Environmental Assessment and Review Framework
Project No. 47279-002 June 2019
PAK: Karachi Bus Rapid Transit Red Line Project
Biogas Plant Development for Karachi Bus Rapid Transit Red Line Project
Prepared by Transport and Mass Transit Department, government of Sindh for the Asian Development Bank.
CURRENCY EQUIVALENTS (as of 11 June 2019) Currency unit – Pakistan rupee (PRs) PRs1.00 = $0.0067 $1.00 = PRs150
ABBREVIATIONS ADB – Asian Development Bank AFD – French Agency for Development AIIB – Asian Infrastructure Investment Bank BRT – bus rapid transit EARF – environmental assessment review framework EIA – environment impact assessment EMP – environmental management plan EPA – Environmental Protection Agency GCF – Green Climate Fund GOP – Government of Pakistan GoS – Government of Sindh IA – implementing agency IEE – initial environmental examination km – kilometer LAA – Land Acquisition Act (of 1984) LARP – land acquisition and resettlement plan Leq – equivalent sound pressure level NEQS – national environmental quality standards O&M – operation and maintenance SMTA – Sindh Mass Transit Authority TMTD – Transport and Mass Transit Department tpd – tonnes per day
NOTE (i) In this report, "$" refers to United States dollars unless otherwise stated.
This environmental assessment and review framework is a document of the borrower. The views expressed herein do not necessarily represent those of ADB's Board of Directors, Management, or staff, and may be preliminary in nature. Your attention is directed to the “terms of use” section on ADB’s website.
In preparing any country program or strategy, financing any project, or by making any designation of or reference to a particular territory or geographic area in this document, the Asian Development Bank does not intend to make any judgments as to the legal or other status of any territory or area.
Table of Content
I. Introduction ...... 6 A. Background ...... 6 B. Purpose of EARF ...... 6 C. Environmental Categorization ...... 7 II. Assessment of Legal Framework and Institutional Capacity ...... 7 A. Legal Framework for Environmental Assessment and Management ...... 7 National Policy and Legal Framework ...... 7 Regulations for Environmental Assessment, Pakistan EPA ...... 7 Sindh Environmental Protection Act, 2014 ...... 8 Other National and Sindh Government Laws and Regulations ...... 10 Regulatory Clearances, Sindh EPA ...... 12 Guidelines for Environmental Assessment, Pakistan EPA ...... 12 National Environmental Quality Standards (NEQS) 2000 ...... 12 Interaction with Other Agencies ...... 13 Provincial EPAs ...... 13 Provincial Departments of Forests and Wildlife ...... 13 Provincial Governments ...... 13 B. ADB Policies ...... 13 ADB’s Safeguard Policy Statement (SPS), 2009 ...... 13 ADB’s Access to Information Policy (AIP) 2018 ...... 14 ADB’s Accountability Mechanism Policy 2012 ...... 14 C. Implications of ADB’s safeguard policies on proposed project...... 14 D. Comparison of International and Local Environmental Legislations...... 16 III. Project Description ...... 21 IV. Anticipated Environmental Impacts ...... 23 V. Consultation, Information Disclosure and Grievance Redress Mechanism 27 A. Public Consultation and Information Disclosure ...... 27 B. Grievance Redress Mechanism ...... 28 VI. Institutional Arrangement and Responsibilities ...... 28 A. Staffing Requirements and Budget ...... 30 VII. Monitoring and Reporting ...... 31
ANNEXURES
Annexure-I ADB Rapid Environmental Assessment (REA) Checklist
Annexure-II Outline of an Environmental Assessment report
Annexure-III Terms of Reference for Consulting Services for Environmental Assessment
Annexure-IV Outline of Environmental Monitoring Report
List of Tables
Table II.1: Other National and Sindh Government Laws and Regulations ...... 10
Table II.2: ADB Policy Principles………………………………………………………15
Table II.3: IFC Work Environment Noise limits……………………………………..17
Table II.4: Comparison of International and local Air Quality Standards……...18
Table II.5: Comparison of International and Local Noise Standards………..….20
Table III.1: Indicative Impacts ...... 23
I. Introduction
A. Background 1. This Environmental Assessment Review Framework (EARF) document has been prepared for developing the biogas plant at Bhans Colony in Karachi city, southern Pakistan in order to provide biogas for fuelling the fleet of buses for the Red Line BRT project which is proposed for Asian Development Bank (ADB) financing. The development of the proposed biogas plant will trigger ADB’s environment safeguards policies1.
2. The Red Line BRT project encompasses both (i) the Red Line Corridor which extends over 24.2-km from Numaish to Malir Halt Depot; (ii) the Common Corridor segment, which extends over 2.4-km from Municipal Park to Merewether Tower along M.A. Jinnah Road; and (iii) eight off-corridor direct and feeder service routes that connect the corridor to nearby communities. The total length of road works under the project is 29.1-km for the main corridor and 2.7-km for the common corridor.
3. The proposed Red Line BRT corridor is specifically defined as a core priority under the JICA Transportation Master Plan 2030 (Karachi Transport Improvement Project, 2012).
4. The project is sponsored by the Transport and Mass Transit Department (TMTD), Government of Sindh (GoS), with financial assistance from the Asian Development
5. Bank (ADB) and co-financiers, including the Asian Infrastructure Investment Bank (AIIB), the French Agency for Development (AFD), and the Green Climate Fund (GCF). The project will be implemented by TransKarachi, a semi-private entity developed specifically to manage the operations of the project.
B. Purpose of EARF 6. The EARF aims to provide guidance on safeguard screening, assessment, institutional arrangements, and processes to be followed for components of the project, where design and/or activity selection takes place after ADB Board approval. The site for the proposed project has yet to be selected while its detailed feasibility is also in progress. Thus, TMTD will agree with ADB on screening and categorization, environmental assessment, preparation and implementation, monitoring of the activities for development of the biogas plant to facilitate compliance with the requirements specified in ADB Safeguard Policy Statement (SPS, 2009) and government rules and laws.
7. This EARF (i) describes the project and its components; (ii) explains the general anticipated environmental impacts and mitigation measures for the proposed project activities, which will be financed after ADB Board approval; (iii) specifies the requirements that will be followed in relation to screening and categorization,
1 As explained in the ADB SPS, 2009. assessment, and planning, including arrangements for meaningful consultation with affected people and other stakeholders and information disclosure requirements; (iv) assesses the capability of the project proponents to implement national laws and ADB’s requirements, and identifies needs for capacity building; (v) specifies implementation procedures, institutional arrangements, and capacity development requirements; and (vi) specifies monitoring and reporting requirements.
8. This EARF provides guidance towards environmental assessment and reporting requirements to comply with both ADB and government policies.
C. Environmental Categorization 9. The proposed biogas plant component is presently categorized as ‘B’ for Environment. An extensive screening of the proposed project activities from the environment aspects cannot be conducted at present since the specific activities and project site/location have yet to be finalized. Once these details are finalized based on the completion of the feasibility study, the detailed screening shall be conducted by TMTD based on the ADB-REA Checklist, provided as Annexure I.
II. Assessment of Legal Framework and Institutional Capacity
A. Legal Framework for Environmental Assessment and Management
National Policy and Legal Framework 10. The Pakistan National Conservation Strategy (NCS) that was approved by the federal cabinet in March 1992 is the principal policy document on environmental issues in the country (EUAD/IUCN, 1992). The NCS outlines the country's primary approach towards encouraging sustainable development, conserving natural resources, and improving efficiency in the use and management of resources. The NCS has 68 specific programs in 14 core areas in which policy intervention is considered crucial for the preservation of Pakistan's natural and physical environment. The core areas that are relevant in the context of the proposed project are pollution prevention and abatement and increasing energy efficiency while conserving biodiversity.
11. Prior to the adoption of the 18th Constitutional Amendment, the Pakistan Environmental Protection Act (PEPA) 1997 was the governing law for environmental conservation in the country. Under PEPA 1997, the Pakistan Environmental Protection Council (PEPC) and Pak EPA were primarily responsible for administering PEPA 1997. Post the adoption of the 18th Constitutional Amendment in 2011, the subject of environment was devolved and the provinces have been empowered for environmental protection and conservation.
Regulations for Environmental Assessment, Pakistan EPA 12. Under Section 12 (and subsequent amendment) of the PEPA (1997), a project falling under any category specified in Schedule I of the IEE/EIA Regulations (SRO 339
Assessment of Legal Framework and Institutional Capacity 7 | P a g e (I0/2000), requires the proponent of the project to file an IEE with the concerned provincial EPA. Projects falling under any category specified in Schedule II require the proponent to file an EIA with the provincial agency, which is responsible for its review and accordance of approval or request any additional information deemed necessary.
Sindh Environmental Protection Act, 2014 13. The following articles of the SEPA 2014 have a direct bearing on the proposed Project:
14. Article 11(1): ‘Subject to the provisions of this Act and the rules and regulations therein, no person shall discharge or emit or allow the discharge or emission of any effluent, waste, pollutant, noise or any other matter that may cause or likely cause pollution or adverse environmental effects, as defined in Section 2 of this Act, in an amount, concentration or level which is in excess to that specified in Sindh Environmental Quality Standards.
