ...... 68 Table 4.18: District-wise Government Medical and Paramedical Personnel in Karachi 2017 ..... 68 Table 4.19: District-wise Government Health Facilities with Bed Capacity in Karachi 2017...... 69 Table 5.1: Stakeholders for Sumya Northern Industrial Zone ...... 72 Table 5.2: Consultations with Primary Stakeholders ...... 73 Table 5.3: Primary Stakeholder Consultations Pictures...... 74 Table 6.1: Checklist for Screening Environmental Impacts ...... 79 Table 6.2: Construction Equipment Noise Range dB (Average) ...... 89 Table 7.1: Mitigation Matrix for Design and Construction Phase ...... 124 Table 7.2: Mitigation Matrix during Operation Phase of the Project ...... 131 Table 7.3: Environmental Monitoring Plan (Construction Phase) ...... 135 Table 7.4: Environmental Monitoring Plan (Operation Phase) ...... 137

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List of Figures

Figure 1.1: Project Location ...... 3 Figure 1.2: Steps of EIA ...... 5 Figure 2.1: Pakistan Environmental Assessment Package (Source: Pakistan EPA) ...... 22 Figure 3.1: Project Location ...... 27 Figure 3.2: Conceptual View of the Project ...... 28 Figure 4.1: Current Status of Project Site ...... 31 Figure 4.2: Project Location ...... 32 Figure 4.3: Soil Characteristics Map of Karachi ...... 34 Figure 4.4: Seismicity & Natural Disasters - Pakistan, 1990-2000 ...... 35 Figure 4.5: Schematic plate tectonic sketch map showing the Karachi Arc and its regional tectonic framework ...... 36 Figure 4.6: Earthquake epicenter plots for the time period 1902-2013 ...... 36 Figure 4.7: Seismic Zones in Karachi ...... 38 Figure 4.8: Seismic Hazard for Pakistan in terms of Peak Ground Acceleration (PGA) ...... 39 Figure 4.9: Daily High and Low Temperature ...... 42 Figure 4.10: Fraction of days on which different types of precipitation are observed ...... 43 Figure 4.11: Canal System of Hub Dam River ...... 52 Figure 4.12: Karachi Monthly Water Demand ...... 56 Figure 4.13: Existing Sewerage System of Karachi ...... 57 Figure 4.14: Flora of the Project site ...... 63 Figure 4.15: Vegetation Trends in Karachi ...... 63 Figure 4.16: District wise Population according to the 1998 and 2017 Census ...... 66 Figure 6.1: Different Impacts Prediction on different stages and their Mitigation Strategy ...... 77 Figure 6.2: Pakistan’s Peak Ground Acceleration (g) Source PMD ...... 81 Figure 6.3: Hypothetical Study of Water Consumption on Construction Site ...... 90 Figure 7.1: Typical EMP Model ...... 108

List of Annexures

Annex I: Site Plan Annex II: Ambient Air Quality and Nosie Monitoring Reports Annex III: No Objection Certificate (NOC) and Approvals Annex IV: SEPA (Review of IEE/EIA) Regulations 2014

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Chapter 1 INTRODUCTION

1.1. General This Environmental Impact Assessment (EIA) report presents the assessment of environmental and social impacts that will arise due to the development of “Sumya Northern Industrial Zone” which will be developed by M/s S.B. Associates. This document has been prepared in compliance with the mandatory requirement of the Section 17 of Sindh Environmental Protection Act (SEPA) 2014. Compliance with provisions of SEPA 1997, Section 17 requires that “no proponent of a project will commence construction or operation unless he has filed with the Agency an environmental impact assessment, and has obtained from the Agency approval in respect thereof”.

M/s EMC Pakistan Private Limited has been commissioned by M/s S.B. Associates to assess the project’s environmental and social viability through various environmental components like air, water, noise, including land, biological along with the parameters of human interest and to prepare Environmental Management Plan (EMP) for mitigation of adverse impacts along with chalking out of post project environmental monitoring programme. This report presents the baseline data collected for air, water, noise including land, biological and socio-economic components of environment, identification, prediction and evaluation of impacts and preparation of environmental management plan for mitigation of adverse impacts that may arise due to the proposed project.

M/s S.B. Associates has successfully executed numerous development projects of similar nature and magnitude with a strong track record of putting together a state-of-the-art building and construction technologies. They have, in their business of construction employed modern management tools and work methodology to implement the project on a fast and right track. With professionally qualified and competent staff, efficient work force, flexible organization and a large pool of modern construction equipment & machinery. The proponent has the capability to undertake mixed-use development projects. The design of the proposed project has been undertaken by a multidisciplinary team of consultants to address the aspects of building stability, energy needs, resource management, sustainability, safety & security and compliance of environmental standards.

The contact details of proponent and EIA consultant are as follows:

Table 1.1: Contact Details Project Proponent EIA Consultant S.B. Associates EMC Pakistan Private Limited Shop # 06, Ayesha Arcade, Plot No 12/3 Suite # 503, Anum Estate, Opp. Duty Free BMCHS, Block 3, Main Jamaul Uddin Shop, Main Shahrah-e-Faisal, Karachi Afghani Road, Karachi Contact: (+) 92 21 34382860 Contact: 021-34931010-34942213 Fax: (+) 92 21 34311467 Email: [email protected]

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1.1. Overview of Project “Sumya Northern Industrial Zone” Project will be developed by M/s S.B. Associates. It will provide professional services for many projects relating to heavy, medium and light engineering industries including textile, automobile manufacturing units, process plants, and others1. Total area of the project site is around 36.50 acres (176660 SQ YDS).

1.2. Project Location The Sumya Northern Industrial Zone project is planned at Survey No. 371, 372 & 373/1, Deh Bund Murad Khan, , Manghopir, Karachi West (site coordinates 25°01'51.46"N and 67°01'15.92"E). The project is directly facing 200’’-0’ ft wide Hum Dam Road which leads to Karachi Northern Bypass when moving northwards; and in the south, Hum Dam Road connects the project site with main Manghopir Road.

The major landmarks near the project site are SkyClan Global Pvt Ltd - Factory/WH, Nishan-e- Haider Farm Houses, and Masjid-e-Taqwa. Towards eastern periphery of the project site, Hub Canal is also passing from north to south.

In the macroenvironment, industrial and commercial units are also located including Siddiqsons Industries, Hamdard Factory, Al-Saud Mini Floor Mills, Al Abbas Grinding Mill, Zamzam Poultry and Livestock and others.

1.3. Brief Description of Project

The salient features of the project are as under:

Table 1.2: Salient Features of the Project Proponent M/s. S.B. Associates Location Survey No. 371, 372 & 373/1, Deh Bund Murad Khan, Gadap Town, Manghopir, Karachi West Components of the Project Nature Area (SQ YDS) Percentage (%) Industrial Area 85879 48.61 Commercial Area 1767 1.00 Recreation Area 5300 3.00 Amenities Area 10636 6.02 Roads 73078 41.37 Total 176660 100.00 Total Area 36.50 acres

1 https://promisemarketing.com.pk/sumya-industrial-zone/

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Figure 1.1: Project Location

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1.4. Objectives of Environmental Assessment This EIA study is conducted in the preliminary stage of the project in order to acquire approval for initiating basic surveys and testing, erection of boundary wall for securing the site. Meanwhile, we will undertake a detailed EIA study as per SEPA IEE/EIA regulations 2014 and follow the review and approval process for the same.

The main objectives of EIA is to identify the environmental and socio-economic impacts both positive and negative that may result from the location of the project. This EIA provides recommendations to mitigate negative impacts and maximize benefits on all aspects of the surrounding environment (physical, biological and social). The objectives outlined for this EIA study are given below:

 To identify and describe elements of community and environment likely to be affected by the proposed developments and / or likely to cause adverse impacts to the project, including natural and man – made environment;  Develop a baseline of its current environmental scenario as well as socioeconomic conditions;  Identify potential impacts that may arise;  To identify any potential losses or damage to flora, fauna and natural habitats;  To identify any damage to land and water drainage patterns present on the site;  Determine social aspects and environmental resources which are particularly sensitive to impacts and categorize impacts on the basis of their severity;  Evaluate impacts due to construction and operation activities of the project with the relevant environmental regulations of Pakistan;  Evaluation of impacts severity / degree and providing necessary mitigation measures;  Provide recommendations / suggestions for the environmental monitoring and management of social and physical environment in the surroundings of project area; and  Ensure that all the impacts of the project have been taken care and all the relevant stakeholders are aware of the impacts.

1.5. Methodology for Environmental Assessment This environmental assessment (examination and evaluation) is based on comparative evaluation of the environmental quality before and after establishment of the project. For this purpose, the baseline of the profile project area was developed by collecting data, records and information on physical, ecological as well as socioeconomic environment, in particular the surrounding areas in its neighborhood. An assessment of impact at the different phases of the project, i.e. pre- construction, construction and operation stages. The changes anticipated in the critical environmental aspects e.g. in the ambient environmental parameters that may be significant have been identified. This leads to identification of significant impact, for which necessary mitigation measures have been proposed.

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Figure below shows the step by step process for the completion of an EIA study.

Figure 1.2: Steps of EIA Source: EIA Study Team

1.5.1. Scoping A scoping exercise was undertaken to identify the potential issues that are to be considered in the environmental impact assessment. The scoping exercise included the following tasks:

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Data Compilation: A generic description of the proposed activities relevant to this environmental assessment was compiled with the help of the Project Proponent.

 Review of Published literature: All available published and unpublished information pertaining to the micro & macro environment of the study area was obtained and reviewed. It included the earlier studies conducted in the study area, environmental & social baseline and impact assessment studies conducted by different consultants in past. Secondary data was very helpful in understanding the issues that were identified by other consultants.  Review of applicable Legislation: Information on relevant legislation, regulations, guidelines, and standards was reviewed and compiled.  Identification of potential impacts: The information collected in the above procedures was reviewed and potential environmental issues identified.  Initial site visit: An initial site visit was conducted to get an overview of site conditions and the surrounding areas.

1.5.2. Acquiring Project Specific Data This was the very first step to embark on the study initiated through meetings held with the officials of the proponent. In the meetings, discussions were made to clarify the nature and location of project in environmental perspectives. Basic information on the form of raw input received from the proponent was analyzed by the experts to comprehend the project and to assess its influence on the environment.

1.5.3. Literature Review While the project details were being acquired, desktop study was also initiated simultaneously to draft environmental baseline information of the project area. The desktop study comprised of literature review, collection of updated authenticated published/printed data on the physical and social environment related to the focused area. The same was also used to delineate the scope of surveys which would then form the basis of environmental assessment.

1.5.4. Stakeholder Consultation A stakeholder consultation was undertaken to document the concerns of the local community and other stakeholders, and to identify issues that may require additional assessment in order to address these concerns. Stakeholder consultation was conducted during the survey with following objectives:

 To inform the Stakeholders, Communities about the project  To gather feedback from primary and secondary stakeholders of project  To identify relevant potential issues, including the socioeconomic impact of the project, and corresponding mitigation measures. During the stakeholder consultation process for the project, following key considerations were focused:

 Identification of sensitive receptors in the area

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 Concerns of the nearby villages about the project

1.5.5. Reconnaissance and Detailed Surveys Preliminary surveys of project location were organized by EMC in which experts visited the area and assessed the physical scenario for the EIA stage. The relevant surveys were carried out under the supervision of environmental experts. Preliminary socio-economic evaluation was also undertaken.

Detailed and comprehensive surveys will be conducted in detailed EIA study stage to investigate various domains of environment and socio-economic sector to highlight various issues, and concerns that may lead to the identification of aspects and subsequent assessment of impacts.

For having an over view of the project area and to assess the existing infrastructure and socio- economic activities, a detailed groundwork investigation was carried out around the microenvironment of project area.

 Ambient Air Quality  Noise Level Measurement  Identification of Cultural Heritage Sites within 500m radius  Ecological Survey

1.5.6. Aspects Identification The EIA process requires development of an inventory of all possible environmental and socio- economic aspects of the project, which provide the basis of categorization and evaluation of impacts and their likelihood to occur due to the materialization of the project. Aspects are those which are the causes of positive or negative impacts. Those aspects are primarily associated with activities performed during construction and operation phases of the Project.

1.5.7. Impact Assessment and Mitigation Measures Based on the developed aspects inventory, experts analyzed the aspects for their logical outcome as potential impacts on the physical and social environment. These impacts have been identified, assessed and weighed for different activities during construction, commissioning and operational phases of the Project.

Mitigation and control measures were also proposed for various activities of Project in order to minimize the potential impacts during the life span of the Project.

1.5.8. Environmental Management and Monitoring Plan In the light of impacts identified and mitigations proposed an Environmental Management Plan (EMP) has been developed which has a pivotal role in assigning tasks to personnel for the environmental management and implementation of mitigation measures as well as to monitor its effectiveness throughout the life cycle of the project. It also provided monitoring plans/procedures to be followed for checking and compliance maintenance of environmental quality and legal requirements through suggested mitigation measures.

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1.5.9. Documentation Review and Conclusion This is the final step to complete the environmental assessment and compile all the work done in shape of an EIA report. Report writing started just after the initiation of environmental assessment. The report has been written by experts of EMC and compiled by the office staff in coordination with the experts. At the end of the study, the entire report is reviewed by the team leader followed by recommendations and conclusion in the light of the assessment.

1.6. Structure of EIA Report The EIA report has been structured on the standard format, prescribed by the Pakistan EPA. The Report has been presented in the following sections:

 Chapter 1: Provides an introduction and overview of the project  Chapter 2: Gives an overview of policy and legislation along with international guidelines relevant to the project  Chapter 3: Includes the project description, its objective, location of the project area and construction /operation related details  Chapter 4: Provides description of the microenvironment and macro environment of the project area. This chapter contains description of the Physical, Biological and built environment of the Site.  Chapter 5: Describes the public consultations and its outcomes.  Chapter 6: Describes screening of environmental and social impacts and appropriate mitigation measures.  Chapter 7: Presents the Environmental Management Plan and Monitoring Program for the project  Chapter 8: Summarizes the report and presents its conclusions. The main text of the report is supported by a series of Annexures which provide auxiliary information including: Respective sections of prominent Provincial Environmental Laws and Guidelines which form part of the environmental study are provided in the Annexures.

1.7. EIA Study Team This EIA report has been prepared by EMC Pakistan organized and coordinated with the team of experts for the purpose of conducting environmental assessment and preparation of the report:

Table 1.3: List of EIA Team Members S# Name Position in EIA Study Team 1. Mr. Syed Nadeem Arif Project Manager / Team Leader 2. Mr. Muhammad Haseeb Project Coordinator/Sr. Environmental Specialist 3. Mr. Ahmed Zohair Siddqui Environmental Engineer 4. Mr. Khurram Shams Social Specialist 5. Ms. Syed Kanwal Environmentalist 6. Ms. Syeda Urooj Fatima Environmental Scientist 7. Mr. Akhlaq Ghouri Sociologist

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Chapter 2 REGULATORY FRAMEWORK

This section provides synopsis of policies, legislation, and guidelines that may have relevance to the proposed Project and describes the current legal responsibilities of the Proponent in the context of the environment and sustainable development, and the institutions that exist in the province that may influence the environmental management of the Project.

The constitution of Pakistan contains provision for environmental protection and resource conservation. The constitution mentions environmental pollution and the ecology as a subject in the concurrent legislative list, meaning that both the provincial and federal government may initiate and make legislation for the purpose.

Legislative assembly of Sindh province of Pakistan passed the bill on 24th February 2014 to enact Sindh Environmental Protection Act 2014. The Act envisages protection, improvement, conservation and rehabilitation of environment of Sindh with the help of legal action against polluters and green awakening of communities. It equally lays emphasis for the preservation of the natural resources of Sindh and to adopt ways and means for restoring the balance in its ecosystem by avoiding all types of environmental hazards.

A detailed review of these legislations and guidelines will be made part of the EIA study. Below is the list of the applicable legislations / guidelines:

2.1. Administrative and Statutory Framework The constitution of Pakistan contains provision for environmental protection and resource conservation. The constitution mentions environmental pollution and the ecology as a subject in the concurrent legislative list, meaning that both the provincial and federal government may initiate and make legislation for the purpose. Article 9 of the Constitution defines the right to life as a “fundamental right” in these words “No person shall be deprived of life or liberty save in accordance with law”. The Supreme Court of Pakistan in its judgment in the case Shehla Zia and others vs WAPDA (1994) declared that the right to a clean environment is part of the fundamental constitutional right to life.

Several laws exist for the protection of the environment. Some of these laws are Federal and the rest Provincial in character. The promulgation of the Environmental Protection Ordinance 1983 was the first codifying legislation on the issue of environmental protection. This was indeed a consolidated enactment to plug the gaps and remove defects/deficiencies in the legislation. The promulgation of this ordinance was followed, in 1984, by the establishment of the Pakistan Environmental Protection Agency, the primary government institution dealing with environmental issues. Significant work on developing environmental policy was carried out in the late 1980s, which culminated in the drafting of the Pakistan National Conservation Strategy. Provincial environmental protection agencies were also established at about the same time. The National Environmental Quality Standards were established in 1993.

Prior to the 18th Amendment to the Constitution of Pakistan in 2010, the legislative powers were distributed between the federal and provincial governments through two ‘lists’ attached to the Constitution as Schedules. The Federal list covered the subjects over which the federal

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government had exclusive legislative power, while the ‘Concurrent List’ contained subjects regarding which both the federal and provincial governments could enact laws. The subject of ‘environmental pollution and ecology’ was included in the Concurrent List and hence allowed both the national and provincial governments to enact laws on the subject.

However, as a result of the 18th Amendment this subject is now in the exclusive domain of the provincial government. The main consequences of this change are as follows: i) The Ministry of Environment at the federal level has been abolished. Its functions related to the national environmental management haves been transferred to the provinces. The international obligations in the context of environment will be managed by various ministries and departments of the federal government, ii) The Pakistan Environmental Protection Act 1997 (PEPA 1997) is technically no longer applicable to the provinces. The provinces are required to enact their own legislation for environmental protection.

The Provincial Environmental Protection Agencies are formed by the respective Provincial Governments. A Director General who exercises powers delegated to him by the Provincial Government heads each Provincial EPA. IEEs and EIAs are submitted to provincial EPAs for approval.

The (GOS) has designated its Ministry of Environment Climate Change & Coastal Development, to administer matters related to the environment in Sindh. The Sindh Environmental Protection Agency (SEPA) is directly under the Ministry of Environment Climate Change & Coastal Development.

2.1.1. Sindh Environmental Protection Act, 2014 Legislative assembly of Sindh province of Pakistan passed the bill on 24th February 2014 to enact Sindh Environmental Protection Act 2014. The Act envisages protection, improvement, conservation and rehabilitation of environment of Sindh with the help of legal action against polluters and green awakening of communities.

It equally lays emphasis for the preservation of the natural resources of Sindh and to adopt ways and means for restoring the balance in its eco-system by avoiding all types of environmental hazards.

Environmental Protection Council (EPC): It has been formed consisting of Chief Minister as Chairman with Minister in charge of Environment Protection Department, Addl. Chief Secretary, Planning & Development Department, Government of Sindh and Secretaries of Environment, Finance, Public Health Engineering, Irrigation, Health, Agriculture, Local Government, Industries, Livestock & Fisheries Forest & Wildlife, Energy, Education Departments Government of Sindh and Divisional Commissioners of Sindh. Non-official members are also included (i.e. representatives of Chamber of Commerce & Industry and from medical or legal professions etc.) along with DG, EPA & two Members of Provincial Assembly also form part of EPC.

The functions and powers of EPC include coordination & supervision of provisions of Act, approving provincial environmental & sustainable development policies & SEQS, provide guidance for protection & conservation, consider annual Sindh Environmental Report, deal with interprovincial and federal provincial issues, provide guidance for bio safety and assist Federal

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Government in implementation of various provisions of UN Convention on laws on Seas (UNCLOS).

Sindh Environmental Protection Agency (SEPA): SEPA would be headed by Director General (DG) with the aim to exercise the powers and perform the functions assigned to it under the provisions of this Act and the rules and regulations made there under. The Agency shall have technical and legal staff and may form advisory committees.

The Agency shall administer and implement the provisions of this Act and rules and regulations. It shall also prepare environmental policies, take measures for implementation of environmental policies, prepare Sindh Environment Report and prepare or revise Sindh Environmental Quality Standards. SEPA shall also establish systems and procedures for surveys, surveillance, monitoring, measurement, examination, investigation research, inspection and audit to prevent and control pollution and to estimate the costs of cleaning up pollution and rehabilitating the environment and sustainable development. SEPA would also take measures for protection of environment such as to promote research; issues licenses for dealing with hazardous substances, certify laboratories, identify need for or initiate legislation, specify safeguards etc. SEPA would also encourage public awareness and education regarding environmental issues.

SEPA would have powers to enter or inspect under a search warrant issued by Environmental Protection Tribunal or a Court search at any time, any land or building etc. where there are reasonable grounds to believe that an offence under this Act has been or is being or likely to be committed. SEPA may also take samples, arrange for testing or confiscate any article in discharge of their duties.

This act has also provided for Sindh Sustainable Fund derived from various sources such as voluntary contributions or fees generated etc. This fund is utilized for protection, conservation or improvement of environment.

Salient Features of the Sindh Environmental Protection Act

Section-11: No person shall discharge or emit or allow the discharge or emission of any effluent waste, pollutant, noise or adverse environmental effects in an amount, concentration or level which is in excess to that specified in Sindh Environmental Quality Standards.

Section-12 & 13: No person shall import hazardous waste into Sindh province and handle hazardous substances except under licenses etc.

Section 14: No person shall undertake any action which adversely affects environment or which lead to pollute or impairment of or damage to biodiversity, ecosystem, aesthetics or any damage to environment etc.

Section 15: This section deals with regulation of motor vehicles banning emission of air or noise pollutants being emitted from them in excess of allowable standards.

Section 17: This section states that no proponent of a project shall commence construction or operation unless he has filed with the Agency an initial environmental examination or environmental impact assessment and has obtained from Agency approval in respect thereof.

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SEPA shall review the IEE & EIA and accord approval subject to such terms and conditions as it may prescribe or require. The agency shall communicate within four (04) months its approval or otherwise from the date EIA is filed failing which the EIA shall deemed to have been approved.

Section 21: Where agency is satisfied that the discharge or emission has occurred in violation of any provision of this act or rules etc. then it may, after giving an opportunity to person responsible, by order direct such person to take such measures within specified period. The agency under this section has been empowered to immediately stop, prevent or minimize emission, disposal etc. for remedying adverse environmental effects.

Section 22: The person who fails to comply with section 11, 17, 18 and 21 shall be punishable with a fine which may extend to five million rupees, to the damage caused to environment and in the case of a continuing contravention or failure, with an additional fine which may extend to one hundred thousand rupees for every day during which such contravention or failure continues. And, where a person convicted under sub-sections 1&2 had been previously convicted for any contravention of this Act, the Environmental Protection Tribunal (EPT) may, in addition to punishment, award imprisonment for a term that may extend up to three years, or order confiscation or closure of facility etc.

Section 23: Where any violation of this Act has been committed by any of employee of any corporate body, then, that employee shall be considered to be guilty of environmental pollution.

Section 25: This section allows for establishment of Environmental Protection Tribunals.

2.1.2. Sindh EPA (Review of IEE/EIA) Regulations 2014 The Sindh Environmental Protection Agency (Review of EIA/IEE) Regulations 2014 define Schedules (I & II) of projects falling under the requirement of IEE or EIA. This EIA Study has, for environmental classification of the Project into Category A or B, taken account of the requirements of the Sindh Environmental Protection Agency (Review of EIA/IEE) Regulations 2014 which define Schedules (I & II) as follows:

Schedule I: A project falls in Schedule I if it is likely to have adverse environmental impacts, but of lesser degree or significance than those for category ‘A’ and all the mitigation measures to handle the impact is manageable. Such types of projects need IEE report including EMP.

Schedule II: Projects are categorized in Schedule II if they generate significant adverse environmental impacts that require a comprehensive management plan, or if the project is located within or passes through: a) Areas declared by the Government of Pakistan as environmentally sensitive (National Parks/Sanctuaries/Game Reserve), b) Areas of international significance (e.g. protected wetland as designated by the RAMSAR Convention), or c) Areas designated by the United Nations Educational, Scientific, and Cultural Organization (UNESCO) as cultural heritage sites.

Sindh Environmental Protection Agency (Review of IEE/EIA) Regulations, 2014 (“2014 Regulations”) made in exercise of powers conferred under the 2014 Act provide the necessary guidelines on the preparation, submission, & review of Initial Environmental Examinations (IEEs)

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and Environmental Impact Assessments (EIAs). The 2014 Regulations categorize projects in three categories provided in Schedule I, II & III of the 2014 Regulations.

According to Sindh Environmental Protection Agency Regulation, 2014, a project falling in any category listed in Schedule II shall file an EIA with the Sindh Environmental Protection Agency (SEPA). The Project “Sumya Northern Industrial Zone” having an area of 36.50 acres (176660 SQ YDS) is placed in Category C(7) of the Schedule II (List of Projects requiring EIA) of the 2014 Regulations, which provides:

C. Manufacturing and processing (7) Industrial estates (including export processing zones)

The submission and approval procedure for the EIA is summarized below:

Filing: Regulation 9 requires submission of ten hardcopies and two electronic copies accompanied by an application form (Schedule-V), copy of receipt of payment of review fee, NOC from relevant departments (where applicable) and environmental checklist (if project falls in schedule III).

Preliminary scrutiny: Regulation 10 states that within 15 days of report submission the agency shall review the report and inform the Proponent for submission of any additional information.

Public participation: SEPA shall call for a Public Hearing for the project to invite all the concerned persons to raise concerns on the project. Following the Public Hearing, SEPA shall constitute a Committee of Experts to assist the agency in review of the EIA.

Review: The agency shall review the EIA report within four months after issuing confirmation of completeness as per Regulation 9. It shall also conduct an experts’ committee meeting or solicit views from concerned advisory committee.

Validity: Regulation 18 defines the validity period of approval of an IEE or EIA to be three years from date of construction and construction must start within three years of report approval. A three- year extension at a time may be granted upon the agency’s discretion with or without the submission of a fresh IEE or EIA.

Monitoring: Sub-regulation 20 requires the submission of a report to agency on completion of construction of project and after issue of confirmation of compliance, the submission of annual report summarizing operational performance of the project with reference to conditions of approval and maintenance and mitigation measures adopted by the project.

2.1.3. Guidelines for Public Consultation Public consultation is mandated under 2014 Act. Regulation 11 of the 2014 Regulations provides the general requirements whereas the sectoral guidelines indicating specific assessment requirements are provided in the Guidelines for Public Consultation 1997 (the ‘Guidelines’). These are summarized below:

Objectives of Public Involvement: ‘To inform stakeholders about the proposed project, to provide an opportunity for those otherwise unrepresented to present their views and values,

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providing better transparency and accountability in decision making, creating a sense of ownership with the stakeholders’;

Stakeholders: ‘People who may be directly or indirectly affected by a proposal will clearly be the focus of public involvement. Those who are directly affected may be project beneficiaries, those likely to be adversely affected, or other stakeholders. The identification of those indirectly affected is more difficult, and to some extent it will be a subjective judgment. For this reason, it is good practice to have a very wide definition of who should be involved and to include any person or group who thinks that they have an interest. Sometimes it may be necessary to consult with a representative from a particular interest group. In such cases the choice of representative should be left to the group itself. Consultation should include not only those likely to be affected, positively or negatively, by the outcome of a proposal, but should also include those who can affect the outcome of a proposal’;

Mechanism of consultations: ‘Provide sufficient relevant information in a form that is easily understood by non-experts (without being simplistic or insulting), allow sufficient time for stakeholders to read, discuss, consider the information and its implications and to present their views, responses should be provided to issues and problems raised or comments made by stakeholders, selection of venues and timings of events should encourage maximum attendance’;

Timing and Frequency: Planning for the public consultation program needs to begin at a very early stage; ideally it should commence at the screening stage of the proposal and continue throughout the EIA process;

Consultation Tools: Some specific consultation tools that can be used for conducting consultations include; focus group meetings, needs assessment, semi-structured interviews; village meetings & workshops;

Other Important Considerations: The development of a public involvement program would typically involve consideration of the following issues; objectives of the proposal and the study; identification of stakeholders; identification of appropriate techniques to consult with the stakeholders; identification of approaches to ensure feedback to involved stakeholders; and mechanisms to ensure stakeholders’ consideration are taken into account’.

As above, the Guidelines for Public Consultation introduces effective ways to inform the contents of the project to the general public during the planning stage and that eventually consensus building toward the implementation of project is reached. However, there are instances where in middle of a project on direction of tribunal or court environmental assessment carried out with public consultation.

Incorporating public involvement into the stages of environmental assessment is explained in the guidelines that public consultation meeting has to be carried out after the works on "developing options and assessing and mitigating impacts" for comments and assessment.

2.1.4. Sindh Environmental Quality Standards (SEQS) With the SEPA Act, 2014 the Sindh EPA revised the Environmental Quality Standards (EQS) with full consultation of the private sector, industrialist, trade and business associations and NGOs and

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approval of Sindh Environmental Protection Council has developed Sindh Environmental Industrial Wastewater, Effluent, Domestic Sewerage, Industrial Air Emission, Ambient Air, Noise for vehicles, Air Emissions for Vehicles and Drinking Water Quality Standards 2015 vide Notification No.EPA/TECH/739/2014.

This Project will comply with SEQS 2016. A monitoring plan is attached with the EIA study which will monitor the compliance of SEQS for any pollutant streams. Concerns of unchecked fuel, oil & lubricant spills in soil & waterways cannot be ruled out. Drifts of such spills may become dangerous to the eco-system. Safe practices and proper disposal of waste petrochemicals will be proposed in the EMP. Project Proponent and all Contractor are committed to comply with the applicable Sindh-EQS in letter and spirit.

The Tables are of SEQS are presented below:

Table 2.1: Sindh Environmental Quality Standard for Ambient Air Pollutant Time-weighted Concentration in Method of measurement average Ambient Air Sulfur Dioxide Annual 80μgm3 Ultraviolet Fluorescence Method (SO2) Average* 24 hours** 120μgm3 Oxides of Nitrogen as Annual 40μgm3 Gas Phase Chemiluminescence (NO) Average* 24 hours** 40μgm3 Oxides of Nitrogen as Annual 40μgm3 Gas Phase Chemiluminescence (NO2) Average* 24 hours** 80μgm3 3 O3 1 hour 130μgm Non dispersive UV absorption method Suspended Particulate Annual 360μgm3 High volume Sampling, (Average Matter (SPM) Average* flow rate not less than 24 hours** 500μgm3 1.1m3/minute) Respirable Annual 120μgm3 Β Ray absorption method Particulate Matter (PM10) Average* 24 hours** 150μgm3 Respirable Particulate Annual 40μgm3 Β Ray absorption method Matter (PM2.5) Average* 24 hours** 75μgm3 Lead (Pb) Annual 1μgm3 ASS Method after sampling using Average* EPM 2000 or equivalent Filter 24 hours** 1.5μgm3 paper Carbon Monoxide (CO) 8hours** 5mg/m3 Non Dispersive Infra Red (NDIR) 1hours 10mg/m3 method *Annual arithmetic mean of minimum 104 measurements in a year taken twice a week 24 hourly at uniform interval. **24 hourly / 8 hourly values should be met 98% of the in a year. 2% of the time, it may exceed but not on two consecutive days.

Table 2.2 shows the standards for motor vehicle noise.

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Table 2.2: The Motor Vehicle Noise Parameter Standards (maximum permissible limit) Measuring method Noise 85dB(A) Sound-meter at 7.5meter from the source

Table 2.3 shows the SEQS for noise.

Table 2.3: Sindh Environmental Quality Standard for Noise S. No. Category of Area / Effective from 1st Effective from 1st January, 2015 Zone January, 2015 Limit it in dB(A) Leq* Day Time Night Time Day Time Night Time 1 Residential area (A) 65 50 55 45 2 Commercial area (B) 70 60 65 55 3 Industrial area (C) 80 75 75 65 4 Silence Zone (D) 55 45 50 45 Note: 1 Day time hours: 6.00 a. m to 10.00 p. m 2 Night time hours: 10.00 p. m to 6.00 p. m 3 Silence zone; Zone which are declared as such by competent authority. An area comprising not less than 100 meters around hospitals, educational institutions and courts. 4 Mixed categories of areas may be declared as one of the four above-mentioned categories by the competent authority. *dB(A)Leq Time weighted average of the level of sound in decibels on scale A which is relatable to human hearing.

The SEQS for effluents are shown in Table 2.4.

Table 2.4: Sindh Environmental Quality Standard for Municipal & Liquid Industrial Effluents S. Parameter Into Inland Into Sewage Into unit # Waters Treatment Sea 1 Temperature or Temp. increase <3 <3 <3 oC 2 pH value (H+) 6-9 6-9 6-9 o 3 Biological Oxygen Demand (BOD)5 at 20 C 80 250 80 mg/l 4 Chemical Oxygen Demand (COD) 150 400 400 mg/l 5 Total Suspended Solids (TSS) 200 400 200 mg/l 6 Total Dissolved Solids (TDS) 3500 3500 3500 mg/l 7 Oil and Grease 10 10 10 mg/l 8 Phenolic Compounds (as Phenol) 0.1 0.3 0.3 mg/l 9 Chloride (as Cl-) 1000 1000 SC mg/l 10 Fluoride (as F-) 10 10 10 mg/l 11 Cyanide (as CN-)total 1.0 1.0 1.0 mg/l 12 An-ionic detergents (as MBAS) 20 20 20 mg/l 2- 13 Sulphate(SO4 ) 600 1000 SC mg/l 14 Sulphide (S2-) 1.0 1.0 1.0 mg/l

15 Ammonia (NH3) 40 40 40 mg/l 16 Pesticides 0.15 0.15 0.15 mg/l 17 Cadmium 0.1 0.1 0.1 mg/l 18 Chromium (trivalent and hexavalent) 1.0 1.0 1.0 mg/l 19 Copper 1.0 1.0 1.0 mg/l 20 Lead 0.5 0.5 0.5 mg/l 21 Mercury 0.01 0.01 0.01 mg/l

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22 Selenium 0.5 0.5 0.5 mg/l 23 Nickel 1.0 1.0 1.0 mg/l 24 Silver 1.0 1.0 1.0 mg/l 25 Total toxic metals 2.0 2.0 2.0 mg/l 26 Zinc 5.0 5.0 5.0 mg/l 27 Arsenic 1.0 1.0 1.0 mg/l 28 Barium 1.5 1.5 1.5 mg/l 29 Iron 8.0 8.0 8.0 mg/l 30 Manganese 1.5 1.5 1.5 mg/l 31 Boron 6.0 6.0 6.0 mg/l 32 Chlorine 1.0 1.0 1.0 mg/l

The SEQS for drinking water quality are shown in Table 2.5.

