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Initial Environmental Examination

Project Number: 37220 October 2008

Pakistan: Improvement Investment Program (SCIP) Solid Waste Management Initial Environmental Examination

Prepared by the for the Asian Development Bank.

Initial Environmental Examination

Project Number: 37220 October 2008

PAK: Sindh Cities Improvement Investment Program Solid Waste Management Initial Environmental Examination

This report has been submitted to ADB by the Government of Sindh and is made publicly available in accordance with ADB’s public communications policy (2005). It does not necessarily reflect the views of ADB.

Sindh Cities Improvement Investment Program IEE Report for Solid Waste Management Sector Subprojects

CONTENTS I. INTRODUCTION 5 A. Overview 5 B. The Investment Program 5 C. Environmental Regulatory Compliance 6 D. Environmental Category of Solid Waste Sector Subprojects 6 E. Objectives and Scope of IEE 6 F. Report Structure 7 II. DESCRIPTION OF SOLID WASTE MANGEMENT SECTOR SUBPROJECTS 7 A. Background and Need 7 B. Proposed Investment 8 C. Secondary Storage Facilities 8 D. Secondary Collection Vehicles 10 E. Sanitary Landfill 10 III. ENVIRONMENTAL SETTING 14 A. Seismic Intensity 14 B. Topography and Soil 14 C. Hydrology and Water Resources 14 D. Climate 15 E. Demography and Socioeconomics 16 F. Waste Generation, Collection and Disposal 17 G. Environmental Conditions in the Vicinity of the Proposed Sites 20 IV. ENVIRONMENTAL IMPACTS AND MITIGATION 27 A. Screening of Environmental Impacts 27 B. Design Related Impacts and Design Principles 30 C. Construction Related Impacts 31 D. Operations Related Impacts 32 E. Positive Impact 34 V. STAKEHOLDERS CONSULTATION 34 A. Identification of Stakeholders and Methodology 34 B. Consultations’ Summary 35 C. Discussion Summary 35 D. Future Consultation 35 VI. INSTITUTIONAL REQUIREMENTS AND ENVIRONMENTAL MANAGEMENT PLAN 35 A. Institutional Arrangements 35 B. Complaints and Grievances Redress 36 C. Environmental Review and Approval 37 D. Environmental Management Plan 37 E. Monitoring and Evaluation 38 F. Training 39 VII. FINDINGS AND RECOMMENDATIONS 42 VIII. CONCLUSIONS 43 APPENDIX A: STAKEHOLDER CONSULTATIONS 45 APPENDIX B: ENVIRONMENTAL MANAGEMENT PLAN 50

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FIGURES Figure 1: The Proposed Landfill Sites in , , Larkana, and Shikarpur..9 Figure 2: Design of a Typical Cell at the Landfill Site ...... 13 Figure 3: Landfill Site for , New Sukkur, and Rohri...... 23 Figure 4: Landfill Site for Khairpur ...... 24 Figure 5: Landfill Site for Larkana...... 25 Figure 6: Landfill Site for Shikarpur...... 26 Figure 7: Monitoring Report Format ...... 40

TABLES

Table 1: Collection System Improvements ...... 10 Table 2: Summary of Landfill Sites...... 12 Table 3: Seasonal Characteristics of Climate of the Project Area ...... 16 Table 4: Demographic Data and Socioeconomic Indicators ...... 18 Table 5: Key Data on Current Waste Generation...... 19 Table 6: Comparison of the Proposed Sites for Landfill...... 22 Table 7: Screening of Environmental Issues – Design and Construction ...... 28 Table 8: Screening of Environmental Issues - Operations...... 29 Table 9: Environmental Monitoring Plan for Tranche 1 SWM Subprojects...... 41 Table 10: Summary of Estimated Costs for EMP Implementation...... 42 Table 11: Operations Phase Environmental Monitoring Plan ...... 42

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LIST OF ABBREVIATIONS

ADB Asian Development Bank DCO District Coordination Officer EARF Environmental Assessment and Review Framework EDO Executive District Officer EIA Environmental Impact Assessment EMP Environmental Management Plan EPA Environmental Protection Agency GoP Government of the Islamic Republic of GoS Government of Sindh IA Implementing Agency IEE Initial Environmental Examination LARF Land Acquisition and Resettlement Framework LARP Land Acquisition and Resettlement Plan M&E Monitoring and evaluation MFF Multi-tranche Financing Facility NEQS National Environmental Quality Standards NGO Non-Governmental Organization NOX Oxides of Nitrogen NSUSC North Sindh Urban Services Corporation P&DD Planning and Development Department Pak-EPA Pakistan Environmental Protection Agency PSC Program Steering Committee PSU Program Support Unit ROW Right of Way SC Safeguards Cell SCIP Sindh Cities Improvement Investment Program SEPA Sindh Environmental Protection Agency SO2 Sulphur Dioxide SR Sensitive Receiver SWM Solid Waste Management TA Technical Assistance TMA Taluka Municipal Administration USC Urban Services Corporation WSS Water Supply and Sanitation Sector