15. Article 11(2): ‘All persons, in industrial or commercial or other operations, shall ensure compliance with the Environmental Quality Standards for ambient air, drinking water, noise or any other Standards established under section 6(1)(g)(i); shall maintain monitoring records for such compliances; shall make available these records to the authorized person for inspection; and shall report or communicate the record to the Agency as required under any directions issued, notified or required under any rules and regulations.
16. Section 11(3): Monitoring and analysis under sub-section (1) and (2), shall be acceptable only when carried out by the Environmental Laboratory certified by the Agency as prescribed in the rules. All stipulated tests will be regularly performed from designated laboratories approved by Sindh EPA.
17. Article 14 (1): ‘Subject to the provisions of this Act and the rules and regulations, no person shall cause any act, deed or any activity’, including; (b) disposal of solid and hazardous wastes at unauthorized places as prescribed; (c) dumping of wastes or hazardous substances into coastal waters and inland water bodies; and (d) release of emissions or discharges from industrial or commercial operations as prescribed.
18. Article 15 (1): ‘Subject to the provisions of this Act, no person shall operate or manufacture a motor vehicle or class of vehicles from which air pollutants or noise are being emitted in an amount, concentration or level which is in excess of the Sindh Environmental Quality Standards or, where applicable, the standards established under sub-clause (i) of clause (g) of sub-section (1) of section 6’.
19. Article 17(1): ‘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 the Agency approval in respect thereof.
List of Tables 8 | P a g e 20. Article 17(2): The agency shall; o a) review the initial environmental examination and accord its approval, subject to such terms and conditions as it may prescribe, or require submission of an environmental impact assessment by the proponent; or o (b) review the environmental impact assessment and accord its approval subject to such terms and conditions as it may deem fit to impose or require that the environmental impact assessment be re-submitted after such modifications as may be stipulated or decline approval of the environmental impact assessment as being contrary to environmental objectives.
21. Article 17(3): ‘Every review of an environment impact assessment shall be carried out with public participation and, subject to the provisions of this Act, after full disclosure of the particulars of the project’.
22. Article 17(4): ‘The Agency shall communicate its approval or otherwise within a period of two months from the date that the initial environmental examination is filed, and within a period of four months from the date that the environmental impact assessment is filed complete in all respects in accordance with the regulations, failing which the initial environmental examination or, as the case may be, the environmental impact assessment shall be deemed to have been approved, to the extent to which it does not contravene the provisions of this Act and the rules and regulations’.
23. Article 20(1): ‘The Agency shall from time to time require the person in charge of a project to furnish, within such period as may be specified, an environmental audit or environmental review report or environmental management plan containing a comprehensive appraisal of the environmental aspects of the project’.
24. Article 20(2): The report of a project prepared under sub-section (1) shall include: (a) analysis of the predicted qualitative and quantitative impact of the project as compared to the actual impact; (b) evaluation of the efficacy of the preventive, mitigation and compensatory measures taken with respect to the project; and (c) Recommendations for further minimizing or mitigating the adverse environmental impact of the project.
25. Article 20(3): ‘Based on its review of the environmental audit report, the Agency may, after giving the person in charge of the project an opportunity of being heard, direct that specified mitigation and compensatory measures be adopted within a specified time period and may also, where necessary, modify the approval granted by it under section 17’.
26. Section 31(1): The Agency shall cause relevant details of any proposed project regarding which an Environmental Impact Assessment has been received to be published, along with an invitation to the public to furnish their comments thereon within a specified period. (2) In accordance with such procedure as may be prescribed, the Agency shall hold public hearings to receive additional comments and hear oral submissions. (3) All comments received under sub-sections (1) and (2) shall be duly considered by the Agency while reviewing the environmental impact
Assessment of Legal Framework and Institutional Capacity 9 | P a g e assessment or strategic impact assessment, and decision or action taken thereon shall be communicated to the persons who have furnished the said comments.
Other National and Sindh Government Laws and Regulations 27. The national laws and regulations are provided in Table II.1 below.
Table II.1: Other National and Sindh Government Laws and Regulations
National and Provincial Brief Description Legislation
Sindh Factories Act 2015 The Sindh Factories Act 2015 deals with regulations related to project area, workers and workplace Environment Health and Safety (EH & S ) requirements. The Factories Act also provides regulations for handling and disposal of toxic and hazardous materials. As construction activity is classified as ‘industry’, these regulations will be applicable to the project & construction contractors’ scope of work also. The Protection against It shall be the responsibility of the employer to ensure Harassment of women at the implementation of this Act, including but not limited to incorporate work place Act 2010 the Code of Conduct for protection against harassment at the workplace as a part of their management policy and to form Inquiry Committee referred to in section 3 and designate a competent authority referred to in section 4 of this act. Employment of Child Act 1991 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 Employment of Child Act (ECA) 1991 disallows the child labour in the country. The ECA defines a child to mean a person who has not completed his/her fourteenth year of age. The ECA states that no child shall be employed or permitted to work in any of the occupation set forth in the ECA (such as transport sector, railways, construction, and ports) or in any workshop wherein any of the processes defined in the Act is carried out. The contractor will be bound by this Act to disallow any child labour at the project sites or campsites. Bonded labor system On the commencement of this act, the bonded labor system shall (Abolition) Act 1992 stand abolished and every bonded labourer shall stand freed and discharged from any obligations to render any bonded labor. Sindh Cultural Heritage Act This provincial Act empowers the Government of Sindh to 1994 preserve and protect any premises or objects of archaeological, architectural, historical, cultural, or national interest in Sindh by declaring them protected. Antiquity act 1975 The Antiquities Act relates to the protection, preservation and conservation of archaeological/historical sites and monuments. The Sindh Minimum Wages To provide for the regulation of minimum rates of wages and Act, 2015 various allowances for different categories of workers employed in certain industrial and commercial undertakings and establishments.
List of Tables 10 | P a g e Workmen’s compensation 1923 The liability of an employer is confined to payment of compensation to a “workman” and then only in respect of an injury caused by “accident arising out of and in the course of his employment”. The liability of employer is limited by ceiling fixed in Schedule to the Act. Land Acquisition Act, 1894 This Legislation relates to land acquisition and compensation. The LAA 1894 is, however, is limited to a cash compensation policy for the acquisition of land and built-up property and damage to other owned assets, such as crops, trees and infrastructure. The LAA does not consider the rehabilitation and resettlement of disrupted populations and the restoration of their livelihoods. The Pollution Charge for Related to methods for evaluation and collection of fee for not Industries (calculation and meeting environmental standards. Collection) Rules 2001
The Sindh Forest Act 2012 The law requires review and revision to meet the challenges of management and empower the forest managers to carryout management interventions with full legal support. The new legal instrument should amply address the provision and requirements of UNFCCC, CBD and Convention on Combating Desertification. Legal aspects of carbon sequestration and carbon credit marketing should also be kept in view. The Cutting of Trees It mandates that no person shall, without prior written approval (prohibition) Act, 1992 from authorized officer shall cut, fell or damage trees growing in: First Zone (Area adjacent to and beyond the external frontier of Pakistan to a line at four kilometers measured from the external frontiers of Pakistan) if the number of remaining trees in any field falls short of the number to be calculated at the rate of fifteen trees per acre; and Second Zone (Area adjacent to and beyond the first one extending towards Pakistan to a line at four kilometers measured from the first zone) if the number of remaining trees in any field falls short of the number to be calculated at the rate of ten trees per acre. Sindh Wildlife Protection This ordinance provides for the preservation, protection and Ordinance, 1972 (SWPO) conservation of wildlife by the formation and management of protected areas and prohibition of hunting of wildlife species declared protected under the ordinance. The ordinance also specifies three broad classifications of the protected areas; national parks, wildlife sanctuaries and game reserves. Activities such as hunting and breaking of land for mining are prohibited in national parks, as are removing vegetation or polluting water flowing through the park. Wildlife sanctuaries are areas that have been set aside as undisturbed breeding grounds and cultivation and grazing is prohibited in the demarked areas. Nobody is allowed to reside in a wildlife sanctuary and entrance for the general public is by special dispensation. However, these restrictions may be relaxed for scientific purpose or betterment of the respective area on the discretion of the governing authority in exceptional circumstances. Game reserves are designated as areas where hunting and shooting is not allowed except under special permits.
Assessment of Legal Framework and Institutional Capacity 11 | P a g e Hazardous Substance Rule, These Rules were notified to streamline procedures for issuance 2014 of licenses to industries / businesses that generate hazardous waste, safety precautions for workers and devices them methods for the removal of hazardous wastes in an environmentally friendly manner. The rules also specify procedures to be adopted for import, transport and disposal of hazardous waste; and identify two hundred and forty-three hazardous substances and synthetic chemicals. The rules also specify the requirement of obtaining license from Sindh EPA for the import, transport, storage and disposal of hazardous substances as specified in the rules
Regulatory Clearances, Sindh EPA 28. In accordance with provincial regulatory requirements, an IEE/EIA satisfying the requirements of the Sindh Environmental Protection Act (2014) is to be submitted to Sindh environmental protection agency (SEPA) for review and approval, and subsequent issuance of NOC before the commencement of construction.