Table 2.5: Sindh Environmental Quality Standards for Drinking Waters (mg/l) S.# Properties / Parameters Standard Values for S.# Properties / Standard Pakistan Parameters Values for Pakistan Bacterial Chemical 1 All water intended for Must not be detectable Essential Inorganics (mg/liter) drinking (E. coli or Thermo in any 100 ml sample 3 Aluminum (Al) ≤ 0.2 tolerant Coliform bacteria) mg/l 4 Antimony (Sb) ≤ 0.005 2 Treated water entering Must not be detectable 5 Arsenic (As) ≤ 0.05 the distribution system (E. in any 100 ml sample 6 Barium (Ba) 0.7 coli or thermo tolerant 7 Boron (B) 0.3 coliform and total coliform bacteria) 3 Treated water in the Must not be Detectable 8 Cadmium (Cd) 0.01 distribution system in any 100 ml sample. In 9 Chloride (Cl-) < 250 case of large supplies, (E. coli or thermo tolerant 10 Chromium (Cr) ≤ 0.05 coliform and total coliform where sufficient samples 11 Copper (Cu) 2 bacteria) are examined, must not be resent in 95% of the Organic (mg/L) samples taken 12 Phenolic <0.0002 throughout any compounds 12 month period. Toxic Inorganics (mg/liter) 13 Cyanide (CN)- ≤ 0.05 14 Fluoride (F) ≤ 1.5 15 Lead (Pb) ≤ 0.05 16 Manganese ≤ 0.5 (Mn) Physical 17 Mercury (Hg) ≤ 0.001 4 Color < 15 TCU 18 Nickel (Ni) ≤ 0.02 5 Non objectionable/ Taste Acceptable 19 Nitrate (NO3)- ≤ 50 6 Odor Non objectionable/ 20 Nitrite (NO2)- ≤ 3 Acceptable 7 Turbidity < 5 NTU 21 Selenium (Se) ≤ 0.01

8 Total Hardness as CaCO3 < 500 mg/l 22 Residual 0.2-0.5 9 TDS <1000 Chlorine At consumer 10 pH 6.5-8.5 end

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0.5-1.5 at source Radioactive 11 Alpha Emitters bq/L 0.1 23 Zinc (Zn) 5.0 12 Beta emitters 1

The SEQS for industrial gaseous emissions are shown in Table 2.6.

Table 2.6: Sindh Environmental Quality Standards for Selected Gaseous Pollutants from Industrial Sources (1) S. No. Parameter Sources of Emission Standards (mg/Nm3 unless defined otherwise) 1 Smoke Smoke opacity not to exceed 40% or 2 on Ringelmann Scale 2 Particulate Boilers and furnaces: Matters (2) Oil fired 300 Coal fired 500 3 Hydrogen Any 400 Chloride 4 Chlorine Any 150 5 Hydrogen Fluoride Any 150 6 Hydrogen Sulfide Any 10 7 Sulphur Oxides (3) Sulphuric acid / sulphonic acid 1700 plants 8 Carbon Monoxide Any 800 9 Lead Any 50 10 Mercury Any 10 11 Cadmium Any 20 12 Arsenic Any 20 13 Copper Any 50 14 Antimony Any 20 15 Zinc Any 200 16 Oxides of Nitrogen Gas fired 400 (4) Oil fired 600 Coal fired 1200 Notes: (1) All values are in mg/Nm3, unless otherwise defined (2) Based on the assumption that the size of the particulate is 10 microns or more. (3) Based on 1% Sulphur content in fuel oil. Higher content of Sulphur will cause standards to be pro-rated (4) In respect of emission sulfur dioxide and nitrogen dioxide. The power plants operation on oil and coal as fuel shall comply with the following Standards:

2.2. Other Relevant Laws & Regulations

2.2.1. Sindh Prohibition of Child Employment Act, 2017 Article 11(3) of the Constitution of Pakistan prohibits employment of children below the age of 14 years in any factory, mines or any other hazardous employment. In accordance with this Article, the Prohibition of Child Employment Act (PCEA) 2017 disallows the child labor in Sindh. The

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PCEA defines a child as a person who has not completed his/her fourteenth years of age, and an adolescent means a person who has completed fourteenth year of age but has not completed eighteenth years of his age. No child shall be employed or permitted to work in any establishment including construction but an adolescent can be employed or permitted to work under strict guidelines provided in the PCEA and rules. An adolescent shall not be employed in any hazardous work included in the schedule to the PCEA.

2.2.2. The Sindh Occupational Safety and Health Act, 2017 The Sindh Occupational Safety and Health Bill 2017 has been approved by the Provincial Assembly of Sindh (Ref. Sindh Bill No. 27 of 2017) and enacted as the Sindh Occupational Safety and Health Act, 2017. The Act makes provision for Occupational Safety and Health conditions at all workplaces for the protection of persons at work places against risk of injury arising out of the activities at work places and the promotion of safe, healthy and decent working environment adapted to the physical, physiological and psychological needs of all persons at work.

2.2.3. Pakistan Penal Code 1860 The Pakistan Penal Code deals with offences where public or private property and/or human lives are affected due to the intentional or accidental misconduct of an individual or body of people. In the context of environment, the Penal Code empowers the local authorities to control noise, noxious emissions and disposal of effluents. The NEQS enforced by the EPAs supersede the application of this legislation on industries and municipalities. The Penal Code, however, can provide a basis for the client to coordinate its activities with the local authorities to ensure that its construction activities do not become a cause of public nuisance or inconvenience.

2.2.4. Sindh Factories Act, 2015 The Sindh Factories Act, 2015, deals with any premises which fall in the category of a Factory i.e. where any manufacturing work is carried out employing ten or more persons. Inspectors, appointed under this act, are empowered to enforce the provisions of this Act. Section 11(1) of the Act “Registration and Deregistration of Factory” states that:

‘Provided also that the registration documents be supported by No Objection Certificates from Industries Department, approval of Sindh Environmental Protection Agency (SEPA) and any other document or forms in the prescribed manner.’

Chapter III of this Act titled “Health & Safety” comprising of Section 15-53, describes various Occupational Health and Safety measures that any Factory has to follow. The provisions of this chapter include clean working environment, arrangements for disposal of wastes and effluents on regular basis, provision of adequate ventilation, prevention from accumulation of dust and fumes generated during manufacturing process, avoidance of overcrowding and ensuring of sufficient lighting arrangements. This chapter also requires availability of amenities such as drinking water, canteen, safety against fire hazards and appointment of welfare officer and measures for prevention from diseases. This Act also prescribes penalties for violation of provisions of the Act.

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2.2.5. Hazardous Substances Rules, 2014 These Rules were notified in 2014 to stream line procedures for issue of licenses to industries that generate hazardous waste and grant of licenses to businesses for removal of hazardous waste in an environment-friendly manner. The rules specify procedures to be adopted for disposal of hazardous waste. The Rules also identify two hundred and forty-two hazardous substances and synthetic chemicals.

2.2.6. Land Acquisition Act, 1894 The Land Acquisition Act (LAA) of 1894 amended from time to time has been factory policy governing land acquisition, resettlement and compensation in the country. The LAA is the most commonly used law for acquisition of land and other properties of development projects. It comprises of 55 sections pertaining to areas notifications and surveys, acquisition, compensation and apportionment awards and disputes resolution, penalties and exemptions.

2.2.7. Self-Monitoring and Reporting by Industry Rules, 2014 These rules classify the industrial units for monitoring and reporting their liquid effluent and gaseous emissions into three and two categories respectively. According to each category they define the priority parameters to be monitored and reported to SEPA according to a specific frequency based on working conditions. This monitoring and reporting is in addition to the monitoring conditions as required by the conditions of approval of Environmental assessment. The sampling for testing must be carried out according to Environmental Samples Rules, 2014 and be sent to SEPA certified environmental testing laboratories.

2.2.8. Sindh Solid Waste Management Board Act, 2014 The SSWMB Act, 2014 was enacted to establish a Board for collection and disposal of all solid waste, to arrange effective delivery of sanitation services, to provide pollution free environment and to deal with other relevant matters. The Board established under the Act headed by the Chief Minister or his nominee and constitutes of thirteen other ex officio members of other relevant departments. Some of the salient features and functions of the Board are; it has the right over the solid waste related issues, assets, funds and liabilities of the Councils and shall possess sole rights on all kinds of solid waste within the limits of all Councils established under the Local Government Act 2013, it has the authority to grant permission to individuals, institutions industries, factories, workshops, furnaces, compost making and power generation from the solid waste, for segregation of the recyclable material from the waste, collection, treatment, sale and purchase, recycling or disposal of any kinds of waste.

The solid waste and wastewater generation during the construction and operation phase of the project will be managed and safety measures will be implemented accordingly as defined in the Environmental Management Plan.

2.2.9. Archaeological Relics After the Eighteenth amendment in the constitution the subject of “Ancient and historical monuments, archaeological sites and remains” the entry No.37 of the concurrent legislative list has also devolved to provincial legislations. There are two laws that are directly relevant for

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archaeological relics. The first is The Antiquities Act, 1975, which ensures the protection of Pakistan’s cultural resources. The Act defines “antiquities” as ancient products of human activity, historical sites or sites of anthropological or cultural interest, national monuments, etc. The Act is designed to protect these antiquities from destruction, theft, negligence, unlawful excavation, trade, and export. The law prohibits new construction in the proximity of a protected antiquity and empowers the GoP to prohibit excavation in any area that may contain articles of archaeological significance. Under the Act, the Project proponents are obligated to ensure that no activity is undertaken within 61 m (200 ft.) of a protected antiquity, and to report to the GoP’s Department of Archaeology any archaeological discovery made during the course of the project. The second is The Sindh Cultural Heritage (Preservation) Act, 1994, which is the provincial law for the protection of cultural assets. Its objectives are similar to those of the Antiquity Act. Heritage Foundation has catalogued 600 historic buildings declared heritage sites under the Sindh Cultural Heritage (Preservation) Act, 1994.

No such sites exist in the vicinity of project.

2.3. National Environmental Guidelines

2.3.1. Pakistan Environmental Assessment Procedures The Federal EPA has prepared a set of guidelines for conducting environmental and social assessments. The guidelines derive from much of the existing work done by international donor agencies and NGOs. The package of regulations, of which the environmental and social guidelines form a part, includes the PEPA 1997 and the NEQS. These guidelines are listed below followed by comments on their relevance to proposed project:

Policy and Procedures for Filing, Review & Approval of Environmental Assessments, Pakistan Environmental Protection Agency, September 1997: These guidelines define the policy context and the administrative procedures that govern the environmental assessment process from the project pre-feasibility stage to the approval of the environmental report. The section on administrative procedures has been superseded by the Sindh IEE/EIA Regulations 2014. The package of regulations prepared by PEPA with relevance to this EIA includes:

 Policy and Procedures for Filing, Review and Approval of Environmental Assessments;  Guidelines for the Preparation and Review of Environmental Reports;  Guidelines for Public Consultation

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Figure 2.1: Pakistan Environmental Assessment Package (Source: Pakistan EPA)

Policy and procedures for filing, review and approval of environmental assessments: These guidelines define the policy context and the administrative procedures that will govern the environmental assessment process, from the project pre-feasibility stage, to the approval of the environmental report. According to the procedures laid out in the policy guidelines, IEE's or EIA's are to be filed with the EPA of the province where the project is to be implemented. The PEPA has, however, been given the right to review any environmental report at any time and the power to revoke the decision of the provincial EPA, if it deems this to be necessary. Projects have been classified in the policy guidelines by expected degree of adverse environmental impacts.

Those projects having potential environmental impacts are listed in Schedule-II. Projects which have comparatively small environmental issues and can be managed by less extensive analysis are included in Schedule-I.

Guidelines for the preparation and review of environmental reports: It requires proponents to prepare terms of reference for the environmental assessment reports. It requires that all studies should contain baseline data on the area and must contain an assessment of the potential environmental impacts and the recommended mitigation measures.

Guidelines for public consultation: These guidelines are intended to provide assistance throughout the environmental assessment of project by involving the public which can lead to better and more acceptable decision-making. Public involvement, undertaken in a positive manner and supported by a real desire to use the information gained to improve the proposal, will lead to better outcomes, and lay the basis for ongoing positive relationships between the participants.

The guidelines define the "objectives of consultation" as follows: Public involvement is a feature of environmental assessment and can lead to better and more acceptable decision-making. It can

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be time consuming and demanding, yet without it, proposals are seldom soundly based, and there is likely to be antagonism from affected people, Public involvement, undertaken in a positive manner and supported by a real desire to use the information gained to improve the proposal, will lead to better outcomes, and lay the basis for ongoing positive relationships between the participants.

The Guidelines for Public Consultation introduces effective ways to inform the contents of the project to the general public during the planning stage & that eventually consensus building toward the implementation of project is reached.

Incorporating public involvement into the stages of environmental assessment is explained in the guidelines that public consultation meeting has to be carried out after the works on "developing options, and assessing and mitigating impacts" for comments and assessment.

2.4. International Environmental Guidelines

2.4.1. IFC General EHS Guidelines The EHS guidelines published by IFC are technical reference documents that address IFC’s expectations regarding the industrial pollution management performance of its projects; however, these guidelines have been benefited from for other projects as well. They are designed to assist managers and decision makers with relevant industry background and technical information. This information supports actions aimed at avoiding, minimizing, and controlling EHS impacts during construction, operation, and decommissioning phase of a project or facility. Environmental issues associated with the construction and maintenance activities may include, among others, noise and vibration, soil erosion, and threats to biodiversity including habitat alteration and impacts to wildlife.

Examples of the impacts addressed in the General EHS Guidelines include:

 Construction site waste generation;  Soil erosion and sediment control from materials sourcing areas and site preparation activities;  Fugitive dust & other emissions (e.g. from vehicle traffic, land clearing activities, & materials stockpiles);  Noise from heavy equipment and truck traffic;  Potential for hazardous materials and oil spills associated with heavy equipment operation and fueling activities.

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Chapter 3 PROJECT DESCRIPTION

3.1. The Project Sumya Northern Industrial Zone Project is proposed in Karachi, providing state-of-the-art physical and business linkages. The proposed project includes the construction and operation of the industrial zone which will provide professional services for many projects relating to heavy, medium and light engineering industries including textile, automobile manufacturing units, process plants, and others2. Total area of the project site is around 36.50 acres (176660 SQ YDS).

3.2. Project Location The Sumya Northern Industrial Zone project is planned at Survey No. 371, 372 & 373/1, Deh Bund Murad Khan, Gadap Town, Manghopir, Karachi West (site coordinates 25°01'51.46"N and 67°01'15.92"E). The project is directly facing 200’’-0’ ft wide Hum Dam Road which leads to Karachi Northern Bypass when moving northwards; and in the south, Hum Dam Road connects the project site with main Manghopir Road.

The major landmarks near the project site are SkyClan Global Pvt Ltd - Factory/WH, Nishan-e- Haider Farm Houses, and Masjid-e-Taqwa. Towards eastern periphery of the project site, Hub Canal is also passing from north to south.

In the macroenvironment, industrial and commercial units are also located including Siddiqsons Industries, Hamdard Factory, Al-Saud Mini Floor Mills, Al Abbas Grinding Mill, Zamzam Poultry and Livestock and others.

3.3. Project Details Sumya Northern Industrial Zone comprises 52 plots for industrial use, 1 plot for commercial use, 1 plot for recreational purposes and 5 plots to build up amenities area. The salient features and area details of each component of the project are given in the tables below:

Table 3.1: Salient Features of the Project Proponent M/s. S.B. Associates Location Survey No. 371, 372 & 373/1, Deh Bund Murad Khan, Gadap Town, Manghopir, Karachi West Components of the Project Nature Area (SQ YDS) Percentage (%) Industrial Area 85879 48.61 Commercial Area 1767 1.00 Recreation Area 5300 3.00 Amenities Area 10636 6.02 Roads 73078 41.37 Total 176660 100.00 Total Area 36.50 acres

2 https://promisemarketing.com.pk/sumya-industrial-zone/

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Table 3.2: Area Schedule of Project Features Total Area Percentage Type Size Area (SYD) No. of Plots (SYD) (%) Industrial Plot No. 1 ODD 1540 01 1540 Plot No. 2 & 15 ODD 1457 02 2914 Plot No. 3 ODD 1308 01 1308 Plot No. 4 & 11 ODD 1964 02 3298 Plot No. 5 & 12 ODD 1794 02 3498 Plot No. 6 & 13 ODD 1534 02 3068 Plot No. 7 & 9 ODD 1532 02 3064 Plot No. 8 & 10 ODD 1383 02 2766 Plot No. 14 ODD 1607 01 1607 Plot No. 16 ODD 1259 01 1259 Plot No. 17 ODD 2314 01 2314 Plot No. 18 ODD 2264 01 2264 Plot No. 19 ODD 2114 01 2114 Plot No. 20 ODD 2233 01 2233 Plot No. 21 ODD 2018 01 2018 Plot No. 21 ODD 1803 01 1803 48.61% Plot No. 23 ODD 2347 01 2347 Plot No. 49 ODD 1930 01 1930 Plot No. 24 & 25 Plot No. 29 & 30 Plot No. 33 & 34 150’ x 100’ 1667 12 20004 Plot No. 37 to 42 Plot No. 43 & 44 Plot No. 26 to 28 150’ x 120’ 2000 05 4234 Plot No. 36 & 41 Plot No. 35 & 42 150’ x 127’ 2117 02 10000 Plot No. 31 & 32 150’ x 96’ 1600 03 4800 Plot No. 45 Plot No. 46 & 47 92’ x 148’ 1513 02 3026 Plot No. 48 180’ x 92’ 1840 04 1840 Total Industrial Area 52 85879 Commercial COM-1 ODD 1767 01 1767 1.00% Total Commercial Area 01 1767 Recreation ST-6 Play Ground ODD 5300 01 5300 3.00% Total Recreation Area 01 5300 Amenities ST-1 School ODD 2987 01 2987 ST-2 P.B ODD 1865 01 1865 ST-3 Hospital ODD 2018 01 2018 6.02% ST-4 P.B 150’x113’ 1883 01 1883 ST-5 Masjid 150’x113’ 1883 01 1883 Total Amenities Area 05 10636 Roads 73078 41.37% Grand Total 36.50 acres 176660 100.00%

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Detailed Site Plan of the Project is presented in the annexures of this report.

3.4. Construction Activities Construction will start from basement followed by concrete works for installations once the sub- base of the site has been prepared and foundations laid for the process equipment and supporting infrastructure. Sealed site roads and paved areas will be constructed. Topsoil will be removed and stored and not disposed of. Typical activities that will be conducted during civil construction are:  Excavation for foundations  Laying of foundations  Masonry work  Concrete work  Pavement, roads etc.  Finishing (plastering, painting etc.) Civil work comprises of construction of all manufacturing units and utilities areas, besides site leveling, drainage, sewerage and all other infrastructure within the project site boundary. The general specifications/details in respect of type of structures, grade of concrete, materials, etc. for all major units have been assumed to confirm the standard practice of civil works. Steel structures will comprise column structures, plated girders, rolled floor beams, floor plates, hand railings, stairs and ladders etc.

List of Equipment / Machinery for Civil Works S. No. Equipment/ Machinery 1 Graders / Levels 2 Excavators 3 Pneumatic chisels / Hammers 4 Scaffolding Pipes and Fittings 5 Concrete mixers or Readymade mixed concrete trucks 6 Vibrators and grouting pressure pumps 7 Survey equipment like theodolite, leveling instruments and compass 8 Dumpers 9 Steel Shuttering 10 Compactors 11 Mobile Cranes 12 Concrete Lifters 13 Tractors with trolleys 14 Welding sets including auto / MIG welders 15 Air Compressors 16 Gas cutting sets

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Figure 3.1: Project Location

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Figure 3.2: Conceptual View of the Project

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The major foundations of the proposed structure will be of concrete on bearing soil or underlying rock. Piling or equivalent soil improvement could be used in filled areas if required. Bearing capacity, settlement, static and dynamic loading conditions will be considered during design stage. Seismic conditions according to seismic zoning of Karachi and project site area will be taken into account. Wind and all environmental conditions will be duly considered in the design. Color and finishing will be chosen with the aim of enhancing the visual aesthetics.

3.5. Utilities during Construction Phase

3.5.1. Electricity Approximately 40-50 kVA/day electricity will be consumed during different construction activities.

3.5.2. Workforce A total of 100 workers will be employed during construction phase.

3.6. Utilities during Operation Phase The industrial zone will comprise heavy, medium and light engineering industries including textile, automobile manufacturing units, process plants, and others3. For each type of industry, the process in the operational phase may vary. However, an overview of the utilities required in the operational phase is given below:

3.6.1. Electricity Approximately 1000-2000 KW per day of electricity shall be required during operation phase which will be acquired from K Electric.

3.6.2. Water Estimated water consumption during operations phase would vary with the nature of the industrial processes for each unit. Water will be sourced from KWSB and bore well.

3.6.3. Workforce The workforce required during operation phase is about 3000 persons or more.

3.7. Health, Safety and Environment All the policies, procedures, and SOPs specific to HSE shall be followed during construction and operations, as following:

 Emergency response plan will be established according to national and international guidelines for fire/emergency response for construction activity as well as during operations.  Trained persons will be appointed on the posts relating to implementation of emergency response plan.

3 https://promisemarketing.com.pk/sumya-industrial-zone/

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 Trained technicians shall be employed and safety equipment will be used during construction and production.  Personal Protective Equipment shall be mandated for all hazardous activities

3.8. Solid Waste Management Solid wastes which will be generated during construction of the project are Construction waste, Excavated Soil Waste, Dust, Electric Wires, pieces of Metal Sheets. All the solid waste will be managed via dedicated waste bins for each type of waste.

Quantity and nature of waste generation during regular operations phase would be in accordance with the nature of the industry. For example, for textile units, the waste will include wasted fabric, pieces of fabric from cutting, paper and food waste. Pieces of fabric will be sold to a third party, whereas, the other forms of waste will be disposed of as per the government laws, regulations, keeping in view the standard practices. The waste management during operation phase will be carried out via EPA approved solid waste contractor.

3.9. Fire Protection System The Firefighting system will consist of Smoke Detector, Fire Hydrant, Fire Hose Reel, Fire Extinguisher as per NFPA Standard.

3.10. Approvals The proponent has obtained No Objection Certificate from Development Authority. NOC and Land documents are attached in annexures.

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Chapter 4 DESCRIPTION OF ENVIRONMENT

This section establishes a profile of the environmental and social conditions which prevail in the project area. Baseline conditions are necessary to determine in order to evaluate the sensitive receptors which might be impacted as a result of project activities. Description of geographical and social profile of the Project area includes information on the existing resources of its microenvironment and macro-environment, including the following: a) Physical Resources b) Ecological Resources c) Socioeconomic environment

4.1. Project Location and Geography The project site is situated at the adjacent of Hub Dam river road, Located at the west part of Haji Ibrahim Goth, Gadap Town, Manghopir, Karachi. The project area has a mixed use environment i.e. it is used for Industrial Area, Commercial Area, Recreation Area (Play Ground), and Amenities (School, Public Buildings, Hospitals and Mosques).

The area is a blend of commercial and industrial entities. There are plots for industrial units. The total area for the Industrial units are comprises of 85, 879 Square Yards. This project will provide professional services for many projects relating to heavy medium or light engineering industries including Textile, automobile manufacturing units, Process plants and others.

Figure 4.1: Current Status of Project Site

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Figure 4.2: Project Location

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4.2. Description of Physical Environment

4.2.1. Geology, Geomorphology and Soil Geology: Karachi is the part of major synclinorium stretching from Ranpathani River in the east to Cape Monze in the west, Mehar and Mole Jabal (Mountains) in the north. Within the synclinorium a number of structures such as Pipri, Gulistan-e-Jauhar, Pir Mango and Cape Monze are exposed. The presence of concealed structures under the Malir River valley, Gadap and plains can fairly be deduced.

Rock aggregates, sand, limestone and clay are some of the potentials for gainful utilization. The area is underlain by rocks of sedimentary origin ranging in age from Eocene to Recent. Major structural trends and the basin axis strike generally south but with a “bulge” to the east also called Karachi Arc (Bender and Raza 1995).

Geomorphology of Karachi: Karachi is located in the south of Sindh, on the coast of the . It covers an area of approximately 3,600 km2, comprised largely of flat or rolling plains, with hills on the western and northern boundaries of the urban sprawl. The city represents quite a variety of habitats such as the sea coast, islands, sand dunes, swamps, semi-arid regions, cultivated fields, dry stream beds, sandy plains, hillocks. Classified according to physiographic features, Karachi City District can be divided into three broad categories: Hilly Region (Mountain Highland), Alluvial Plain (Piedmont Plain) and Coastal Areas (Valley Floor). The metropolitan area is divided by two non-perennial river streams namely Lyari and Malir Rivers. The Malir River flows from the east towards the South and Centre, and the flows from north to the south west. Gujjar and Orangi are the two main tributaries of the Lyari

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River while Thaddo and Chakalo are the main tributaries of the Malir River. The dry weather flow of both rivers carries urban sewage that is ultimately drained in the Arabian Sea. Among the various physiographic features, low flat-topped parallel hills devoid of vegetation, interspersed with widespread plains and dry riverbeds are the main topographic characteristics of the city.

The greatest height of the region is 250 ft. that gradually decreases to 5 ft. above mean sea level along the coastline. The Karachi Harbour is a sheltered bay to the south-west of the city, protected from storms by the Sandspit Beach, the Manora Island and the Oyster Rocks.

The Arabian Sea beach lines the southern coastline of Karachi. Dense mangroves and creeks of the Indus delta can be found towards the south east side of the city. Towards the west and the north is Cape Monze an area marked with projecting sea cliffs and rocky sandstone promontories.

Soil: In the Project area, the rocks belong to Paleozoic, Mesozoic and Tertiary Geological timescale. Soils of river plain are generally loamy, clayey and seasonally flooded soils. Some areas nearby Malir river salt affected soils. These soils found along river i.e. Loamy and some sandy stratified soils (Torrifluvents and Torripsamments) of recent river plains. The Town of Malir situated on the right bank of River Malir shows variable percentages of fine fractions in the soil components and the bulk density values in the range of 1.83-1.95 gm/cm3.

Figure 4.3: Soil Characteristics Map of Karachi

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4.2.2. Seismicity Seismotectonic study for macro-environment of Project site aims at elucidating the impact of tectonic movement induced seismicity on the microenvironment. Seismicity in the Karachi region is related to the pressure potential being built at the convergence of the three lithospheric plates: Indian, Arabian, and Eurasian at the Triple Junction (Figure 4.4 & 4.5) formed by the intersection of Owen fracture zone, the Makran subduction zone and the Ornach-Nal fault. The Murray Ridge extends northward into Pakistan, to unite the Ornach-Nal-Chaman Fault system onshore, displaying a strike-slip boundary between the major tectonic plates of India and Eurasia4.

Karachi and its environs fall in the synclinorium, described earlier as being part of Indus deltaic region. Recession of the delta and its retreat towards the southeast dried up its numerous channels, estuaries and creeks that characterize the synclines and are part of the active faults. Tectonic instability of this region can be attributed to this large number of reverse and tear faults and the recently described wrench faults.5

Figure 4.4: Seismicity & Natural Disasters - Pakistan, 1990-2000

4 (Baloch, S.M. & Quirk, D.G., Mesozoic to Neogene Tectonism and Evolution of Murray Ridge, Pak. Jour. of Hydrocarbon Research, Islamabad, 13). 5 (Riding the mobile Karachi arc, Pakistan: Understanding tectonic threats Ghulam Sarwar and Anwar Alizai, Journal of Himalayan Earth Sciences 46(2) (2013) 9-24).

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Figure 4.5: Schematic plate tectonic sketch map showing the Karachi Arc and its regional tectonic framework

Figure 4.6: Earthquake epicenter plots for the time period 1902-2013

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The first number refers to the list numbers whereas the second number represents depth of hypocenter in kilometers. The Red Crosses represent neighborhoods plagued by recurrent seismic activity, usually of low magnitude6.

Sarwar and Alizai have compiled a list of earthquakes during the 1902-2013 period and also produced the above map that gives a distribution of hypocenters of earthquakes during the same period. From the distribution of hypocenters, it has been inferred that the entire Karachi Arc and surrounding areas are seismically active with hypocenters ranging in depth from 0-500 kilometers. From the depth of hypocenters, it is inferred that active deformation has taken place at multi-levels ranging from shallow too deep in the basement. Quite a few of the recent epicenters are found within or in close proximity to parts of Karachi that have faced recurrent earthquake activity.

Seismic activity in the region is the result of the triple junction as well as the Karachi Arc, located in southeastern Pakistan, as a large fold and thrust belt that shows Neogene thin-skinned eastward movement (Sarwar and DeJong, 1979; Schelling, 1999). Seismic activity in and around the region shows that the Karachi Arc has been active since long in prompting the eastward movement of the delta. It is possible that the movement is related to the rebound that takes place after mass shift. Sarwar has suggested that the eastward creep of Karachi Arc is directly related to active subsidence of the Hyderabad graben that underlies it and also defines the northern and southern limits of the Karachi Arc.7

It may be added that subsidence such as that on Southern coast of Sindh, occurs naturally as a result of plate tectonic activity above active faults, and in places where fluid is expelled from underlying sediments and is common at river deltas that may have receded. Earthquakes arise and result from the release of the force along the growth fault plane. As a result, many different growth faults are created as sediment loads shift basin-ward and landward.

Earthquakes: Historically the coastal region has suffered a number of earthquakes. A list of earthquakes that have affected Karachi and its vicinity has been compiled by the Meteorological Department and listed by Sarwar and Alizai.

Some of the events are listed in Table-4.1.

Table 4.1: List of Earthquake in Indus Deltaic Region and surrounding within Latitude 23.0-25.0N and Longitude 67.5-71.0E Magnitude Date Lat-N Lat-E Depth (km) Richter Scale 26-09-1977 25.4 68.2 33 4.5 25-11-1982 25.6 67.9 33 4.9 17-12-1985 24.9 67.4 33 4.9

6 (Source: Pakistan Meteorological Department, June 2013 & Ghulam Sarwar and Anwar Alizai, Journal of Himalayan Earth Sciences 46(2) (2013) 9-24) 7 (Sarwar, G., 2004. Earthquakes and the Neo-Tectonic Framework of the Kutch-Hyderabad-Karachi Triple Junction Area, Indo-Pakistan. Pakistan Journal of Hydrocarbon Research, 14, 35-40).

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24-12-1985 24.8 67.6 33 4.7 10-09-1991 24.4 67.7 33 4.8 19-09-1991 24.3 68.7 33 4.7 23-04-1992 24.3 68.8 33 3.7 24-12-1992 25.2 67.7 33 3.6 05-02-1993 24.6 68.9 33 4.3 26-01-2001 23.4 70.3 17 7.6

The largest earthquake that was incident in 1819, had a magnitude of 8.0; it was felt over almost all over the Indian sub-continent. Eastern branch of the was blocked, long tract of alluvial land was uplifted, and there was surface faulting and subsequent subsidence in the epicenter area. This fault produced a scarp called “The Allah Bund”.

Seismicity of the Site: According to the Uniform Building Code (1997), Karachi and its adjoining areas fall in Seismic Zone-2B.

Figure 4.7: Seismic Zones in Karachi8

8 Map data source(s): PMD, GSP, Pakistan Engineering Council – Prepared by Al hasan Systems Private Limited

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Figure 4.8: Seismic Hazard for Pakistan in terms of Peak Ground Acceleration (PGA)9

4.2.3. Liquefaction Features Caused by Earthquake Liquefaction is a total loss of strength due to undrained restructuring. Disturbance, by shearing or vibration, destroys soil skeleton, with loss of grain contact and decrease of porosity, soil load is transferred to pore water, water pressure>normal stress=0, and soil acts as a liquid. Drainage reduces pore water pressure, allows grain contact and thixotropic recovery of strength (Waltham, 2002). Strong shaking produces liquefaction in the fine sands and silts during the earthquake. This causes the mineral grains to settle and expel their interstitial water to the surface. If the pore-water pressure rises to a level approaching the weight of overlying soil, the granular layer behaves as a viscous liquid rather than a solid and leads to collapse of even engineered structures. Liquefaction has been abundant in areas, where groundwater lies within 10 meters of the ground surface (Husain et al., 2004). Investigators typically have designated sites as “Liquefied” on the basis of the presence of surficial liquefaction features, such as venting of sediment to the surface (i.e., sand boils), ground cracking associated with liquefaction (e.g., lateral spreading), or surface settlements. Other evidence of liquefaction includes tilting or settling of overlying structures and floating of underground structures (Olson et al., 2002). Mahmood and Shaikh (2008) investigated the “sinking” of a water tower in 2006 near Clifton area and speculated about liquefaction due to mild earthquakes.

4.2.4. Meteorology and Climate The climate of the macro-environment can be characterized by dry, hot and humid conditions and in general terms it is moderate, sunny and humid. There is a minor seasonal intervention of a mild

9 PMD Seismic Monitoring and Early Tsunami Warning Centre - http://seismic.pmd.gov.pk/seismicnew/map2.html

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winter from mid-December to mid-February followed by a long hot and humid summer extending from April to September, with monsoon rains from July to mid- September. The characteristic climatic feature of the four seasons of Karachi is presented in Table 4.2.

Table 4.2: Seasonal Characteristics of the Climate of Karachi Season Temperature Rainfall Wind Summer (Mid- The summer is hot with There are less frequent The wind speed in summer is March to Mid- temperature increasing rain showers in summer variable. It is around 2.5 m/s in June) from 26.2 °C in March, with no more than 1 or 2 March and rises upto 18 m/s in rising up to 40 °C in rainy days in summer. April and drops to 4 m/s for the June. Average total amount of rest of the season. The rain in summer is around direction mostly remains 10 mm blowing from West Monsoon (Mid- The temperature in Almost 80 % of the yearly The wind direction in the June to mid- monsoon remains high rain occurs in the monsoon is mostly blowing September) but relatively lower than monsoon with July and from East. summer and oscillates August being the wettest around 32°C. month. Post-Monsoon The average The post-monsoon period The wind speed in September Summer (Mid- temperature post remains mostly dry and is around 3.7 m/s and drops to September to monsoon drops and rainfall in November is 1.4 m/s in November. November) average min around 1.8 mm. temperature may reach 12 °C in November. Winter The winter is mild with Like the other seasons, The wind speed in the winter (December to January being the except monsoon, there is season increases from 1.4 m/s mid-March) coolest month where little occasional rainfall. in December to 2.6 m/s in average minimum The rainfall in winter is March. The wind direction for temperature falls to 6 less than 50 mm. most part winter season is °C. blowing from NE and changes its course to blowing from West in early March

4.2.4.1. Temperature The air temperature in Karachi Division and its coastal areas are generally moderate throughout the year due to presence of sea. Climate data generated by the meteorological station at Karachi Air Port represents climatic conditions for the region. The mean monthly maximum and minimum temperatures, recorded during the last 19 years in Karachi to describe the weather conditions are shown in Table 4.3 and 4.4 respectively. The Tables indicate that the mean monthly maximum temperature in Karachi ranged between 24.9°C to 38.7°C during the 2001-2019 periods, while the mean monthly minimum temperature ranged between 11ºC to 29.6°C. The annual mean maximum and mean minimum temperature during 2001-2019 periods were 21°C to 33.0°C, which

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indicates that there has been significant rise in the mean minimum temperature during the last 19 years.