WEIGHTS AND MEASURES

dB(A) Decibel (A-weighted) ft Feet/Foot km kilometre m meter m3 cubic meter m2 square meter mgd million [imperial] gallons per day s seconds

LAWS AND REGULATIONS

IEE-EIA Regulations 2000 Pakistan Environmental Protection Agency Review of Initial Environmental Examination and Environmental impact Assessment Regulations 2000 PEPA 1997 Pakistan Environmental Protection Act 1997 SLGO 2001 Sindh Local Government Ordinance 2001

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I. INTRODUCTION

1. Government of Pakistan (GoP) has requested the Asian Development Bank (ADB) to provide a multi-tranche financing facility (MFF) to facilitate investments to support the proposed Sindh Cities Improvement Program (SCIP, the Program). The SCIP will implement a number of subprojects within seven components including: support to institutional reform and development; waste supply and wastewater management; and solid waste management. 2. This Initial Environmental Examination (IEE) presents the environmental assessments of the solid waste management sector subprojects in Tranche 1 of the MFF. This IEE has been carried out to ensure that the potential adverse environmental impacts are appropriately addressed in line with ADB’s Environmental Policy (2002) and Environmental Assessment Guidelines (2003). This IEE has also been prepared to meet the requirements of the GoP for environmental assessment. 3. This IEE is submitted to ADB by the Government of Sindh on behalf of North Sindh Urban Services Corporation (NSUSC) and this report will be submitted for review and approval by the Sindh Environmental Protection Agency (SEPA) as required by the Pakistan Environmental Protection Act, 1997, as regulated.

A. Overview

4. The ultimate objective of the solid waste management (SWM) sector subprojects of the SCIP MFF is to improve the collection and disposal of solid waste from the cluster cities in northern Sindh. 5. To achieve these objectives, an integrated, long-term package of investments and support programs have been developed. In the solid waste management sector, the sub- projects included under the first tranche will comprise: (i) construction of communal bins for secondary waste collection, (ii) procurement of equipment/vehicles for collection of solid waste; and (iii) construction of 4 sanitary landfill sites for one cluster (Sukkur, New Sukkur, and Rohri) at Rohri and three towns, Khairpur, Larkana, and Shikarpur. 6. An IEE is required for all MFF subprojects under ADB and the EMP of the IEE aims to mitigate all the reasonably foreseeable impacts. The EMP must be updated later before construction starts and reviewed periodically as the project proceeds in order to take account of any unanticipated impacts for the Tranche 1 subprojects. A detailed environmental assessment and review framework (EARF) procedure has been prepared that must be followed as required by ADB for all the subprojects in future tranches.

B. The Investment Program

1. The Investment Program aims at facilitating sustainable urban development by assisting government efforts to improve basic urban infrastructure and services in Sindh Province. The Investment Program comprises four parts: (i) Part A: Urban Planning, Institutional Development and Program Implementation provides specialized technical assistance and seeks to establish a Program Support Unit (PSU) and regional urban services corporations (USCs), beginning with the NSUSC, and an Urban Policy and Strategic Planning Unit (the Urban Unit) under Planning and Development Department (P&DD). (ii) Part B: Urban Water Supply and Wastewater Management Improvements may include construction of new tube wells, groundwater

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monitoring facilities, new transmission lines, high storage reservoirs (HSRs), or water treatment plants and construction/rehabilitation of water tanks, pumping stations, and filtration systems. This component also includes rehabilitation or extension of secondary/tertiary drains in each cluster town. (iii) Part C: Solid Waste Management (SWM) Improvements includes provision of communal bins for secondary waste collection, landfill development and procurement of equipment/vehicles for collection and disposal of solid waste to landfill site. (iv) Part D: Transition and Operational Support Funding to supplement urban services corporation operating cash flow needs.

C. Environmental Regulatory Compliance

7. Section 12(1) of the Pakistan Environmental Protection Act 1997 requires that “No proponent of a project1 shall commence construction or operation unless he has filed with the Federal Agency2 an initial environmental examination or, where the project is likely to cause an adverse environmental effect, an environmental impact assessment, and has obtained from the Federal Agency approval in respect thereof.” 8. The Pakistan Environmental Protection Agency Review of Initial Environmental Examination and Environmental Impact Assessment Regulations, 2000 (IEE-EIA Regulations 2000) provide the necessary details on the preparation, submission, and review of the IEE and the environmental impact assessment (EIA). The regulation categorizes the projects on the basis of anticipated degree of environmental impact. Project types that are likely to have significant adverse impact are listed in Schedule II of the regulations and require an EIA. Projects that are not likely to have significant adverse impact are listed in Schedule I and require an IEE, provided that the project is not located in an environmentally sensitive area3. Waste disposal facilities for domestic wastes with an annual capacity of more than ten thousand cubic meters’ require EIA (Schedule II). Disposal facilities with capacity less than ten thousand cubic meters requite IEE. 9. The National Environmental Quality Standards (NEQS) are also applicable to any non- fugitive emission or effluent from the sites.