Guidelines for Environmental Assessment, Pakistan EPA 29. The Pak-EPA has published a set of environmental guidelines for conducting environmental assessments and the environmental management of different types of development projects. The guidelines that are relevant to the proposed project are listed below:
▪ Guidelines for the Preparation and Review of Environmental Reports, Pakistan, EPA1997; ▪ Guidelines for Public Consultations; Pakistan EPA May 1997;
National Environmental Quality Standards (NEQS) 2000 30. The National Environmental Quality Standards (NEQS), 2000, specify the following standards:
▪ Maximum allowable concentration of pollutants (32 parameters) in municipal and liquid industrial effluents discharged to inland waters, sewage treatment facilities, and the sea (three separate sets of numbers); ▪ Maximum allowable concentration of pollutants (16 parameters) in gaseous emissions from industrial sources; ▪ Maximum allowable concentration of pollutants (two parameters) in gaseous emissions from vehicle exhaust and noise emission from vehicles; ▪ Maximum allowable noise levels from vehicles;
31. These standards apply to the gaseous emissions and liquid effluents discharged by batching plants, campsites and construction machinery. The standards for vehicles will apply during the construction as well as operation phase of the project. Standards for ambient air quality have also been prescribed.
List of Tables 12 | P a g e Interaction with Other Agencies 32. The Transport & Mass Transit Department (TMTD), GoS is responsible for ensuring that the project complies with the laws and regulations controlling the environmental concerns of the bus rapid transit (BRT) construction and operation and that all preconstruction requisites, such as permits and clearances are met.
Provincial EPAs 33. TMTD will be responsible for providing the complete environmental documentation required by the SEPA and remain committed to the approved project design. No deviation is permitted during project implementation without prior and explicit permission of the SEPA.
Provincial Departments of Forests and Wildlife 34. No uprooting or clearing of trees is expected for the proposed project. However, any removed trees or vegetation under private ownership will be compensated as per provision that in case of disruption to vegetation or trees, the project contractor will be responsible for acquiring a 'No-Objection Certificate' (NOC) from the concerned forest department. The application for an NOC will need to be endorsed by the TMTD.
Provincial Governments 35. The TMTD and its contractors must ensure that the project meets the criteria of provincial/district governments as related to the establishment of construction camps and plants, and the safe disposal of wastewater, solid waste, and toxic materials. TMTD will coordinate and monitor environment related issues.
B. ADB Policies
ADB’s Safeguard Policy Statement (SPS), 2009 36. The ADB’s SPS 2009 requires that environmental considerations be incorporated into ADB funded projects to ensure that the project will have minimal environmental impacts and be environmentally sound. Occupational health & safety of the local population should also be addressed as well as the project workers as stated in SPS. A Grievance Redress Mechanism (GRM) to receive application and facilitate resolution of affected peoples’ concerns, complaints, and grievances about the project’s environmental performance is also established.
37. All loans and investments are subject to categorization to determine environmental assessment requirements. Categorization is to be undertaken using Rapid Environmental Assessment (REA) checklists, consisting of questions relating to (i) the sensitivity and vulnerability of environmental resources in project area, and (ii) the potential for the project to cause significant adverse environmental impacts. Projects are classified into one of the following environmental categories:
Assessment of Legal Framework and Institutional Capacity 13 | P a g e Category A: A proposed project is classified as category A if it is likely to have significant adverse environmental impacts that are irreversible, diverse or unprecedented. These impacts may affect an area larger than the sites or facilities subject to physical works. An environmental impact assessment (EIA) is required. Category B: A proposed project is classified as category B if its potential adverse environmental impacts are less adverse than those of category A projects. These impacts are site-specific, few if any of them are irreversible, and in most cases mitigation measures can be designed more readily than for category A projects. An initial environmental examination (IEE) is required. Category C: A proposed project is classified as category C if it is likely to have minimal or no adverse environmental impacts. No environmental assessment is required although environmental implications need to be reviewed. Category FI: A proposed project is classified as category FI if it involves investment of ADB funds to or through a financial intermediary (FI).
ADB’s Access to Information Policy (AIP) 2018 38. ADB’s new Access to Information Policy (AIP), reflects the ADB’s ongoing commitment to transparency, accountability, and participation by stakeholders. The policy contains principles and exceptions to information sharing with external stakeholders, led by a new overarching principle of “clear, timely, and appropriate disclosure.”
ADB’s Accountability Mechanism Policy 2012 39. The objectives of the Accountability Mechanism is providing an independent and effective forum for people adversely affected by ADB-assisted projects to voice their concerns and seek solutions to their problems, and to request compliance review of the alleged noncompliance by ADB with its operational policies and procedures that may have caused, or is likely to cause, them direct and material harm. The Accountability Mechanism is a “last resort” mechanism.
C. Implications of ADB’s safeguard policies on proposed project 40. The objectives of ADB’s safeguards are to:
▪ avoid adverse impacts of projects on the environment and affected people, where possible;
▪ minimize, mitigate, and/or compensate for adverse project impacts on the environment and affected people when avoidance is not possible; and
▪ help borrowers/clients to strengthen their safeguard systems.
41. ADB’s SPS sets out the policy objectives, scope and triggers, and principles for three key safeguard areas:
▪ environmental safeguards,
▪ involuntary resettlement safeguards, and
List of Tables 14 | P a g e ▪ Indigenous Peoples safeguards.
42. The objective of the environmental safeguards is to ensure the environmental soundness and sustainability of projects and to support the integration of environmental considerations into the project decision-making process. ADB’s policy principles are summarized in Table II.2 below.
Table II.2: ADB Policy Principles
Policy principle Summary
1 Screening and Screening process initiated early to determine the categorization appropriate extent and type of environmental assessment.
2 Environmental Conduct an environmental assessment to identify assessment potential impacts and risks in the context of the project’s area of influence.
3 Alternatives Examine alternatives to the project’s location, design, technology, and components and their potential environmental and social impacts, including no project alternative.
4 Impact minigation Avoid, and where avoidance is not possible, minimize, mitigate, and/or offset adverse impacts and enhance positive impacts. Prepare an environmental management plan (EMP).
5 Public consultations Carry out meaningful consultation with affected people and facilitate their informed participation. Involve stakeholders early in the project preparation process and ensure that their views and concerns are made known to and understood by decision makers and taken into account. Continue consultations with stakeholders throughout project implementation. Establish a grievance redress mechanism.
6 Disclosure of Disclose a draft environmental assessment in a environmental timely manner, in an accessible place and in a form assessment and language(s) understandable to stakeholders. Disclose the final environmental assessment to stakeholders.
7 Environmental Implement the EMP and monitor its effectiveness. management plan Document monitoring results, and disclose monitoring reports.
Assessment of Legal Framework and Institutional Capacity 15 | P a g e 8 Biodiversity Do not implement project activities in areas of critical habitats.
9 Pollution prevention Apply pollution prevention and control technologies and practices consistent with international good practices. Adopt cleaner production processes and good energy efficiency practices. Avoid pollution, or, when avoidance is not possible, minimize or control the intensity or load of pollutant emissions and discharges. Avoid the use of hazardous materials subject to international bans or phaseouts.
10 Occupational health and Provide workers with safe and healthy working safety conditions and prevent accidents, injuries, and disease. Establish preventive and emergency Community safety. preparedness and response measures to avoid, and where avoidance is not possible, to minimize, adverse impacts and risks to the health and safety of local communities
11 Physical cultural Conserve physical cultural resources and avoid resources destroying or damaging them. Provide for the use of “chance find” procedures.
D. Comparison of International and Local Environmental Legislations 43. The ADB SPS requires application of pollution prevention and control technologies and practices consistent with international good practice, as reflected in internationally recognized standards. The SPS states that when host country regulations differ from these standards, the executing agency will achieve whichever is more stringent.
44. In order to select the most stringent standards applicable, a mix of local (NEQS) and international (IFC) regulations have been selected. In case of high baseline noise levels in the project area, it shall be ensured that the increase in noise levels is minimized as far as possible. Also, in such a scenario, project related noise levels in the project area will not be allowed to increase the existing levels by 3 dB or more. Furthermore, it shall be ensured that all necessary noise mitigation measures are implemented to minimize the noise levels in the project area.
45. The Table II.3 presents IFC workplace noise standards that are applicable to the construction workers. It should also be noted that IFC EHS guidelines advise that where existing ambient noise levels already exceed thresholds, the Project should not result in an increase of more than 3 dB over existing ambient noise at the nearest receptor location off-site.