Table 4.3: Mean Monthly Maximum Temperature °C Year Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec Annual 2001 27.2 29.6 33.1 34.6 35.1 34.9 32.2 32.3 33.1 36.0 33.5 30.4 32.7 2002 27.0 28.2 33.3 35.4 35.6 35.1 32.2 31.6 31.4 36.5 32.7 28.1 32.3 2003 27.6 28.5 32.4 36.6 35.7 34.9 34.1 32.6 32.5 37.0 32.2 28.3 32.7 2004 26.6 29.9 36.2 35.4 36.8 35.6 33.8 32.7 32.8 33.7 33.1 29.4 33.0 2005 24.9 26.3 31.5 35.3 35.4 36.0 33.2 32.2 34.2 35.2 33.1 28.4 32.1 2006 26.0 31.3 31.8 34.0 34.6 35.3 33.8 31.0 34.2 35.0 33.4 26.3 32.2 2007 26.9 29.4 31.4 37.7 36.0 36.4 N/A N/A N/A N/A N/A N/A 33.0 2008 24.4 26.9 34.3 34.4 33.9 35.1 33.5 31.9 34.7 35.5 32.5 27.2 32.0 2009 26.2 29.8 33.0 36.0 36.8 35.7 34.5 33.0 32.8 35.9 33.0 28.6 32.9 2010 27.5 29.2 34 35.7 36.5 34.7 34.6 33.2 34.5 35.9 32.7 28 33.0 2011 26.9 28.5 33.2 35.8 35.3 35.3 34.2 32.8 32.9 N/A N/A N/A N/A 2012 25.7 26.9 31.7 35.1 35.5 34.6 33.2 32.7 33.2 35.0 32.7 28.2 32.0 2013 26.7 28.0 33.3 34.0 35.1 36.5 33.8 32.1 33.0 35.7 32.3 28.3 32.4 2014 25.5 28.0 31.7 35.1 35.9 36.5 34.0 33.7 33.8 36.3 32.9 28.7 32.7 2015 26.3 28.9 31.5 35.9 36.0 37.7 34.1 32.3 34.6 35.8 33.0 28.6 32.9 2016 27.8 30.3 33.3 34.7 35.7 36.1 33.6 33.0 32.9 34.0 33.3 31.0 33.0 2017 25.4 30.2 32.8 35.5 36.2 36.3 33.1 33.8 33.4 36.6 32.3 28.2 32.8 2018 28.5 30.4 34.4 36.2 38.7 35.4 33.8 31.9 32.6 36.8 33.8 28.2 33.4 2019 26.3 26.8 31.3 35.4 36.0 37.2 34.7 32.5 35.7 35.8 31.5 27.1 32.5 Source: Pakistan Meteorological Department

Table 4.4: Mean Monthly Minimum Temperature °C Year Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec Annual 2001 11.5 14.9 19.6 23.8 28.1 29.0 27.1 26.5 25.9 24.4 18.6 15.8 22.1 2002 12.8 13.8 19.5 23.9 27.0 28.2 29.6 25.6 24.8 22.5 17.7 14.9 21.7 2003 12.7 16.9 19.8 24.2 26.5 28.2 23.6 27.0 25.3 20.9 15.2 12.0 21.0 2004 12.9 14.5 19.1 24.8 27.3 28.8 27.5 26.3 25.3 22.4 18.0 15.4 21.9 2005 12.3 11.3 20.3 23.0 26.4 28.3 27.2 26.6 26.6 22.9 18.9 13.0 21.4 2006 11.7 18.1 19.6 24.5 27.5 28.5 28.3 26.3 26.8 25.7 19.4 14.0 22.5 2007 13.0 17.3 19.7 24.7 27.6 28.6 N/A N/A N/A N/A N/A N/A 21.8 2008 10.1 11.1 19.6 24.0 27.3 29.1 27.9 26.8 26.6 23.8 17.6 14.9 21.6 2009 14.7 16.5 20.8 23.8 27.6 28.7 28.1 27.5 26.5 22.6 17.0 13.9 22.3 2010 12.2 14.7 21.3 25.1 28 28.2 28.3 27.2 25.8 23.9 17.4 11.1 21.9 2011 11 14.5 19.7 23.1 27.1 28.8 27.8 28.6 26.5 N/A N/A N/A N/A 2012 11.2 11.9 19.1 24.5 27.2 28.0 27.9 26.9 26.4 22.7 18.6 14.2 21.5 2013 11.6 15.1 19.2 24.2 27.1 29.3 28.0 26.6 25.5 25.4 18.1 13.0 21.9 2014 9.9 13.1 18.9 24.4 27.0 29.2 28.3 27.1 26.8 23.3 19.5 13.1 21.7 2015 12.6 16.4 19.2 25.7 27.7 29.8 28.4 26.9 26.3 24.9 18.6 12.6 22.4 2016 14.8 14.9 21.7 24.6 27.9 27.9 28.1 27.1 26.4 24.0 17.1 15.5 22.5 2017 12.5 18.2 20.3 24.4 27.8 29.2 27.7 27.0 26.2 23.5 16.8 13.0 22.2

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2018 12.9 15.8 20.9 25.3 27.7 28.8 28.1 26.3 25.5 23.0 19.3 13.1 22.2 2019 13.3 15.3 19.0 24.0 26.6 28.9 28.1 26.8 27.2 24.0 19.4 13.7 22.2 Source: Pakistan Meteorological Department

Figure 4.9: Daily High and Low Temperature

The daily average low (blue) and high (red) temperature with percentile bands (inner band from 25th to 75th percentile, outer band from 10th to 90th percentile). The warm season lasts from March 25 to July 13 with an average daily high temperature above 34°C. The hottest day of the year is May 5, with an average high of 36°C and low of 26°C. The cold season lasts from December 18 to February 7 with an average daily high temperature below 27°C. The coldest day of the year is January 10, with an average low of 13°C and high of 25°C10.

4.2.4.2. Precipitation The probability that precipitation will occur has been found to vary from different days of July and August at Karachi throughout the 1992-2012 period. Precipitation most likely occurs around August 4, in 35% of all days. Precipitation is least likely around April 27, occurring in 2% of all days.

Thunderstorms are the most severe type of precipitation observed during 38% days precipitation. They are most likely around August 12, when it is observed during 12% of all days. Drizzle is the most severe precipitation observed during 34% of those days with precipitation. It is most likely around July 30, when it is observed during 14% of all days. Moderate rain is the most severe precipitation observed during 22% of those days with precipitation. It is most likely around July 28, when it is observed during 8% of all days. When precipitation does occur, it is most often in the

10(Average Weather for Karachi (https://weatherspark.com/averages/32864/Karachi-Sindh-Pakistan).

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form of thunderstorms (40% of days with precipitation have at worst thunderstorms) and cloud burst, drizzle (36%), moderate rain (19%), and light rain (5%).11

Figure 4.10: Fraction of days on which different types of precipitation are observed

The main source of precipitation is rainfall which is received mostly in the months of July to September during SW Monsoon winds. It is very erratic as some years are very dry and there is no rain. The average rainfall is 217 mm and most of it is received in the month of July.

Occasional winter rains are also received in the months of December – February as result of NE winds which count 15-25% of total rainfall.

The record for rainfall of PMD at Karachi Airport (2001-2009 & 2012-2019) suggests that July and August are the wettest months and that the maximum rainfall recorded in Karachi during 2001- 2009 & 2012-2013 period was 270.4 mm during the month of July 2003, while the maximum annual rainfall was 324.9 mm during the year 2003, followed by 301.1 mm in 2006 and 279.9 mm in 2009.

Table 4.4: Monthly Amount of Precipitation (mm) at Karachi Airport Year Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec Annual 2001 0.0 0.0 0.0 0.0 0.0 10.6 73.6 16.2 N/A 0.0 0.0 0.0 33.46 2002 0.0 2.4 0.0 0.0 0.0 N/A N/A 52.2 N/A 0.0 0.5 0.4 13.87 2003 6.4 21.8 0.0 0.0 0.0 16.3 270.4 9.8 N/A 0.0 0.2 0.0 54.15 2004 13.7 0.0 0.0 0.0 0.0 N/A 3.0 5.6 N/A 39.3 0.0 4.3 13.18 2005 6.6 12.8 N/A 0.0 0.0 N/A N/A 0.3 54.9 0.0 0.0 17.1 18.34 2006 N/A 0.0 N/A 0.0 0.0 0.0 66.2 148.6 21.9 0.0 3.1 61.3 60.22 2007 0.0 13.2 33.4 0.0 0.0 110.2 N/A N/A N/A N/A N/A N/A 52.26 2008 8.0 Trace 1.1 0.0 0.0 0.0 54.0 37.5 Trace 0.0 0.0 21.0 24.32

11 Average Weather for Karachi (https://weatherspark.com/averages/32864/Karachi-Sindh-Pakistan).

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2009 3.0 Trace 0.0 Trace 0.0 2.6 159.9 44.0 68.9 0.0 0.0 1.5 55.68 2012 0.2 0.0 0.0 0.0 0.0 Trace Trace 8.1 121.0 0.0 0.0 22.8 152.1 2013 Trace 20.0 2.8 30.0 0.0 Trace 5.5 105.4 4.0 1.2 0.0 0.0 168.9 2014 Trace 0.0 12.4 0.0 1.3 Trace 1.1 9.9 1.4 0.0 4.6 0.0 30.7 2015 0.3 2.1 2.8 0.0 0.0 Trace 46.6 1.4 Trace 0.0 0.0 0.0 53.2 2016 3.1 0.0 Trace 0.0 0.0 65.8 1.9 96.9 Trace 0.0 0.0 0.0 167.7 2017 41.5 Trace 0.0 0.0 0.0 58.8 33.3 65.6 26.4 0.0 0.0 6.6 232.2 2018 0.0 0.0 0.0 0.0 0.0 10.6 73.6 16.2 N/A 0.0 0.0 0.0 33.46 2019 0.0 2.4 0.0 0.0 0.0 N/A N/A 52.2 N/A 0.0 0.5 0.4 13.87 Source: Pakistan Meteorological Department

The wet years have been found to follow a 3-year cycle during the first 9 years of the 3rd Millennium. The year 2010 was among the wettest years since Karachi City had witnessed more than 5 spells of 50 mm each during the month of July, three major spells of 60 to 100 mm in August and two spells of 25 and 10 mm each in the month of September. In July and August 2011 again, there was heavy rainfall all over Sindh. Hyderabad received about 74 to 103 mm rain in 24 hours and the same amount poured in Karachi and the villages in its outskirts. The torrential rains resulted in flooding of several villages in Karachi District.

Inundation due to Heavy Rainfall Events: Highest rainfall events have occurred in July 1994: 256.3mm, July 2003: 270.4mm and August 2006: 77mm in 3 hours. According to observations recorded for the year 2007, August 10 and 11 were witnesses to unusually high rainfall of 107 mm in 24 hours compared with the normal of about 60 mm for August. The wettest August ever experienced by the city was in 1979, when over 262mm of rainfall was recorded. The record for the maximum rainfall within 24 hours in the eighth month was 166mm of rain on August 7, 1979. The heavy rainfall was not unusual since it was caused by the general monsoon system that travels from across Rajasthan and lays over Sindh. The monsoon weather system did not move towards Baluchistan but the penetration of moist currents from Sindh brought scattered to heavy rain in southern Baluchistan, particularly along its coastal regions. Major inundation and land submergence was noticed in Karachi in July 2003 and August 2006. On both occasions precipitation pattern and intensity was almost similar. The downpour on both occasions was a cloud burst. For estimating the impact of inundation on the six corridors, the maximum intensity of Rainfall of 18th August 2006 at 77mm in about 3 hours i.e. 25.7mm/hour will be considered critical and adopted for making estimates on land submergence.

4.2.4.3. Humidity The relative humidity typically ranges from 25% (dry) to 70% (humid) over the course of a year, rarely dropping below 20% (very dry) and reaching as high as 90% (very humid).

Table 4.5: Mean Monthly Relative Humidity (Mean) at 1200 UTC (%) Year Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec Annual 2014 25.0 27.0 35.0 47.0 57.0 61.0 64.0 61.0 60.0 36.0 36.0 31.0 45.0 2015 38.0 41.0 37.0 45.0 60.0 56.0 69.0 67.0 56.0 47.0 28.0 31.0 47.9

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2016 46.0 25.0 41.0 47.0 60.0 60.0 68.0 70.0 63.0 57.0 34.0 38.0 50.8 2017 38.0 25.0 36.0 44.0 59.0 62.0 70.0 67.0 63.0 44.0 29.0 20.0 46.4 2018 36.0 37.0 33.0 45.0 46.0 65.0 65.0 68.0 63.0 40.0 32.0 30.0 46.7 2019 40.4 33.9 36.6 48.0 55.6 58.8 64.8 72.6 67.6 41.1 34.6 29.7 48.6 Source: Pakistan Meteorological Department

4.2.4.4. Wind Speed & Direction The wind direction and speed between the summer and winter monsoon seasons are rather unsettled and large variations are noted both with respect to speed and direction.

The eleven years’ wind velocity record (2001-2019) indicates that the velocity varies and ranges between 1.0 m/s to 13.4 m/s. The Tables 4.7 and 4.8 show the wind speed and direction respectively.

Table 4.6: Wind Speed (m/s) at 12:00UTS Year Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec Annual 2001 2.6 3.4 4.3 5.6 7.5 8.1 6.8 7.3 5.5 3.7 2.0 2.4 4.9 2002 3.6 3.9 4.0 6.5 8.5 8.2 9.8 7.3 7.7 3.3 2.9 3.2 5.7 2003 4.0 5.0 5.4 5.2 7.7 8.8 6.7 7.1 6.0 3.2 3.1 3.0 5.4 2004 3.4 3.7 4.0 6.0 8.0 9.0 10.0 9.5 7.3 3.8 1.0 2.5 5.7 2005 3.6 4.2 4.8 5.1 7.1 7.5 9.0 6.9 6.4 3.9 2.0 1.5 5.2 2006 2.0 3.0 3.0 6.2 8.0 7.7 8.3 6.2 4.7 4.2 2.2 3.0 4.9 2007 2.0 3.7 4.0 4.0 6.0 6.3 N/A N/A N/A N/A N/A N/A 4.3 2008 4.3 7.6 8.2 10.5 12.6 7.6 11.0 9.3 8.7 6.6 5.1 3.9 7.9 2009 7.0 7.2 7.9 9.3 9.8 9.7 9.5 9.3 9.1 6.1 5.0 3.9 7.8 2012 5.8 6.6 9.3 9.8 12.3 12.8 13.1 11.2 8.4 7.1 5.7 5.8 9.0 2013 5.2 6.9 9.0 10.3 11.5 10.8 12.0 11.2 10.3 7.7 5.1 4.5 8.7 2014 5.9 8.9 8.6 11.5 12.4 13.4 12.8 11.6 11.7 8.3 6.0 4.5 9.6 2015 6.9 10.3 10.1 11.5 12.8 12.3 13.7 12.3 10.5 8.7 5.6 5.8 10.0 2016 7.5 8.7 4.8 1.1 13.0 11.7 11.8 10.5 12.1 9.2 5.5 5.2 8.4 2017 7.0 8.0 10.8 12.1 12.8 11.5 12.1 10.3 8.7 8.5 5.4 7.4 6.9 2018 6.3 7.0 9.5 10.2 10.8 11.1 12.3 12.4 12.2 8.7 6.1 6.8 9.4 2019 6.7 8.9 10.2 11.7 12.1 11.7 13.7 9.1 8.5 8.0 6.9 7.4 9.6 Source: Pakistan Meteorological Department

Table 4.7: Wind Direction at 12:00UTS Year Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec 2001 S54W S43W S42W S45W S46W S45W N52W S59W S44W N56W S45W S06W 2002 S67W S52W S51W S55W S51W S42W S54W S45W S48W S56W N54W S41W 2003 S60W N50W S45W S48W S45W S68W S60W S47W S43W S54W S50W S27W 2004 N27E S46W S53W S49W S52W S54W S54W S62W S56W S47W S45W N86E 2005 N63E S51W S50W S52W S63W S48W S54W S49W S87W S54W S52W N23W

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2006 S48W S62W S50W S57W S64W S60W S67W S78W S51W S53W S49W N79E 2007 S30W S62W S47W S55W S58W S47W S41W S55W S60W S48W S48W N45E 2008 N45E S47W S54W S51W S52W S39W S50W S52W S46W S39W S38W N 2009 N45E S45W S41W S58W S46W S46W S56W S49W S56W S42W S39W S45E 2012 S3E N56E S62W S46W S61W S51W S66W S51W S53W S41W S41W N9W 2013 N39W S54W S56W S54W S61W S40W S53W S52W S55W S47W S17W N50W 2014 S72E S54W S43W S46W S46W S45W S54W S48W S85W S45W S49W S45E 2015 S72E S54W S43W S48W S50W S40W S54W S55W S50W S41W S S58W 2016 S43W S36W S48W S54W S54W S45W S48W S36W S51W S45W S43W S36W 2017 S83E S56W S51W S45W S45W S44W S66W S57W S48W S51W S59W N45E 2018 S54W S43W S42W S45W S46W S45W N52W S59W S44W N56W S45W S06W 2019 S67W S52W S51W S55W S51W S42W S54W S45W S48W S56W N54W S41W Source: Pakistan Meteorological Department

4.2.5. Impact of Climate Change - Karachi A UK-based climate change expert has warned that there will be an exceptional change in the temperatures in Pakistan as a whole in the coming years, but that the province of Sindh will be less affected as compared to the other provinces of the country. Karachi may however face the threat of rising sea levels by the year 2100, at about 8 feet below sea level. The UK-based climate change expert said that climate change could influence monsoon dynamics and cause summer precipitation levels to drop, as well delays in the start of the monsoon season. While another report said that the impact of climate change in Karachi will deepen by 2030. Due to global warming the coastline of Karachi is likely to be flooded due to rising sea levels. Many seminars and public gathering are held in the city to make the government and public fully aware of global warming, speakers at the seminar have urged the government to prepare long and short-term plans to reduce the impact of global warming on natural resources. Karachi also faces the threat from super cyclones which are said to increase their intensity and momentum in years to come.

List of cyclones that affected Karachi and the Sindh coast: Cyclones that form in the Arabian Sea do not usually hit Karachi or the Sindh coast, during 1902, 1907, 1944, 1964, 1985, 1999, 2007 and 2010, cyclones made landfall in the Sindh coast including Karachi. Other cyclones that are listed below caused rains as remnants.

 In May 1902, a cyclonic storm struck the coast in the vicinity of Karachi.  In June 1907, a tropical storm struck the coast near Karachi.

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 On 27 July 1944, a cyclone left some 10,000-people homeless in Karachi.  On 12 June 1964, a deadly cyclone made landfall near Karachi.  On 15 December 1965, a powerful cyclone slammed the city with 10,000 casualties.  In May 1985, a cyclonic storm made a landfall in the eastern direction of Karachi. The cyclonic storm in 1985 which was moving towards Karachi actually had weakened over the sea while still a few 100 Kilometers away south of Karachi.  In November 1993, a category 1 cyclone approached the Sindh-Gujarat border but dissipated due to high vertical shear over open waters.  In June 1998, remnants of the category 3 Gujarati cyclone (the 5th strongest cyclone of the Arabian Sea) killed 12 people near and in the city.  In May 1999, again a category 3 major cyclone (the 4th strongest cyclone of Arabian Sea) hit near the city; this Cyclone killed 700 people in Sindh including Karachi. It is the strongest cyclone recorded in Pakistan.  In May 2001, the powerful category 3 cyclone (the 3rd strongest cyclone of the Arabian Sea) hit the Indian border of Gujarat. It caused rain along the Sindh coast, but no damage was reported.  In October 2004, a severe cyclonic storm, Cyclone Onil, approached the Sindh coast but later recurved back to the sea; it caused heavy rain that killed 9 people in Karachi.  In early June 2007, Super cyclonic storm Gonu (the strongest cyclone in the Arabian sea) caused strong gusty winds in the metropolis with light rainfall as the storm was moving towards .  In June 2007, a cyclonic storm, Cyclone Yemyin, passed near the city and killed 200 people before moving towards Balochistan where it killed 380 people.  In November 2009, remnants of Cyclone Phyan caused gusty winds along the Sindh coast including Karachi. However, six Pakistani fishermen were trapped in the storm later rescued by the Indian Navy.  In June 2010, Cyclone Phet (the 2nd strongest cyclone in the Arabian Sea), once a powerful category 4 cyclone, made landfall near the city as a weak tropical depression, with a total 14 casualties in and near the city.  In November 2010, remnants of Cyclone Jal caused drizzle with dusty winds in Karachi while it caused light to moderate rainfall in southeastern Sindh.  In November 2011, the outerbands of cyclone Keila brought drizzle to the city while moderate showers to the Makran coast.

List of Notable floods in Karachi: Most of the flooding in Karachi occurs due to the monsoon season. But due to the enhancement of the city’s infrastructure flooding has been controlled. But still excessive and irregular rains can lead to major flooding in the metropolis. Following are some of the major floods in the city;

 On 7 August 1953, the city received its record-breaking 24-hour rainfall causing widespread flooding about 278.1 millimeters (10.95 in) rain was recorded.  On 1 July 1977, Karachi received its third highest rainfall of 207 millimeters (8.1 in) in 24 hours, it caused massive flooding in the city and killed 248 people in the city.

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 In 2003, massive flooding during monsoon season devastated the Sindh, two days of rainfall of 284.5 millimeters (11.20 in) created havoc in the city.  In 2006, after two year of drought period heavy rainfall lashed the city during the monsoon season, but the city came to standstill on 17 August when widespread rainfall of 77 millimeters (3.0 in) created flood-like situation in the city killing 13 people and submerging roads, low-lying areas and underpasses with rainwater.  In 2007, almost all the rains that occurred in this monsoon season brought flooding with it, During the month of June Cyclone Yemyin created havoc in the city from 21 June to 26 June 2007 110.2 millimeters (4.34 in) of heavy downpour was recorded which killed 228 Karachiites on 23 June, then from 9 August to 11 August a strong tropical depression brought massive flooding in the city with 191 millimeters (7.5 in) of rain killing 21 people and submerging low- lying areas and underpasses. While on 22 August a monsoon depression once again flooded the city with 80 millimeters (3.1 in) of rainfall killing 10 people.  On 18 July 2009, there was severe flooding due to a tropical depression, in which city’s second highest rainfall of 245 mm (9.6 in) occurred in just 4 hours, killing 20 and injuring 150 people. Another flooding event occurred on August 31, 2009 when a well-marked low pressure was present over Sindh, the rainfall was recorded to be around 147 mm (5.7 in).  On September 13, 2011, life was crippled in the city due heavy rainfall that caused urban flooding in the city. The rainfall was recorded to be around 145 mm (5.7 in).  In Aug & Sep 2019, life in the city was crippled due to multiple spells of heavy rain that caused urban flooding and loss of life and property.  6 – 9 Jul 2020, spells of heavy rain caused urban flooding in several areas of city, causing loss of life and property, mainly due to electrocution.  The hours-long spell, which began before sunrise and continued till night, broke previous records of rainfall recorded in the city during August 2020. The Met department said that Karachi had received 345mm of rainfall so far in August, breaking the previous record of 298mm reported in August 1984.

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List of droughts in Karachi: Drought-like conditions in the city are not common but if the Monsoon season fails to deliver rains then drought emerges. Following are some of worst drought in Karachi city.

 The major drought in Karachi as well as for whole Pakistan was from 1996 till 2002, peaking from 1998 till 2001. While in 2002 drought conditions started to dissipate. The drought of 1998- 2001 was considered worst in 50 years.  In 2004, no rain occurred in the city as well as in Sindh province but during the month of October heavy downpour lashed different parts of Sindh due to Cyclone Onil.  In 2005, the drought conditions continued, but a post-monsoon low pressure dumped heavy rains during 12 and 13 September.  In 2009, drought conditions emerged during the summer season in suburban areas of Karachi, due to El Nino phenomenon and caused drought during the winter season but the monsoon rains of 2009 were above-normal.

List of dust storms in Karachi: Windstorms generally occur when a monsoon system or tropical storms is moving towards the city. However, dust storms sometimes occur in winter seasons due to Western Disturbance. Dust storms also occur before the onset of monsoon season, they are locally known as ‘Andhi’ in the country. Following is a list of windstorms as well as dust storms that occurred in the city, however windstorm generated by a tropical storm is not mentioned in this list.

 On September 1, 1926, a windstorm hit Karachi but not much is known about this storm.  On May 31, 1986, a blinding dust storm hit the city for 15 minutes that toppled trees and advertising signs, overturned vehicles and tore down electrical wiring. It reduced visibility to near zero and blew down flimsy wood and bamboo shanties in Karachi, at least 11 persons were killed and more than 250 injured. The dust storm of 67 mph (108 km/h) occurred due to the interaction between the strong cold airflow and monsoon depression present over north- western Gujarat.  On July 4, 1994, a windstorm generated by monsoon low pressure system killed 26 people in the city.  On June 23, 2007, a massive dust storm hit the city followed by a heavy downpour, the interaction between a strong low-pressure system and the outer bands of Cyclone Yemyin which was still over western India as a tropical depression caused 69 mph (111 km/h) windstorm that uprooted billboards, trees, traffic signals and caused 200 deaths in the city due to the collapse of roofs of many houses in the port city.  On February 22, 2008, a dust storm struck the city which reduced the visibility to merely 500 meters, the dust storm was due to the westerly winds that were coming from the desert regions of Baluchistan.  On March 19, 2012, a mild dust storm hit the city that caused 65 km/h winds to blow in the city while the visibility dropped to just 200 meters.  On May 19, 2012, a weak dust storm gripped the metropolis with highest wind of 72 km/h.  At least 4 killed as gusts, dust storm battered Karachi on June 3, 2020.  Loss of property reported as dust storm battered parts of Karachi on Jul 5, 2020.

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4.2.6. Ambient Air Quality

To analyze the air quality near the housing scheme, the ambient air quality has been analyzed for the criteria pollutants such as NOx (NO & NO2), SO2, CO, O3, PM2.5, PM10 and SPM for 24 hr monitoring at proposed project site.

Air pollution Monitoring at Site

The air quality parameters were measured using the state-of-the-art instruments based upon the USEPA and ASTM methods. The Ambient Air Quality has been tested by Quality Testing Services which is an ISO certified laboratory.

4.2.6.1. Ambient Air at Project Site An Ambient Air monitoring study was conducted in the microenvironment of the proposed project site. The results of Ambient Air quality is presented below:

Table 4.8: Ambient Air Quality SEQS Parameters

Date Time CO NO NO2 SO2 PM 10 PM 2.5 SPM Lead (µg/m3) (µg/m3) (µg/m3) (µg/m3) (µg/m3) (µg/m3) (µg/m3) (µg/m3) 09.03.2021 10:00 0.14 12.3 14.8 18.5 83 26 278 BDL 09.03.2021 11:00 14.3 17.0 19.4 87 35 245 BDL 09.03.2021 12:00 14.9 13.4 20.2 89 30 221 BDL 09.03.2021 13:00 0.09 16.2 11.2 22.3 93 29 233 BDL 09.03.2021 14:00 18.3 09.4 24.4 101 21 275 BDL 09.03.2021 15:00 19.5 07.9 25.9 105 23 239 BDL 09.03.2021 16:00 0.08 18.6 09.4 26.2 109 19 245 BDL

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09.03.2021 17:00 17.3 10.8 21.9 112 18 254 BDL 09.03.2021 18:00 16.5 14.4 20.6 126 20 291 BDL 09.03.2021 19:00 0.12 12.6 12.5 19.2 132 28 304 BDL 09.03.2021 20:00 12.9 15.3 18.3 125 33 319 BDL 09.03.2021 21:00 13.0 12.4 19.5 118 37 310 BDL 09.03.2021 22:00 0.24 11.4 16.5 20.6 107 42 302 BDL 09.03.2021 23:00 10.6 18.5 21.4 90 39 194 BDL 10.03.2021 00:00 10.2 20.0 20.7 85 33 287 BDL 10.03.2021 01:00 0.18 10.0 21.4 17.0 72 28 291 BDL 10.03.2021 02:00 11.3 22.2 12.2 71 25 290 BDL 10.03.2021 03:00 12.5 19.6 14.3 66 21 282 BDL 10.03.2021 04:00 0.12 13.8 16.7 15.4 62 20 278 BDL 10.03.2021 05:00 14.5 14.5 13.3 67 19 251 BDL 10.03.2021 06:00 14.9 13.6 14.2 82 18 243 BDL 10.03.2021 07:00 0.10 15.3 15.3 18.5 89 16 250 BDL 10.03.2021 08:00 12.6 18.7 19.5 95 21 261 BDL 10.03.2021 09:00 13.8 21.2 20.3 98 24 274 BDL MIN 0.08 10.0 07.9 21.2 62 16 221 BDL MAX 0.24 19.5 22.2 31.5 132 42 319 BDL AVG 0.13 14.0 15.2 19.3 94.3 26.0 267.3 BDL SEQS 5 40 80 120 150 75 500 1.5 LDL-Limits 0.01 0.0 0.0 0.0 10 2.5 1.0 0.01

4.2.7. Noise Quality Noise level monitoring conducted by EMC representative and the results mentioned in Table below. The objective of the noise pollution survey around the project site was to identify existing noise sources and to measure the noise levels.

Table 4.9: Noise Level Test Result Noise Level Readings S. No. Location/Source Min Max Average Mean 1 Front Side Right Corner 45.5 56.4 50.9 SEQS 2 Front Side Left Corner 46.2 57.6 51.9 Limits 3 Back Side Right Corner 42.4 50.2 46.3 *75dB(A) *Leq 4 Back Side Left Corner 41.8 51.0 46.4

4.2.8. Water Resources, Water Quality and Drainage Hydrogeologically, the city of Karachi lies in the Hub River Basin and the Malir River Basin. The aquifer of Karachi is, therefore, mainly recharged by seepage from Hub River, Hub Dam as well as the Malir and the Lyari Rivers. The Hub River is situated 56 km from Karachi city in Karachi and Districts on Sindh and Balochistan provinces border. The dam is

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extended to 24300 acres with gross storage capacity of 857000 acre feet. It is the Pakistan's third- largest dam. It is an important source that provides the drinking water to the metropolitan city Karachi

The Hub River lies on the western frontier of Sindh and for some distance the boundary between Sindh and the Baluchistan provinces. It located about 30 km to the west of Karachi, along the Karachi- Lasbela boundary. It falls into the Arabian Sea near Cape Monze, with a total drainage course length of 336 km. During the past several years, a number of pumping wells have been installed to meet requirements for the irrigation-water supply (to raise vegetables, fruits, dairy and poultry) and drinking-water supply for Karachi. Excessive pumping of groundwater and continuous lowering of water-table is likely to result in intrusion of seawater into the Malir Basin under natural seepage conditions and under artificially induced conditions of recharge of saline seawater in the coastal aquifer(s) of Karachi.

Figure 4.11: Canal System of Hub Dam River

Recharge Sources: Five possible water-sources are contributing to the groundwater recharge in Karachi. The first possible source is the rainfall. As the city of Karachi suffers from deficit of precipitation (only rainfall), the contribution to shallow groundwater storage from rain is very little. However, rainfall in the hinterlands and other areas surrounding Karachi may significantly contribute to the groundwater flow-system. The two freshwater sources are the Hub Lake/Hub Dam and the Indus River. Water from Hub Dam and the Indus River is piped to various residential zones in Karachi for drinking and irrigation purposes. The spring water discharges

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into Malir River and Lyari River and the municipal/industrial waste effluents added to these rivers are also contributing to groundwater storage as a fourth recharge source. Seawater intrusion along Karachi coast is the fifth possible source.

Shallow Groundwater: Physico-chemical data of shallow groundwater (depth less than 30 meters) shows that the shallow wells, located in the vicinity of coast and in the proximity of polluted rivers, have relatively higher values of electrical conductivity, salinity and population of Coliform bacteria. The shallow groundwater is moderately saline, representing electrical conductivity values in the range of 1.1 to 1.9 mS/cm and salinity in the range of 1 ppt. The pH of shallow groundwater varies from mildly acidic (~6.3) to mildly alkaline values (~7.9). Areas with quite poor sanitary conditions have relatively low values of pH (~6.3 to 6.8). Shallow groundwater below 20 meters is slightly reducing. The dissolved oxygen is in the range of 1.5 to 7.9 mg/L. Turbidity of shallow groundwater varies between 3.6 NTU and 95 NTU. The - - -2 concentration of HCO3 (356-514ppm, n=4), Cl (82-169 ppm, n=4) and SO4 (38-117 ppm, n=4) - -2 in shallow groundwater is very reasonable. The mean chemical concentrations of Cl , SO4 and - HCO3 in shallow groundwater are as follows:

 Mean Cl- (Shallow Groundwater): 132.8 + 36.5 ppm (n=4) -2  Mean SO4 (Shallow Groundwater): 63.3 + 36.7 ppm (n=4) -  Mean HCO3 (Shallow Groundwater): 423 + 67.4 ppm (n=4)

The range of variation in stable isotope content of total dissolved inorganic carbon (TDIC) and oxygen in Lyari River water is as follows:

 δ 18 O (Shallow Groundwater) -6.3 to -5.8 ‰ V-SMOW (n=8)  δ 13 C (TDIC-Shallow Groundwater): -16.5 to -5.5 ‰ PDB (n=8)

The mean stable isotope content of 18O and 13C in shallow groundwater is as follows:

 Mean δ 18 O (Shallow Groundwater): -5.9 + 0.32 ‰ V-SMOW (n=8)  Mean δ 13 C (TDIC-Shallow Groundwater): -10.1 + 3.3 ‰PDB (n=8)

The stable-isotope results indicate that the shallow / phreatic aquifers are recharged by a mixture of fresh waters of Indus River and Hub River (draining spring water and flooded rainwater), as well as polluted Lyari and Malir rivers and their feeding drains (both under natural infiltration conditions and artificially induced infiltration conditions) and, to a much smaller extent, from direct recharge of local precipitation.

Deep Groundwater: In general, Deep groundwater is mostly saline and has high electrical conductivity (range: 1.9- 19.1 mS/cm) and salinity (range: 1.7-7.4 ppt), as compared to shallow groundwater.

Based on hydro chemical data of water samples collected from pumping wells, it is assumed that the shallow mixed deep groundwater discharged by large-scale pumping wells mainly

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represents the deep groundwater from confined aquifer. The mean chemical concentrations of - -2 - Cl , SO4 and HCO3 in shallow mixed deep groundwater are as follows:

 Mean Cl- (Deep Groundwater): 2169.2 + 1828.0 ppm (n=9)  Mean SO4-2 (Deep Groundwater): 458.4 + 691.4 ppm (n=9)  Mean HCO3- (Deep Groundwater): 353.6 + 215.4 ppm (n=9)

The range of variation in stable isotope content of total dissolved inorganic carbon (TDIC) and oxygen in shallow mixed deep groundwater is as follows:

 δ 18 O (Deep Groundwater): - 6.2 to -4.2 ‰ V-SMOW (n=10)  δ 13 C (TDIC - Deep Groundwater): -13.2 to -0.3 ‰ PDB (n=10)

The mean stable isotope content of 18O in shallow mixed deep groundwater is as follows:

 Mean δ 18 O (Deep Groundwater): -5.3 +0.7‰ V-SMOW (n=10)  Mean δ 13 C (TDIC- Deep Groundwater): -10.5 + 3.7‰ PDB (n=10)

The hydro chemical and stable isotope results indicate that the confined aquifer hosts a mixture of rainwater from hinterlands and surrounding regions around coastal Karachi, as well as sea trapped water / seawater, through intrusion under natural infiltration conditions or under induced recharge conditions.

Groundwater Recharge Characteristics/Sea water Intrusion: Presently, coastal Karachi is known to have five sources of recharge to its groundwater reserves: i. Rainfall, ii. Indus River water supply iii. Hub-River & Hub Lake water supply iv. Polluted Lyari and Malir rivers/ contributory channels draining mixtures of domestic industrial and agricultural wastewater, composed of pre-said three sources v. Seawater.