D. Environmental Category of Solid Waste Sector Subprojects

10. Under ADB’s Environmental Assessment Guidelines (2003) the Tranche 1 subprojects are Category “B” and require Initial Environmental Examination (IEE).

E. Objectives and Scope of IEE

11. The objectives of this IEE were to: i) Assess the existing environmental conditions in the areas where the SWM sector subprojects are located including the identification of environmentally sensitive areas;

1 Defined as “any activity, plan, scheme, proposal or undertaking involving any change in the environment and includes-(a) construction or use of buildings or other works; (b) construction or use of roads or other transport systems; (c) construction or operation of factories or other installations; (d) mineral prospecting, mining, quarrying, stone-crushing, drilling and the like; (e) any change of land use or water use; and (f) alteration, expansion, repair, decommissioning or abandonment of existing buildings or other work roads or other transport systems, factories or other installations. 2 The Ministry of Environment, Government of Pakistan has delegated the power of the Federal Agency for EIA and IEE reviews for projects falling in the provinces to the environmental protection agencies of the respective provinces. Federal Agency in this case is the sindh Environmental Protection Agency. 3 Sensitive areas are listed on the Federal EPA website and periodically updated.

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ii) Assess the proposed activities, identify and evaluate the potential impacts and determine their significance; iii) Propose appropriate mitigation measures that can be incorporated into the proposed activities to minimize any adverse impacts, ensure that residual impacts are acceptable and propose monitoring and planning of future projects in this sector in Sindh. 12. This IEE is based mainly on secondary sources of information and field reconnaissance surveys.

F. Report Structure

13. Following this introduction this report contains seven more sections including (ii) description of water sector subprojects; (iii) description of the environment; (iv) environmental impacts and mitigation; (v) public consultation; (vi) institutional requirements and environmental management plan; (vii) findings and recommendations; and (viii) conclusions. 14. Selected photographs of the project area are included as Appendix A, the stakeholder’s list is presented as Appendix B and the environmental management plan matrix is presented in Appendix C.

II. DESCRIPTION OF SOLID WASTE MANGEMENT SECTOR SUBPROJECTS

A. Background and Need

15. Secondary towns and cities in Sindh are in desperate need of basic services. With the exception of small pockets of high income and commercial areas, cities and towns are characterized by quality-of-life poverty in the form of poor access to water, sanitation, drainage and solid waste management services. The absence of potable water supply and adequate sanitation and waste management in these towns is responsible for a number of health threats and vulnerabilities to major epidemics. To improve theses services in these towns, the GoS through its own resources and the SCIP aims at providing both investment in infrastructure and service provision and, more importantly major reforms in service delivery mechanisms are needed. 16. These towns have very similar characteristics. All the towns function as market towns for the surrounding agriculture land and livestock. Another important similarity in the towns is the continuous influx of immigrants from the surrounding villages. Other than Sukkur that has an industrial estate housing over 50 medium-sized industrial units, industrial base of these towns is limited and is confined to agriculture related industries such as rice mills, flour mills, and dairy industry. Many of them also support some small cottage industries. The industrial base, in particular the cottage industries are reportedly growing in size. 17. Solid waste management systems are either non-existent or exist but are poorly operated in most of these towns. Government’s own surveys suggest that only 10% of the population is satisfied with the current solid waste management and collection situation. Many Town Nazims rate the need for improvement in solid waste management as their top priority. In comparison to cities like , and , the solid waste services in secondary towns of Sindh are extremely basic. The service provided often comprises only: (i) the sweeping of less than 5% of the total road network—those which are considered ‘important’ roads and streets; and (ii) cleaning drains when they are blocked on an ad-hoc basis. Few areas enjoy a curb-side solid waste collection service. In most cases, people bring their waste to accessible roads or just dispose of it in open areas or to the drainage network within communities. In general, the municipality transports only half of the waste