List of Tables 16 | P a g e 46. A comparison of applicable local and international guidelines for ambient air quality has been provided in Table II.4 below. In the case of most pollutants, the NEQS standards for ambient air quality are more stringent in comparison to USEPA and WHO/IFC standards. The applicable and most stringent parameters for each respective pollutant are highlighted in green.
47. Similar to the standards for air quality, the comparison of noise standards provided in Table II.5 clearly shows that NEQS standards for noise are more stringent in comparison to the IFC standards. The only exception is the daytime noise level standard for Industrial areas where the IFC standard is more stringent (70 dB(A)) in comparison to NEQS (75 dB(A)) and so for this particular parameter, the IFC standard will be used. Apart from this one exception, the NEQS standards have been used for the proposed BRT project.
48. As far as regulations regarding other environmental parameters are concerned such as acceptable effluent disposal parameters, the local regulations i.e. NEQS take precedence over any other international regulations such as IFC.
Table II.3: IFC Work Environment Noise limits
Type of Work, workplace IFC General EHS Guidelines
Heavy Industry (no demand for oral communication) 85 Equivalent level Leq,8h
Light industry (decreasing demand for oral 50-65 Equivalent level Leq,8h communication)
Assessment of Legal Framework and Institutional Capacity 17 | P a g e Table II.4: Comparison of International and local Air Quality Standards*
USEPA WHO/IFC Pak. NEQS Pollutants Avg. Time Standard Avg. Time Standard Avg. Time Standard
3 hrs 0.5 ppm 24 hr 20 ug/m3 Annual Mean 80 ug/m3 SO2 1 hr 75 ppb 10 min 500 ug/m3 24 hrs 120 ug/m3
8 hrs 9 ppm (11 mg/m3) 8 hrs 5 mg/m3 CO - - 35 ppm (43 1 hr 10 mg/m3 1 hr mg/m3)
Annual 100 ug/m3 (53 40 ug/m3 1 yr 40 ug/m3 Annual Mean Mean ppb) NO2 80 ug/m3 1 hr 200 ug/m3 24 hrs 1 hr 100 ppb
8 hrs 100 ug/m3 130 ug/m3 0.07ppm (148 O3 8 hrs 1 hr ug/m3)
Annual Mean 360 ug/m3 TSP - - - - 24 hrs 500 ug/m3
3 3 3 PM10 24 hrs 150 ug/m 1 yr 20 ug/m Annual Mean 120 ug/m 24 hr 50 ug/m3 24 hrs 150 ug/m3
Annual Average 15 ug/m3 Annual 15 ug/m3 1 yr 10 ug/m3 Mean 3 PM2.5 24 hrs 35 ug/m 35 ug/m3 24 hr 25 ug/m3 24 hrs 1 hr 15 ug/m3
*: The standards highlighted in green for each respective pollutant are the most stringent based on a comparison between local and international regulations and thus shall be applicable for the proposed project.
* In instances where the airshed is significantly degraded and the pollutant levels are already exceeding the ambient pollutant concentrations provided in the table above, it shall be ensured that the project activities cause as small an increase in pollution levels as feasible, and amounts to a fraction of the applicable short term and annual average air quality guidelines or standards as established in the project specific environmental assessment. .
Assessment of Legal Framework and Institutional Capacity 19 | P a g e Table II.5: Comparison of International and Local Noise Standards
Limit in dB(A) Leq
Category of Area/Zone NEQS WHO/IFC
Day Time Night Time Day Time Night Time
06:00 – 22:00 22:00-06:00 07:00 – 22:00 22:00-07:00
Residential area (A) 55 45 55 45
Commercial area (B) 65 55 70 70
Industrial area (C) 75 65 70 70
Silence zone (D) 50 45 55 45
*: The standards highlighted in green for each respective Area/Zone are the most stringent based on a comparison between local and international regulations and thus shall be applicable for the proposed project.
* In instances where baseline noise levels are already exceeding the standards above, it will need to be ensured that the project activities do not cause an increment of more than 3 dB(A) from the baseline noise levels.
Assessment of Legal Framework and Institutional Capacity 20 | P a g e III. Project Description
49. The Karachi Bus Rapid Transit (BRT) Red Line plans to provide services from downtown Karachi to near the Jinnah International Airport. The BRT line proposes to use natural gas-powered buses to reduce environmental and social impacts created by diesel vehicles. The BRT red line will require 10,725 kg per day of compressed natural gas (CNG) in the first year of operations and 14,611 kg per day of CNG by year 12 of its operations. Natural gas is high demand in Karachi city with only two import terminals available and limited supply of gas from the local gas fields resulting in a considerable gap between supply and demand.
50. Currently, over 3,200 tons of cattle waste is produced at farms in the Cattle Colony area of Karachi and this waste is then discarded into Karachi Bay. To wash the waste into the Bay, about 50,000 cubic meters of freshwater are lost. The resulting impact of this process is catastrophic both to the local ecology and the global environment. The waste overwhelms the Bay with bacteria that wipe out the marine life, and as the waste undergoes anaerobic digestion, large quantities of methane bubble through the surface. Methane is a greenhouse gas that is 30 times more powerful in its global warming impact than carbon dioxide.
51. Karachi Bhens Colony is located on Mehran Highway in the east of Karachi, approximately 30 km from city center and 15 km from Jinnah International Airport Karachi. The site is connected from Shahra-e-Faisal N-5 through a 2 km long link road. Area of cattle colony is around 7.5 sq.km (1853 acres). The cattle colony is bounded by Port Qasim export processing zone in east, Arabian Sea in south, Landhi industrial estate in west and thickly populated “Jumma Goth Village” in the north. Administratively Cattle Colony is situated with revenue estate of “Gangiaro”, Thaluka Ibrahim Haidri, District Malir, Karachi.
52. It is proposed to build a plant to convert buffalo faeces from the Cattle Colony into biogas. This biogas will then be upgraded to 88.9% biomethane and injected into the Sui Southern gas pipeline. Under a loan and supply contract, gas will be extracted from the Sui Southern gas pipeline at the depot near Jinnah International Airport.
53. The Buffalos faeces effluent will be fed into a closed digestor - a CIGAR® (Covered In Ground Anaerobic Reactor) and processed into a biogas through an advanced anaerobic digestion process. The CIGAR® is deigned to take the waste from 60,000 buffaloes which is approximately 8,400 cubic meters of wastewater per day.
54. After an evaluation of the fuel options for the BRT vehicles, biomethane produced from the cattle waste has been determined to be both cost effective and the most environmentally beneficial. Hence, the development of biogas plant to be fueled by cattle waste will be a source for CNG (i.e. biomethane) for the buses. After an initial assessment and discussion, the area requirement of the proposed biogas plant would be around 15 acres which is to be acquired/allotted by the Project Implementation Unit, Karachi BRT Red Line Project, Transport and Mass Transit Department, Government of Sindh.
Project Description 21 | P a g e 55. The biogas facility will also produce positive social and environmental impacts through the reduction of greenhouse gas emissions through the treatment of the toxic wastewater, as well as significantly reducing the possibility of soil and ground water pollution that may be generated by the yard. The Project will meet all environmental laws as mandated by the Pakistan Government.
56. The biogas plant to convert the waste into biomethane will be funded under the project by the GCF through a highly concessional loan. This enhances further the project financial viability by ensuring the stability and reducing the cost of fuel, one of the system’s main operational cost.
57. The biogas plant will be implemented through a Design-Build-Operate (DBO) contract managed by TransKarachi. The Request for Proposal and the draft contract are currently being prepared through ADB’s Clean Energy Fund (additional grant), including all necessary due diligences.
58. Some of the key project impacts for this project are:
▪ US $ 10.2 million Capital Expenditure,
▪ The production of approximately 64,000 cubic meters of methane gas per day, with a portion of that used in a biogas cogeneration system to provide electrical power to the plant and neighboring cattle yards and the balance being converted to biomethane to meet the BRT Red Line’s needs,
▪ The production of approximately 29,200 metric tonnes per year of fertilizer that is high in Nitrogen, Phosphorous and Potassium (NPK),
▪ Compliance to Pakistani law that the yard meets all environmental laws and regulations,
▪ Reduction of the risk of soil and water pollution of dairy operations,
▪ Provision of wash water to dairy operators to reduce depletion of ground wells,
▪ A reduction in disease and pest problems due to removal of faeces in timely manner,
▪ An opportunity to change the urban environment in the cattle colony; and
▪ The possibility of establishment of new downstream industries that can make use of the excess biogas/waste heat from the project’s operational processes (subject to further investigation).
Proposed Facility
The feasibility study for the proposed biogas plant is presently in progress, however, the design of the project will be made up of the following constituents:
Project Description 22 | P a g e
▪ Buildings such as Master Control Center (MCC), office and fencing.
▪ Programmable Logic Controllers (PLC), SCADA controls and other electrical and monitoring components,
▪ Pumps,
▪ Valves,
▪ Covered In-Ground Anaerobic Digestor (CIGAR®) including membrane,
▪ Biogas handling System,
▪ Gas Engines,
▪ Biogas upgrading from 60% to 88.9% methane
▪ Biogas Flare,
▪ Concrete Works, and
▪ Mechanical Equipment such as blowers.