The possibilities of major contribution to groundwater recharge of shallow/phreatic aquifer directly by local rainfall seems very small, due to very poor frequency of rainfall events and rainfall intensities in the Karachi and high evaporation rates. The long-term (15 years annual record) mean monthly average precipitation for Karachi is between 0-15 mm during the months of January to June, 23 - 91 mm during the months of July to September, and 0-7 mm during the months of October to December. The remaining four sources play a significant role in recharge of the shallow aquifer-system and deep groundwater system (confined aquifer) in coastal Karachi. Unpolluted seawater of Karachi coast is characterized by a δ 18O value of ~ +1 ‰ VSMOW and a chloride content of ~23000 ppm. Both the Lyari River and Malir River waters, as well as the Indus River water and the Hub Lake water, have extremely very low aqueous

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contents of chloride and sulfate ions as compared to seawater. The average mean value of δ 18O in polluted river waters is ~ 5 ‰ V-SMOW and in shallow groundwater is -5.9 ‰ V-SMOW. The relatively deeper ground waters representing confined aquifer have a mean δ 18O value of -4.3 ‰ VSMOW and excessively high values of aqueous chloride and sulfate.

Water Supply and Sewerage System: The water supply and sewerage system is managed by Karachi Water Supply & Sewerage Board (KW&SB). Present water supply system of Karachi City has a supply capacity of 560 mgd. Actually, as of the end of year 2006, the KW&SB supply bulk water of about 630 MGDbeyond the capacity as shown in following Table. Out of 630 mgd, water of 209 MGDis supplied without filtration, which is equivalent to one third of actual supply amount of 630 mgd.

Table 4.10: Present Water Supply Capacity Supplied from Rated Capacity Actual Supply Gharo Filtration Plant 20 MGD 30 MGD Pipri Filtration Plant with Filtration 100 MGD 102 MGD without Filtration - 32 MGD Dumlottee Conduit (without from Wells 20 MGD 0 MGD Filtration) from GK/K-III Systems - 17 MGD NEK Old Filtration Plant 25 MGD 5 MGD NEK New Filtration Plant 100 MGD 100 MGD COD Filtration Plant with Filtration 115 MGD 104 MGD without Filtration - 48 MGD Hub Filtration Plant 80 MGD 80 MGD Supply without Filtration (from K-III System) 100 MGD 95 MGD Supply without Filtration (from GK System) - 17 MGD Total 560 MGD 630 MGD

The water distribution network in Karachi covers 18 towns, 6 Cantonments and a Defense Housing Authority (DHA) Area. These 18 towns are included in 5 administrative water supply zones classified by the KW&SB, which is shown on Figure.

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Figure 4.12: Karachi Monthly Water Demand (Source: Pakistan Development Perspective)

The existing sewerage catchment area which covers 18 towns in Karachi city is divided into three districts, namely: respective catchment area of T.P-1, T.P-2 and T.P-3. KW&SB formulated the Master Plan of the water supply and sewerage system in cooperation with JICA in 2008. However, most of the projects for rehabilitation and augmentation proposed in the Master Plan study, etc. have not been carried out due to financial constraint of KW&SB. Due its negligence to maintain and operationalize the treatment plants, not only municipal effluent but industrial effluent also is directly going into sea destroying marine life.

In January 2018, the Supreme Court appointed Honorable Justice Amir Hani Muslim, a retired Supreme Court judge, the new head of the water commission with a mandate to ‘implement” the recommendations of the previous commission that the apex court had formed in December 2016 in response to my constitutional petition. The commission turned into a forum of first choice for many water-starved people, whether living in Tharparker’s deserts or Karachi’s posh localities. Treatment of sewage, a much-neglected issue, saw a revival under the commission. Thus, Sewage Treatment Plant-III (77MGD) was restored in June 2018. STP-I (100MGD) would start by end of 2019. STP-IV (180MGD) should also operate by December 2020. Five industrial effluent treatment plants are scheduled to be built in the SITE, Trans-Lyari, F.B, and Superhighway areas.

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Figure 4.13: Existing Sewerage System of Karachi

Land use Changes and their Impacts on Natural Drainage Systems: Rapid urbanization of mega cities in developing countries has been responsible for not only alterations in the natural phenomena but has posed serious health challenges due to insufficient water and sanitation infrastructures, inappropriate waste treatment and disposal facilities and substandard living conditions. Less privileged communities that migrate to big cities are not only victims of several types of communal diseases but are more vulnerable to natural disasters. Rapid urbanization of a city may alter its natural hydrology giving rise to blockage and frequent flooding of the drains.

Surface Water Drainage and Flooding in Karachi City: The problem of urban flooding is quite significant in Karachi which is the industrial and business hub of Pakistan. Karachi had experienced severe floods which occurred periodically. In 1977 severe flood occurred in the flood plains of the Malir River and the Lyari River killed 267 people, more than 30,000 were homeless and 100,000 were temporarily dislocated. Houses were destroyed and roads were damaged. The total loss was estimated about 5 billion rupees (KDA, 1981). The present study deals with urban flooding which has now become a serious problem all over the world, affecting urban life, infrastructure, mobility of people and economy of the city. In this context Karachi has been selected for study which is the largest city of Pakistan.

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Table 4.11: Blockage in Malir River and its Tributaries based on Satellite Data Rivers of Malir # Blockage Type Geographical Position Basin 67º22’24.272”E 1 Sukkan Nadi Agriculture field/Siltation 24º57’16.871”N 67º19’21.075”E 2 Bazar Naddi Agriculture/Settlemetn 24º57’2.247”N 67º22’33.461”E 3 Jamado Ndi Siltatiom & Agriculture 25º0’15.589”N 67º10’18.873” E 4 Malir Nadi Agriculture/Seweage/Siltation/Urban 24º51’57.589”N 67º24’14.539”E 5 Mol Nadi Agriculture 25º3’33.235”N 67º25’40.299”E 6 Khadeji Nadi Agriculture 25º2’32.542”N 67º15’40.689”E 7 Thaddo Nadi Agriculture/Siltation 24º58’2.917”N 67º14’11.128”E 8 Konkar Nadi Agriculture 25º1’3.743”N *Coordinate system: WGS 1984 UTM Zone 42N

Flooding in Karachi: Urban flooding is caused by heavy rainfall overwhelming drainage capacity. The primary cause of flooding in Karachi city is torrential rainfall due to tropical storm and monsoon which saturate soil and create huge surface runoff. Floods in urban conditions are flashy in nature and occur both on built up surfaces like roads and streets, parking lots, yards, parks etc. and creeks of urban areas like the Lyari, the , and the creek.

4.2.9. Water Quality Because of unsafe and insufficient water supply and low sanitation coverage, as well as people’s poor hygiene habits, around 60 percent of children suffer from diarrhea that is fatal if not treated in time. Concerns have been raised by various quarters about contamination in drinking water supply in the distribution network and possible linkages with water borne diseases in the city. The seriousness of the issue can be rated from the fact that in the year 2002, the Provincial Ombudsman Sindh, Justice Haziqul Khairi in response to a growing number of reports received from all over the Sindh province about the supply of contaminated drinking water, instituted a study for investigating the claims of the public and assessing the causes of contamination.

Regarding the quality of surface water supplied to the consumers, the Study Report prepared by Dr. Mirza Arshad Ali Beg, concluded that about 75% of the water supplied to Karachi is chlorinated. Shortfall in the availability of water for drinking constrains the distribution to intermittent supply that is one of the main causes of water pollution.

The water that leaks through the distribution mains and smaller pipes, particularly the ones that were laid long time before and in the Third Phase of the Bulk Water Supply scheme for Karachi,

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creates an underground pool during the supply hours. This serves as a nursery to the micro- organisms, including fecal coliform released by the leaky sewers crisscrossing the water supply pipes. Sewage might enter into the distribution system due to vacuum created during idle hours. This is the reason for the gradual depletion of free-active chlorine in the treated water as it proceeds from the filter plant to the distribution network and in its onward journey to the households. The findings of the analysis of the water samples suggest that the water even though treated gets contaminated in the distribution network and on its way to the consumers.

This finding suggests that the water as received by the residents is not safe for drinking. Assessment of ground water quality in the aforementioned Ombudsman Study Report indicated that ground water has been over exploited in Sindh and the drying of traditional wells in the vegetable and fruit growing areas in the suburbs of Karachi has occurred. Although water quality has not been tested yet, groundwater pollution by nitrates, pesticides, heavy metals and hydrocarbons discharged into the environment is not negligible. The salinity of groundwater in Southern Sindh, particularly in the coastal areas has increased since over pumping has induced seawater to flow in, causing what is known as seawater intrusion.

The fact, also acknowledged by KW&SB that 150 MGD(681,900 m3/day) of water supplied to the consumers is chlorinated and bypasses the KW&SB filter plants is an important indicator of the need of addressing this issue on a priority basis. The Ombudsman Study Report says that the water drawn from about 95% of the wells in the city of Karachi is contaminated with sewage bacteria and also contains total dissolved solids beyond permissible limits. The Ombudsman Study Report also documents that 90% of the survey sample tests conducted by PCSIR indicate that the water is unfit for drinking purposes referring to the guidelines set by the World Health Organization (WHO).

Physical, Chemical & Microbial Profile of Macro-Environment: The physical, chemical and microbial profile given in table 4.12 the pH value of drinking water samples is 7.47. According to Sindh Standard for Drinking Water Quality (SSDWQ), pH value for safe drinking should range 6.5 to 8.5. The pH value in sample met the WHO guidelines as well. Water with pH above 11 and below 4, is responsible for skin, eye irritation and corrosive effects respectively. WHO warns that extreme pH levels can worsen existing skin conditions12.

Turbid water in fact devalues water quality from consumer’s point of view. According to WHO guidelines and SSDWQ the turbidity level should not exceed 5 NTU for drinking water. The values of turbidity of the sample within the acceptable limits (4.34). Turbidity in water mainly results from the presence of fine colloidal and suspended particles. Turbidity level is a vital consideration for effective planning and functioning of the processes of treatment and also an indicator presence of microorganism responsible for causing health issues13.

TDS in water represents the amount of inorganic substances that originates from sewage, natural sources, industrial waste and other chemicals. High amount of suspended, dissolved and total solids depreciates palatability of water rendering it unsuitable for drinking purpose. TDS value of

12 WHO Working Group, 1986. Health impact of acidic deposition. Science of the Total Environment, 52: 157-187. 13 Perveen, F., U. Asghar and T.H. Usmani, 2001147. Evaluation of Water Quality of Different Colleges of Karachi City. Journal of the Chemical Society of Pakistan, 29(5): 458-462.

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the samples is detected 1649 mg/l. The recommended guideline for TDS as reported by SSDWQ <100 mg/l. Generally, water having TDS value less than 500 mg/l is considered to be water of good quality but values of up to 1000 mg/l can be tolerated. High TDS levels can also lead to corrosion, decrease gases solubility, increase water density and make water unfit for drinking purpose.

Table 4.12: Descriptive statistics of physical, chemical and microbiological analysis of Ground water of Macro-environment S.NO. Parameters UNITS LDL RESULTS SSDWQ Limits 1 pH value - 0.01 7.47 6.5 – 8.5 2 Total Dissolved Solids(TDS) mg/L 1.0 1649 < 1000

3 Total Hardness(as CaCO3) mg/L 0.1 915 < 500 4 Turbidity NTU 0.01 4.34 < 5 NTU

5 Nitrate(NO3) mg/L 0.01 0.19 ≤ 50

6 Nitrite(NO2) mg/L 0.001 0.11 ≤ 3 7 Phenolic compounds(as phenol) mg/L 0.001 0.006 < 0.0002 8 Chloride(as Cl-) mg/L 0.01 562 < 250 9 Fluoride(as F-) mg/L 0.01 1.92 ≤ 1.5 Microbiological Test Report 10 Total Coliform cfu 750 11 Faecal Coliform cfu >500 Must not be 12 Escherichia Coli(E-Coli) cfu 128 detectable in any 100ml Sample SSDWQ = Sindh Standards for Drinking Water Quality BDL= Below Detection Limit, ND= Not Detected, LDL=Least Detectable Limit

4.2.10. Storm Water Drainage Following Table outlines storm water drainages and nallahs under each township administration. Drainages are artificial water channels for storm water drainage; on the contrary, nallahs are natural water channels. Many drainages are connected to nallahs and some drainages connected to river directly; Nallahs discharge into rivers such as Lyari River and Malir River receiving storm water. As sewage collection system in Karachi City is not enough and its maintenance is not satisfactory, storm water drainage and nallahs have to receive sewage all year long in addition to storm water in rainy season.

Table 4.13: Town-wise Storm water Drainage/Nallah Length Town Depth (m) Width (m) Length (km) 1. Town 1.21 0.91~3.04 7.62 2. SITE Town 2.13 3.65 16.08 3. 1.22 2.43 11.77 4. 1.52 2.43~3.65 34.1

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5. 1.37 0.6~13.7 19.4 6. Town 1.37 3.05 11.14 7. 1.5 2.43 33.8 8. Gulshan -e- Iqbal Town 3.64 2.4~15.2 28.0 9. Faisal Town 1.22~4.57 1.52~24.0 20.1 10. 1.22 2.43 35.36 11. 1.52 2.74 36.4 12. North Town 1.22 2.4 30.7 13. Town 1.22 2.4 45.1 14. Gulberg Town 1.37 2.4 22.1 15. Town 1.52 3.65 19.5 16. 1.22 3.04 6.15 17. 1.22 3.64 14.63 18. Gadap Town 1.22 3.65 24.43 Total 416.38 Source: KWSB There are no exclusive pumping facilities for storm water drainage in Malir. However, many pumping stations called “ejector” which were constructed for sewage discharge to natural nallahs or rivers have worked as storm water pumping facilities in rainy season. Roadside drains are cleaned by KWSB 1-2 months before the monsoon season. Removed and collected silt/garbage is conveyed to designate solid waste disposal sites.

However, at times roads are cleaned afterwards by town administration and silt/garbage is transferred to drains again. This is said to be how inundation is caused. In addition to the other mentioned issues in Malir Town many drains and nallahs have been already encroached on by illegal houses and buildings. Storage enforcement of building code and other relevant laws.

Another major issue with malfunctioned drains / nallahs is that garbage is easily and routinely dumped to these facilities, which leads to their reduced sections. Comprehensive solid waste management system has to be introduced. There are no exclusive pumping facilities for storm water drainage in Karachi City. However, many pumping stations called “ejector”, which were constructed for sewage discharge to natural nallahs or rivers have worked as storm water pumping facilities in rainy season.

Roadside drains are cleaned by KW&SB one to two months before monsoon season comes every year. Removed and collected silt/garbage is conveyed to designated solid waste disposal sites. However, roads are cleaned afterwards by town administration and silt/garbage is transferred to drains again. This is said to be how inundation is caused. In addition to above mentioned administrative issues, many drains and nallhas have been already encroached on by illegal houses and buildings. Strong enforcement of building code and other relevant laws is expected. Another major issue with malfunctioned drains/nallahs is that garbage is easily and routinely dumped to these facilities, which leads to their reduced sections. Comprehensive solid waste management system has to be introduced.

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4.3. Ecological Baseline This section provides an overview of the eco-zones, wild flora and fauna, and the habitat conditions prevailing in the project area.

4.3.1. The Ecology of Project Area Ecological surveys have been conducted in and around the project area by study team comprising of Ecologists and Environmentalists, in order to check the current ecological status of the project site and its immediate surroundings.

Data in respect of fauna and flora were gathered from both primary and secondary sources. The sampling was done in the entire area ensuring that the representative locations were sampled from each habitat and the maximum possible number of species belonging to each habitat was recorded. Secondary data were collected through information obtained from the local communities. Some information was also congregated about the fauna of the area during various faunal studies conducted previously in the area.

The plant communities were determined within the various habitats of the Project Area.

4.3.2. Vegetation In terms of macro-environment, the vegetation of Greater Karachi can be divided into three edaphic types14: Some of plant at Macro-environment Ecological risk of high order has been induced by land clearance and removal of natural vegetation from the plains during the urban sprawl to make room for industrialization and urbanization. This has degraded the physical environment as quantified in the above section & the biological environment in the sense that the entire macro-environment has lost its biodiversity. During the survey, less number of flora species was recorded in the project area such as Conocarpus, Acacia nilotica (Sindhi Babur), Capparis decidua (Kirar), Ficrus religiosa (Pepul), Azadirachta indica (Neem), Prosopis juliflora (Devi) and Saveda fruticosa (Lani). Horticulturists and tree activists have declared Conocarpus as harmful as the eucalyptus trees planted in the past. Eucalyptus was planted in huge numbers across the city only to be cut down for its negative impact on the environment. The same mistake was repeated with Conocarpus. In response to the growing concern against planting Conocarpus, district governments have put tremendous efforts in recent years towards plantation of neem trees and other native species in the city.

14 Chaudhri, I. I. (1961). The vegetation of Karachi. Vegetatio, 10(3-4), 229-246. https://link.springer.com/article/10.1007/BF00241786#Bib1

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Figure 4.14: Flora of the Project site

Figure 4.15: Vegetation Trends in Karachi15

15 Change detection map of Karachi Division vegetation for the years 1998, 2008 and 2018. Adapted from “Raza, D., Karim, R. B., Nasir, A., Khan, S. U., & Zubair, M. H. (2019). Satellite Based Surveillance of LULC with Deliberation on Urban Land Surface Temperature and Precipitation Pattern Changes of Karachi. Pakistan. J Geogr Nat Disast, 9(237), 2167-0587”.

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4.3.3. Fauna of Macro-environment Restricted number of birds, mammals and reptiles were recorded from the site survey for EIA study of this project. This include visual, review of documents of previous study conducted in this area and interview with local people. Direct and indirect observation such as observing pug marks, fecal material, territorial marking signs, etc. Most of the small mammals, like rodents were not observed but their burrow holes were found near bushes, lagomorphs such as wild hare and was observed.

4.4. Socioeconomic Environment The social baseline chapter provides a comprehensive review of the socio-economic conditions of the project area. This socio-economic profile is based on a literature review and several primary data gathering activities including site visits, sample socio-economic survey of stakeholders in the area and consultations with primary and secondary stakeholders. This social baseline provides an overview of the socio-economic conditions of the people who reside and work in the project vicinity. It also includes an assessment of public utilities and social services (education and health facilities) in the area concerning the proposed construction and operation of Sumya Northern Industrial Zone.

International best practice for EIA studies demands an alignment of the proposed project components with the Sustainable Development Goals (SDGs) defined by the UN. In 2017, the global indicator framework was developed and agreed upon by the Inter-Agency and Expert Group on SDG Indicators (IAEG-SDGs). Indicator 11.3 of Goal 11 of UN Sustainable Development Goals (SDGs) focuses on achieving sustainable development of cities through improvement in urban planning and management in participatory and inclusive ways by 2030. For the sustainable development of Karachi, integrating the project design of the proposed project “Sumya Northern Industrial Zone” to ensure alignment with relevant aspects of SDG Goal 11 is essential to ensure development that is socially acceptable and environmentally sound.

The social baseline chapter helps in understanding the existing socioeconomic conditions of the project area as well as the larger macro-environment under which the project is falling. The social baseline is divided into the macro and micro environment of the project area. The macro- environment encompasses District West Karachi under which the project area is falling. The discussion on the macro-environment covers the administrative setup, demography, education and health profile of the area. The immediate neighbourhood of the project area is considered to be the micro-environment of the project and covers the land use, education, health and utilities profile of the area.

4.5. Macro Environment

4.5.1. Administrative Context The Karachi Division was abolished in 2000 and five districts of Karachi were merged in City District Karachi. The City District Karachi was divided into 18 Towns and 178 union councils. On 11 July 2011, Sindh Government restored 5 districts of Karachi division and abolished City District Government Karachi. In November 2013, a new district (6th), Korangi was formed by splitting District Karachi East. In September, 2020, the Government of Sindh approved establishment of

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the 7th district of Karachi i.e. Keamari District, that has come about after splitting Karachi West District. Now Karachi Division has District Central, District East, District Malir, District South, District Korangi, District West and District Keamari. These districts form the Karachi Division now. There are also six military cantonments, which are administered by the Pakistan Army.

The proposed project “Sumya Northern Industrial Zone” is located near Hamdard University, which falls under the jurisdiction of Mangopir sub-division of District West, Karachi. In September, 2020, the Government of Sindh approved establishment of the 7th district of Karachi i.e. Keamari District, that has come about after splitting Karachi West District. District West covers a total area of 169 Sq.km while the Mangopir sub-division covers an area of 149 Sq.km in the district west. A total of 3 subdivisions fall under District West Karachi which include Mangopir sub-division, sub-division, Orangi sub-division.

Table 4.14: Covered Area of District & Sub-Division District West Mangopir Sub-Division 169.25 Sq. km 149 Sq. km

4.5.2. Demography District West is a blend of urban and rural settlers residing in varied landforms, including hills, islands, agricultural plains and industrial zones. It is an industrial and commercial district enjoying diverse land use occupations. The main occupation of the people is business and trade. The other major portion of the population consists of labour class including skilled and unskilled labour. There are large numbers of people involved in the construction and industial business. The remaining small portion of the population are employed in government departments and private companies. The residents from a diverse array of ethnic and linguistic backgrounds, including those who speak , Pashto, Balochi, Punjabi, Sindhi, Siraiki and Hindko.

Table 4.15: Demographic Change in District West and Manghopir Sub-Division (1998-2017) 1998 Census Population 2017 Census Population %Change (1998-2017) District West 1,052,046 2,080,893 98 Manghopir Sub-Division 118,267 717,753 607 Source: Pakistan Bureau of Statistics 2017 (PBS)

The total population of District West was 1,052,046 in the 1998 census which increased to 2,080,893 in the 2017 census showing an increase of 98% with a growth rate of 5%. The total population of the Mangopir sub-division was 118,267 according to the 1998 census which increased to 717,753 in the 2017 census showing an increase of 506% having a growth rate of 27% per annum.

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Figure 4.16: District wise Population according to the 1998 and 2017 Census

According to the 1998 census, District West was the second most densely populated District of Karachi comprising 21% after District Central comprising 23% of the entire population. According to the latest census of 2017 District West became the most populated District of Karachi comprising 24% of the population.

The pie-charts above illustrate the relative distribution of population in Karachi’s districts based on 1998 and 2017 Census. Moreover, an additional modification to the District Wise Population of Karachi 2017 has been made to account for the demographic changes that have come about due to splitting of District West in 2020. Based on the new findings, one can observe that population distribution of West was highest before coming out of 7th district Keamari. Now we see that West and Keamri have the relatively close 13% and 11% share in the total population of the city.

4.5.3. Transportation The impact of the transport crisis on people’s lives is enormous. Travelling in environmentally degraded conditions for long hours results in physical and mental health problems. This effects family and social life and limits peoples’ choice of livelihoods (especially for women) since they wish to work in areas that they can easily access through the existing transport system. Increasingly, transport availability and quality is also determining where they would like to live.

The Hub River Road, a 4-5-kilometre long which connects Sindh to Balochistan is busiest and important road. It has heavy traffic which also links to Karachi- Hyderabad Motor way through Northern Bypass road. The Northern bypass links the Karachi Port Trust to the National Highway and the Super Highway and provides an easy access to the transporters and to the commuters who can go directly to the Karachi port without entering the main arteries of city.The existing road infrastructure serves the localized traffic of the densely populated areas along both sides, traffic of

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local industries, the recreational traffic to the beaches, the heavy traffic between the port/ SITE area and the Hawksbay truck stand, and the defence / logistic needs of Pakistan Airforce and Naval establishments at Mauripur and Manora. The situation becomes even worse during the rainy season or on holidays and it takes a long time to cross this section.

4.5.4. Economy Karachi city has a very large and diverse economy. It is home for some of the largest and most dynamic industrial complexes in the country such as Sindh Industrial & Trading Estate (SITE), Korangi Industrial & Trade Estate, FB Area, North Karachi Industrial & Trade Estate, Dhabeji and Port Qasim etc. SITE is the largest industrial park of the country comprising about 4000 factories. The areas like I.I. Chundrigar Road, Sharah-e-Faisal, Clifton and Defense are the main business hub of Karachi.

Since Sindh Industrial Trading Estates (SITE) Karachi was fully occupied and there was no room for the establishment of fresh industries in this sector a new Industrial Estates are being established at Northern Bypass and Super Highway to meet the growing demand of the industrialists and to boost exports and provide employment to the needy people. District West is situated at an ideal location most suitable for the establishment of industries. It is southern part of Karachi and is directly connected with Super High Way through Northern Bypass.

4.5.5. Education Sector The education facilities available in the District West are not commensurate with the number population. A large number of schools, colleges, technical colleges have been opened up in the district by the government as well as by private organization. Hamdard University (Madinatul Hikmat) founded by the late Hakeem Muhammad Saeed is promoting knowledge in the field of Medicine, Computer Science and Business Administration is one of the leading institute in the district.

Table 4.16: District wise Number of Schools, Enrollment and Staff in Karachi (2016-17) No. of Schools Enrollment Teacher District Boys Girls Mixed Total Boys Girls Total Male Female Total Central 117 141 348 606 44,822 58,510 103,332 1,803 4,996 6,799 East 51 64 163 278 23,022 29,106 52,128 870 2,271 3,141 South 70 87 173 330 26,122 35,824 61,946 1,079 2,496 3,575 West 128 101 340 569 38,562 45,454 84,016 1,443 1,909 3,352 Malir 136 113 414 663 34,548 32,333 66,881 1,540 1,148 2,688 Korangi 97 94 220 411 35,192 46,918 82,110 1,025 3,082 4,107 Source: Sindh Education Management Information System (SEMIS) Census 2016 – 2017

The above statistics show that District West has second higher numbers of schools, the enrollment of the students and sufficient numbers of teachers than other districts.

The number of schools, enrollment and teachers shows here active involvement of the residents of the District West in the education sector. Facilities available in the schools are presented in the table below.

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Table 4.17: District-wise Basic and Advance Facilities in Schools of Karachi Drinking Boundary Districts Schools Electricity Washroom Lab Library Water Wall Central 607 447 484 507 529 121 56 East 264 223 241 219 238 59 25 South 482 383 426 356 432 49 49 West 363 232 301 256 340 82 27 Korangi 550 397 431 391 509 46 37 Malir 591 240 398 302 479 56 21 Source: SEMIS Census 2016 – 2017

The above table illustrates that advance facilities in schools of District West have improved their standard in educating its residents on a certain level. Apart from the Government-run education institutions, dozens of private schools are also functioning in the district.

4.5.6. Public Health Sector It's quite obvious that the most famous city in Pakistan would have the best of urban facilities. In terms of healthcare, Karachi is equipped with the best hospitals in Pakistan. These hospitals are possessed by top-notch doctors, surgeons, and health specialists who provide the most authentic and reliable diagnosis and treatment to the patients.

The following table shows the number of health practitioners and paramedical personnel in Karachi.

Table 4.18: District-wise Government Medical and Paramedical Personnel in Karachi 2017

District

L.H. V L.H.

Nurses

Doctors

Midwives

Ray Assistants Ray

-

Ray Technicians Ray

O.T. Assistants O.T.

Lab. Assistants Lab.

-

O.T Technicians O.T

Lab Technicians Lab

X

X

Dispensers/Dressers

Central 579 207 15 82 12 17 25 0 3 12 26 South 324 115 4 51 14 23 33 0 8 8 2 East 245 18 22 26 4 0 3 0 4 1 6 West 356 83 19 67 12 14 22 5 12 15 19 Malir 234 25 14 53 9 4 6 0 10 5 18 Korangi 252 90 38 - - - - 0 8 8 25 Source: Directorate General of Health Services, Hyderabad

The following table shows the number of health practitioners and paramedical personnel in Karachi.

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Table 4.19: District-wise Government Health Facilities with Bed Capacity in Karachi 2017 Hospital Hospital Dispensaries R.H T.B. B.H. M.C.H.C. Beds Centers Centre Units

District

No. No. No. No. No.

Beds Beds Beds Beds Beds

Teaching Teaching

Civil, Specialized Civil, Specialized Civil,

Central - - 3150 - 5 - - - 8 - 2 - 3 6 South 2 4 - 960 5 - - - 10 5 - - - - East - - 361 - 5 - - - 5 97 4 - 4 - West 1 1 - 248 14 15 4 20 8 - 7 14 5 6 Malir - 1 - 48 7 - 2 8 4 - 14 22 6 - Korangi - 7 - 724 8 - - - 7 - 8 16 4 41 Source: BOS, Government of Sindh (Development Statistics of Sindh-2018)

The public health facilities in Karachi are highly centralized in a few locations and cannot cater to a large part of the population. The above mentioned public health facilities data is not updated in the government records thus subject to some shortcomings. Though health facilities available in District West Karachi include public, private and welfare hospitals need to be increased.

However, there is several dispensaries, maternity homes and child welfare centers and hospitals in the district which cater to the medical emergencies of the people of different localities. Namely Valika Hospital on Manghopir Road. Qatar Hospital in Orangi, Murshid Hospital and Naval Hospital in Mauripur, Ziauddin Hospital, KPT Hospital, Korean Hospital, Al-Khidmat Hospital, Arain General Hospital, Patni General Hospital, Metro Lion’s Hospital, Hazrat Hassan Hospital, Rasheeda Memorial Hospital, Al-Mujeeb Welfare Hospital etc.

4.6. Description of Microenvironment The micro-environment of the project area comprises of mostly underdeveloped housing schemes including North Town Residency Phase 2, Ali Town and Ahsan City. There are few villages/Goths in the microenvironment namely Haji Ibrahim Goth, Noorani Goth and Hazratabad. The majority of the villages are relatively small (50 to 100 houses). Also, Hamdard University, Hospital and School are within half a kilometer of the project site and is a major land mark in the area. The project area faces 140ft Hub Dam Rd and Karachi Northern Bypass (M-10) runs close to the project.

During the site visit, a total of three major villages were identified in the project area. Major socio- economic findings regarding the three villages were obtained from village residents and gatekeepers of the under-construction housing schemes. These villages are located within 2 km radius of the project site. The villager’s work mostly as laborers in construction work of developing housing societies and crush plants in the nearby areas. The majority of villagers are poor and work hard to maintain their families properly. The people of project area are Urdu speaking, , . Pathans with other ethnicities having majority of the Balochis. They largely earn their

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income through engagement in various petty jobs and other are engaged in laborer work within and out of the city.

4.6.1. Education Facilities Educational institutes are available in the area. The major NGO working in the neighborhood is Al-Khair Khidmat Foundation which has established three schools in different goths of the town namely, Al-Khair 1, Al-Khair 2 and Al-Khair Secondary School, where some villagers send their children. However, poverty does not allow poor parents (villagers) to educate their children beyond primary level. The drop out ratio is at a much higher rate for the girls.

4.6.2. Healthcare Facilities There are no major health facilities in the villages, except Hamdard Hospital, which has a dispensary and hospital to take care of the nearby villagers which is 5.5 Km away from there. The villagers also go to the Jinnah and hospitals for better treatment. The major diseases reported in this area are Diabetes, Diarrhea and Malaria. There are a couple of small family clinics near the premises of the proposed project namely Umer Clinic and Danish Clinic which can only cater to a limited number of patients and ailments.

4.6.3. Utilities Electricity and gas is not available in the villages. Some villagers have small solar panels which they use as an alternate energy. There are no gas connections in the villages, so people use wood for meeting their cooking and heating needs. Boring water is also used and quality of that water is satisfactory. The main water board line enters the area from where every village is connected for water supply by the concerned authority. Hub Dam Canal also passes through the area which is a picnic spot for the locals families during summers. The villages do not have proper sewerage system for disposal of domestic waste. There is no proper solid waste disposal service in the area. In general practice, villagers dispose their waste in an open area and burn it when waste piled up.

4.6.4. Transportation The main Northern Bypass (M-10) is 4 kilometers away from the project site which connects with Karachi-Hyderabad Motorway (M-9) at a distance of 19 kilometers, where heavy traffic flow is constant. There is no facility of proper public transportation, but few rickshaws are available which are used for public transportation. Majority of the male villagers own motorbikes which they use for transportation. Villages are accessible to the main road by smaller un-metaled/unpaved roads. Road conditions are deteriorating due to heavy transport vehicles which carry construction material or water frequently.

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Chapter 5 INFORMATION DISCLOSURE, CONSULTATION & PARTICIPATION

The participation of project stakeholders in project planning, design and implementation are now universally recognized as an integral part of environmental & social impact assessment. Local communities, their representatives, government departments, national and international NGOs and the civil society at large may all be able to contribute to and benefit from, the dialogue directed at identifying and resolving key project-related issues. Stakeholder consultation has become an important requirement of the EIA study after the enactment of the guidelines for public consultation under the Pakistan Environmental Protection Act (PEPA) 1997. After the 18th Amendment to the Constitution, the Government of Sindh passed the Sindh Environmental Protection Act 2014, which also stresses the importance of engaging with the concerned primary and secondary stakeholders during the EIA study.

While in the short-term, the impacts might be felt only in the microenvironment of the project, in the long-term, the impacts may also spread to other nearby neighbourhoods and activities including traffic management, the swift passageway for fire tenders and ambulance and stress on existing utilities. Instead of these perceived impacts, meaningful engagement with the project stakeholders has been carried out to identify the potential positive and negative impacts, assess the magnitude of these impacts from a social perspective and prescribe solutions that identify Best Management Practices (BMPs) in the construction and operations of the proposed project. In this chapter, an overview of the various stakeholders has been given, the engagement interventions carried out with the stakeholders and the concerns and suggestions raised by them.

5.1. Stakeholder Mapping To better understand the different stakeholder groups for this project, a stakeholder mapping exercise has been carried out whereby the different stakeholder groups and their interests in the project are discussed in this section:

5.1.1. Local People/Neighborhood Individuals or groups in the vicinity of the project site are informed regarding the project background and context. Due to their proximity to the project site, they are often the most vulnerable stakeholders and therefore, consultation with these stakeholders is carried out throughout the project life. The consultation exercise provides an opportunity to appraise the stakeholders regarding the consultation process, identify likely project impacts, and record concerns of local communities. Moreover, intensive stakeholder engagement during the planning stage of the project provides a basis for reducing the trust deficit and encourages confidence-building.

5.1.2. Proponent The main aim of the project proponent is to accomplish the objectives of the project through cost- effective and sustainable project activities. To this end, the project proponent has to recognize that strong associations and responsive relations with stakeholders would go a long way to achieve the project objectives. Therefore, the proponent has to strive to engage stakeholders at all levels from the outset; inform them regarding project goals, design and alternatives. Moreover, they have to

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Environmental Impact Assessment (EIA) Study Sumya Northern Industrial Zone keep trying to create public understanding and acceptance of the proposal through a commitment to implement the promised objectives. They have to accomplish the project through general acceptance of the design and keep improving through the use of public inputs on alternatives and mitigation measures.

5.1.3. Government Agencies The government agencies involved in the EIA process is mandated to have their policy and regulatory responsibilities addressed in impact analysis and mitigation consideration. For the competent authority, an effective public involvement program will ensure a project proposal that effectively incorporates environmental and social concerns. During the EIA review, the most important concern for SEPA is a transparent public consultation process and a strong stakeholder engagement plan that can address the concerns and suggestions of all stakeholders.

5.1.4. NGOs/Interest groups Comments from NGOs and specific interest groups often provide a useful policy perspective on the project’s methodology and implementation mechanisms. For example, due to the vast exposure of certain NGOs and interests groups, alternative measures for reaching the project goals may be advised that is more environmentally friendly and socially acceptable.