IV. Anticipated Environmental Impacts
59. The proposed works for the biogas project are expected to be medium term in duration and limited to the construction phase of the project. The anticipated environmental impacts and mitigation measures related to the design, construction and operation phases of the proposed proposed are provided in the Table III.1 below. These are indicative impacts and will need to be further explored during the detailed design stage.
Table IV.1: Indicative Impacts
Anticipated Environmental Impacts Mitigation Measures
Design/Pre-Construction Phase
Loss of land and other properties Proposed project activities to minimize land acquisition and/or resettlement impacts to ensure it remains as Category ‘B’.
Relocation of Utilities ▪ Contractor(s) will assess construction location(s) in advance for potential disruption to services and identify risks prior to starting construction. Any damage or hindrance/disadvantage to local businesses caused by the premature
Anticipated Environmental Impacts 23 | P a g e removal or insufficient replacement of public utilities is subject to full compensation, at the full liability of the contractor who caused the problem.
▪ If temporary disruption is unavoidable, the contractor will, in collaboration with relevant local authorities such as power company, water supply company and communication company, develop a plan to minimize the disruption and communicate the dates and duration in advance to the affected persons.
Identification of Labor Camps and ancillary ▪ In order to prevent a nuisance, specific facilities locations shall be designated in the project area for development of the labor camps. All necessary facilities and amenities shall be provided in these camps such as electricity, sufficient supply of water, solid and liquid effluent waste disposal facilities etc.
▪ The use of proper planning while identifying locations for the labor camps will ensure there is minimal disturbance to all key receptors in the project area and the traffic is not disrupted by labor camps being set up.
Development of Traffic Management Plan ▪ The traffic management plan shall be prepared by the Contractor for implementation prior to commencement of the project construction activity. The main objectives of the plan shall be to maximize the safety of the workforce and the travelling public while keeping the traffic flowing as freely as possible.
▪ The detailed traffic plan shall ensure that traffic is diverted to alternate routes wherever possible, which will minimize traffic jams and bottlenecks in the project area and also minimize the chances of traffic related accidents.
Anticipated Environmental Impacts 24 | P a g e Construction Phase
Traffic Management Traffic management plan to be prepared beforehand by Contractor and implemented during construction work.
Ambient Air Quality Regular water sprinkling on the exposed surfaces to reduce dust emissions and proper maintenance of all equipment at regular intervals to minimize impact of exhaust emissions.
Noise Levels Proper noise management plan to be prepared, indicating frequency of noise monitoring and thresholds to be used.
As part of this plan, necessary control equipment and techniques to be applied to control noise levels and limit their nuisance effects
Community Health and Safety ▪ Buffer strips or other methods of physical separation around the project sites ▪ Siting and safety engineering criteria shall be incorporated to prevent failures ▪ Inventories of hazardous materials shall be reduced ▪ Safety trainings to communities ▪ Vehicle speed limit controls Worker Health and Safety ▪ Contractor must prepare health and safety protocols and submit to ADB for approval. ▪ Random audits (possible unannounced) must be organized by PMU to check and issue penalties if non-compliances are detected. ▪ Trainings to Labor staff ▪ Provision of PPEs ▪ Monitoring of labor staff by Contractor management Camp Effluent Closed sewage treatment system will treat the effluent Soil Erosion and Sedimentation ▪ Sediment ponds must be developed
Anticipated Environmental Impacts 25 | P a g e wherever felt necessary ▪ Coverage of unpaved areas must be conducted Soil & Site Contamination ▪ Use of spill prevention trays ▪ Regular inspections ▪ Storage of chemicals etc. in covered bounded areas Drainage & Storm water Run off ▪ Compacting of all unpaved exposed surfaces ▪ Natural drainage must not be hampered or blocked Hazardous and Non-hazardous waste ▪ Waste management plan to be developed management ▪ Periodic on-site audits of waste management ▪ Records of all waste generated Historical/Archaeological Sites Any archaeological finds during works must require stopped of works and use of ‘Chance Find’ procedures.
Disruption to businesses and communities ▪ Prepare and implement traffic management plans in coordination with local authorities.
▪ Conduct widespread public awareness prior and during construction.
Loss of forest trees and vegetation and Damage to flora and/or fauna to be strictly hunting/killing of fauna forbidden.
Operation and Maintenance
Heavy vehicle (trailers, trucks etc.) A detailed traffic management plan shall be movement to transport raw manure to biogas developed for transport of raw manue to plant the plant each day. On the basis of this plan, the concerned roads and highways shall be properly repaired and managed to ensure smooth logistical movement of the project related vehicles and prevent any congestion and/or accidents.
Accidental Release of Biogas into ▪ Quantitative risk assessment (QRA) will be atmosphere due to leak at plant and potential prepared to assess all potential scenarios poisoning of communities in area of biogas leakage from the plant and necessary counter measures shall be
Anticipated Environmental Impacts 26 | P a g e developed as part of preparedness in the event of any such leakage.
▪ All necessary emergency equipment shall be placed at the plant to effectively respond and manage any such leakage, including alarm system(s) to signal leaks.
▪ All staff at the plant shall be trained to respond suitably in the event of such a leakage event.
▪ First Aid equipment in case of gas leakage such as oxygen tanks, gas masks etc. shall be stocked in an adequate quanitity.
Disposal of sludge/by-product from biogas By-product produced from biogas plant plant as result of biogas production shall be effectively treated and disposed off at a suitable pre-determined location(s) through contractual arrangements made with licensed third parties.
Climate Change impacts Positive impacts are expected since the cattle manure which is presently decomposing openly (and releasing harmful gases into the environment) and also being disposed into the Arabian Sea from the Cattle Colony shall be properly collected and used to produce biogas with any waste sludge disposed off as per international best practices.
V. Consultation, Information Disclosure and Grievance Redress Mechanism
A. Public Consultation and Information Disclosure 60. It is recommended that public consultation be carried out during the early stages of the program commencement and throughout the program implementation to address any environmental issues that affect the local communities. It is important that consultation with stakeholders occurs at an early stage of program preparation and implementation.
61. As a minimum, stakeholders will be consulted regarding the scope of the environmental study before work has commenced in earnest, and will then be
27 | P a g e informed about the likely impacts of the proposed activities and proposed mitigation once the draft IEE report is under preparation. The report will record the views of stakeholders and indicate how these have been taken into account in project development. There are a variety of approaches for such contacts, including public meetings, FGDs, workshops, public information campaigns, etc., and several methods will be used in order to reach all sectors of society, as well as institutional stakeholders, nongovernmental organizations (NGOs), and others.
62. Information will be disclosed through public consultations, and more formally by making documents and other materials available in a form and at a location easily accessed by stakeholders. This will involve making draft reports available at public locations in the town(s) and providing a mechanism for the receipt of comments, and making documents available more widely by lodging them on the ADB and the TMTD website.
63. In case an EIA study is necessary in order to obtain the national approval (No Objection Certificate) from the Sindh EPA, once the EIA document is submitted to SEPA and they have completed their initial review, they shall call for a public hearing in one month’s time. This public hearing will be free for all stakeholders to attend and express any comments/suggestions or concerns regarding the proposed project. Based on the discussion and feedback received from the stakeholders during this public hearing, SEPA will instruct the project proponent (TMTD) to address all comments and submit the revised and updated EIA document for review and issuance of NoC by SEPA.
B. Grievance Redress Mechanism 64. A grievance redress mechanism (GRM) will be established to receive, evaluate, and facilitate the resolution of affected people’s concerns, complaints, and grievances about the social and environmental performance at the level of the project. The GRM aims to provide a trusted way to voice and resolve concerns linked to the project and to be an effective way to address affected people’s concerns.
65. In addition, information boards shall be placed at the construction sites where it shall be mandatory to indicate information regarding the mechanism for filing complaints and/or suggestions. Any complainant shall have the following options to file a grievance/complaint.
66. The main purpose of the GRM is to receive operational and objective information, evaluation and consideration of requests (statements, proposals, complaints, requests, positive feedback) concerning the scope of the implementation of TMTD projects at all stages of implementation.
VI. Institutional Arrangement and Responsibilities
Institutional Arrangement and Responsibilities 28 | P a g e 67. In order to prepare the project from an environmental safeguards perspective and to comply with ADB’s Safeguard Policy Statement (2009) and the Pakistan environmental legislation, TMTD and ADB have agreed on the following:
(i) TMTD will take the following responsibilities:
a. Prepare the REA screening checklist and classify the potential project;
b. Based on the environmental classification of the project, prepare the terms of reference to conduct an IEE or an EIA study2 (outline of an environmental assessment report is shown in Annexure II);
c. Engage an environmental consultant or firm to prepare an IEE or EIA report, including an EMP for disclosure;
d. Undertake an initial review of the IEE or EIA;
e. Submit the IEE or EIA report and the review form to ADB as part of the approval of the project;
f. Ensure that all regulatory clearances are obtained before starting civil works for the project.
g. Submit to ADB all the required clearances/certificates obtained from the relevant Government authorities.
h. Ensure that all the mitigation measures required to be implemented during construction are included along with its estimated costs in the bidding document;
i. Establish an Environment and Social Unit within PMU to monitor the contractors and the implementation of the environmental management measures required for the project;
j. Require the contractor to prepare Site-Specific EMP(s) for operations that includes a sub-plan for each of the work areas.
k. Ensure that no land will be released to the contractor until the SSEMP for that area has been prepared and approved.
l. Require that the contractor employ a suitably qualified or experienced environment specialist on a full-time basis to supervise the implementation of the EMP.
m. Require that the contractor provide awareness training in environmental management for all employees working on the project.
2 The proposed project is expected to fall into Category ‘B’ as per ADB SPS 2009 based on the expected scope of work and resulting impacts from the project. Thus, the preparation of an IEE study is expected to be sufficient for the proposed biogas plant development.
Institutional Arrangement and Responsibilities 29 | P a g e n. Ensure that an environmental management plan, including all proposed mitigation measures and monitoring programs, are properly implemented.
o. Monitor the implementation of environmental management plan and prepare an environmental monitoring report (on ADB approved format) every six months, to be delivered to ADB.
p. In the case of unpredicted environmental impacts occurring during project implementation, require the contractor to provide and implement a corrective action plan.
q. In case the needs to have its environmental category upgraded, consult with ADB to decide whether a supplementary IEE or EIA study is required. If it is required, prepare the terms of reference for undertaking a supplementary IEE or EIA and hire an environment consultant to carry out the study.
r. Ensure that meaningful public consultation be undertaken with affected groups, women, and NGOs.
(ii) ADB will take the following responsibilities:
a. Review the IEE or EIA reports as a basis for the approval of the project.
b. Disclose the final IEE or draft full EIA (at least 120 days prior to ADB Board consideration) and Final EIA, and/or environmental assessment and review framework before project appraisal, a new or updated EIA/IEE and corrective action plan prepared during project implementation, if any, as well as environmental monitoring reports on the ADB website
c. Monitor the implementation of the EMP and due diligence as part of overall project review mission.
d. Assist TMTD, if required, in carrying out its responsibilities and safeguard capacity building.
e. Facilitate the required consultations with project affected groups and local NGOs, and to ensure that the borrower or project sponsor provides relevant information on the project’s environmental issues in a form and language(s) accessible to those being consulted.
A. Staffing Requirements and Budget 68. TMTD will recruit environmental consultant(s) or firm as part of engineering design team to prepare an Initial Environmental Examination / Environmental Impact Assessment report for the proposed biogas project.
69. The project environmental costs shall need to be incorporated into a budget and resources allocated to (i) implement the environmental review and screening procedure, (ii) undertake the IEE/EIA studies for the project, (iii) conduct
Institutional Arrangement and Responsibilities 30 | P a g e stakeholder’s consultations, (iv) monitor the implementation of EMP(s), and (v) undertake environmental mitigation measures as required.
70. The costs of conducting training, undertaking monitoring, procuring laboratory equipment for instrumental monitoring, hiring environmental consultants, and implementing the environmental impact assessment and review framework needs also to be incorporated in the project budget.
VII. Monitoring and Reporting
71. The extent of monitoring activities, including their scope and periodicity, will be commensurate with the project risks and impacts. TMTD is required to implement safeguard measures and relevant safeguard plans, as provided in the legal agreements, and to submit periodic monitoring reports (see the template in Annexure IV) on their implementation performance. ADB will require TMTD to:
▪ Establish and maintain procedures to monitor the progress of implementation of EMP(s);
▪ Verify the compliance with environmental measures and their progress toward intended outcomes;
▪ Document and disclose monitoring results and identify necessary corrective and preventive actions in the periodic monitoring reports;
▪ Follow up on these actions to ensure progress toward the desired outcomes,
▪ Retain qualified and experienced external experts or qualified NGOs to verify monitoring information for projects with significant impacts and risks; and
▪ Submit periodic monitoring reports on safeguard measures as agreed with ADB.
72. ADB will carry out the following monitoring actions to supervise the project implementation:
▪ Conduct periodic site visits for projects with adverse environmental or social impacts;
▪ Conduct supervision missions with detailed review by ADB’s safeguard specialists/officers or consultants for aspects of the project with significant adverse social or environmental impacts;
▪ Review the periodic monitoring reports submitted by TMTD to ensure that adverse impacts and risks are mitigated as planned and as agreed with ADB;
▪ Work with TMTD to rectify to the extent possible any failures to comply with their safeguard commitments, as covenanted in the legal agreements, and exercise remedies to reestablish compliance as appropriate; and
Monitoring and Reporting 31 | P a g e ▪ Prepare project completion reports that assesses whether the objective and desired outcomes of the EMPs have been achieved, considering the baseline conditions and the results of monitoring.
Monitoring and Reporting 32 | P a g e Semi-annual Environmental Monitoring Report
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ANNEXURE-I
ADB REA Checklist
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Rapid Environmental Assessment (REA) Checklist
Instructions:
(i) The project team completes this checklist to support the environmental classification of a project. It is to be attached to the environmental categorization form and submitted to the Environment and Safeguards Division (RSES) for endorsement by Director, RSES and for approval by the Chief Compliance Officer. (ii) This checklist focuses on environmental issues and concerns. To ensure that social dimensions are adequately considered, refer also to ADB's (a) checklists on involuntary resettlement and Indigenous Peoples; (b) poverty reduction handbook; (c) staff guide to consultation and participation; and (d) gender checklists.
(iii) Answer the questions assuming the “without mitigation” case. The purpose is to identify potential impacts. Use the “remarks” section to discuss any anticipated mitigation measures.
Country/Project Title:
Sector Division:
Screening Questions Yes No Remarks
A. Project Siting Is the Project area adjacent to or within any of the following environmentally sensitive areas?
▪ Cultural heritage site
▪ Protected Area
▪ Wetland
▪ Mangrove
▪ Estuarine
▪ Buffer zone of protected area
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Screening Questions Yes No Remarks
▪ Special area for protecting biodiversity
▪ Bay
B. Potential Environmental Impacts Will the Project cause…
▪ ecological disturbances arising from the establishment of a plant or facility complex in or near sensitive habitats?
▪ eventual degradation of water bodies due to discharge of wastes and other effluents from plant or facility complex?
▪ serious contamination of soil and groundwater?
▪ aggravation of solid waste problems in the area?
▪ public health risks from discharge of wastes and poor air quality; noise and foul odor from plant emissions?
▪ short-term construction impacts (e.g. soil erosion, deterioration of water and air quality, noise and vibration from construction equipment?
▪ dislocation or involuntary resettlement of people?
▪ disproportionate impacts on the poor, women and children, Indigenous Peoples or other vulnerable groups?
▪ environmental degradation (e.g. erosion, soil and water contamination, loss of soil fertility, disruption of wildlife habitat) from intensification of agricultural land use to supply raw materials for plant operation; and modification of natural species diversity as a result of the transformation to monoculture practices?
▪ water pollution from discharge of liquid effluents?
▪ air pollution from all plant operations?
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Screening Questions Yes No Remarks
▪ gaseous and odor emissions to the atmosphere from processing operations?
▪ accidental release of potentially hazardous solvents, acidic and alkaline materials?
▪ uncontrolled in-migration with opening of roads to forest area and overloading of social infrastructure?
▪ occupational health hazards due to fugitive dust, materials handling, noise, or other process operations?
▪ disruption of transit patterns, creation of noise and congestion, and pedestrian hazards aggravated by heavy trucks?
▪ disease transmission from inadequate waste disposal?
▪ risks and vulnerabilities related to occupational health and safety due to physical, chemical, and biological hazards during project construction and operation?
▪ large population increase during project construction and operation that cause increased burden on social infrastructure and services (such as water supply and sanitation systems)?
▪ social conflicts if workers from other regions or countries are hired?
▪ community health and safety risks due to the transport, storage, and use and/or disposal of materials likely to create physical, chemical and biological hazards during construction, operation and decommissioning?
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ANNEXURE-II
Outline of an Environmental Assessment report
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This outline is part of the Safeguard Requirements. An environmental assessment report is required for all environment category ‘A’ and ‘B’ projects. Its level of detail and comprehensiveness is commensurate with the significance of potential environmental impacts and risks. A typical EIA report contains the following major elements, and an IEE may have a narrower scope depending on the nature of the project. The substantive aspects of this outline will guide the preparation of environmental impact assessment reports, although not necessarily in the order shown.
A. Executive Summary
This section describes concisely the critical facts, significant findings, and recommended actions.
B. Policy, Legal, and Administrative Framework
This section discusses the national and local legal and institutional framework within which the environmental assessment is carried out. It also identifies project-relevant international environmental agreements to which the country is a party.