5.2. Primary and Secondary Stakeholders Primary stakeholders are those who have a direct interest in the project which includes residents, commercial entities and institutions falling in the immediate environs of the project area. Secondary stakeholders include the relevant government agencies and public interest groups which may indirectly influence or be influenced by the project. The concerns and input from both primary and secondary stakeholders are important to identify the issues arising from the construction and/or operation phase of the project and propose mitigation measures that minimize the negative project impacts and enhance the positive ones.

Within the project vicinity of the proposed project there are the primary stakeholders who are the residents of Haji Ibrahim Goth, Noorani Goth, Hazratabad, North Town Residency Phase 2, Ali Town and Ashan City. The commercial interests in the immediate vicinity include Cement Block Factory, Noorani Hotel, Lal Shahbaz General Store, A J Communication and Byco Gas Station. The secondary stakeholders for this project include the utility companies that operate in the area including K-Electric, SSGC, as well as the regulatory authorities, mandated to ensure environmental protection in the city, which falls under the remit of SEPA and compliance with building and construction laws which is looked after by SBCA. The primary and secondary stakeholders for the Sumya Northern Industrial Zone have been identified in the table below:

Table 5.1: Stakeholders for Sumya Northern Industrial Zone Neighbourhood Residential Interests  Haji Ibrahim Goth  Noorani Goth

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 Hazratabad  North Town Residency Phase 2 (Under Development)  Ali Town (Under Development) Commercial Interests  Cement Block Factory  Noorani Hotel  Lal Shahbaz General Store  A J Communication  Byco Gas Station Government Agencies &  Sindh Environmental Protection Agency (SEPA) Other Service Providers  K-Electric  Sui Sothern Gas Company (SSGC)  Sindh Building & Control Authority (SBCA)  DMC West NGOs/Interest groups  Shehri-CBE  National Forum for Environment & Health (NFEH)  Citizens for Environment (NGO)

5.3. Consultation Approach & Methodology

5.3.1. Consultation with Primary Stakeholders A Neighborhood Survey was conducted to identify the residential and commercial interests in the area that may face direct impacts from the proposed development. The survey was conducted in two stages. In the first stage, several site visits were carried out to identify all stakeholders that either reside or work in the project vicinity and conduct an initial identification of potential positive and negative impacts. Relevant public service institutions directly involved in service provision in the areas were also identified.

During the second stage, a social survey field team used a pre-designed semi-structured template to engage the area residents, commercial interests and public service institutions. Those stakeholders, who were not available at the first attempt, were re-visited on the same day or followed- up for their comments during the next few days. During each meeting, the project team introduced the project to the stakeholders, recorded their concerns, suggestions and provided contact details to enable stakeholders to share further comments over email or in writing. A ‘Project Brief’ providing the salient features of the project were also handed over to the available stakeholders as part of the information disclosure process.

Moreover, the team inquired about the current situation of the area such as the status of utilities, security and law & order situation in the project area from the residents near the project site. Several open-ended questions were also included in the questionnaire to ensure that the respondents could openly share their opinions and suggestions relevant to the study. The following table shows the stakeholders that were approached during the Neighborhood Survey.

Table 5.2: Consultations with Primary Stakeholders S. No Respondent Name Location Stakeholder Type 1 Mr. Ali Akbar Haji Ibrahim Goth Residential 2 Mr. Aman Ullah 3 Mr. Agha Ali Hazratabad Residential

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4 Mr. Abdul Qadir Baloch 5 Mr. Jabbar Ali Noorani Goth Residential 6 Mr. Afaq Ahmed (Owner) Cement Block Factory 7 Mr. M. Irshad (Owner) Noorani Hotel 8 Mr. Punja (Owner) Lal Shahbaz General Store Commercial 9 Mr. Ayaz (Owner) A J Communication 10 Mr. Jibran Ali (Owner) Byco Gas Station

5.4. Consultation Feedback The comments, concerns and suggestions received from stakeholders during the neighborhood survey have been collated in this section. The comments solicited from stakeholders were helpful in the screening of the potential environmental & social aspects of the project.

The following major issues and concerns were raised by the primary stakeholders:

 The residents of the area expressed that such industrial projects can give a boost to the job opportunities in this area which will bring a positive change to the economic situation of the local people here.  The residents highlighted that this locality is mostly uneducated and unskilled, but they desperately need employment and preference should be given in hiring local labor force over outside labor.  Commercial stakeholders said that the property value of the neighborhood has slowly started increasing as different industries are being constructed in this area.  The residents of Ibrahim Goth hoped that new development in this area will also bring educational, health and other basic facilities that are severely lacking in the area.  The residents expressed their concerns about the solid waste which is thrown by the factory staff that leads to unhygienic conditions in the area.  They also complained of heavy loaded trucks with huge marble cut pieces which are damaging the roads drastically.  Public transportation service is a major concerns for the residents of the neighborhood as it allows mobility for the locals to get work opportunities within the Karachi city. They added that they have to reach by different means at 4k roundabout from where they get public transport to go to other part of the city. They demanded to commence a transport service for the locals.

Table 5.3: Primary Stakeholder Consultations Pictures

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Consultation with Owner, Cement Block Factory Consultation with Residents, Haji Ibrahim Goth

Consultation with Owner, Lal Shahbaz General Consultation with Owner, Noorani Hotel Store

Consultation with Owner, AJ Communication

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Consultation with Owner, Byco Gas Station

Consultation with Transporters

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Chapter 6 SCREENING OF POTENTIAL ENVIRONMENTAL AND SOCIAL IMPACTS AND APPROPRIATE MITIGATION MEASURES

This section presents the screening process that identifies the environmental and social aspects and makes assessment of impact of various activities during the design, construction and operation phases of the project only.

The screening process has been a thorough review of literature, primary and secondary baseline data, and experts’ judgment, made assessment of the potential impacts of the said activities on the physical, biological and socioeconomic environment of the project. Mitigation measures have been proposed to reduce, minimize or compensate for the identified potential negative impacts from this project.

Environmental impact of a project is worked out using various factors, so that an environmental management plan (EMP) can be evolved to take mitigation measures.

Impacts arising from different stages of the project are summarized in Figure below:

Residual Predict Evaluate Mitigate/enhance impact

What could happen as a consequence of What can be done Is there still a doing what is Is it important? about it? significant impact? proposed?

The project is currently Interact with the For some impacts the planned and the Stakeholders can help stakeholders and sequence may need to mitigation already decide this project to develop be repeated incorporated solution

Figure 6.1: Different Impacts Prediction on different stages and their Mitigation Strategy

The proposed Sumya Northern Industrial Zone Project will involve the design / siting, construction and operation phase impacts associated with the proposed activities. The environmental and social aspects of the project as identified by situation analysis which are based on the following:

i. Physical environment, particularly siting of the project ii. Biological environment, and iii. Socio-economic environment

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The following section provides a summary of issues associated with the proposed project that occur during the siting/design, construction and operations phases, along with recommendations for their management of issues.

Environmental issues associated with the siting/design, construction and operations phases of the proposed project, primarily including the following:

 Topography and Geology  Seismicity, vulnerability to seismic shocks  Present land use  Sediments migration  Vulnerability of site to flooding and storm water drainage  Operation of vehicular traffic  Noise and other forms of nuisance during construction at site  Air pollution due to fugitive dust emission and operation of equipment during construction  Use of Utilities including water, gas and electricity  Wastewater generation and Solid Waste during construction and operation  Ecological impact due to planning, construction and operation phase  Social Impacts  Employment  Security issues  Water issues

6.1. Methodology for Impact Assessment Potential environmental impacts of the proposed Sumya Northern Industrial Zone project on different features of micro and macro-environment are assessed pertain to siting/design, construction and operation of the project.

A systematic strategy was developed to provide an assessment of the likely impacts on the micro and macro-environment of the Project area. The strategy included:

 Review of General Guidelines;  Identification of potential environmental impacts by conducting survey, public consultation and using checklists;  Assessment of the intensity and significance of potential impacts by obtaining expert opinion and carrying out environment analysis;  Defining mitigation measures to reduce impacts to as low as practicable;  Predicting any residual impacts, including all long-term and short-term, direct and indirect, and beneficial and adverse impacts;  Monitoring of residual impacts.

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Guidelines and checklists were used for the verification of permissible levels of environmental parameters during project construction and operation and classification of the site with respect to airshed, water shed, geology, soil, ecology including fauna, flora, religious and archaeological sites, neighboring communities.

6.1.1. Environmental & Social screening checklist The rapid assessment checklist is used here and divided in two parts to screen the project i.e. A) screening of environmental impacts; and B) screening of social impacts.

Table 6.1: Checklist for Screening Environmental Impacts Impact Yes No Remarks Project Location Is the project area in or close to: - Densely populated area  No - Cultural heritage site  No - Protected area  No - Wetland  No - Mangrove  No - Estuarine  No - Buffer zone of protected area  No - Special area for protection of biodiversity  No Heavy development activities in progress?  Not Envisaged Environmental Impacts Will project require temporary or permanent  No support facilities? Will project cause any loss of precious ecology,  Not envisaged. Only wild shrubs and ecological and economic functions due to Xerophytic vegetation are present at the construction of infrastructure? site due to lack of surface water resources and less rainfall. Are ecosystems related to project fragile or  Not envisaged. degraded? Will project cause impairment of ecological  Not envisaged. opportunities? Will project cause increase in peak and flood  Not envisaged. flows? (including from temporary or permanent waste waters) Will project cause air, soil or water pollution?  Environmental Management Plan will be followed. Will project cause soil and water siltation?  Not envisaged. Will project cause increased waste production?  Yes. Waste Management Plan will be followed. Will project cause Hazardous Waste  Yes, because it is Industrial zone project. production? Will project cause threat to local ecosystem due  Not envisaged. to invasive species? Will project cause Greenhouse Gas Emission?  Yes, sustainable technology will be followed. Will project cause use of pesticides?  Yes Does the project encourage the use of  Yes environmentally friendly technologies?

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Other environmental issues, e.g. noise and  Traffic volumes along M10 may be traffic increased in operation phase of project. However, negative impact will be minimal as the traffic is already very thin along M10. Will the project cause impact on Lakes  Not envisaged. Canals  Not envisaged. Reserved Forests  Not envisaged. Ground water  Yes to some extent. As the water abstraction from ground water is needed for the project. However use of treated sanitary water for the horticulture purposes will replenish the water table. Wildlife Sanctuaries  Not envisaged. River  Not envisaged. Cattle Farming  Not envisaged due to lack of vegetation and agriculture. Villages  Few settlements are present in the microenvironment. Livestock Grazing  Not envisaged due to lack of vegetation and agriculture. Social Impacts Will the project cause social problems and  Not envisaged. The area is already conflicts related to land tenure and access to deprived of resources. However, the resources? project will provide basic necessities by which locals can be benefitted. Does the project incorporate measures to allow  Yes. affected stakeholders information and consultation? Will the project cause change to beneficial uses  Not envisaged. The current land use is of land and resources? of no use. Will the project cause technology or land use  Yes but it will benefit the local modification that may change present social and communities. economic activities? Will the project cause dislocation or involuntary  No. resettlement of people? Will the project cause increased local or regional  No. unemployment? Does the project include measures to avoid  Yes. Forced or child labour will be forced labour and/or child labour? prohibited. Does the project include measures to ensure a  Yes. EMP will be followed in letter and safe and healthy working environment for spirit. workers employed as part of the project? Will the project cause disproportionate impact to  Not envisaged. women or other disadvantaged or vulnerable groups? Will the project components generate or  Not envisaged. contribute to cumulative or long-term environmental or social impacts? Is it possible to isolate the impact from this  Yes project to monitor E&S impact?

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6.2. Screening of Potential Impacts at Siting / Planning & Designing (Pre-Construction) Phase There are few environmental aspects which will be taken into account in the designing and siting phase of the Project so that these may not impact the environment in both construction and operational phase. These impacts are as follows:

6.2.1. Structural Stability The seismic zone map of Pakistan has divided the country into 4 seismic zones ranging in term of major, moderate, minor and negligible zones with respect to ground acceleration values. Under this zoning the proposed project site lies in the moderate to high hazard zone with minor to moderate damaging impact.

The recently developed guidelines for earthquake design of buildings in Karachi have assigned an expected Peak Ground Acceleration (PGA) value of 0.20.

The project area lies into the Uniform Building Code (UBC) Zone 2B. The intensity which is estimated in accordance with the Modified Mercallis Scale (MM) will be VIII and higher.

Figure 6.2: Pakistan’s Peak Ground Acceleration (g) Source PMD

Mitigation Measures

 During the construction, it will be important to maintain the stability of excavated area.  During monsoons it will be essential to protect the excavation walls with shoring/bracing.

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Environmental Impact Assessment (EIA) Study Sumya Northern Industrial Zone

6.2.2. Threat to Biodiversity The site visit of the Sumya Northern Industrial Zone project area by the EMC team has revealed that there are significant fauna of biological importance present within the project area. And they will be threatening during the construction and operational phase of the project.

There is no Wildlife Reserve in close proximity of Project site. Low frequency of visits of a small number of mammals, birds, and reptiles leads to the conclusion that biodiversity of the area has been substantially reduced. Indian Monitor lizard (Varanus bengalensis) Wadhi Go/Gioh (reported but not spotted), and Monitor lizard (Varanus griseus) were neither reported nor spotted during the surveys for this study. The spiny-tailed lizard (Uromastix hardwickii) Sandha is in abundance. All sand mounds in the area have burrows of the sandhas. With extensive wood cutting the mounds are also getting flattened and despite their being protected by the locals they are getting endangered.

Mitigation Measures

 The footprint of construction materials to be limited to areas of low value for fauna.  All existing and retained fauna habitat to continue to be under favorable management.  Mitigate impacts that cannot be avoided, i.e. reduce the level of impacts by making changes to the development plans or implementing special measures.  Compensate for any residual impacts by taking positive measures, such as creating new reptile habitat.

6.2.3. Archaeological / Cultural / Protected Areas No protected and gazetted heritage site protected under Antiquities Act was noted in the vicinity or the microenvironment of the proposed project. There is also no evidence of any ancient civilization, no negative effects would likely to be imparted during construction.

Mitigation Measures

If any archaeological site discovered during the construction stage of the project implementation, the contractor is constrained to:

 Put a halt on working activities;  Label the particular vicinity  Inform the department of concern

6.2.4. Land Acquisition Land for the proposed project is acquired by the proponent so that there is no issue pertaining to land acquisition. Approval of the plan has been sought from the relevant authority.

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6.3. Screening of Potential Environmental Impacts at Construction Phase and their Mitigation Measures The activities that take place during the construction phase of Project with their potential primary and secondary impacts on the environment due to these activities and their mitigation measures are discussed as under:

6.3.1. Erosion of Soil Generally, the exposed soil after site clearance, road development, excavation for foundations is vulnerable to erosions and runoff by rains. Such a situation will be of temporary nature and short duration and lasts during construction phase.

Mitigation Measures

The proposed mitigation measures are:

 The establishment of a permanent vegetative cover over exposed soil areas such as islands of the roads will stabilize the soil, slow the movement of storm water runoff, and increase infiltration to help protect nearby water bodies, streams or other environmentally sensitive areas.  Intensification in fugitive dust emission caused by erosion of soil will be mitigated by appropriate measures to reduce the level of impact to minor significance.  Sediment barriers such as silt fencing can be utilized at construction sites to help prevent sediment from washing offsite, from washing into environmentally sensitive areas.  Control of air emissions during construction will be done and the contractors are mandated to adopt the following measures:  Exposed surface will be regularly wetted to effectively keep airborne dust levels to minimum.  Stockpiles of fine material will be wetted or covered with tarpaulin especially during windy weather conditions.  A pad of clean crushed stone, located at points where construction traffic will be accessing a site, will help to reduce the tracking or flowing of sediment onto roadways or other paved surfaces. This will help to prevent sediment from being transported offsite and from being deposited into nearby drainage systems, or water bodies. Other Mitigation Measures

Erosion will be reduced or prevented by adopting the following measures:

 The project will be scheduled to avoid heavy rainfall periods (i.e., during the dry season) to the extent practical.  Off-site sediment transport will be reduced or prevented by the use of settlement ponds, silt fences, water treatment, as well as modifying or suspending activities during extreme rainfall and high winds to the extent practical.

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 The environmental impact of soil erosion can best be mitigated by removing vegetative cover only from the specific site on which construction is to take place and by disturbing the vegetation in adjacent areas as little as possible.  Construction activities that result in the soil being laid bare could be scheduled in such a way that some type of vegetative cover appropriate to the site could be established prior to the onset of intense rain or windstorms.  If grass is to be seeded, mulch of straw will help to protect the soil from less extreme erosive forces until vegetative and root development begins.  Exposed surface was regularly wetted to effectively keep airborne dust levels to minimum.  The excavated soil will be contained in an enclosure to reduce the chances of runoff during the seasons of precipitation.  During the windy weather situation, the stockpiles of fine materials will be covered with tarpaulin.  Site workers were mandated to wear dust masks especially during dry and windy weather conditions.

6.3.2. Soil Contamination During the construction stage, the contamination of land occurs due to unchecked chemicals or fuel spillage through their improper handling, transportation and storage.

The sources of spills are:

 During refueling, the transfer of fuel from one container to the other;  By the maintenance of vehicle and machinery;  Leakage from the container or equipment’s;  Traffic Accident; Mitigation Measures

Actions necessary to manage the risk from contaminated land will depend on factors such as the level and location of contamination, the type and risks of the contaminated media, and the intended land use. However, a basic management strategy will include:

 Fuel oils, lubricants, and chemicals will be stored in covered areas, underlain with impervious lining.  Vehicles and equipment’s maintenance will be taken place at specified site.  Washing of vehicles will be carried out in the designated areas.  Construction vehicles and machinery will be examined on a regular basis for leakage prevention.  Removal of oil and contaminated soil around the fuel and oil storage areas will be made possible by the availability of appropriate implements i.e. shovels, plastic bags and absorbent materials.

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 Contaminated media will be managed with the objective of protecting the safety and health of labors at the site, the surrounding residents, and the environment.  Transport chemicals and wastes or any other material which are capable of contaminating the soil in covered vehicles.

6.3.3. Construction Waste Typical construction waste generated during construction activity includes waste concrete, excavated soil, steel and wooden scaffoldings, cement bags, wood remains etc. This waste has the potential to cause negative impact on the surroundings if not properly managed and disposed to approved dumpsites. It could block nearby drainage channels that could ultimately cause localized flooding, particularly during the monsoon season. Irregular storage of this waste may have posed hazards to the workers at site and residents in the neighborhood. Poor waste management practices may have constituted short term as well as long term negative impact.

Mitigation Measures

The following measures will be adopted to manage the disposal of construction waste:

 Unusable wastes will be transported to the approved landfill sites.  An approved person will be nominated to be responsible for good site practice. Their responsibilities should include arranging collection and effective disposal to an appropriate facility (including efficient recording to transfer notes) of all waste generated at the site.  A system of recording and monitoring the amount of waste generated, recycled and disposed of (including the disposal site location) will be established.  Site practices will be in place to minimize the potential for damage or contamination of construction materials (for example designated areas for storage).  Excavated soil will be disposed of through the regular channel of the site contractor.  Prefabricated panels will be used in construction, where feasible, in order to reduce waste generation on site and associated transportation impacts.  Proper solid waste containers of adequate capacity are provided to cater to daily waste generation.  On-site concrete crushing and screening of materials will be used to generate secondary aggregate for the development. This material can be used in various elements of the construction including as a sub-base for minor roads and pathways. Other Mitigation Measures

Some other mitigation measures laid down as under will help to mitigate the impacts posed due to the constructional phase of the proposed project:

 A comprehensive waste disposal plan to be developed to effectively manage these waste in large quantities.

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 The construction waste which will be sent for recycling like damage pipes left over steel, wooden and plastic pieces. While, the rest of the left over waste will then be taken away to the dumping sites for disposal.  The construction material will be kept in a cover place, especially during the precipitation season.  The excavated soil will be re-used by adopting different methods, which will be used as a filling material for low lying areas or excavated areas.  Separate bins will be placed for different type of wastes - plastic, paper, metal, glass, wood, and cotton.  Recyclable material will be separated at source. The recyclable waste will be sold to waste contractors for recycling.  Non-hazardous non-recyclable wastes such as construction camp kitchen wastes will be disposed of in landfill site through municipal administration or approved waste manager/contractor.  Various waste containers for different types of waste will be deployed, in order to treat the waste in accordance with its nature.  The waste bins will be properly marked for each type of waste produced during the constructional activities.  The project area will contain the sewage and litter facility to overcome the problem of unchecked dumping of waste.  Use of building materials that have minimal packaging to avoid the generation of excessive packaging waste.  Use of durable, long-lasting materials that will not need to be replaced as often, thereby reducing the amount of construction waste generated over time.  All hazardous waste will be separated from other wastes. Hazardous wastes will be stored in designated areas with restricted access and proper marking. Hazardous wastes will be disposed of through approved waste manager/contractor.  Surplus construction materials including partially filled chemical and paint containers will be returned to suppliers. Inert construction wastes will be disposed of onsite as fill material or sold as scrap to contractors.  Records of all waste generated during the construction period will be maintained. Quantities of waste disposed, recycled, or reused will be logged on a Waste Tracking Register.  Training will be provided to personnel for identification, segregation, and management of waste.  The waste management plan developed for construction phase shall be followed in letter and spirit.

6.3.4. Ambient Air Quality The major source of air pollution during the construction phase will be dust emission due to earth works and gaseous emissions from construction equipment. The major source of air pollution during the operation phase when the Project is functional will be the pollutant emissions from the stand-by

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Environmental Impact Assessment (EIA) Study Sumya Northern Industrial Zone generator in case of power breakdown. Impacts from each source and proposed mitigation measures are as follows:

Dust Emissions: Dust emission from construction site is a concern particularly if the site is near villages or other inhabitants. The main health hazards are the particles smaller than 10 microns

(designated as PM10) as they are respirable. In cases where they reach the receptors, the dust is considered a nuisance as it may spoil property and affect visibility. Particulate matter emitted during construction activities may result in deterioration of ambient air quality in the vicinity of the source, and is usually a nuisance to the neighborhood besides the construction workers. The impact on the environment would be considered significant if there is an increase in suspended particulate matter within and beyond the boundaries of the project site due to activities at the site, or if the dust affects local property or results in complaints from the community. Potential sources of particulate matter emission during construction activities include earthworks (dirt or debris pushing and grading), exposed surfaces, exposed storage piles, truck dumping, hauling, vehicle movement on unpaved roads, and concrete mixing and batching. The quantity of dust that is generated on a particular day depends on the magnitude and nature of activity and the atmospheric conditions prevailing on the day.

Mitigation Measures

The following mitigation measures will be adopted during the earthwork and construction phase:

 Water will be sprinkled daily or when there is an obvious dust problem on all exposed surfaces to suppress emission of dust.  Dust emission from soil piles and aggregate storage stockpiles will be reduced by appropriate measures. These include:  Keeping the material moist by sprinkling of water at appropriate frequency  Erecting windshield walls on three sides of the piles such that the wall project 0.5 m above the pile, and covering the pile, for example with tarpaulin or thick plastic sheets, to prevent emissions.  Construction materials that are fragile and vulnerable to raising visible dust will be transported only in securely covered trucks to prevent dust emission during transportation.  The exposure of construction workers to dust will be minimized by provision of dust masks.  Cover storage piles at concrete batch plants if they are a source of fugitive dust.  Keep soil loads below the freeboard of the truck to minimize fugitive dust.  Minimize drop heights when loaders dump soil into trucks.  Cover dump trucks before traveling on public roads.  When possible, schedule construction activities during periods of low winds to reduce fugitive dust. Vehicle and Equipment Exhaust: Combustion exhaust from vehicles and construction equipment can affect the ambient air quality of the site surroundings. The impact would be potentially significant when the ambient air quality deteriorates due to emissions from construction equipment and

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Environmental Impact Assessment (EIA) Study Sumya Northern Industrial Zone machinery or the construction generators etc. beyond the guidelines especially at the environmental receptors in the neighborhood. The exhaust emissions will include particulate matter (PM), hydrocarbons, Oxides of Nitrogen, Sulphur, and Carbon (NOx, SO2, CO).

Mitigation Measures

The emissions from operation of construction equipment and machinery as well as generators is not expected to have been significant as to affect the ambient air quality of the area. The small amount of exhaust emissions from the operation of generators and equipment are expected to have dispersed with the prevailing wind and may not have had any significant impact on the local air quality. Adoption of following mitigation measures will result in further reduction / prevention of these emissions.

Mitigation Measures

 All vehicles, generators and other equipment used during the construction will be properly tuned and maintained in good working condition in order to minimize emission of pollutants.  The stack height of the generators will be vented through vertical stacks to minimize exposure at ground level.

6.3.5. Impact on Ambient Noise Levels In general, human sound perception is such that a change in sound level of 3 dB is clearly noticeable, and a change of 10 dB is perceived as a doubling or halving of sound level.

Impacts on noise levels during construction of the proposed project would include noise and vibration from the operation of construction equipment. The severity of impacts from these noise sources would depend on the noise characteristics of the equipment and activities involved, the construction schedule, and the distance to potentially sensitive noise receptors. Noise and vibration levels at a given location are dependent on the kind and number of pieces of construction equipment are being operated, as well as the distance from the construction site. Noise caused by the construction activities would vary widely, depending on the phase of construction – land clearing and excavations, foundations and capping, erection of structural steel, construction of exterior walls, etc. and the specific task being undertaken.

Baseline noise measurements were obtained through continuous monitoring for a 24 hour period at the project site. It was found from the noise monitoring that the typical average noise level in the project area was 50-54 dB (A) and 64-66 dB (A) near the vicinity. The Sindh Environmental Quality Standards for noise require that the sound level in commercial areas should not exceed 55 dB and 65 dB respectively during day time and 45 dB and 55 dB respectively during the night time.

During the construction phase the noise is likely to be generated by the following activities:

 Operation of pile drivers  Earth moving and excavation equipment  Concrete mixers

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 Transportation of equipment’s  Use of diesel generators  Increase in transport noise from within the site from the nearby roads Construction noise associated with the proposed action is expected to be similar to noise generated by other construction projects in the city. Increased noise levels caused by construction activities can be expected to be most significant during the early phases of construction. The most significant noise sources associated with the construction equipment would be the use of pile – drivers as well as concrete batching plants. This noise would be intrusive and would be heard by the villagers living in the nearby surrounding area of the project site; however, this construction noise would be temporary in nature. Increase in noise levels caused by delivery trucks and other construction vehicles would not be significant. Small increases in noise levels are expected to be found near defined truck routes and the streets in the immediate vicinity of the project site.

Mitigation Measures

The following measures are adopted in order to keep the noise within the limits as prescribed by the EPA:

 The activities associated with greatest potential to generate noise will be planned during the day period that will result in least disturbance to the nearby residents at night.  Noise control devices will be used such as temporary noise barriers and deflectors for impact activities.  Noise and vibration will be minimized in the projects site and surrounding areas through sensitization of the truck drivers to switch off vehicle engines while offloading material.  Truck drivers will be instructed to avoid gunning of vehicle engines or hooting especially when passing through sensitive areas such as mosques, schools and hospitals.  Construction machinery will be kept in good condition to reduce noise generation.  All generators and heavy-duty equipment’s will be installed and placed in enclosures to minimize ambient noise levels. Table 6.2: Construction Equipment Noise Range dB (Average) Equipment Peak Noise Typical Peak Typical ‘ Quieted Equivalent Noise Level in Range at Sound level in a Equipment’ an 8-hr Shift at Receptor 15.2 m Work Cycle Sound Level 150m from Source. Batching plant 82-86 84 81 62.9 Concrete mixers 76-86 85 82 63.9 Cranes 70-94 83 80 54.5 Excavators 74-92 85 82 59.5 Tractors and 77-94 88 85 62.1 trolleys Graders 72-92 85 82 59.5 Bulldozers 65-95 80 75 54.5 Paver 87-89 88 80 62.5 Pumps 68-72 76 75 54.9 Diesel generators 72-82 78 75 58.1 Vibrators 68-82 76 75 50.5 Drilling Machines 82-98 90 87 61.5

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Compressors 74-84 81 71 58.1 Dumpers 77-96 88 83 59.5 Road Rollers 73-77 75 72 49.5

6.3.6. Water Consumption Water will be required during the construction activity for human consumption at the construction stage of the Sumya Northern Industrial Zone project as well as for the construction activities including sprinkling of water for dust suppression. Potable water will be provided for drinking for the construction workers and regular testing of the water will be conducted. There is scarcity of water in that region and the ground water in that area is not suitable for drinking, therefore, water tankers will be used during construction phase.

Mitigation Measures:

Adherence to the following measures will ensure efficient use of water during the subsequent stage of construction:

 A complete record of water consumption during the construction phase will be maintained.  Water conservation practices will be adopted to prevent wastage of water.  The water supply lines will be checked and repaired for leaks, if any, in order to reduce wastage of water.

Water Consumption

Foundation, 1.69 Other, 17.49 Structure, 12.89 Masonry, 0.24 Coating, 2

Waterproofing Tests, 7.79

Human Use, 57.9

Figure 6.3: Hypothetical Study of Water Consumption on Construction Site

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Environmental Impact Assessment (EIA) Study Sumya Northern Industrial Zone

6.3.7. Impacts of Wastewater Generation During the construction phase, the wastewater generated from the run-off from the project site during the season of precipitation, washing and leakage of fuel from the construction vehicles etc. Construction activities of the project may include the generation of sanitary wastewater discharges in varying quantities depending on the number of workers involved.

The source of wastewater includes toilets, washrooms, laundry and kitchen. The wastewater would be routed to the existing municipal drain/sewerage system. This wastewater would comply with the SEQS values provided that other hazardous wastes (i.e. paints etc.) are not mixed with it. The impact of disposal of such wastewater would not be significant since it is expected to comply with the Sindh Environmental Quality Standards (SEQS) for municipal effluent.

Mitigation Measures

The following are the recommendations to reduce and control the wastewater generated during the constructional activities:

 Washing of vehicles and construction machinery will be restricted to a designated area.  Wastewater will not be disposed of directly into the water bodies, but will be routed to septic tanks and soak pits.  Development of wastewater treatment facility i.e. septic tank, at the site of the proposed project area.  Wastewater generation will be minimized by controlling the pollutant at the source.  The oily waste will be contained before disposing the wastewater into septic tanks.  Regular monitoring of the wastewater generation will be taken into consideration.  Adequate portable or permanent sanitation facilities serving all workers will be provided at all construction sites.  Sewage will not be mixed with any other waste.

6.3.8. Operation of Vehicular Traffic Learning from experience of the past construction projects, it is envisaged that there would be substantial increase in the traffic volume during the construction and completion of Sumya Northern Industrial Zone Project. Vehicular traffic management will have to be undertaken seriously to restrain unnecessary traffic jams that may cause annoyance to the commuters at Manghopir and Gadap Town. Additional traffic generated by operation of industrial zone on completion of the project will induce significant impact if the traffic volume is sufficient to cause congestion and becomes a hassle for the existing road users.

Appropriate space has been allocated along with each industrial unit to cater for the parking requirements of the vehicles. Moreover, induction of traffic management plan will result in the smooth flow of traffic during the rush hours.

Mitigation Measures

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The following mitigation measures are being adopted to remove the constraints to smooth flow of traffic:

 Heavy traffic during construction phase will come to the project site during late night hours.  Project vehicles shall not be fitted with pressure horns.  Speed of vehicles will be regulated during construction phase.  Designated parking areas will be provided for different type of project vehicles within and around the project site.  Traffic management plan will be introduced to manage smooth flow of vehicular traffic and to avoid traffic jam.  Traffic management plan will be implemented and monitored.  Vehicles will be parked at designated parking areas during operational phase.  Parking of vehicles alongside the road would be prohibited at all time.

6.3.9. Materials Selection General specification/details have been worked out in respect of type of structures, concrete, and all other materials required for the Construction of the Project. The following measures will be adopted to ensure sustainable development of the Project:

Mitigation Measures

 The structures and materials will, in the subsequent construction stage, conform to recommended standards and follow standard practice of civil works.  Materials including paving stones, crush, gravel and sand will be brought from commercial quarries located in Sindh province. Environmentally sound materials and goods will be selected, with priority being accorded to products meeting national and international standards.  Traditionally well-tried materials and components will be selected and selection of construction materials would be based on sustainable source.  Construction site will be adequately isolated to prevent entry of public specially the children from the nearby villages and general safety measures will be evocatively imposed throughout the construction period.  Temporary inconveniences due to construction works will be minimized through planning and coordination with relevant authority.  The production, use and disposal of building materials during the construction stage of Project will utilize considerable amount of energy and resources; all attempts will be made towards efficient consumption and minimization of wastage of water, energy and materials.  Best practice of energy efficiency will be adopted in the building design. The Project building would be constructed with high level of thermal insulation.  Large open spaces have been provided between the Industrial units for natural lighting and cross ventilation.

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 The environmental impacts arising from selection of building materials and components would take account of the environmental issues during the materials selection process, and introduce Recycling strategies such as Reuse and Reduction of Wastewater.  The design of concrete building structure with use of low energy glass on windows and doors to reduce carbon footprint.

6.3.10. Occupational Health and Safety Site-specific occupational health and safety hazards are also critical to identify based on job safety analysis or comprehensive hazard or risk assessment. Health and safety management planning should include the adoption of a systematic and structured approach for prevention and control of physical, chemical, and biological health and safety hazards. Contractor shall ensure that Job Hazard Analysis (JHA) is performed prior to commencing jobs. It shall also be ensured that the JHA is reviewed after the following,

 Whenever work is stopped  Every time work conditions or the job scope changes  Persons working or visiting the job shall review and acknowledge the JHA by their signature

6.3.10.1. Crane and Lifting Operations For all Crane & Lifting Operations Contractor shall ensure full compliance with standard operating procedures. Contractor shall develop a site-specific pre-lift checklist which includes the following at minimum:

 Crane rigging capacity adequately for load  Condition of slings  Rigging condition adequate for load  Area of swing or travel unobstructed  Multiple crane use  Power line approach distance maintained  Stability and footing  Taglines and spotters  Illumination and weather  Signal operator  Job hazard analysis and other permits All lifting and rigging activities shall be supervised and conducted by a competent person or team, Contractor shall maintain a lifting gear registry for all lifting gear on-site inclusive of a listing of all lifting gear, copies of equipment certificates (manufacturer, safe working load, serial number) and the inspection/recertification frequency. Every person who supplies machine for such use must be in good condition, the machine, device, tool or equipment complies with OSHA and related regulations. Regular inspection should be carried out of the equipment to make sure its safe use.

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6.3.10.2. Forklifts and Non-Road Vehicles Maintaining lifting equipment in good condition to prevent mechanical or operational failures. Contractor should ensure forklift and non-road vehicles are fit for purpose and operated according to manufacturer’s requirements. Only competent operators are permitted to operate forklifts and non- road vehicles. They shall be examined to determine their load capacity.

At minimum, all forklifts and non-road vehicles shall be equipped with following equipment:

 Seat belts  Horn  Emergency Brake  Wheel chock  Labelled Controls  Fire Extinguishers  First Aid Kit  Back-up Alarm Annual inspection shall be completed by a qualified third party, records of which shall be readily available at site

6.3.10.3. Hazardous Substance Handling and Storage Contractor should ensure that chemicals are handled and stored in accordance with the manufacturer recommendations found in the MSDS. Chemicals should be stored in a manner which will minimize releases to soil, groundwater or the atmosphere.