C. Description of the Project
This section describes the proposed project; its major components; and its geographic, ecological, social, and temporal context, including any associated facility required by and for the project (for example, access roads, power plants, water supply, quarries and borrow pits, and spoil disposal). It normally includes drawings and maps showing the project’s layout and components, the project site, and the project's area of influence.
D. Description of the Environment (Baseline Data)
This section describes relevant physical, biological, and socioeconomic conditions within the study area. It also looks at current and proposed development activities within the project's area of influence, including those not directly connected to the project. It indicates the accuracy, reliability, and sources of the data.
E. Anticipated Environmental Impacts and Mitigation Measures
This section predicts and assesses the project's likely positive and negative direct and indirect impacts to physical, biological, socioeconomic (including occupational health and safety, community health and safety, vulnerable groups and gender issues, and impacts on livelihoods through environmental media), and physical cultural resources in the project's area of influence, in quantitative terms to the extent possible; identifies mitigation measures and any residual negative impacts that cannot be mitigated; explores opportunities for enhancement; identifies and estimates the extent and quality of available data, key data gaps, and uncertainties associated with predictions and specifies topics that do not require further attention; and examines global, transboundary, and cumulative impacts as appropriate.
F. Analysis of Alternatives
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This section examines alternatives to the proposed project site, technology, design, and operation - including the no project alternative - in terms of their potential environmental impacts; the feasibility of mitigating these impacts; their capital and recurrent costs; their suitability under local conditions; and their institutional, training, and monitoring requirements. It also states the basis for selecting the particular project design proposed and, justifies recommended emission levels and approaches to pollution prevention and abatement.
G. Information Disclosure, Consultation, and Participation
This section:
(i) describes the process undertaken during project design and preparation for engaging stakeholders, including information disclosure and consultation with affected people and other stakeholders;
(ii) summarizes comments and concerns received from affected people and other stakeholders and how these comments have been addressed in project design and mitigation measures, with special attention paid to the needs and concerns of vulnerable groups, including women, the poor, and Indigenous Peoples; and (iii) describes the planned information disclosure measures (including the type of information to be disseminated and the method of dissemination) and the process for carrying out consultation with affected people and facilitating their participation during project implementation.
H. Grievance Redress Mechanism
This section describes the grievance redress framework (both informal and formal channels), setting out the time frame and mechanisms for resolving complaints about environmental performance.
I. Environmental Management Plan
This section deals with the set of mitigation and management measures to be taken during project implementation to avoid, reduce, mitigate, or compensate for adverse environmental impacts (in that order of priority). It may include multiple management plans and actions. It includes the following key components (with the level of detail commensurate with the project’s impacts and risks):
(i) Mitigation:
(a) identifies and summarizes anticipated significant adverse environmental impacts and risks;
(b) describes each mitigation measure with technical details, including the type of impact to which it relates and the conditions under which it is required (for instance, continuously or in the event of contingencies), together with designs, equipment descriptions, and operating procedures, as appropriate; and
(c) provides links to any other mitigation plans (for example, for involuntary resettlement, Indigenous Peoples, or emergency response) required for the project. 39
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(ii) Monitoring:
(a) describes monitoring measures with technical details, including parameters to be measured, methods to be used, sampling locations, frequency of measurements, detection limits and definition of thresholds that will signal the need for corrective actions; and
(b) describes monitoring and reporting procedures to ensure early detection of conditions that necessitate particular mitigation measures and document the progress and results of mitigation.
(iii) Implementation arrangements:
(a) specifies the implementation schedule showing phasing and coordination with overall project implementation;
(b) describes institutional or organizational arrangements, namely, who is responsible for carrying out the mitigation and monitoring measures, which may include one or more of the following additional topics to strengthen environmental management capability: technical assistance programs, training programs, procurement of equipment and supplies related to environmental management and monitoring, and organizational changes; and
(c) estimates capital and recurrent costs and describes sources of funds for implementing the environmental management plan.
(iv) Performance indicators: describes the desired outcomes as measurable events to the extent possible, such as performance indicators, targets, or acceptance criteria that can be tracked over defined time periods.
J. Conclusion and Recommendation
This section provides the conclusions drawn from the assessment and provides recommendations.
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ANNEXURE-III
Terms of Reference for Consulting Services for Environmental Assessment
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A. Objectives
The objective of the consulting services is ensuring the environmental soundness and sustainability of the project and supporting the integration of environmental considerations into the project-making process in accordance with ADB’s SPS 2009 (Safeguard Requirement 1: Environment), and considering WB Group EHS Guidelines. This will be achieved by conducting environmental impact assessment (EIA) or initial environmental examination (IEE) of the proposed project to identify potential environmental impacts on physical, ecological, socioeconomic, and physical cultural resources, and preparing EIA/IEE report with environmental management plan in accordance with the ADB’s Safeguard Policy Statement (2009). The indicative duration of an EIA study is 4-6 months3 and an IEE study – 1.5 – 3 months.
B. Scope of Work
The consultant’s scope of work will include the following tasks:
Analysis of the background materials. Background materials of the earlier studies including ecological, geotechnical, hydrogeologic, and other relevant studies for each sub-project will be collected from the relevant organizations and analyzed;
Assessment of Environmental Impacts and Development of Mitigation Measures. An EIA or IEE study to assess potential direct, indirect, cumulative, induced, as well as transboundary and global impacts of the project to physical, biological, socioeconomic, and physical cultural resources during design, construction and operation stages will be conducted. Adverse environmental impacts will be avoided, or where it is not possible
Examination of Alternatives. Alternatives to the project’s location, design, technology, as well as “no project” alternative will be assessed;
Public consultations. Meaningful public consultations with affected people (at least two rounds consultations for EIA and one consultation for IEE) ensuring participation of all stakeholders including non-governmental organizations, women will be conducted. The list of people attended the consultation, time and locations, subjects discussed during consultation will be recorded in systematic manner and attached in the EIA/IEE report as an appendix;
Grievance Redress Mechanism will be established;
Preparation of IEE/EIA report. An EIA/IEE report including executive summary, policy, legal, and environmental framework, description of the project, baseline data, expected environmental impacts and mitigation measures, analysis of alternatives, information disclosure, consultation and participation, grievance redress mechanism, in accordance with ADB’s Safeguard Policy Statement (2009);
3 More time should be planned for EIA preparation if seasonal (winter/summer) data needs to be collected.
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Preparation of EMP. Site-specific environmental management plan will be prepared within the framework of this activity.
C. Team Composition and Organization
Composition of an environmental assessment team will depend on the level of environmental assessment required (IEE or EIA), as well as location, type and magnitude of the project. In general, it will be based on the following requirements: both international and domestic specialists will be involved in environmental assessment process; in case of an IEE, the team will by composed of, in most cases, environmental specialists; in case of an EIA, sub-specialists such as biologists, hydrologists, botanists, etc will be brought into the process depending on the project sensitive field; the Team Leader (International Environmental Specialist) will have 10-15 years of experience in environmental assessment, environmental management and monitoring, construction supervision of projects including road construction, team management skills, experience working in teams of multi-discipline experts and leading a national team of consultants, understanding of administrative, procedural, and technical requirements of environmental assessment;
Domestic Specialists will be graduates in environmental science, environmental engineering, geological science, engineering hydrology, biology or related discipline with significant experience in environmental management and monitoring of projects, environmental assessment and/or design and implementation of environmental mitigation measures.
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ANNEXURE-IV
Outline of Environmental Monitoring Report
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{Semi Annual Environmental and/or Social} Monitoring Report
Project Number: {XXXXX} {Reporting period: Month Year}
{Full Country Name}: {Project Title} {(Financed by the
Prepared by {author(s)} {Firm name} {City, country}
For {Executing agency} {Implementing agency}
Endorsed by: (staff name of IA/PIU) and signature, submission date
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[Subject] [Title] ______
Table of Contents
1 INTRODUCTION ...... 3 1.1 Preamble ...... 3 1.2 Headline Information ...... 3 2 PROJECT DESCRIPTION AND CURRENT ACTIVITIES ...... 4 2.1 Project Description ...... 4 2.2 Project Contracts and Management ...... 4 2.3 Project Activities During Current Reporting Period ...... 4 2.4 Description of Any Changes to Project Design ...... 4 2.5 Description of Any Changes to Agreed Construction methods ...... 5 3 ENVIRONMENTAL SAFEGUARD ACTIVITIES ...... 6 3.1 General Description of Environmental Safeguard Activities ...... 6 3.2 Site Audits ...... 6 3.3 Issues Tracking (Based on Non-Conformance Notices) ...... 6 3.4 Trends...... 7 3.5 Unanticipated Environmental Impacts or Risks ...... 7 4 RESULTS OF ENVIRONMENTAL MONITORING ...... 8 4.1 Overview of Monitoring Conducted during Current Period ...... 8 4.2 Trends...... 8 4.3 Summary of Monitoring Outcomes ...... 8 4.4 Material Resources Utilisation ...... 8 4.4.1 Current Period ...... 8 4.4.2 Cumulative Resource Utilisation ...... 8 4.5 Waste Management ...... 9 4.5.1 Current Period ...... 9 4.5.2 Cumulative Waste Generation ...... 9 4.6 Health and Safety ...... 9 4.6.1 Community Health and Safety ...... 9 4.6.2 Worker Safety and Health ...... 9 4.7 Training ...... 9 5 FUNCTIONING OF THE SEMP ...... 10 5.1 SEMP Review ...... 10 6 GOOD PRACTICE AND OPPORTUNITY FOR IMPROVEMENT ...... 11
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6.1 Good Practice ...... 11 6.2 Opportunities for Improvement ...... 11 7 SUMMARY AND RECOMMENDATIONS ...... 12 7.1 Summary ...... 12 7.2 Recommendations ...... 12
Annexes: Photographs (with date printed) Monitoring data Etc..