Containers and tanks which are used to store hazardous substances shall be,

 In good conditions  Compatible with the material stored inside  Closed when material is not being transferred into or withdrawn from them  Flammable or combustible liquids shall not be stored in areas used for exits, stairways, or normally used for safe passages. Electrical pumps shall not be used to transfer flammable or combustible liquids. Toxic chemicals shall be stored and handled as defined in the chemical MSDS. Explosive products should be handled and stored according to applicable regulations. Explosive storage shall be located away from corrosives, flammable, oxidizers, or acids.

6.3.10.4. Scaffolding Contractor is responsible to establish periodic inspection, certification and recertification program for scaffold works. Only qualified worker is authorized to erect, inspect and certify scaffold. All scaffolds should have a guardrail system on each open side, up to the access point. It should be equipped with toe boards having suitable access ladder. Workers on scaffolding should use a fall arrest system. Scaffoldings should be properly designed by an engineer before being installed.

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6.3.10.5. Over-exertion Over-exertion, and ergonomic injuries and illnesses, such as repetitive motion, over-exertion, and manual handling, are among the most common causes of injuries at construction site.

Mitigation Measures

Recommendations for their prevention and control include:

 Workers will be trained with lifting and materials handling techniques before the construction of the project, including the placement of weight limits above which mechanical assists or two-person lifts are necessary.  Work site layout will be planned to minimize the need for manual transfer of heavy loads.  Tools will be selected and work stations would be designed to reduce force requirements and holding times, which promote improved postures, including, where applicable, user adjustable work stations.  Administrative controls, such as job rotations and rest or stretch breaks will be implemented into the work processes.

6.3.10.6. Slips and Falls  Slips and falls on the same elevation associated with poor housekeeping, such as excessive waste debris, loose construction materials, liquid spills, and uncontrolled use of electrical cords and ropes on the ground, are also among the most frequent cause of lost time accidents at construction site. Mitigation Measures

Recommended methods for the prevention of slips and falls from, or on, the same elevation include:

 Good house-keeping practices, such as the sorting and placing loose construction materials in established areas away from foot paths, would be implemented.  Excessive waste debris and liquid spills will be cleaned up regularly.  Electrical cords and ropes will be located in common areas and marked corridors.  Slip retardant footwear will be used.

6.3.10.7. Work at Heights Falls from elevation associated with working with ladders and scaffolding are among the most common cause of fatal or permanent disabling injury at construction site. If fall hazards exist, a fall protection plan will be in place which includes one or more of the following aspects, depending on the nature of the fall hazard.

Mitigation Measures

 Training and use of temporary fall prevention devices, such as rails or other barriers able to support a weight of 200 pounds, when working at heights equal or greater than two meters or at any height if the risk includes falling into operating machinery, into water or other liquid, into hazardous substances, or through an opening in a work surface.

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 Training and use of personal fall arrest systems, such as full body harnesses and energy absorbing lanyards as well as fall rescue procedures to deal with workers whose fall has been successfully arrested.  Use of control zones and safety monitoring systems to warn workers of their proximity to fall hazard zones, as well as securing, marking, and labelling covers for openings in floors, roofs, or walking surfaces.

6.3.10.8. Struck By Objects Construction activities of the project may pose significant hazards related to the potential fall of materials or tools, as well as ejection of solid particles from abrasive or other types of power tools which can result in injury to the head, eyes, and extremities.

Mitigation Measures

Techniques for the prevention and control of these hazards include:

 Maintaining clear traffic ways to avoid driving of heavy equipment over loose scrap.  Temporary fall protection measures in scaffolds and out edges of elevated work surfaces would be used, such as hand rails and toe boards to prevent materials from being dislodged.  Appropriate PPE such as safety glasses with side shields, face shields, hard hats, and safety shoes, would be wore.

6.3.10.9. Moving Machinery Vehicle traffic and use of lifting equipment in the movement of machinery and materials on a construction site may pose temporary hazards, such as physical contact, spills, dust, emissions, and noise.

Heavy equipment operators have limited fields of view close to their equipment and may not see pedestrians close to the vehicle. Center-articulated vehicles create a significant impact or crush hazard zone on the outboard side of a turn while moving.

Mitigation Measures

Techniques for the prevention and control of these impacts include:

 The location of vehicle traffic, machine operation, walking areas, and controlling vehicle traffic will be planned and segregated through the use of one-way traffic routes, establishment of speed limits, and on-site trained flag-people wearing high-visibility vests or outer clothing covering to direct traffic.  The visibility of personnel will be ensured through the use of high visibility vests when working in or walking through heavy equipment operating areas as well as training of workers to verify eye contact with equipment operators before approaching the operating vehicle.  Inspected and well-maintained lifting devices will be used that are appropriate for the load, such as cranes, and securing loads when lifting them to higher job-site elevations.

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6.3.10.10. Other Site Hazards Construction of site may pose a risk of exposure to dust, chemicals, hazardous or flammable materials, and wastes in a combination of liquid, solid, or gaseous forms.

Mitigation Measures

It can be prevented through the implementation of project specific plans and other applicable management practices, including:

 Use of waste-specific PPE based on the results of an occupational health and safety assessment, including respirators, clothing/protective suits, gloves and eye protection.

6.3.11. Energy Use Electricity during construction phase will he produced from diesel generators. A back up diesel operated generator will also be installed in case of emergency or suspension of power supply from the mains. The power produced will be significant in terms of costs both environmental and economic. Since energy produced from non-renewable resource results in CO2, SO2, and NOx emissions, it is important to ensure that energy is used prudently and best management practices are adopted.

6.3.12. Community Health and Safety

6.3.12.1. General Site Hazards Projects should implement risk management strategies to protect the community from physical, chemical, or other hazards associated with sites under construction.

Risks may arise from inadvertent or intentional trespassing, including potential contact with hazardous materials, contaminated soils and other environmental media, buildings that are under construction or excavations and structures which may pose falling and entrapment hazards.

Mitigation Measures

Risk management strategies may include:

 Access to the site will be restricted through a combination of institutional and administrative controls.  Removing hazardous conditions on construction sites that cannot be controlled affectively with site access restrictions, such as covering openings to small confined spaces, ensuring means of escape for larger openings such as trenches or excavations, or locked storage of hazardous materials.

6.3.12.2. Disease Prevention Increased incidence of communicable and vector-borne diseases attributable to construction activities represents a potentially serious health threat to project personnel and residents of local communities.

Mitigation Measures

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 The mobility of the community living in the area will be restricted from the project site in order to prevent from catching any type of communicable diseases.  Any labors found to catch any type of disease will leave the site immediately; and would be given proper medical facilities.  Water after rain or after sprinkling will not be left stagnant to attract mosquitoes and will be removed or drained properly.  Waste management plan will be followed during construction to avoid attraction of vector towards waste material.

6.3.12.3. Traffic Safety Construction activities may result in a significant increase in movement of heavy vehicles for the transport of construction materials and equipment increasing the risk of traffic-related accidents and injuries to workers and local communities.

Mitigation Measures

 The incidence of road accidents involving project vehicles during construction will be minimized through a combination of education and awareness-raising, provision or specified routes, installation of safety signage and the adoption of procedures.

6.4. Impact Associated with the Operations of Project The most focusable area in the impact study is operation of the project as the impacts may arise have long term and continues effects. Probable impacts have been evaluated in this EIA study; however, detailed impact assessment will be done in the EIA stage. Those impacts are given below one-by-one along with their appropriate mitigation measures:

6.4.1. Soil Contamination During the Handling of chemicals and dyes there are chances of leaks, spills, and accidental mixing of chemicals and dyes. The potential for accidental spills and leaks is highest at the point of transfer of chemicals and dyes from bulk drum storage to process equipment.

Mitigation Measures

 Material should never be poured directly from drums to small containers.  Secondary containment should be provided in order to prevent the soil contamination.  Spigots or pumps should always be used to transfer waste materials to storage containers  Do not handle chemicals and dyes with bare hands, no matter how harmless they may be.  After handling chemicals, hands should be washed prior to eating or drinking.  Chemicals and dyes that can produce fumes, dusts should always be handled in a well- ventilated area. Use of containment devices such as fume hoods, and gas cabinets is particularly advisable. A fume hood, glove box or other appropriate exhaust ventilation is necessary when handling particularly hazardous substances.

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 Use appropriate devices like funnels or spatulas when transferring chemicals from one container to another or when mixing chemicals.  Use corrosion-resistant tools and equipment

6.4.2. Groundwater Contamination Major aspects of groundwater deterioration are same as for soil contamination such as spills, leakages, improper handling, storage of finishing chemicals, etc. in power house. In case of accidental fire, water hydrant will be used that will cause huge quantity of wastewater and if that wastewater is not handled properly may penetrate in the soil and ultimately mix with groundwater and pollute this resource. Indirectly groundwater quality effects on human health. Use of contaminated groundwater may enter the food chain as a source of drinking water and irrigation by poor communities.

Mitigation Measures

 Segregation of the process wastewater from other wastewater.  Wastewater generated during firefighting will be handled through designated drains and treated accordingly.  Wastewater drains shall be covered at all time to avoid entrance of rainwater runoff during rainy season.  Drain lines are to be checked for leakages periodically.

6.4.3. Solid and Hazardous Waste: Generation and Disposal There is going to be an excessive amount of solid waste generation from the proposed Industrial project. The solid general waste generated from the industrial units is going to consist of plastic bottles, paper, glass, food waste and packing material other types of hazardous and nonhazardous waste will depend on nature of the industrial units in proposed industrial zone. Such waste if not properly managed (disposed of or recycled), will pose serious environmental hazard especially to the inhabitants and the visitors of the proposed project, soil and water environment and not to forget the ecological impacts especially to the fauna. Poor garbage management at the project site would lead to unsanitary living conditions including vermin and fly infestation and odors as well as unsightly conditions.

Waste generated during operation of the proposed project will include both hazardous and non- hazardous wastes. Wastes specific to the textiles industry include trials, selvedge, trimmings, cuttings of fabrics, and yarns; and sludge from process wastewater treatment (if any) containing mainly fibers and grease.

Other waste includes empty chemical drums and plastic packing materials, sludge from wastewater treatment plan, expire chemicals, spills, electrical and electronics waste, metals, woods etc.

Solid waste is also expected to generate from the packaging section i.e. plastic bags and cartoons as well as their remains. This type of waste is inert in nature.

Domestic waste during cleaning may include paper waste, cardboard, plastic, packaging etc. Some people will tend to throw the waste outside their facility if a proper waste collection system is not

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Environmental Impact Assessment (EIA) Study Sumya Northern Industrial Zone introduced. It is also anticipated that a proper waste contractor will be responsible for collection and disposal of waste from the site.

The quantity of solid waste that is to be managed can be segregated at the source into organic and recyclable components. Nearly half of the waste generated is expected to be of organic nature i.e. biodegradable and the remaining as recyclable. Therefore waste segregation can solve much of the solid waste management problem. The viable options after storing, collecting and transportation of segregated waste components for its ultimate safe disposal are composting and recycling, respectively which need to be carefully designed and managed appropriately.

Mitigation Measures

 A site-specific waste management plan will be developed and implemented at project site during operation phase  Ensure regular collection of garbage by waste disposal service.  Ensure waste is disposed of at the landfill site.  All solid waste shall be segregated into organic and recyclable waste at source and then collected, stored, and transported for ultimate safe disposal.  The solid waste management plan developed shall be followed and facilities for collection, storage and transportation will be established and organized.  Classification of Hazardous and non-Hazardous waste will be done  Hazardous and non-hazardous hospital waste shall be separately collected and disposed of by a SEPA approved waste management contractor authorized for dealing with such type of waste. A proper viable option after storing, collecting and transportation of segregated waste components for its ultimate waste disposal needs to be carefully designated and managed properly.

Other Mitigation Measures

The following mitigation measures would be adopted to combat from the impacts imposed upon the project site and immediate environs due to the solid waste generation activities in the operational phase:

 All solid waste shall be segregated into organic and recyclable waste at source and then collected, stored, and transported via to vendors or ultimate safe disposal while hazardous solid waste will be collected by EPA approved waste contractor.  Handling and disposal of such waste shall be managed by a dedicated waste management contractor.  The solid waste management plan will be developed and facilities for collection, storage and transportation will be established and organized.  Adequate waste collection bins will be supplied.  Appropriate waste signage will be used at appropriate places to increase awareness among residents/visitors.

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 Industrial units of the project will be provided different colored bins for different categories of waste.  Waste managing contractor should have binding to dispose the waste to official dumpsites of Karachi.

6.4.4. Water Consumption and Quality Assurance Water consumption in textile and automobile manufacturing has potentially significant environmental impacts, in terms of freshwater needs, wastewater/sludge production, and energy use in heating.

Mitigation Measures

Adherence to the following measures will ensure efficient use of water during the subsequent stage of operation:

 Reuse of dye baths  A complete record of water consumption during the operation phase will be maintained.  Water conservation practices will be adopted to prevent wastage of water.  Faucets allowed will be of low water consumption.  The water supply lines will be checked and repaired for leaks, if any is to be found, it will be repaired.  Use of water efficient sanitary fittings such as low flush toilets, water efficient shower heads, and aerators on faucets will be ensures throughout the project cycle. Other Recommended water management strategies for domestic water usage at the facility include:

 All water usage (lit/unit) at the scheme should be recorded.  All the main water inlets will be provided with water flow meters to record consumption of water.  Drinking water and service water sources should be clearly labeled.  The facility should put initiatives in place to reduce water usage.  Use signs and educational initiatives to reduce water wastage and consumption among users.  Install appropriate technological solutions to reduce water consumption. Some conservation measures that can be taken in apartments are to install low-flow shower heads and toilets, reduced water capacity washing machines at laundry and dishwashers at kitchen etc.  Reuse and recycle water as much as possible for example by using gray water for flushing toilet. Gray water is the term use for the used water that goes down our sinks and shower drains. Black water is another term for the water ‘and stuff’ that goes down from our toilets. The gray water from bathrooms sink can be reused it to flush the toilets thereby turning gray into black.  Sanitary wastewater includes that water generated from Industrial units and amenities including restrooms, kitchen, showers, toilets and others. This sanitary wastewater can also be divided into sewage/black (toilet) and gray water. The gray water comes from

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sinks and showers and this can be collected separately and treated on site if required and can be reused for gardening, floor washing and other purposes. Sewage (toilet water) is collected in the sewerage treatment plant and treated at site.  It is proposed by the EIA Consultant that a dedicated sewerage treatment plant shall be installed and the space shall be designated in the master plan of the project to overcome the sewage problem. This system effectively eliminates contaminants from the effluent and then releases the effluent water for non-potable uses such as horticulture purposes and daily water requirements for trees and road islands. It can also replenish the groundwater table.

6.4.5. Wastewater and its Disposal When the proposed Industrial zone becomes functional it will generate wastewater from manufacturing units such as textile and automobiles. Generally, the textile industry’s wastewater not only contains high levels of suspended and total solids such as fats and grease, dyestuff, dispersants and levelling agents, phosphate in washing products, and coloring, at various stages of manufacturing but also, a significant amount of dissolved organics, resulting in high BOD or COD loads. Moreover, soda ash, caustic soda, acetic acid, and other such acids and bases are used that can change the pH of the water. The automobile industry' s wastewater also not only contains high levels of suspended and total solids such as oil, grease, dyestuff, chromium, phosphate in washing products, and coloring, at various stages of manufacturing but also, a significant amount of dissolved organics, resulting in high BOD or COD loads .

Small quantities of hazardous waste will also be produced during the maintenance activities in the building (such as oily waste etc.). The cleaning waste generated by the use of surfactant and cleaning agents used during the operational phase of the Industrial units.

The wastewater generated can be a potential source of pollution to the surface and ground water resources of the area.

All type of wastewater generated (i.e. drainage of sewage, showers and kitchen effluent etc.) will be directed to the wastewater treatment plant prior to disposal into a nearby out fall sewer. This will ensure the specifications stipulated in SEQS will comply.

Mitigation Measures

Following measures will be adopted for effective management of wastewater during the operational phase of the project:

 Optimum use of water to avoid excessive wastewater generation through process controls, use of new technologies, water and wastewater metering, etc.  Grease interceptor and/ or oil skimmer to be installed on kitchen effluent to maintain oil levels within SEQS limits.  Waste segregation measures would be employed to minimize entry of solid waste into the wastewater stream.  Water conservation strategies will be employed to avoid wastage of water.  Periodic preventive maintenance of pumps, diffusers and other ancillary equipment’s.

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 Periodic monitoring of wastewater to ensure compliance with SEQS.

6.4.5.1. Wastewater Treatment Since textile and automobile manufacturing operations use a myriad of raw materials, chemicals and processes, wastewater treatment may require the use of unit operations specific to the manufacturing process in use. Techniques for treating industrial process wastewater in this sector include source segregation and pretreatment of wastewater streams as follows: (i) high load (COD) streams containing non-biodegradable compounds using chemical oxidation, (ii) reduction in heavy metals using chemical precipitation, coagulation and flocculation, etc. and (iii) treatment of highly colored or high TDS streams using reverse osmosis.

Typical wastewater treatment steps include:

 Primary Treatment Primary treatment mainly involves grease traps, skimmers or oil water separators for separation of floatable solids; filtration for separation of filterable solids; flow and load equalization; sedimentation for suspended solids reduction using clarifiers

 Secondary Treatment Biological treatment, typically aerobic treatment, for reduction of soluble organic matter (BOD); biological nutrient removal for reduction in nitrogen and phosphorus. The process reduces to a minimum the content of nitrogen and phosphorus in wastewater in addition to significantly reducing organic matter (BOD), ammonia and suspended solids.

 Tertiary and Specific Treatment Reverse osmosis for reuse of water, Chlorination of effluent when disinfection is required; dewatering and collection of residuals (sludge). Sludge should be separated from the wastewater and consider hazardous waste and disposed of environmentally friendly through approved waste contractor.

6.4.6. Fire Hazard Fire is one major hazard in industrial zone. Fire can cause loss of life and property. However at the same time fire have the potential to severely harm the people in the vicinity and affect the environment.

Mitigation Measures

Risks involved with fire hazard can be reduced by adopting following measures:

 A dedicated fire tender (brigade) will be available at the project site.  For all engineering designs, NFPA (National Fire Protection Association) codes needs to be followed.  Standard fire and smoke detection and protection devices such as alarms, fire hoses and hydrants to be provided in all critical areas.  The facility will possess a detailed emergency and evacuation plan that will be regularly drilled to make sure that the responsible staff remains trained at all times.

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 Firefighting equipment such as fire extinguishers and hydrant systems will be maintained at strategic locations e.g. Industrial units, schools & hospitals.  Regular inspection and servicing of the extinguishers will be undertaken by a reputable service provider and record of such inspections should be maintained.  Signs such as “NO SMOKING” will be prominently displayed within the premises, especially in parts where fuel storage is involved. Fire extinguishers and buckets of sand to be provided in the fire-prone area and elsewhere.

6.4.7. Air Quality During the operational phase, air emissions will mainly come from industrial processes and process related activities and also from standby generators and other process fired equipment’s at different industrial units. If vented at lower heights, the exhaust gases will disperse locally and cause localized pollution to the working staff and residents. Other emissions coming from this project will be from the exhausts of additional traffic movement related to proposed project activity.

Mitigation Measures

Impacts of Emissions may be reduced to prescribed level by attempting the following measures:

 To prevent generation of fugitive emissions, all plant and machinery piping and insulation will be maintained on regular basis  All equipment, machinery and vehicles should be regularly tuned maintained and monitored.  Air emission should comply the SEQS limits  The air emissions will be monitored for the specified parameters on regular basis and results reported to SEPA as per the SMART Rules.  Regularly carry out ambient air quality monitoring at various points on the access road and immediately outside the proposed project premises.  Monitor all exhausts at regular frequency.  Regularly carry out ambient air quality monitoring at various points on the access road and immediately outside the proposed project premises.  Carbon monoxide detectors are to be provided in car parking which would be interlocked with the ventilation system.  Carry out regular maintenance of generators.

6.4.8. Noise The cumulative noise level within the textile and automobile industry, generally, is higher as there are several high noise machinery and processing sections during the processes of spinning, knitting and sewing etc. in textile; and assembly, welding and painting in automobile industry. Other noise sources include utility and power house area.

Mitigation Measures

 Controls should be applied to minimize the in-house noise.

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 Steps should be taken to reduce the noise at source level.  Regular maintenance of all machinery and equipment PPEs should be worn all the time.  Mufflers – Similar concept as duct silencers, but applied to motors or compressed air piping to reduce equipment exhaust noise. Typically applied generators.  Acoustical Louvers – Provides sound reduction without restricting airflow in buildings and enclosures. Used in place of standard louvers for a high level of noise reduction.  Sound Enclosures – The highest reductions in source noise control. Encloses noisy equipment while providing airflow and access for maintenance.  Absorptive Panels – Reduces noise levels in buildings and enclosed spaces. Typically applied to interior or exterior walls to reduce sound reflected from noisy equipment.  Sound Barrier Walls– Open top enclosures used to effectively block noise by surrounding noisy equipment while not restricting airflow.  Sound attenuation measures such as wall and banks (e.g. maintenance on noisy machines, rubber curtains of openings at transfer systems, noise adsorbing claddings and encapsulation).

6.4.9. Energy Consumption During operation, the units of commercial zone will use a lot of electrical energy mainly for domestic purposes including lightning, cooking, running of air-conditioning equipment, running of refrigerating systems etc.

During operation phase, power supply from Karachi Electric (K.E) will be made available. The power consumed will be significant in terms of costs both environmental and economic. Since energy produced from non-renewable resource results in CO2, SO2, and NOx emissions, it is important to ensure that energy is used prudently and best management practices are adopted in building design. Energy saving techniques such as Energy efficient mechanical systems and Passive ventilation/cooling will be employed to conserve energy.

Mitigation Measures

 Energy efficient lighting on the access roads will be employed.  The energy-efficient lighting system installed for the project will contribute immensely to energy saving during the operational phase of the project.  The occupants of the apartments will be sensitized to ensure energy efficiency in their domestic operations.  The energy usage during the operational phase will be monitored and targets would be set for efficient use of energy.

6.4.10. Illumination There will be extensive internal and external lightning for different industrial units, access roads and parking areas. Purpose of external lightning is to provide safe movement of pedestrians and vehicles over frequented routes. However, at the same time external lightning has a potential to cause nuisance to the neighboring communities.

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Mitigation Measures

The issue highlighted above may be avoided by adopting the following points:

 Evaluation of minimum illumination requirement will be carried out in MEP design.  It is suggested to keep the levels at minimum for all external lightning.

6.4.11. Traffic Flow and Congestion Traffic will be generated in the operation phase of the project. With this project coming on stream, it is expected that the traffic flow is going to increase. It is expected to have only localized attraction from the surrounding areas for commercial purposes, which may not contribute substantially to the parking and the travel demand requirement i.e. Trip attraction/generation. Traffic congestion is going to further increase during peak hours.

The Proposed Project would be expected to result in an increase of several dispatch trucks per week in and out of the property after the industry is fully operation. This additional truck traffic would constitute the percentage of the current truck traffic on Hub Dam Road.

Appropriate building spaces have been allocated to cater for parking requirements of the vehicles. Moreover, induction of traffic management plan will result in the smooth flow of traffic during the rush hours.

Mitigation Measures

Following measures will be adopted by to minimize the impacts of traffic flow.

 Designated parking areas will be provided for the type of project vehicles within and around the project site.  Traffic management plan will be introduced to manage smooth flow of vehicular traffic and to avoid traffic jam.  Traffic management plan will be implemented and monitored.  Vehicles will be parked at designated parking areas during operational phase.  Parking of vehicles alongside the road would be prohibited at all times.  Engineering design to examine vehicles exit and entry strategy so that it aligns with the traffic flow to cause minimum hindrance.  Ramp slopes and passage areas to cater for worst case scenarios traffic flow on the main and service roads.

6.4.12. Land Use and Aesthetics Construction of Industrial zone in line with the objectives of sustainable development that aims at improvement of quality of life with optimum utilization of resources, in this case densification of an area by construction of industrial units that are self - contained in having their own utility services like electricity, water supply and sewage disposal system in addition to provision of parking space. The

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Environmental Impact Assessment (EIA) Study Sumya Northern Industrial Zone proponent of the project will accordingly be mandated by the EPA to ensure sustainability of the Project.

As per the existing land use of the project site, the area is bounded by uninhabited. The development of the project would not contribute the change in the existing land use of the area but however the aesthetics of the area will be improved due to the development of the site and provision of utilities only if all the pollution control systems and mitigation measures as suggested in this EIA will be adhere to by the management of project.

With 24-hour security system all over the industrial units the designers have ensured that the concerns on invasion of privacy are alleviated and eased. The Project would thus achieve its objective of providing a secure industrial operation. This being a positive impact would be an indicator of achievement of the objectives of the Project. No mitigation measures will be required.

6.4.13. Socio-Economic Impacts

6.4.13.1. Provision of Utilities and access to amenities It is envisaged that by the provision of better utilities in the scheme, villagers near the site may benefit the provision of utilities. However it should be the Corporate Social Responsibility (CSR) of proponent to provide better services to the nearby community. Also as a part of CSR, the access to amenities proposed in the scheme like hospital, schools and college should be given to the nearby villages.

6.4.13.2. Employment Opportunities The labor force whether skilled or unskilled is the inhabitants of the nearby areas will be deployed at the project. This will not only provide them with the employment opportunities but they will now be having easy excess to the basic necessities of life by earning their both ends meet through the learning of skills. Some people will be employed by the project as management agents, caretakers, cleaners, security personnel and technicians.

6.4.13.3. Increased Business Opportunities The large number of project staff required will provide ready market for various goods and services, leading to several business opportunities for small scale traders such as food vendors around the project site.

6.4.13.4. Revenue to National and Local Government Through payment of relevant taxes, rates and fees of the government and the local authority, the proposed project will contribute towards the national and local revenue earning

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Chapter 7 ENVIRONMENTAL MANAGEMENT PLAN

7.1. Introduction This Environmental Management Plan (EMP) details the principles, practices and procedures to be implemented by the Proponent for the proposed Sumya Northern Industrial Zone project to manage, remedy and mitigate potential adverse environmental effects during construction and operation phase. These principles, practices and procedures meet resource consents and designation conditions, relevant legislation and the environmental objectives of the EPA.

An EMP establishes what an organization need to do in order to manage itself so as to meet tis environmental, economic and social goals. A typical EMP model is represented diagrammatically below.

Policy

Manage ment Planning Review

Checking Impleme Corrective ntation Action

Figure 7.1: Typical EMP Model

For any residual impacts (impacts remaining after applying the recommended mitigation measures) or for impacts in which there has been a level of uncertainly in prediction, monitoring measures have been recommended. Advice on monitoring measures required was sought from experts involved in the EIA and case studies of similar development activates at national and international level.

For the effective implementation and management of the mitigation measures and monitoring requirements an Environmental Management Plan (EMP) has been prepared and presented in this section. The EMP has been prepared following all the applicable Sindh Environmental Protection Agency guidelines and satisfies the requirements of guidelines for the preparation and review of environmental reports.

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Environmental Management Plan (EMP) has been made part of this document, which defines all the impacts and their mitigation measures and has highlighted the responsible personnel to work for the implementation of this EMP.

7.2. Need for EMP The EMP is meant to provide an overall approach for managing and monitoring environment- related issues and to describe the institutional framework for implementing the EMP.

The previous sections identified the environmental impacts of different activities during the designing, pre-construction, construction and operation stages of the proposed Project and mitigation measures to reduce the severity of the impacts. For successful environmental practices, an essential requirement of the SEPA 2014 is to develop an environmental management plan (EMP) to guide through the procedures to the management and employees of the organization for continual improvement. This EMP will be implemented by proponent of the project. It is essential for Top management to implement this EMP in letter and spirit and to make changes where required, with information to the Responsible Authority. EMP aims to achieve the following objectives:

 Outlining measures to be taken during the implementation and operation of a project to eliminate or offset adverse environmental impacts, or reduce them to acceptable levels.  The actions needed to implement these measures such as defining roles and responsibilities of the project proponent for the implementation of EMP and identifying areas where these roles and responsibilities can be shared with other stakeholders.  Defining the requirements for communication, documentation, training & management and implementation of the mitigation measures.  Actions required assessing the effectiveness of the mitigation measures employed such as guide through the monitoring mechanism and identifying related parameters that will be required for confirming the effective implementation of the mitigation measures.

7.3. EMP Process The EMP comprises of the following areas & defining the methods and procedures of implementation.

 Organizational structure and roles and responsibilities of project personnel.  Specific requirements for the implementation of the EMP.  Mitigation or impact management matrix.  Monitoring plan with the emphasis on specific parameters to monitor.  The preparation of this plan has involved an extensive and detailed program of investigation to the processes involve and with consultation the issues concerned. Therefore, this network will provide a structure to assist in the implementation of the management plan accordingly.  The proponent establishes environment, health & safety (EHS) department which handles the entire environment related concerns and issues. The EHS manager is the Incharge of EHS department and liable to report Managing Director. EHS department will appoint EHS

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officer who will coordinate with the contractor during construction process and also monitor during the operations of incinerator.

7.4. Management Approach Sumya Northern Industrial Zone Project Management will undertake overall responsibility for compliance with the EMP. It will ensure that all the activities that the management executes comply with positive environmental sensitivities as well as it will cooperate with the concerned regulatory agencies such as Sindh Environmental Protection Agency (SEPA). The dynamic approaches that are followed towards successful implementation of the environmental management plan listed below:

 Compliance with the relevant legislative and regulatory requirements of the project.  Developing appropriate monitoring indicators in order to assess the performance as well as magnitude of impact on the environment.  Regular review of the project activities and assessing their impacts on the environment  Setting project’s key environmental concerns and addressing issues through public support, awareness and publicly reporting its progress.  Communicating broadly with internal & external stakeholder on issue of environmental concerns

7.5. Maintenance of the EMP EMP needs to be revised on periodic basis to maintain up-to-date environmental management requirements with the changing physical and regulatory constraints. Therefore, outlining and defining the responsibilities of personnel and activities under the project’s operation execution, implementation, mining, operation & monitoring and decommissioning phase are integral part of maintenance of the EMP. Dissemination of reviewed and revised EMP need to be notified to all stakeholders particularly, relevant government and municipal agencies so that their modified role is also redefined and re-established in the overall environmental management process

7.6. Health Safety and Environment Management System Health, Safety and Environment Management System is essential and integral component of the environmental management system for the safe and secure working environment assuring sustained development, dependent on health associated performance of human resources. EHS issues and aspects are outlined in EMP with mitigation measures based on principles of best management practices. EHS management system undertakes carrying out a complete assessment, evaluating, monitoring, identifying and control measures (mitigation) of all potential hazards and risks arising during the construction, and operation phases of the proposed project. It needs to ensure that the Health and Safety Plan (HSP) along with the Health and Safety Rules is established, documented and enforced. The plan also outlines roles, responsibilities and expected outcomes of proper implementation with respect to the environment, health and safety management of various phases of the project. These measures should be implemented to ensure that no significant adverse, health and safety impacts occur due to proposed activities associated with the project.

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Protection of the public in general and workforce health and safety in particular during both construction and operations is of paramount importance to the project. Utilizing expert personnel and adopting tailor made Environment, Health and Safety Management System (EHSMS) that is specifically designed for the project, the potential health and safety hazards and risks associated with the project as identified and assessed, would then be mitigated by adopting standard procedures for various operations at facilities in the project.

7.7. Risk Assessment

7.7.1. Identification of Environmental and Social Aspects of Project Potential environmental and social aspects from the development and operation of the proposed project include the following key activities:

 Siting the proposed project  Construction and installation the project  Water consumption and wastewater generation  Construction waste generation and disposal  Plant operations  Air Emissions  Handling and management of waste during operations  Emergency situations Risk assessment of the abovementioned project activities identifies the following environmental liabilities which would require mitigation/control measures to be implemented to reduce the environmental impacts to an acceptable level.

 Air and noise emissions  Possible contamination of water, soil and land from discharge of effluents including oily waste and seepage to land and water  Solid waste including excavated material, hazardous and non-hazardous wastes  Traffic issues during construction and operation phase  Resource consumption  Emergency case scenarios  Socioeconomic impacts Workers are prone to safety hazards during construction work such as accidents during work at height, poor ergonomic conditions etc. and exposure to hazards and toxic and explosive materials.

Hazards associated with the operational activities of the proposed project can be of the following categories:

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 Electrical: Electrocution from live conductors and misuse of power tools, overhead power lines, downward electrical wires, buried cables, and work during electric storms.  Structural: Potential for falling or strain when working conditions include slippery surfaces, steep grades, narrow stairs, open holes, trip hazards and unstable flooring; potential puncture from objects and potential burial from trench cave-ins or from unstable slopes on material stock-piles.  Mechanical: Collision accidents with moving equipment, especially when operating in reverse, failed pulleys, snapped cables, and clothes catching in gears or drills.  Temperature: Heat stress in hot environments or when working in clothing which limits the dissipation of body heat and moisture.  Noise: Stress and physical damage to the ear when subjected to noise levels exceeding recommended guidelines (e.g. an 8-hour, time-weighted average sound level of 90 dB(A), as per US guidelines, SEQS recommend 85dB (A) as the limiting value for motor vehicle noise- there is no SEQS limitation imposed on noise generated from industrial process).  Exposure to Hazardous Material: During handling of hazardous chemicals worker can be exposed to hazardous and toxic materials. In addition, it is possible that if the work areas are not designed properly, they can cause workers discomfort and mental stress, which can result in loss of efficiency, and thus lessen the worker’s ability to respond promptly to any hazard. Also, creation of such conditions can cause monotony and fatigue, thereby increasing the potential for hazards and accidents to occur.

7.8. Legislation and Guidelines The EIA for the proposed Project has discussed in detail the national and international legislation and guidelines that are relevant to the project in Chapter 3 of the EIA report.

The proponent of the project will ensure that the project is conducted in conformance with national legislation and relevant international conventions and that guidance is sought form national and international guidelines. It will also be ensured that key project management of the company and all its assigned contractors are aware of these legislation and guidelines prior to start of the project activities

7.9. Roles and Responsibilities Environmental management should become an integral part of policy of the project management. Therefore, committing to reduce the environmental impacts will reflect the management approach and believe that good performance in this area is synonymous with running well-managed efficient proposed project operations. During the construction phase, main responsibility of environmental performance will reside with sponsor’s construction manager, who in turn will be assisted in daily activity monitoring by site HSE officer.

In case of normal operational phase, main responsibility for environmental performance will be supervised by Site Manager of the industrial zone project while the daily management will be performed under the Site Supervisor. Under their surveillance, environmental management during

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Environmental Impact Assessment (EIA) Study Sumya Northern Industrial Zone operations will be performed as per the mitigation and monitoring plans outlined in this EIA. A brief structure of role and responsibilities is given below:

7.9.1. Top Management Environmental management plan (EMP) will be regulated by the Top Management of proposed project; therefore, will play an important role. Some of the key role & responsibilities are given below:

 To cooperate and consult with relevant environmental agency in order to perform in better way.  To evaluate the progress of development and implementation of this management plan.  To approve any change in decision making with the consultation of respective managers, if appropriate.

7.9.2. Construction Manager The role of Construction Manager is very important. The success of an EMP will mainly depend upon effective management of the EMP by this person. Following are some of the roles and responsibilities given to the Construction Manager:

 To ensure that the points of views of staff, contractors and HSE officers are considered and placed in the EMP accordingly.  To identify issues and where possible propose solutions for inclusion in the management plan review process.  To improve coordination and exchange of information between top management, employees, contractors, etc.  To contribute towards the actions to deliver the management plan and ensure its continued development.  To monitor the progress of development and implementation of this management plan.

7.9.3. HSE Officer The role of HSE officer will be vital during the construction as well as operational phases. He will be the key advisor on environmental issues to the construction manager of proposed project and in the operational phase his responsibility will be to manage day to day HSE issues. Following will be his main responsibilities;

 To integrate, as far as possible, the aims and objectives of different users within an agreed plan.  To maintain a balanced, holistic approach to the solution of concerned issues in accordance with the compliance to the legislative requirements.  To provide professional guidance on questions relating to the environmental management and issues raised by contractors personals.  To progress the EMP process through development towards implementation.

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7.9.4. Construction Contractor On behalf of contractor, the main responsibilities for all matters pertaining to environment will be that of the chief executive officer of the assigned contractor. The role and responsibilities of the contractor will consist of the following basic points:

 To carry out construction activities in environmentally sound manner.  To coordinate with the HSE officer to resolve issues arise during construction phase.  To manage and implement environmental management practices as per the impact assessment report as well as HSE polices belong to both contractor and proponent.  To manage construction crew and reduce the environmental impacts.  To appoint a dedicated environment officer that will understand and tackle environmental issues more easily.

7.9.5. Independent Monitoring Consultants The proponent shall appoint an Independent Monitoring Consultant (IMC) who will monitor to ensure that the construction is in accordance with the EIA approval conditions. The results of the periodic monitoring will be compiled in monitoring reports which will be submitted to the project management for review and necessary action. The consultant will maintain monitoring records and any deviations from or changes to the contract plans.

7.10. Regulatory Requirements

7.10.1. Approvals, Authorizations and Permits Obtaining NOC from SEPA does not relieve the proponent for other obligations and hence proponent and the contractor will obtain all relevant clearances and necessary approvals required by the Government of Sindh prior to initiate the proposed operations.

The list of potential approvals, authorizations and permits required for the Project from various agencies are given below:

 Sindh Environment Protection Agency (SEPA).  Sanction of utilities from concern department such as Sui Southern Gas Company (SSGC), Karachi Water and Sewerage Board (KW&SB), K-Electric, Pakistan Telecommunication Company Limited (PTCL) and other civic agencies etc.

7.10.2. Compliance Monitoring It would be required by the management of project proponent to comply with the Environmental Monitoring Plan laid in the subsequent section. The compliance shall also require periodic reporting of the monitoring results in form of report submitted to the Environmental Protection Agency. During the construction phase, it will be on monthly basis and during the operation phase it will be done on quarterly basis. It is also understood that monitoring shall be done by an independent consultant /organization.

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7.11. Audits In particular, there will be:

 Annual audit reports.  A biannual/annual review and improvement of the EMP. Management recognizes that periodic external compliance audits and inspections will be made to monitor, assess and validate the level of performance and compliance pursuant to the commitments made in the accepted Environmental Management Plan. Management also proposes to conduct the following in-house audits:

7.11.1. Site Internal Environmental Audit It is required in order to enable site management to assess the day-to-day environmental management of activities at the site. Environmental activities include all aspects of operations that result in emissions, effluent or wastes, etc.

7.11.2. Environmental Management Systems Audit It is required to assess the implementation and operational success of the EMS at the site. This is achieved by assessing the objectives, organizational structure, responsibilities, procedures, processes and resources available at the site. The EMS Audit is a systems assessment, rather than an audit of environmental compliance, which is assessed through the Site Internal Environmental Audit.

7.12. Implementation Stages of EMP The success of the management plan will lie with its implementation. An EMP requires to be executed in three stages. Those are, planning & design stage, construction stage and operation stage.

7.12.1. Planning and Design of Proposed Project Implementation of EMP at this stage may tackle the environmental issues before they arise. The main components to consider in an EMP prior the construction phase are given below:

7.12.1.1. Design of Proposed Facility It describes the location of proposed project, its adjoining conditions in the area, facilities to be installed in particular locations as well as their mechanics and other related operations. If any design parameter changes the environmental impacts that may arise from such changes will be assess. If the impacts are found to be different and in excess of those mentioned in the report, project staff will develop further mitigation measures with respect to the changes to minimize these impacts and seek approval for the required change from SEPA as well as other regulatory authorities, if comes under.

7.12.1.2. Contractual Provisions The requirements of environmental impact assessment in terms of environmental mitigation shall be incorporated into the operations plans and procedures of the contract. Therefore, signing of contract

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Environmental Impact Assessment (EIA) Study Sumya Northern Industrial Zone will strictly bind contractor to follow those procedures and must comply the environmental regulations.

7.12.2. Construction and Operation Phase In order to implement EMP successfully during construction and operation phase, it is required to follow mitigation measures, monitoring plan and emergency procedures strictly. Training will be required at each step and phase, also if necessary to change management processes, will be documented and available to the employees.

7.12.2.1. Construction Work Management All construction related work including campsite establishment, operation, and management of waste streams, equipment and material mobilization etc. shall be in compliance with the

(1) agreed procedures (if) provided by the proponent to the contractor and (2) provisions of NOC. The contractors will abide by the relevant contractual provisions relating to the environment.

Performance of contractor and subcontractor will be monitored by IMC periodically and site supervisor constantly. All the construction crew particularly the technical staff will be provided with necessary PPEs and other safety equipment as required by their job. Site supervisor and contractor will ensure that each job is being performed in safe and sound manner and in accordance with the safe work procedures.

Solid waste during construction will be removed on daily basis either through a local waste contractor or by the construction contractor himself who will engage some workers for removal of construction waste from site and disposal to a waste collection facility.

Proper drainage will be provided to construction camp and construction site, especially near excavations. The wastewater will be initially treated by sedimentation technique to remove suspended solids and reused if it meets the desired quality. If the effluent cannot be reused, it will be discharged to local sewers after ensuring that it does not contain any solid debris which can choke the sewer lines. Where possible, wastewater will be used for watering the vegetation nearby.

Type of construction material for the Project shall meet the seismic design requirements for buildings located in seismic zone 2B. The design consultant also needs to consider other safety aspects for events like cyclones, Tsunami etc.

The Site Supervisor also needs to ensure that construction and operation of the project does not influence the business going on in the vicinity. This is possible during construction phase from obstruction of routes; campsite location, noise emissions, and resource consumption e.g. water. Similarly, during operation phase, logistics will be managed by traffic management plan. Any complaints from nearby industrial units will be addressed effectively.

Site Restoration

The Site Supervisor will ensure that the restoration of the site after the end of construction activities is carried out according to the requirements of the EIA and EMP.

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7.12.2.2. Water Sourcing and Wastewater Management Measures will be implemented to maximize water recovery and reduce dependence on the use of fresh water for operations. For treatment of wastewater, a full-scale wastewater treatment is planned with RO Plant for recovery and recycling of water. Detailed measures have been provided in previous chapter.

7.12.2.3. Control of Air Pollution Air pollution due to the project activities would primarily result from construction activity and construction machinery during construction. During operation the air pollution sources will mainly include emission stacks, standby generator and vehicular movement. Detailed mitigation measures to control air pollution have been provided in previous chapter. To ensure effective implementation of all mitigation measures and compliance with the Sindh Environmental Quality Standards (SEQS) regular monitoring of stack emissions will be carried out.

7.12.2.4. Waste Management Hazardous and non-hazardous waste will be generated during project activities. Waste management is a critical component of operating policies. Waste management includes proper handling, accumulation, storage, transportation, and disposal of the waste generated and collected.

A Project-specific Waste management procedure will be developed by proponent which primarily relates to the different activities of the project. It supports the EMP and addresses actions and requires responses of proposed project employees and contractors.

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7.12.2.5. Fire Fighting System The proponent has planned for an efficient firefighting system. The new Unit will be equipped with the necessary fire protection and detection equipment. The following fire- fighting facilities should be provided depending upon the nature and risk of the installation:

 Fire water system (mixed installation)  Foam generation system  Fixed fire-fighting equipment  Mobile fire-fighting equipment  Fire detection and alarm system  Communications Design of the fire-protection system facilities is provided as per the following criteria, and recommendations of the NFPA 30 have generally been followed:

 Fire-protection facilities are based on the single largest emergency contingency.  All the potential fire risk areas are fully covered by hydrant and monitoring systems.  Water spray systems will be considered in hazardous locations and equipment in process unit areas.

7.12.2.6. Personal Protective Equipment (PPEs) Personal Protective Equipment (PPE’s) shall be provided according to the nature of operations.

7.12.2.7. Co-ordination with Stakeholders The proponent will ensure that co-ordination required with the project stakeholders on environmental and social matters as required by the EMP is maintained throughout the operation of the project.

7.12.3. Mitigation Plan It defines all the impacts and their remedial with highlighting the responsible personals to work on those mitigations. A mitigation plan is basically a mitigation matrix which is given as table 7.1 and table 7.2 for construction & operational phase respectively. All these impacts and mitigations have already been given in previous section of this report. The proponent and construction contractor will be required to adhere to these mitigation measures throughout the project.

7.12.4. Monitoring and Review Monitoring of all the activities will be required to analyze the impacts of construction and operation on the environment and detailed Monitoring plan is given in table 7.3. HSE officer will coordinate with construction manager and contractor site representative to monitor environmental parameters during the construction phase. During operation phase HSE officer will be responsible for monitoring.

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7.12.5. Training This is another major step for the implementation of EMP. All the employees will require to be trained appropriately to work on EMP effectively. Employees training can provide workers to minimize waste generation, conserve resources such as water and natural gas etc. The HSE officer will determine the training requirements in consultation with contractor among the staff of both construction contractor and developer’s staff with the advice of Construction Manager.

Necessary training on environmental and other safety issues will be provided to the technical and supporting staff before start of activities to ensure that all the staff is well acquainted with the nature of job, inherent risks, hazards, requirements of job safety and EMP. The Project Manager will determine the training requirements.

During the training, the following areas of knowledge and experience are considered essential:

 Understanding the properties (e.g. flammability, corrosiveness, toxicity, reactivity, infectious) of hazardous waste, as well as the levels at which they pose a significant danger requiring protective measures.  Waste management plan  Health and safety risks associated with the plant operation  Awareness of early-warning indicators, hazards/risk identification, and ability to recognize potentially hazardous situations.  Familiarity with engineering controls to avoid occurrence of hazardous situations.  Knowledge of the use and maintenance of emergency response equipment, as well as routine equipment for health and safety monitoring and protection.  Knowledge of methods and procedures for decontaminating equipment, and facility, following potential chemical contamination. Records of all trainings should be maintained. It is recommended that in case of any undesirable event or emergency situation, a follow-up session should be arranged to review the weaknesses ad gaps in the existing system and possible reasons which caused the event. This would enable the management in keeping such events from recurring by placing additional and more efficient controls.

7.12.6. Communications For effective management and monitoring of the environmental performance during the construction and operation phase, communication will be maintained by the Site Supervisor and Project Manager who will coordinate with the project management and regulatory agency on necessary matters.

 Construction Phase: Site supervisor will be responsible for coordinating the project progress to the Construction Manager during construction phase. He will supervise the construction work to ensure that provisions of EMP/EIA are not violated at any stage. If any undesirable event such as work-related injury, death, or any other emergency situation

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arises during construction, the Site Supervisor shall report this to the Project manager. Any issues that require attention of higher management will be communicated.  to them for action by the EHS manager. The site supervisor should report to the Project Manager on weekly basis during the construction phase.  Operation Phase: Following is suggested for an effective communication of project’s EHS performance during the operation phase of the project.  Kick-off Meeting to define the environmental responsibilities, awareness of EMP to the managing staff and to streamline the work plan according to the EMP. This meeting is to be arranged prior to commencement of activities.  Quarterly Meetings to review the progress of activities performed and effectiveness of measures in place for pollution control. Deadlines are re-evaluated in it and if necessary, the project program is revised in these meetings. In the end of quarterly meetings, minutes will be issued to include the outcome of the meeting, issues discussed, and decisions. The minutes of meeting will also be provided to the project manager and the contractor for their own record.  Peer Review for professional opinion and evaluation of the project performance, recommendations for innovation such as new available pollution controls, waste minimization strategies etc.

7.12.7. Emergency Procedures The EHS department will prepare contingency plans to deal with any emergency situation that may arise during the operation e.g. fire, major oil, chemical spills, medical evacuation and communicate these to the regulatory agencies if required by these agencies.

The EHS department will also implement necessary measures to prevent fire hazards, contain oil spills, and perform soil remediation as needed.

7.12.7.1. Fire Contingency Plan Possibility of presence of flammable materials at this site, fire is an ever-present hazard. All personnel and subcontractors are not trained professional fire-fighters. Therefore, if there is any doubt that a fire cannot be quickly contained and extinguished, a designated officer will notify by radio and vacate the area. The designated officer will immediately notify the local Fire Department.

The following procedures will be used to prevent the possibility of fires and resulting injuries:

 Sources of ignition will be kept away from where flammable materials are handled or stored.  “No Smoking" signs will be conspicuously posted in areas where flammable materials are present.  Fire extinguishers will be placed in all areas where a fire hazard may exist. The following procedures will be implemented in the event of a fire:  Anyone who sees a fire will notify their designated fire officer who will then contact the work crew and ring the siren.

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 When the emergency siren sounds, workers will disconnect electrical equipment in use (if possible) and proceed to the nearest fire exit.   Work crews will be comprised of pairs of workers (buddy system) who join each other immediately after hearing the fire alarm and remain together throughout the emergency. Workers will assemble at a predetermined rally point for a head count. When a small fire has been extinguished by a worker, all workers will be notified.

7.12.7.2. Training All employees will receive general firefighting training (i.e. fire extinguisher use). Employees who are members of the fire brigade shall receive at a minimum the following training:

 Use and limitations of the firefighting equipment.  Firefighting strategies and methods.  Use of respiratory equipment and its limitations.  Donning bunker gear and its care.  Care and maintenance of firefighting equipment and hoses.  Confined space entry and fire fighting in a confined space.  First aid.  High level rescue (if the site assigns this responsibility to this group).

7.12.7.3. Emergency Response Plan (ERP) Emergency may be defined as a sudden event causing and has the potential to cause serious human injury and/or environmental degradation of large magnitude. The best “cure” for an emergency is, of course, “prevention”.

The probable emergency situation can be:

 Serious fire and explosion;  Natural calamity such as heavy rain, flooding, dust storm, earthquake etc.;  Bomb threat or any sabotage/terrorist activity;  Any other incident involving all or large part of the premises and its workers. A Project-specific ERP will be developed by proponent which primarily relates to the different construction activities of the project. It supports the EMP and addresses actions and requires responses of proposed project employees and contractors.

Emergency response management will be provided with small teams of senior managers (the control committee) who in turn will direct all response activities through the Emergency response unit, industry security, communications, public relations, environment and safety affairs and material procurement departments. Each of these departments has specific responsibilities to perform in the event of an emergency.

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7.12.8. Change Management

7.12.8.1. Change in Operations Any change in the operation of proposed project if required, will be made in relevance to the EMP and all the impacts associated with changed process will be either similar to the existing impacts and if different, will be assessed and included in the mitigation management plan. This has, on the basis of nature of process change, been distributed into three categories. Type of changes that may occur and require EMP updating are given below.

First-Order Change is one that leads to a significant removal of any operation from the project described in the chapter on description of project of this report and consequently requires a reassessment of the environmental impacts associated with the changes. In such an instance, reassessed environmental impacts of the proposed change will be sent to Sindh EPA for approval.

Second-Order Change is one that entails project activities not significantly different from those described in the EIA report, and which may result in project impacts whose overall magnitude would be similar to the assessment made in this report. In case of such changes, the environmental impacts of the activity will be reassessed. Additional mitigation measures if required will be identified and documented for being reported to Sindh EPA for their record.

Third-Order Change is one that is of little consequence to the EIA findings. This type of change does not result in impact levels exceeding those already assessed in the EIA report; rather these may be made onsite to minimize the impact of an activity. The only action required in this regard will be to record the details of process change in the record register.

During routine operations, workers may develop occupational diseases of the lungs, skin, and other organs, depending on the amount and length of time of exposures. Workers exposed to hazardous noise levels may develop noise-induced hearing loss. Other dangers include confined spaces, in which untrained workers may get seriously injured or killed.

In view of the existence of the occupational health and safety risks in the proposed facility, the EHS department needs to develop an Occupational Health and Safety Risk Management Plan for exposure control in situations when workers may be overexposed to chemical hazards. This plan should provide a detailed approach for protecting workers against chemical exposures, including health hazard information, engineering controls, safe work procedures, worker training, and record keeping.

It is recommended that the Occupational Health and Safety Risk Management Plan should necessarily include the following elements:

 Statement of purpose  Responsibilities of employers, supervisors, and workers  Risk identification and assessment  Risk controls

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 Worker education and training  Written safe work procedures  Hygiene facilities and decontamination procedures  Documentation  Health monitoring (may also be required, depending on the nature of the chemicals being used)

7.12.8.2. Change in Record Register A record register will be maintained at project site at the start of construction activity. All the changes to be made will be recorded in this register. This will assist in the step-by-step environmental monitoring and decision-making. Record register will be the responsibility of HSE department, and will be used internally.

7.12.8.3. Change in EMP Changes in project design may necessitate changes in the EMP. In this case, the following actions will be taken:

 A meeting will be held between project management and construction contractor, to discuss and agree upon the proposed change to the EMP.  Based on the discussion during the meeting, a report will be produced collectively, which will include the additional EMP clauses and the reasons for their addition.  Additional EMP clauses will be added to the original EMP as a second volume which will be distributed to the relevant project personnel and contractor.

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Table 7.1: Mitigation Matrix for Design and Construction Phase S. Affected Areas Possible Mitigation Measures Responsibility No 1. Structural During the construction of basement it will be important to maintain the stability of excavated Site Management Stability walls. During monsoons it will be essential to protect the excavation walls with shoring/bracing. Site Management/ Construction Contractor 2. Threat to Erect fencing to exclude reptiles from the working areas and relocate any reptiles or mammals Site Management/ Biodiversity in the working areas to safe areas. Construction Contractor 3. Soil Erosion The project will be scheduled to avoid heavy rainfall periods (i.e., during the dry season) to the Site Management extent practical. After constructional activities, the site which is cleared temporarily will be re-vegetated Construction promptly. Contractor Off-site sediment transport will be reduced or prevented by the use of settlement ponds, silt Site Management fences, water treatment, as well as modifying or suspending activities during extreme rainfall and high winds to the extent practical. The environmental impact of soil erosion can best be mitigated by removing vegetative cover Site Management only from the specific site on which construction is to take place and by disturbing the vegetation in adjacent areas as little as possible. Construction activities that result in the soil being laid bare could be scheduled in such a way Site Management that some type of vegetative cover appropriate to the site could be established prior to the onset of intense rain or windstorms. If grass is to be seeded, mulch of straw will help to protect the soil from less extreme erosive Site Management forces until vegetative and root development begins. Exposed surface was regularly wetted to effectively keep airborne dust levels to minimum. Construction Contractor During the windy weather situation, the stockpiles of fine materials will be covered with Construction tarpaulin Contractor Site workers are mandated to wear dust masks especially during dry and windy weather Construction conditions. Contractor

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4. Soil Fuel oils, lubricants, and chemicals will be stored in covered dyked areas, underlain with Site Management Contamination impervious lining. Maintenance of vehicles and equipment will be carried out in designated areas. Construction Contractor Washing of vehicles will be carried out in the designated areas. Construction Contractor Construction vehicles and machinery will be examined on a regular basis for leakage Construction prevention. Contractor Removal of oil and contaminated soil around the fuel and oil storage areas will be made Construction possible by the availability of appropriate implements i.e. shovels, plastic bags and absorbent Contractor materials. Contaminated media will be managed with the objective of protecting the safety and health of Site Management laborer at the site, the surrounding residents, and the environment. Plans and procedures will be prepared, to respond to the discovery of contaminated media to Site Management minimize or reduce the risk to health, safety, and the environment consistent with the approach for Contaminated Land. 5. Construction A comprehensive waste disposal plan to be developed to effectively manage these waste in Site Management Waste large quantities. The construction waste which will be sent for recycling like damaged pipes, left over steel, Site Management wooden and plastic pieces. While, the rest of the left over waste will then be taken away to the dumping sites for disposal. The construction material will be kept in a covered place, especially during the precipitation Contractor season. The excavated soil will be re-used by adopting different methods, which will be used as a filling Contractor material for low lying areas or excavated areas. Separate bins will be placed for different type of wastes - plastic, paper, metal, glass, wood, Contractor and cotton. Recyclable material will be separated at source. The recyclable waste will be sold to waste Contractor contractors for recycling. Non-hazardous non-recyclable wastes such as construction camp kitchen wastes will be Contractor disposed of in landfill site through municipal administration or approved waste manager/contractor.

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All hazardous waste will be separated from other wastes. Hazardous wastes will be stored in Contractor / Waste designated areas with restricted access and proper marking. Hazardous wastes will be Contractor disposed of through approved waste manager/contractor. Surplus construction materials including partially filled chemical and paint containers will be Contractor returned to suppliers. Inert construction wastes will be disposed of onsite as fill material or sold as scrap to contractors. Records of all waste generated during the construction period will be maintained. Quantities of Contractor waste disposed, recycled, or reused will be logged on a Waste Tracking Register. Training will be provided to personnel for identification, segregation, and management of Site Management waste. The waste management plan developed for construction phase shall be followed in letter and Contractor spirit. Various waste containers for different types of waste will be deployed, in order to treat the Contractor waste in accordance with its nature. The waste bins will be properly marked for each type of waste produced during the Contractor constructional activities. The project area will contain the sewage and litter facility to overcome the problem of Site Management unchecked dumping of waste. Use of building materials that have minimal packaging to avoid the generation of excessive Site Management packaging waste. Use of durable, long-lasting materials that will not need to be replaced as often, thereby Site Management reducing the amount of construction waste generated over time. 6. Ambient Air Minimizing dust from open area sources by using control measures such as installing Contractor Quality enclosures and covers, and increasing the moisture content. Dust suppression techniques will be implemented, such as applying water to minimize dust Site Management from vehicle movements. PPE, such as dusk masks, will be used where dust levels are excessive. Contractor Sprinkling of water and fine spray from nozzles to suppress the dust. Site Management Only those vehicles having certificate with respect to exhaust emission quality and noise will Site Management be allowed to supply the construction material to the project site Sand and other materials transported by trucks shall be kept covered to prevent dust Contractor dispersion.

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Speed bumps are commonly used to ensure speed reduction. In cases where speed reduction Site Management cannot effectively reduce fugitive dust, it may be necessary to divert traffic to nearby paved areas. Fabrics and plastics for covering piles of soils and debris is an effective means to reduce Contractor fugitive dust. Care will be taken to keep all the material storages adequately covered and contained so that Site Management they are not exposed to situations where winds on the site could lead to dust / particulate emissions. Ensure that the vent of generator exhaust is at adequate height so it will not be a cause of Site Management localized dispersion 7. Water A complete record of water consumption during the construction phase will be maintained. Site Management Consumption Construction workers will be trained to use water efficiently in way to reduce the wastage of Site Management water during different activities occurring in the construction phase. /Contractor 8. Wastewater Washing of vehicles and construction machinery will be restricted to a designated area. Contractor Generation and Wastewater will not be disposed of directly into the water bodies, but will be routed to septic Site Management Disposal tanks and soak pits. Development of wastewater treatment facility i.e. septic tank, at the site of the proposed project Site Management area The wastewater treatment facility of the project will be leak proof. Regular monitoring of the wastewater generation will be taken into consideration. Site Management Wastewater generation will be minimized by controlling the pollutants at the source. Contractor The oily waste will be contained before disposing the wastewater into the sewer. Site Management/ Contractor Adequate portable or permanent sanitation facilities serving all workers will be provided at all Site Management construction sites. Sewage will not be mixed with any other waste. Site Management 9. Noise and Noise control devices will be used such as temporary noise barriers and deflectors for Contractor Vibration constructional activities. The activities associated with greatest potential to generate noise will be planned during the Site Management day period that will result in least disturbance to the nearby residents at night. Truck drivers will be instructed to avoid gunning of vehicle engines or hooting especially when Contractor passing through sensitive areas such as mosques, school, etc.

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Noise and vibration will be minimized in the projects site and surrounding areas through Site Management sensitization of the truck drivers to switch off vehicle engines while offloading material. Construction machinery will be kept in good condition to reduce noise generation. Site management/ Contractor All generators and heavy duty equipment will be installed and placed in enclosures to minimize Contractor ambient noise levels. 10. Vehicular Traffic Heavy traffic during construction phase will come to the project site during late night hours. Site management Project vehicles shall not be fitted with pressure horns. Site Management/ Contractor Speed of vehicles will be regulated during construction phase. Contractor Designated parking areas will be provided for different type of project vehicles within and Site Management/ around the project site. Contractor Traffic management plan will be introduced to manage smooth flow of vehicular traffic and to Site management avoid traffic jam. Traffic management plan will be implemented and monitored. Site Management Vehicles will be parked at designated parking areas during operational phase. Site Management Parking of vehicles alongside the road and Motorway would be prohibited at all time. Site Management 11. Materials Materials including paving stones, crush, gravel and sand will be brought from commercial Site Management Selection quarries located in Sindh province. Environmentally sound materials and goods will be selected, with priority being accorded to products meeting national and international standards. Traditionally well-tried materials and components will be selected and selection of construction Site Management materials would be based on sustainable source. Construction site will be adequately isolated to prevent entry of public and general safety Site Management measures will be evocatively imposed throughout the construction period. The production, use and disposal of building materials during the construction stage of The Site Management project will utilize considerable amount of energy and resources; all attempts will be made towards efficient consumption and minimization of wastage of water, energy and materials. Best practice of energy efficiency will be adopted in the building design. The Project building Site Management would be constructed with high level of thermal insulation. The environmental impacts arising from selection of building materials and components would Site Management take account of the environmental issues during the materials selection process, and introduce Recycling strategies such as Reuse and Reduction of wastewater.

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Temporary inconveniences due to construction works will be minimized through planning and Site Management coordination with relevant authority. 12. Occupational Tools will be selected and work stations would be designed to reduce force requirements and Site Management Health and holding times, which promote improved postures, including, where applicable, user adjustable Safety work stations. Administrative controls, such as job rotations and rest or stretch breaks will be implemented Site Management into the work processes. Good house-keeping practices, such as the sorting and placing loose construction materials in Site Management established areas away from foot paths, will be implemented. Excessive waste debris and liquid spills will be cleaned up regularly. Site Management Electrical cords and ropes will be located in common areas and marked corridors. Use of control zones and safety monitoring systems to warn workers of their proximity to fall Site Management hazard zones, as well as securing, marking, and labeling covers for openings in floors, roofs, or walking surfaces. Training and use of temporary fall prevention devices, such as rails or other barriers able to Site Management support a weight of 200 pounds, when working at heights equal or greater than two meters or at any height if the risk includes falling into operating machinery, into water or other liquid, into hazardous substances, or through an opening in a work surface. Training and use of personal fall arrest systems, such as full body harnesses and energy Site Management absorbing lanyards as well as fall rescue procedures to deal with workers whose fall has been successfully arrested. The location of vehicle traffic, machine operation, walking areas, and controlling vehicle traffic Site Management will be planned and segregated through the use of one-way traffic routes, establishment of speed limits, and on-site trained flag-people wearing high-visibility vests or outer clothing covering to direct traffic Appropriate PPE such as safety glasses with side shields, face shields, hard hats, and safety Site Management shoes, would be wore. The visibility of personnel would be ensured through the use of high visibility vests when Site Management working in or walking through heavy equipment operating areas as well as training of workers to verify eye contact with equipment operators before approaching the operating vehicle Inspected and well-maintained lifting devices will be used that are appropriate for the load, Site Management such as cranes, and securing loads when lifting them to higher job-site elevations.

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Access to the site will be restricted through a combination of institutional and administrative Site Management controls. 13. Community Removing hazardous conditions on construction sites that cannot be controlled affectively with Site Management Health and site access restrictions, such as covering openings to small confined spaces, ensuring means Safety of escape for larger openings such as trenches or excavations, or locked storage of hazardous materials. Access to the site will be restricted through a combination of institutional and administrative Site Management controls. The mobility of the community living in the area will be restricted from the project site in order Site Management to prevent from catching any type of communicable diseases. Any labors found to catch any type of disease will leave the site immediately; and would be Site Management given proper medical facilities. Water after rain or after sprinkling will not be left stagnant to attract mosquitoes and will be Contractor removed or drained properly. Waste management plan will be followed during construction to avoid attraction of vector Contractor towards waste material. The incidence of road accidents involving project vehicles during construction will be minimized Site Management through a combination of education and awareness-raising, provision or specified routes, installation of safety signage and the adoption of procedures

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Environmental Impact Assessment (EIA) Study Sumya Northern Industrial Zone

Table 7.2: Mitigation Matrix during Operation Phase of the Project S. No. Affected Possible Mitigation Measures Responsibility Monitoring Areas 1. Soil Fuel oils, lubricants, and chemicals will be stored in covered dyked areas, underlain with Proponent Proponent/IMC Contamination impervious lining. Construction machinery will be kept in good condition in order to prevent soil contamination. Vehicles and equipment maintenance will be taken place at specified site. Washing of vehicles will be carried out in the designated areas. Construction vehicles and machinery will be examined on a regular basis for leakage prevention.

2. Water A complete record of water consumption during the operation phase will be Proponent Proponent/IMC Consumption maintained. Water conservation practices will be adopted to prevent wastage of water. The water supply lines will be checked and repaired for leaks, if any, in order to reduce wastage of water. Use of water efficient sanitary fittings such as low flush toilets, water efficient shower heads, and aerators on faucets will be ensured throughout the Project cycle. 3. Solid Waste Ensure regular collection of garbage by private waste disposal service. Proponent Proponent/IMC Ensure waste is disposed of at the landfill site. All solid waste shall be segregated into organic and recyclable waste at source and then collected, stored, and transported for ultimate safe disposal. It is proposed by the EIA consultant that a dedicated Garbage Transfer Station shall be developed and space must be allocated in the master plan that will gather all the waste generated from the project proponent, segregate the waste material and disposed / sold via waste management contractor via waste management contractor. The solid waste management plan developed shall be followed and facilities for collection, storage and transportation will be established and organized.

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Environmental Impact Assessment (EIA) Study Sumya Northern Industrial Zone

Storage facilities will be created and established by taking into account quantities of waste generation in the apartment complex and the population densities. All solid waste shall be segregated into organic and recyclable waste at source and then collected, stored, and transported via GTS for recycling/sold to vendors or ultimate safe disposal. Handling and disposal of such waste will be managed by a dedicated waste managing contractor. Adequate waste collection bins will be supplied. Appropriate waste signage will be used at appropriate places to increase awareness among residents/visitors. The solid waste management plan will be developed and facilities for collection, storage and transportation will be established and organized. A storage facility will be so placed that it is accessible to resident, employees and visitors of the project. A storage area will be allocated for storage and pre - treatment of the waste. This storage area will be covered and the pollutants from the waste would not affect the surrounding. Waste managing contractor should have binding to dispose the waste to official dumpsites of Karachi. 4. Wastewater Grease interceptor and / or oil skimmer to be installed on kitchen effluent to Proponent Proponent/IMC Generation maintain oil levels within SEQS limits. &Disposal Water conservation strategies will be employed to avoid wastage of water. Waste segregation measures would be employed to minimize entry of solid waste into the wastewater stream. Periodic preventive maintenance of pumps, diffusers and other ancillary equipment’s. Periodic monitoring of wastewater to ensure compliance with SEQS. Provision of proposed package wastewater treatment plant so that the effluent is primary treated and then disposed of to the main sewer line. It is proposed by the EIA Consultant that a dedicated sewerage treatment plant Proponent Proponent/IMC shall be installed and the space shall be designated in the master plan of the

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Environmental Impact Assessment (EIA) Study Sumya Northern Industrial Zone

project to overcome the sewage problem. This system effectively eliminates contaminants from the effluent and then releases the effluent water for non- potable uses such as horticulture purposes and daily water requirements for trees and road islands. The cleaning agents used will be non-hazardous. Proponent Proponent/IMC 5. Energy The energy usage during the operational phase will be monitored and targets Proponent Proponent/IMC Consumption would be set for efficient use of energy. The occupants of the apartments will be sensitized to ensure energy efficiency in their domestic operations. The energy-efficient lighting system installed for the project will contribute immensely to energy saving during the operational phase of the project. 6. Air Emission Regularly carry out ambient air quality monitoring at various points on the access Proponent Proponent/IMC road and immediately outside the proposed project premises. Carbon monoxide detectors are to be provided in car parking which would be interlocked with the ventilation system. Monitor all exhausts at regular frequency. Carry out regular maintenance of generators. 7. Traffic Flow & Designated parking areas will be provided for the type of project vehicles within Proponent Proponent/IMC Congestion and around the project site. Traffic management plan will be introduced to manage smooth flow of vehicular traffic and to avoid traffic jam. Engineering design to examine vehicles exit and entry strategy so that it aligns with the traffic flow to cause minimum hindrance. Traffic management plan will be implemented and monitored. Vehicles will be parked at designated parking areas during operational phase. Parking of vehicles alongside the road would be prohibited at all times. Ramp slopes and passage areas to cater for worst case scenarios traffic flow on the main and service roads. 8. Illumination Evaluation of minimum illumination requirement will be carried out in MEP Proponent Proponent/IMC design. It is suggested to keep the levels at minimum for all external lightning.

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Environmental Impact Assessment (EIA) Study Sumya Northern Industrial Zone

9. Fire Standard fire and smoke detection and protection devices such as alarms, fire Proponent Proponent/IMC hoses and hydrants to be provided in all critical. A dedicated fire tender (brigade) will be available at the project proponent. For all engineering designs, NFPA (National Fire Protection Association) codes needs to be followed. The facility would possess a detailed emergency and evacuation plan that must be regularly drilled to make sure that the responsible staff remains trained at all times. Firefighting equipment such as fire extinguishers and hydrant systems would be maintained at strategic locations within the premises. Regular inspection and servicing of the extinguishers will be undertaken by a reputable service provider and record of such inspections should be maintained. Signs such as “NO SMOKING” will be prominently displayed within the premises, especially in parts where inflammable material are handled. 10. Socio- Shading to be provided to overcome this problem. Proponent Proponent/IMC economic Plantation around the boundary wall will be done to restrict the gazing and to Impacts provide a buffer between the other schemes and villages.