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Abbreviations Include list of abbreviations used in the report
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• INTRODUCTION
• Preamble
This report represents the Semi - Annual Environmental Monitoring Review (SAEMR) for INSERT PROJECT NAME.
This report is the (insert number of report, i.e. 1st, 2nd etc) EMR for the project.
• Headline Information
Include a brief summary of significant outcomes of the project construction process and any specific areas of concern of which ADB should be informed.
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• PROJECT DESCRIPTION AND CURRENT ACTIVITIES
• Project Description
Provide a brief description of the project. – this should not vary from one report to the next.
• Project Contracts and Management
Provide a list or table of main organisations involved in the project and relating to Environmental Safeguards. This should include lender, borrower, PIU, Main Contractor/s and significant sub-contractors, environmental staff of various organisations should be named, and contact details provided.
Provide a description of how the contracts are being managed and names of key personnel.
• Project Activities During Current Reporting Period
Provide an outline of major activities which have been carried out during the current reporting period. Provide adequate information so the reader can understand what has been taking place on site. Include photographs (with date stamp) of activities where possible and relevant. Place bulk photographs into an annex to the main report or a separate photographic record.
Where multiple work sites are involved provide information on which work sites have been active during the current reporting period. Provide map of work site areas if relevant.
Provide details (chart) of worker numbers (maximum, Minimum) in the current reporting period and anticipated changes in staff in following period
Highlight any significant new activities commenced during the current reporting period.
For the above make maximum use of charts, images and tables.
• Description of Any Changes to Project Design
Describe any changes to the project design from that which was assessed in the Impact Assessment phase of the project and is set out in the Initial Environmental Examination/Environmental Impact Assessment. If none have taken place, please state – No changes.
Note if significant changes have occurred the PIU should have already informed ADB of this and made a decision on the need for updates to the EIA/IEE and/or Environmental Management Plans
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• Description of Any Changes to Agreed Construction methods
Provide a description and reason for changes to any construction processes, for example, blasting of rock rather than excavation, open channel rather than thrust boring at road crossings.
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• ENVIRONMENTAL SAFEGUARD ACTIVITIES
• General Description of Environmental Safeguard Activities
Please provide a summary of the routine activities undertaken by environmental safeguard staff during the current reporting period. This should include the work undertaken by the contractor’s environmental manager, the Environmental Supervisor and any informal visits by the PIU environmental staff.
• Site Audits
Please provide details (table form preferred) of any formal audits undertaken by environmental safeguard process staff during the current reporting period. This would include Contractors Environmental Manager, Environmental Supervisor, PIU Staff and ADB staff during review missions.
Information required includes:
Date of Visit Auditors Name Purpose of Audit Summary of any Significant Findings Cross reference to Audit Report which should be included as an annex. Summarise Findings of Audits under taken in the current period, compare with previous periods and identify any trends or common issues.
• Issues Tracking (Based on Non-Conformance Notices)
Provide an overview and description of issues tracked during the current period.
Provide commentary on key statistics based on graphs and tables which can be copied from the Environmental Safeguards Issues Tracing Workbook. For example
Table 0-1 Summary of Issues Tracking Activity for Current Period
Summary Table Total Number of Issues for Project 6 Number of Open Issues 1 Number of Closed Issues 5 Percentage Closed 17% Issues Opened This Reporting Period 5 Issues Closed This Reporting Period 4
Figure 0-1 - Summary of Issues by Non-Conformance
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Use data from workbook as required.
• Trends
Use information from previous period reports and the current period information to identify trends in issues. For example -
Quarterly Report Total No of Issues % issues Closed % issues closed No late 1 5 87 0 2 18 56 15 3 59 23 26
Provide a commentary on the trends, explain why they may be occurring and in the case of negative trends explain what steps have been taken to make corrections.
Provide a copy of all NCN’s for all major Non-Conformances in an annex. If none state this.
• Unanticipated Environmental Impacts or Risks
Document any unanticipated environmental impacts and risks which have been identified in the current period (as a reminder, these are impacts or risks which were not identified in the Impact Assessment process). State what actions were taken to mitigate the impacts and risks, were these successful.
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• RESULTS OF ENVIRONMENTAL MONITORING
• Overview of Monitoring Conducted during Current Period
Provide a commentary on what environmental measurements have been undertaken during the current reporting period. Highlight any areas where agreed monitoring has not taken place.
Include sub sections for the report on those environmental media which have been measured, for example
Noise Air Quality Water Quality The sections should present highlights of the outcomes of the monitoring focussing on a comparison of the results with the agreed standards as set out in the Specific Environmental Management Plan and/or Monitoring Plan.
In particular make clear where exceedances in the standards have occurred and provide reasons and actions which have been implemented to correct – refer to relevant NCN as appropriate.
Detailed monitoring results should be presented as an annex.
• Trends
Based on the current and past periods of monitoring identify and discuss any trends which may be developing.
• Summary of Monitoring Outcomes
Provide any recommendations on the need for additional monitoring, or requests for ceasing/altering monitoring if activities have been completed or monitoring is showing no significant effects over long period.
• Material Resources Utilisation
• Current Period
Provide values (tables, graphs etc) for current reporting period of utilisation of electricity, water and any other materials which have been include in the SEMP for monitoring.
• Cumulative Resource Utilisation
Provide values (tables, graphs etc) for cumulative resource utilisation of power water etc, for whole project life. Identify trends or significant changes and provide reasons for any such changes.
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• Waste Management
Provide summary of waste management activities during the current period. Provide waste contractors/s names and location of waste sites.
• Current Period
Provide breakdown using graphs, table etc, of waste streams during current reporting period. This information should include
Type of Waste (description and classification – e.g. hazardous – non-hazardous; Waste Source – what activity generated the waste and where; Quantity of waste generated; Treatment/disposal route – provide information on quantities of waste reused, recycled and sent to landfill or incineration; and Final disposal sites for waste. Provide commentary on results.
• Cumulative Waste Generation
Using the above bullet points for waste develop cumulative waste generation results.
Discuss trends and provide suggestions for waste reduction, increase in reuse and recycling if possible.
1.1 Health and Safety
• Community Health and Safety
Provide information on any incidents which have occurred during the reporting period which resulted in or could have resulted in Community Health and Safety issues. Include within this section traffic accidents.
• Worker Safety and Health
Provide detailed statistics on accident rates, including Lost Time Incidents, Accidents and near misses.
Provide information on safety campaigns conducted during the reporting period.
• Training
Provide information on all environmental safeguard related training activities undertaken in this period and cumulatively for project life to date. These may include specific training of environmental staff, HSE inductions of site workers etc.
Discuss the need for additional training and what training is planned for coming quarter.
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• FUNCTIONING OF THE SEMP
• SEMP Review
Provide a commentary on the SEMP in terms of the ability of the contractor to implement fully the requirements set out. Highlight any areas where the contractor has not been able to implement mitigation or monitoring measures.
Is the SEMP effective, are mitigation measures set out still appropriate and are they working as intended – do they need changing?
Are there better alternative mitigation measures?
Can some mitigation measures be reduced or removed as the specific risk identified in the IEE/EIA and/or SEMP has not materialised?
Provide a table of requests for changes to the current mitigation measures for consideration by ADB. Note you can send these at any time during the project, there is no need to wait until the quarterly reporting period to be completed. If PIU has supplied requests to ADB, these should be listed along with ADB response. Where changes (additions/deletions and modifications) of mitigation or monitoring measures have been approved, the PIU shall ensure that the SEMP is updated to reflect these changes.
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• GOOD PRACTICE AND OPPORTUNITY FOR IMPROVEMENT
• Good Practice
Provide an overview with charts, images etc of examples of continuing good practice for the project. State why these have been implemented and how they are reducing environmental impacts or risks.
• Opportunities for Improvement
Identify any areas which may be outside of the formal NCN process, but which changes to construction techniques, mitigation etc would result in an improvement in environmental, health and safety performance of the project.
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• SUMMARY AND RECOMMENDATIONS
• Summary
Provide a summary of the effective implementation of Environmental Safeguards during the reporting period and for the overall project construction period to date.
• Recommendations
Provide any recommendations for consideration by the ADB for changes to the Environmental Safeguarding process for the project.
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