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Environmental Impact Assessment (EIA) Study Sumya Northern Industrial Zone

Table 7.3: Environmental Monitoring Plan (Construction Phase) Environmental Concerns Parameters to be Monitoring Location Frequency Standards Responsibility Monitored Ambient Air Quality - SPM Construction Site - Contractor (Suspended - Proponent / Particulate - IMC Matter), - PM10 (Particulate - Matter<10 microns), Quarterly SEQS - PM2.5 (Particulate Matter - <2.5 microns), - SOx, NOx. CO, O3, Lead Exhaust emissions - Generator and - Contractor from generators, Equipments: CO, Exhaust at - Proponent / construction NOx, SOx and construction site IMC Quarterly SEQS equipment & PM Generators Vehicles - Vehicles: Smoke, Equipment, Vehicles etc. CO and Noise Noise level - Decibels Construction site as well - Contractor [dB(A)Scale] as the generators, - Proponent / Quarterly SEQS equipment and the IMC vehicles. Drinking Water - Heavy metals, TDS, Drinking water Sources - Contractor TSS, pH, Total Sindh Standards for - Proponent / Quarterly Coliform, Fecal Drinking water quality - IMC Coliform Wastewater - Temperature, pH, Camp site discharge - Contractor BOD5, COD, TSS, points into drains - Proponent / Quarterly SEQS TDS, Oil & IMC - Grease

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Environmental Impact Assessment (EIA) Study Sumya Northern Industrial Zone

Solid Waste Management - Record and logging At main solid waste - Contractor of daily generated collection point from where Best Practices / - Proponent / waste. Hazardous the waste is transported Proponent IMC On going and non- from site management hazardous waste procedures quantity Soil Contamination - Visual inspections Construction site and its On going - Contractor and photographic surrounding are Best Practices - Proponent / evidences IMC Occupational Health and - HSE compliance Construction site On going Best Practices / - Contractor Safety Proponent - Proponent / management IMC procedures

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Environmental Impact Assessment (EIA) Study Sumya Northern Industrial Zone

Table 7.4: Environmental Monitoring Plan (Operation Phase) Environmental Parameters to be Monitoring Frequency Standards Responsibility Concerns Monitored Location Ambient Air Quality - SPM (Suspended Particulate Matter), - PM10 (Particulate Matter<10 microns), Project Site Quarterly SEQS Proponent / IMC - PM2.5 (Particulate Matter <2.5 microns), - SOx, NOx. CO, O3, Lead Exhaust emissions - CO, NOx, SOx and PM Exhaust at Generator, Vehicles - Vehicles: Smoke, COx and operational site, Noise Generators, Quarterly SEQS Proponent / IMC Equipment, Vehicles etc. Noise level - Decibels [dB(A)Scale] At the interface of proposed facility & neighborhood, Quarterly SEQS Proponent / IMC generators, equipment and the vehicles. Drinking Water - Heavy metals, TDS, TSS, Sindh pH, Total Coliform, Fecal Drinking water Standards for Quarterly Proponent / IMC Coliform Sources Drinking water quality Wastewater - Effluent Flow, Temperature, pH, BOD5, Wastewater COD, TSS, TDS, Oil & Monthly SEQS Proponent / IMC Discharge Point - Grease, Copper and Chromium Solid Waste Management - Record and logging of daily Waste storage Project On going Proponent / IMC generated waste. and transportation management

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Environmental Impact Assessment (EIA) Study Sumya Northern Industrial Zone

- Hazardous and non- procedures hazardous waste quantity - Waste Disposal record Soil Resource - Visual inspection for Best Practices/ contamination and oil spills Project Project Site On going management Proponent / IMC spill control procedures Occupational Health and - HSE compliance Project Project Site On going Proponent / IMC Safety management

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Environmental Impact Assessment (EIA) Study Sumya Northern Industrial Zone

Chapter 8 CONCLUSION

The EIA study for Project has identified potential impacts that are likely to arise during construction and operational phases of the project. Potential environmental impacts are associated with air quality, solid waste, wastewater, noise, surface and groundwater quality, soil quality, terrestrial biodiversity, resource use, health and safety, as well as socio-economic impacts. The project is expected to bring a positive change in the socioeconomic setup of the area through creation of jobs.

Potential Project impacts have been identified related to the project construction and operation phases. Impact predictions are based on the consultants’ previous experiences on similar projects; professional judgment; data collected in the field; discussions with local communities, relevant government officials and relevant technical specialists. Many of the mitigation measures are related to good design practices, others with good construction and housekeeping practices.

A series of mitigation and monitoring measures have been included to address the concerns for these measures. Assuming effective implementation of the mitigation measures and monitoring requirements as outlined in the Environmental Management Plan, the adverse environmental and social impacts of the proposed Project activities and operations of the facility are likely to be within the acceptable limits.

It can be said with confidence that every effort will be been made by S.B. Associates to accommodate the mitigation measures recommended during the EIA process to the extent that is practically possible, without compromising the economic viability of the Project. The implementation of the mitigation measures, detailed in Chapter 7 and listed in the Environmental Management Plan (EMP) of the EIA Report, including monitoring, will provide a basis for ensuring that the potential positive and negative impacts associated with the establishment of the development are enhanced and mitigated to a level which is deemed adequate for the development to proceed.

In summary, based on the findings of this assessment there is no reason why the proposed project should not be authorized, dependent on the mitigations and monitoring for potential environmental and socio-economic impacts as outlined in the Environmental Impact Assessment and EMP being implemented.

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ANNEXURES

Annex I: Site Plan

Annex II: Ambient Air Quality and Nosie Monitoring Reports

EPA Certified Lab EPA/LAB/Certificate/QTS-11/2013

QMS/III/018 PM Revision : 03 Date 14.01.2021

Ambient Air Quality Test Report Project Name: Northern Industrial Zone Test Report No: QTS/NIZ/21/8984

Client Name: M/s S.B. Associates Sample Duration: 24hr’s 25° 01'53.68"N Sample Description: Ambient Air Quality Test Location: 67° 01'12.77"E

SEQS-PARAMETERS

CO NO NO2 SO2 PM 10 PM 2.5 SPM Lead Date Time (µg/m3) (µg/m3) (µg/m3) (µg/m3) (µg/m3) (µg/m3) (µg/m3) (µg/m3) 09.03.2021 10:00 12.3 14.8 18.5 83 26 278 BDL 0.14 09.03.2021 11:00 14.3 17.0 19.4 87 35 245 BDL 09.03.2021 12:00 14.9 13.4 20.2 89 30 221 BDL 09.03.2021 13:00 16.2 11.2 22.3 93 29 233 BDL 0.09 09.03.2021 14:00 18.3 09.4 24.4 101 21 275 BDL 09.03.2021 15:00 19.5 07.9 25.9 105 23 239 BDL 09.03.2021 16:00 18.6 09.4 26.2 109 19 245 BDL 0.08 09.03.2021 17:00 17.3 10.8 21.9 112 18 254 BDL 09.03.2021 18:00 16.5 14.4 20.6 126 20 291 BDL 09.03.2021 19:00 12.6 12.5 19.2 132 28 304 BDL 0.12 09.03.2021 20:00 12.9 15.3 18.3 125 33 319 BDL 09.03.2021 21:00 13.0 12.4 19.5 118 37 310 BDL 09.03.2021 22:00 11.4 16.5 20.6 107 42 302 BDL 0.24 09.03.2021 23:00 10.6 18.5 21.4 90 39 194 BDL 10.03.2021 00:00 10.2 20.0 20.7 85 33 287 BDL 10.03.2021 01:00 10.0 21.4 17.0 72 28 291 BDL 0.18 10.03.2021 02:00 11.3 22.2 12.2 71 25 290 BDL 10.03.2021 03:00 12.5 19.6 14.3 66 21 282 BDL 10.03.2021 04:00 13.8 16.7 15.4 62 20 278 BDL 0.12 10.03.2021 05:00 14.5 14.5 13.3 67 19 251 BDL 10.03.2021 06:00 14.9 13.6 14.2 82 18 243 BDL 10.03.2021 07:00 15.3 15.3 18.5 89 16 250 BDL 0.10 10.03.2021 08:00 12.6 18.7 19.5 95 21 261 BDL 10.03.2021 09:00 13.8 21.2 20.3 98 24 274 BDL MIN 0.08 10.0 07.9 21.2 62 16 221 BDL MAX 0.24 19.5 22.2 31.5 132 42 319 BDL AVG 0.13 14.0 15.2 19.3 94.3 26.0 267.3 BDL SEQS 5 40 80 120 150 75 500 1.5 LDL-Limits 0.01 0.0 0.0 0.0 10 2.5 1.0 0.01

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EPA Certified Lab EPA/LAB/Certificate/QTS-11/2013

QMS/III/018 PM Revision : 03 Date 14.01.2021

Ambient Air Quality Test Report Test Report No: QTS/NIZ/21/8984 Project Name: Northern Industrial Zone Sample Duration: 24hr’s Client Name: M/s S.B. Associates 25° 01'53.68"N Location: Sample Description: Ambient Air Quality Test 67° 01'12.77"E

Average Monitoring LDL- Parameter Unit Obtained SEQS Methodology Duration Limits Concentration Non Dispersive Carbon Monoxide (CO) mg/m3 08 Hours 0.13 5.0 0.01 Intra Red (NDIR) Nitrogen oxide (NO) µg/m3 24 Hours 14.0 40.0 0.0 Chemiluminescence Nitrogen Dioxide (NO2) µg/m3 24 Hours 15.2 80.0 0.0 Ultraviolet Sulphur Dioxide (SO2) µg/m3 24 Hours 19.3 120.0 0.0 Fluorescence Method Non Dispersive UV Ozone (O3) µg/m3 01 Hour 22.4 130.0 0.0 Absorption Method Particulate Matter (PM10) µg/m3 24 Hours 94.3 150.0 10.0 β Ray Absorption Particular Matter (PM2.5) µg/m3 24 Hours 26.0 75.0 2.5 Method Suspended Particulate µg/m3 24 Hours 267.3 500.0 1.0 Matter (SPM) Lead (Pb) µg/m3 24 Hours BDL 1.5 0.01 ASS Method SEQS= Sindh Environmental Quality Standards (The Gazette of Pakistan) Registered No. EPA/TECH/739/2014 (24 Hours Standard for all the parameters Except O3 and CO), µg/m3= Micrograms per Cubic Meter mg/m3= Milligrams per Cubic Meter ND= Not Detected LDL=Least Detection Limit Terms & Conditions:  This report is not valid for any negotiations  Report is valid for current batch(sample)  This report is intended only for your guidance & not for legal purpose or for advertisement.

Signature of Laboratory Incharge:______Sample Analyzed By: Sajid Ali Name : Sumbla Ahmed

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EPA Certified Lab EPA/LAB/Certificate/QTS-11/2013

QMS/III/018 PM Revision : 03 Date 14.01.2021

Lab Report Ref. No. : QTS/NIZ/21/8983 Reporting Date: 12/03/2021 Project: EMC-EIA Project Northern Industrial Zone SAMPLE DESCRIPTION Sample ID: Noise Level Test Sample Description: Ambient Noise No. of samples: 04 Sample Collected/Submitted by: QTS representative Sampling Date :09/03/2021 Sample Receipt at QTS - Date : 09/03/2021

NOISE LEVEL TEST REPORT Noise Level Readings S.NO. LOCATION/SOURCE Minimum Maximum Average Mean 1 Front Side Right Corner 45.5 56.4 50.9 SEQS 2 Front Side Left Corner 46.2 57.6 51.9 Limits : 3 Back Side Right Corner 42.4 50.2 46.3 *75dB(A) *Leq 4 Back Side Left Corner 41.8 51.0 46.4 SEQS= Sindh Environmental Quality Standards (The Gazette of Pakistan) Registered No. EPA/TECH/739/2014 *dB (A) Leq:= Time weighted average of the level of sound in decibel on scale which is relatable to human hearing. *Noise Standard Limits for Category (C)- Industrial Area/Zone. Terms & Conditions:  This report is not valid for any negotiations  Report is valid for current batch(sample)  This report is intended only for your guidance & not for legal purpose or for advertisement.

Comments: The Noise level from the source is within acceptable level as describe in SEQS.

Signature of Laboratory In charge:______Sample Analyzed by: Sajid Ali Name : Sumbla Ahmed

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Annex III: No Objection Certificate (NOC) and Approvals

Annex IV: SEPA (Review of IEE/EIA) Regulations 2014

GOVERNMENT OF SINDH SINDH ENVIRONMENTAL PROTECTION AGENCY

Karachi dated the 16th December, 2014.

NOTIFICATION

NO.EPA/TECH/739/2014:- In exercise of the powers conferred by section 37 of the Sindh Environmental Protection Act, 2014, the Sindh Environmental Protection Agency, with the approval of Government, is pleased to make the following regulations, namely:-

1. Short title and commencement

(1) These regulations may be called the Sindh Environmental Protection Agency (Review of Initial Environmental Examination and Environmental Impact Assessment) Regulations, 2014.

(2) They shall come into force at once.

2. Definitions.-

(1) In these regulations, unless there is anything repugnant in the subject or context -

(a) “Act” means the Sindh Environmental Protection Act, 2014 (VIII of 2014);

(b) “Agency” means the Sindh Environmental Protection Agency as defined under section 2(ii);

(c) “Committee” means the Environmental Assessment Advisory Committee constituted under regulation 24;

(d) “Director General” means the Director General of the Agency;

(e) “EIA” means an environmental impact assessment as defined in section 2(xv);

(f) “IEE” means an initial environmental examination as defined in section 2(xxx);

(g) “section” means a section of the Act.

(h) "Firm” means the Environmental Consulting Firm certified by the Agency;

1 (i) “Environmental Sensitive areas” means the area which falls under sensitive sites like protected areas, or the sites which may have crucial and growing importance;

(j) “protected area” means any area which safeguards the earths precious bio-diversity protect outstanding areas of natural beauty and conservation of cultural significance;

(k) “Schedule” means the Schedule to these regulations;

(l) “urban area” means an area within the limits of a town, municipality or city and includes any area declared as such by Government by notification in the official gazette;

(2) All other words and expressions used but not defined in these regulations shall have the same meaning as are assigned to them in the Act.

3. Projects requiring an IEE

A proponent of a project falling in any category listed in Schedule-I shall file an IEE with the Agency, and the provisions of section 17 shall apply to such projects.

4. Projects requiring an EIA

A proponent of a project falling in any category listed in Schedule-II shall file an EIA with the Agency, and the provisions of section 17 shall apply to such projects.

5. Projects requiring checklist

A proponent of a project falling in any category listed in Schedule-III shall file environmental checklist with the Agency and the provisions of section 17 shall apply to such projects.

6. Projects not requiring an IEE or EIA

(1) A proponent of a project not falling in any category listed in Schedules-I, II and III shall not be required to file an IEE or EIA:

Provided that the proponent shall file -

(a) an EIA, if the project is likely to cause an adverse environmental effects;

(b) an application for projects not listed in Schedules-I, II and III in respect of which the Agency has issued guidelines for construction and operation for approval accompanied by an undertaking and an affidavit that the aforesaid guidelines shall be fully complied with.

2 (2) Notwithstanding anything contained in sub-regulation (1), the Agency may direct the proponent of a project, whether or not listed in Schedule I or II or III, to file an IEE or EIA or environmental check list, for reasons to be recorded in such direction:

Provided that no such direction shall be issued without the recommendations in writing of the Committee.

(3) The provisions of section 17 shall apply to a project in respect of which an IEE or EIA or environmental checklist is filed under sub-regulation (1) or (2).

7. Preparation of IEE/EIA and environmental checklist

(1) The Agency may issue guidelines for preparation of an IEE or an EIA or an environmental checklist, including guidelines of general applicability, and sectoral guidelines indicating specific assessment requirements for planning, construction and operation of projects relating to particular sector.

(2) Where guidelines have been issued under sub-regulation (1), an IEE or EIA or environmental checklist shall be prepared, to the extent practicable, in accordance therewith and the proponent shall justify in the IEE or EIA or in environmental checklist any departure therefrom.

8. Review Fees

The proponent shall pay, at the time of submission of an IEE or EIA or environmental checklist, a non-refundable review fee to the Agency as per rates shown in Schedule-IV

9. Filing of IEE, EIA and environmental check list.

(1) Ten hard copies and two electronic copies for an IEE and EIA reports shall be filed with the Agency prepared by Firm.

(2) Every IEE and EIA shall be accompanied by -

(a) an application, in the form prescribed in Schedule-V;

(b) copy of receipt showing payment of the Review Fee.

(c) no objection certificates from the relevant departments in case of EIA shall be the part of reports;

(d) the environmental check list as per its guidelines.

10. Preliminary scrutiny

(1) Within fifteen working days of filing of the IEE or EIA or environmental check 3 list, the Agency shall –

(a) confirm that the IEE or EIA or environmental check list is complete for purposes of initiation of the review process; or

(b) require the proponent to submit such additional information as may be specified; or

(c) return the IEE or EIA or environmental checklist to the proponent for revision, clearly listing the points requiring further study and discussion.

(2) Notwithstanding anything contained in sub-regulation (1), the Agency may require the proponent to submit an additional information at any stage during the review process.

11. Public participation

(1) In the case of an EIA, the Agency shall simultaneously with issue of confirmation of completeness under sub-regulation (2) of regulation 9, cause to be published in any English or Urdu national newspaper and in a local newspaper of general circulation in the area affected by the project, a public notice mentioning the type of project, its exact location, the name and address of the proponent and the places at which the EIA of the project can, subject to the restrictions in sub-section (3) of section 17, be accessed.

(2) The notice issued under sub-regulation (1) shall fix a date, time and place of public hearing for any comments on the project or its EIA.

(3) The date fixed under sub-regulation (2) shall not be earlier than fifteen days from the date of publication of the notice.

(4) The Agency shall also ensure the circulation of the EIA to the concerned Government Agencies and solicit their comments thereon.

(5) All comments received by the Agency from the public or any Government Agency shall be collated, tabulated and duly considered by it before decision on the EIA.

(6) The Agency may issue guidelines indicating the basic techniques and measures to be adopted to ensure effective public consultation, involvement and participation in EIA assessment.

12. Review

(1) The Agency shall make every effort to carry out its review of the environmental checklist within thirty days, IEE within sixty days, and of the EIA within four months of issue of confirmation of completeness under regulation 9.

4 (2) In reviewing the EIA, the Agency shall consult such Committee of Experts be constituted for the purpose by the Director General, and may also solicit views of concerned Advisory Committee, if any, constituted by the Agency.

(3) The Director-General may, where he considers it necessary, constitute a committee to inspect the site of the project and submit its report on such matters as may be specified.

(4) In reviewing the IEE, the Director General may constitute a committee of the officers from within the Agency on case to case basis in view of the jurisdiction and location of the project for the purpose to extend final recommendation about the approval or rejection of the IEE.

(5) In reviewing of the IEE, the Director General may direct the proponent and Firm to present the report before the committee as given under sub- regulation (4) and the Director General may also invite environmental experts from outside the Agency for the purpose of assistance.

(6) The review of the IEE or EIA by the Agency shall be based on quantitative and qualitative assessment of the documents and data furnished by the proponent, comments from the public and Government Agencies received under regulation 10, and views of the committees mentioned in sub-regulations (2) and (3) above.

(7) The environmental check list shall be reviewed as per guidelines issued by the Agency.

13. Decision

(1) Subject to regulation 9 and 11, the documentary evidence in the form of videos (soft copies) of public hearing shall be submitted by the proponent at the time of environmental approval or at any stage of review process, to the Agency.

(2) On completion of the review, the decision of the Agency shall be communicated to the proponent in the form prescribed in Schedule-VI in the case of an IEE and environmental check list, and in the form prescribed in Schedule-VII in the case of an EIA and for environmental checklist.

14. Conditions of approval

(1) Every approval of an IEE or EIA or check list shall, in addition to such conditions as may be imposed by the Agency, be subject to the condition that the project shall be designed and constructed, and mitigatory and other measures adopted, strictly in accordance with the IEE or EIA or environmental check list, unless any variations thereto have been specified in

5 the approval by the Agency.

(2) Where the Agency accords its approval subject to certain conditions, the proponent shall -

(a) before commencing construction of the project, acknowledge acceptance of the stipulated conditions by executing an undertaking in the form prescribed in Schedule-VIII;

(b) before commencing operation of the project, obtain from the Agency written confirmation that the conditions of approval, and the requirements in the IEE or EIA or environmental check list relating to design and construction, adoption of mitigatory and other measures and other relevant matters, have been duly complied with.

15. Confirmation of compliance

(1) The request for confirmation of compliance under clause (b) of sub-regulation (2) of Regulation 13 shall be accompanied by an Environmental Management Plan indicating the measures and procedures proposed to be taken to manage or mitigate the environmental impacts for the life of the project, including provisions for monitoring, reporting and auditing.

(2) Where a request for confirmation of compliance is received from a proponent, the Agency may carry out such inspection of the site and plant and machinery and seek such additional information from the proponent as it may deem fit:

Provided that every effort shall be made by the Agency to provide the requisite confirmation or otherwise within twenty days of receipt of the request, with complete information, from the proponent.

(3) The Agency may, while issuing the requisite confirmation of compliance, impose such other conditions as the Environmental Management Plan, and the operation, maintenance and monitoring of the project as it may deem fit, and such conditions shall be deemed to be included in the conditions to which approval of the project is subject.

16. Deemed approval

The period for communication of decision stipulated in sub-section (4) of section 17 shall commence from the date of filing of an IEE or EIA or environmental check list in respect of which confirmation of completeness is issued by the Agency under clause (a) of sub-regulation (1) of regulation 9.

17. Extension in review period

Where the Agency in a particular case extends the period of four months under the provisions of sub-section (4) of section 17, it may extend the further period as it may 6 deem fit, for the reasons to be recorded in writing thereof.

18. Validity period of approval

(1) The approval accorded by the Agency under section 17 read with regulation 12 shall be valid, for commencement of construction, for a period of three years from the date of issue.

(2) If construction is commenced during the initial three years validity period, the validity of the approval shall stand extended for a further period of three years from the date of issue.

(3) After issue of confirmation of compliance, the approval shall be valid for a period of three years from the date thereof.

(4) The proponent may apply to the Agency for extension in the validity periods mentioned in sub-regulations (1), (2) and (3), which may be granted by the Agency in its discretion for such period not exceeding three years at a time, if the conditions of the approval do not require significant change:

Provided that the Agency may require the proponent to submit a fresh IEE or EIA, if in its opinion changes in location, design, construction and operation of the project so warrant.

19. Entry and inspection

(1) For the purpose of verification of any matter relating to the review or to the conditions of approval of an IEE or EIA or environmental check list prior to, before or during and after commencement of construction or operation of a project, duly authorized staff of the Agency shall be entitled to enter and inspect the project site, factory building and plant and equipment installed therein.

(2) The proponent shall ensure full cooperation of the project staff at site to facilitate the inspection, and shall provide such information as may be required by the Agency for this purpose and pursuant thereto.

20. Monitoring

(1) After issue of approval, the proponent shall submit a report to the Agency on completion of construction of the project.

(2) After issue of confirmation of compliance, the proponent shall submit an annual report summarizing operational performance of the project, with reference to the conditions of approval and maintenance and mitigatory measures adopted by the project.

7 (3) The proponent shall, in order to enable the Agency to effectively monitor compliance with the conditions of approval, furnish such additional information as the Agency may require.

21. Cancellation of approval

(1) Notwithstanding anything contained in these regulations, if, at any time, on the basis of information or report received or inspection carried out, the Agency is of the opinion that the conditions of an approval have not been complied with, or that the information supplied by a proponent in the approved IEE or EIA or environmental check list is incorrect, it shall issue notice to the proponent for show cause within two weeks of receipt thereof as to why the approval should not be cancelled.

(2) In case no reply is received or if the reply is considered unsatisfactory, the Agency may, after giving the proponent an opportunity of being heard -

(i) require the proponent to take such measures and to comply with such conditions within such period as it may specify, failing which the approval shall stand cancelled; or

(ii) cancel the approval.

(3) On cancellation of the approval, the proponent shall cease construction or operation of the project forthwith.

(4) Any action taken under this regulation shall be without prejudice to any other action that may be taken against the proponent under the Act or rules or regulations or any other law for the time being in force.

22. Registers of IEE,EIA and Check list projects

Separate Registers to be maintained by the Agency for IEE, EIA and environmental check list projects under sub-section (6) of section 17 shall be in the form prescribed in Schedule-IX.

23. Environmentally sensitive areas

(1) The Agency may, by notification in the official Gazette, designate an area to be an environmentally sensitive area.

(2) Notwithstanding anything contained in regulations 3, 4 and 5, the proponent of a project situated in an environmentally sensitive area shall be required to file an EIA with the Agency.

(3) The Agency may from time to time issue guidelines to assist proponents and other persons involved in the environmental assessment process to plan and prepare projects located in environmentally sensitive areas.

8 (4) Where guidelines have been issued under sub-regulation (3), the projects shall be planned and prepared, to the extent practicable, in accordance therewith and any departure therefrom justified in the EIA pertaining to the project.

24. Environmental Assessment Advisory Committee.- For the purpose of rendering advice on all aspects of the environmental assessment including guidelines procedure and categorization of projects, the following Advisory Committee shall be constituted:-

(i) Director Technical, Sindh Environmental Protection Agency Chairman (EIA/IEE)

(ii) Chief Environment, Planning and Development Department Member

(iii) Four representative on each of industry, non-Governmental Members organization, legal and other experts

25. Repeal and Savings. (1) The provisions of the Pakistan Environmental Protection Agency Review of Initial Environmental Examination and Environmental Assessment Impact Regulations 2000, to the extent of the Province of Sindh are hereby repealed.

(2) All orders made, notification issued, actions taken under the repealed Regulations shall remain in force until amended, altered or repealed by the provisions of these Rules.

DIRECTOR GENERAL SINDH ENVIRONMENTAL PROTECTION AGENCY

9 SCHEDULE I (See Regulation 3)

A. Agriculture, Livestock and Fisheries

1. Poultry, livestock, stud and fish farms

2. Projects involving packaging, formulation, cold storage and warehouse of agricultural products.

B. Energy

1. Hydroelectric power generation less than 50 MW

2. Thermal power generation less than 100MW

3. Coal fired power plants with capacity less than 50 MW

4. Transmission lines less than 11 KV, and grid station

5. Waste-to-energy generation projects including bio-mass less than 25 MW

6. Solar project

7. Wind project

C. Oil and Gas projects:

1. Oil and gas 2D/3D Seismic survey and drilling activities

2. Oil and gas extraction projects including exploration and production located outside the environmentally sensitive areas

3. Construction of LPG storage facilities

4. Construction of LPG,CNG filling station and petrol pumps

D. Manufacturing and processing

1. Ceramics and glass units less than 500 million

2. Food processing industries with total cost less than Rs. 200 millions

3. Pharmaceutical units.

4. Marble units

10 5. Carpet manufacturing units

6. Rice mills, ghee/oil mills ,

7. Brick kilns

8. Stone crushing units

9. Man-made fibers and resin projects with total cost less than Rs. 200 millions

10. Manufacturing of apparel, textile garments unit , including dyeing, bleaching and printing, with total cost less than Rs.50 million

11. Wood products with total cost more than Rs.100 million

12. Steel re-rolling mills

13. Recycling plants

E. Mining and mineral processing

Commercial extraction of sand, gravel, limestone, clay, sulphur and other minerals not included in Schedule II with total cost less than Rs.100 million

1. Crushing, grinding and separation processes

2. Smelting plants with total cost less than Rs100 millions

F. Transport

1. Flyovers, underpasses and bridges having total length less than 500 meters

G. Water management, dams, irrigation and flood protection

1. Dams and reservoirs with storage volume less than 25 million cubic meters of surface area less than 4 square kilometers

2. Small-scale irrigation systems and drainage system with total cost less than Rs. 100 million

H. Water supply and filtration

Water supply schemes and filtration plants with total cost less than 100 million (Including projects of maintenance, up gradation, reconstruction of existing projects.)

I. Waste disposal and treatment

11 1. Solid and non-hazardous waste with annual capacity less than 10,000 tons

2. Waste water treatment for sewage treatment facility with total cost less than 200M

3. Industry specific Waste water treatment facility for Industrial effluent (small scale plant)

J. Urban development

1. Housing schemes less than 10 acres

2. Mutli-story buildings having residential and commercial setup on the total plot size is less than 2000 sq.yards

3. Hospitals with capacity of 50 beds, health care unit/laboratories with 500 OPD/day.

4. Construction of Educational, Academic institutions on land less than 10 acres.

K. Other projects

Any other project for which filing of an IEE is required by the Agency under sub- regulation (2) of Regulation 6.

12 SCHEDULE II

(See Regulation 4)

List of projects requiring an EIA

A. Energy

1. Hydroelectric power generation over 50 MW

2. Thermal power generation over 100MW

3. Coal power projects above 50 MW

4. Transmission lines (11 KV and above) and distribution projects.

5. Nuclear power plants

6. Wind energy projects if falls under any sensitive, protected area.

B. Oil and Gas projects

1. Petroleum refineries.

2. LPG and LNG Projects(including LNG Terminals, re-gasification units) except LPG filling stations

3. Oil and gas transmission systems

4. Oil and gas gathering system, separation and storage.

C. Manufacturing and processing 1. Cement plants 2. Chemical manufacturing industries 3. Fertilizer plants 4. Steel Mills 5. Sugar Mills and Distilleries 6. Food processing industries including beverages, dairy milk and products, slaughter houses and related activities with total cost more than Rs. 200 Million 7. Industrial estates (including export processing zones) 8. Man-made fibers and resin projects with total cost of Rs 200M and above 9. Pesticides (manufacture or formulation) 10. Petrochemicals complex 11. Synthetic resins, plastics and man-made fibers, paper and paperboard, paper pulping, plastic products, textiles (except apparel),printing and publishing, paints and dyes, oils and fats and vegetable ghee projects, with total cost more than Rs. 13 10 million 12. Tanning and leather finishing projects 13. Battery manufacturing plant

D. Mining and mineral processing

1. Mining and processing of coal, gold, copper, sulphur and precious stones

2. Mining and processing of major non-ferrous metals, iron and steel rolling

3. Smelting plants with total cost of Rs. 100 million and above

E. Transport

1. Airports

2. Federal or Provincial highways or major roads (including rehabilitation or rebuilding or reconstruction of existing roads)

3. Ports and harbor development

4. Railway works

5. Flyovers, underpasses and bridges having total length of more than 500m

F. Water management, dams, irrigation and flood protection

1. Dams and reservoirs with storage volume of 25 million cubic meters and above having surface area of 4 square kilometers and above

2. Irrigation and drainage projects serving 15,000 hectares and above

3. Flood Protection

G. Water supply and filtration

Large Water supply schemes and filtration plants.

H. Waste Disposal and treatment

1. Handling, storage or disposal of hazardous or toxic wastes or radioactive waste (including landfill sites, incineration of hospital toxic waste )

2. Waste disposal facilities for municipal or industrial wastes, with total annual capacity of 10,000 tons and above.

3. Waste water treatment facility for industrial or municipal effluents.

14 I. Urban development and tourism

1. Housing schemes above 10 acres

2. Residential/commercial high rise buildings/apartments from15 stories and above.

3. Land use studies and urban plans (large cities)

4. Large scale public facilities.

5. Large-scale tourism development projects

J. Environmentally Sensitive Areas

All projects situated in environmentally sensitive areas

K. Other projects

1. Any other project for which filing of an EIA is required by the Agency under sub-regulation (2) of Regulation 5.

2. Any other project likely to cause an adverse environmental effect

15 SCHEDULE-III List of projects requiring environmental screening (through check list) a. Construction of, offices and small commercial buildings (1-6 story),home industrial units, ware houses, marriage / banquet facilities, large scale motor vehicles workshops, restaurants / food outlets ,large baking unit subject to the compliance with existing zoning laws.

b. Reconstruction / rehabilitation of roads ( small roads in urban area and farm to market roads more than 2 km.

c. On-farm dams and fish farms.

d. Pulses mills.

e. Flour Mills

f. Projects promoting energy efficiency (small scale).

g. Lining of existing minor canals and /or water courses.

h. Canal cleaning

i. Forest harvesting operations

j. Rain harvesting projects

k. Rural schools (Secondary and Higher Secondary) and rural and basic health units having at least ten beds capacity.

l. BTS Towers

m. Lime Kilns

n. Ice factories and cold storage.

o. Cotton oil mill

p. Warehouses for pesticides and pharmaceuticals

16 Schedule-IV

(See Regulation 7)

Environmental Check Description IEE EIA list

Rs.30,000 except BTS Towers which is Projects Rs.100,000 Rs.200,000 Rs.15,000

17 SCHEDULE V [See Regulation 8(2)(a)] Application Form

1. Name and address of Phone: Proponent Fax: Telex: 2. CNIC No. of proponent 3. Description of project

4. Location of project

6. Objectives of project

7. IEE/EIA attached? IEE/EIA : Yes/No

8. Have alternative sites been considered and Yes/No reported in IEE/EIA? 9. No Objection Certificate of relevant Name(s) stakeholders 10. Existing land use Land requirement 11. Is basic site data (only tick yes if the available, or has it data is reported in the been measured? IEE/EIA) Available Measured Meterology (including Yes/No Yes/No rainfall) Ambient air quality Yes/No Yes/No Ambient water quality Yes/No Yes/No Ground water quality Yes/No Yes/No 12. Have estimates of the Estimated Reported following been Water balance Yes/No Yes/No reported, especially Solid waste disposal Yes/No Yes/No Quantitative Analysis? Liquid waste treatment Yes/No Yes/No 13. Source of power Power requirement 14. Labour force Construction: (number) Operation: 15. Environmental Consulting Firm Verification. I do solemnly affirm and declare that the information given above and contained in the attached IEE/EIA is true and correct to the best of my knowledge and belief.

Date Signature, name and ______designation of proponent (with official stamp/seal)

18 SCHEDULE VI [See Regulation 12]

Decision on IEE/Environmental Check List

1. Name and address of proponent

2. Description of project

3. Location of project

4. Date of filing of IEE

5. After careful review of the IEE, the Agency has decided –

(a) to accord its approval, subject to the following conditions:

or (b) that the proponent should submit an EIA of the project, for the following reasons –

[Delete (a) or (b), whichever is inapplicable]

Dated

Tracking no.___

Director-General Sindh Environmental Protection Agency (with official stamp/seal)

19 SCHEDULE VII

[See Regulation 12]

Decision on EIA

1. Name and address of proponent

2. Description of project

3. Location of project

4. Date of filing of EIA

5. After careful review of the EIA, and all comments thereon, the Federation Agency has decided –

(a) to accord its approval, subject to the following conditions:

or (b) that the proponent should submit an EIA with the following modifications-

or (c) to reject the project, being contrary to environmental objectives, for the following reasons:

[Delete (a)/(b)/(c), whichever is inapplicable]

Dated

Tracking no.___

Director-General Sindh Environmental Protection Agency (with official stamp/seal)

20 SCHEDULE VIII [See Regulation 13(2)]

Undertaking

I, (full name and address) as proponent for (name, description and location of project) do hereby solemnly affirm and declare that I fully understand and accept the conditions dated , and undertake to design, construct and operate the project strictly in accordance with the said conditions and the IEE/EIA/Environmental Check List.

Signature, name and designation of proponent (with official stamp/seal)

Witnesses (full names and addresses)

21 SCHEDULE IX (See Regulation 21) Form of Registers for IEE and EIA and Environmental Check List projects

S. No. Description Relevant Provisions 1 2 3 1. Tracking number 2. Category type (as per Schedules I, II & III) 3. Name of proponent 4. Name and designation of contact person 5. Name of consultant

6. Description of project 7. Location of project 8. Project capital cost 9. Date of receipt of IEE/EIA/Environmental Check List 10. Date of confirmation of completeness 11. Approval granted (Yes/No) 12. Date of approval granted or refused 13. Conditions of approval/reasons for refusal 14. Date of Undertaking 15. Date of extension of approval validity 16. Period of extension

17. Date of commencement of construction

18. Date of issue of confirmation of compliance 19. Date of commencement of operations 20. Dates of filing of monitoring reports 21. Date of cancellation, if applicable

22