10/19/08 Page 7 of 59 Sindh Cities Improvement Investment Program IEE Report for Solid Waste Management Sector Subprojects generated in residential and commercial areas, unloading it from trucks without any further processing in open areas within or on the edge of the towns. Another concern of the present system is the lack of segregation of hazardous waste, mainly medical waste, from the municipal waste. Often the medical waste is also disposed of with the municipal waste. 18. Although no study is available on the direct health impact of the present waste management practices, there are no second opinions that the practices are hazardous to health. Given the rapid urbanization and the growing industrial base, there is an urgent need to improve the hygienic conditions of the towns and make their roads and streets aesthetically more appealing. In order to achieve this, the basic needs in the solid waste management sector are i) To undertake institutional reforms to make the waste management system more efficient and responsive to the present and growing needs. ii) To invest in equipment and works to increase system coverage and allow for appropriate disposal. In particular, improve the storage and collection from homes by introducing neighborhood bins which are not accessible to rodents and vectors, and reduce the reliance of the system on manual loading. iii) To identify at source and separately collect, appropriately treat and dispose hospital and industrial waste.

B. Proposed Investment

19. This Program will support the development of infrastructure and systems that will address the basic needs for the effective and environmentally sound management, removal and disposal of solid waste, and will generate significant efficiency gains in waste collection, storage and final disposal. This project will cover four similar subprojects in: (i) the sub- cluster of Sukkur, New Sukkur and Rohri, and (ii) in each of the three cluster cities of Khairpur, Larkana and Shikarpur. In all towns the subprojects comprise: (i) Construction of secondary domestic solid waste storage facilities (skip points to accommodate two or more standard 5 cum metal skips and associated civil works to ensure easy access to skips). (ii) Procurement of adequate 5 cum metal skips to accommodate all waste currently generated. (iii) Procurement of secondary collection, skip hoist vehicles with a hoisting and tipping mechanism capable of placing, carrying and discharging 5 cum skips (iv) Development of a landfill site and procurement of landfill equipment. 20. The collection, transportation and disposal system adopted by each of the program TMAs will be identical, although in the case of the sub-cluster of Sukkur, New Sukkur and Rohri, a single common landfill site will serve all three TMAs. The components are further described below. The location of the towns is shown in Figure 1.

C. Secondary Storage Facilities

21. Secondary storage facilities will be constructed in those residential areas where door-to- door collection is not possible (most areas). Secondary waste collection points will be identified and wherever possible will be developed on existing secondary collection storage points so as to avoid public objections. The sites will be located within 200 meters of all households and will be constructed so as to facilitate the placing and lifting of skips, allowing the necessary vehicle turning. The skip points will be designed to accommodate at least two skips (so that an empty skip may be placed when a full one is lifted) and the base will be concreted, drained and provided with steps or a ramp to allow children and those with carts to dispose of waste to the skip. The skips will be of 5 m3 nominal volume and will be provided with removable covers containing access points for disposal of waste to the skip.

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Figure 1: The Proposed Landfill Sites in Rohri, Khairpur, Larkana, and Shikarpur

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D. Secondary Collection Vehicles

22. Investment in collection vehicles is needed to systematically improve both the population coverage and the quantities transported from the current average of below 50% to 95% of urban populations and of the quantities generated. The proposed vehicle fleet of skip hoist vehicles will replace the existing fleet of tractors and trailers. These vehicles (which are of Pak-Hino 300 series light duty type skip hoist vehicle carrying 1x 5 m3 skip—or equivalent) are preferred over other types of technology because of their simplicity, robustness and availability of skills and spare parts for repair and maintenance. The system has the benefit of avoiding double-handling of waste, and the skip-hoist vehicle can be operated by a driver alone—although initially it is preferable to use a driver and a crew of one. In addition, while double handling is avoided, this assumes all waste is disposed of to the skip. Initially NSUSC or contractor’s staff will need to ensure the cleanliness of areas around the skip-points. Table 1 presents the summary of the collection system improvement.

Table 1: Collection System Improvements

TMA Current Current Est. Proposed Vehicle Fleet and Storage Est. Vehicle Fleet Collection Collection Efficiency Skip Skips Ship-hoist Efficiency Points Trucks Sukkur 5 T&T, 1 truck 50% 90 105 15 95% New Sukkur 2 T&T 50% 30 35 5 95% Rohri 1 T&T < 50% 18 21 3 95% Khairpur 4 T&T 50% 48 56 8 95% Larkana 4 T&T, 2 trucks 50% 114 133 19 95% Shikarpur 3 T&T < 50% 54 63 9 95% T&T = Tractor and Trailers

E. Sanitary Landfill

23. The final disposal of domestic, (non-toxic) trade, commercial, and institutional waste will be through landfilling at a sanitary landfill site, which will provide controlled facilities for the final disposal of waste in such a way that any short- and long-term negative environmental impacts can be minimized or avoided. The waste collected from the municipal areas will be brought directly to the landfill site. The waste will be weighed, inspected and directed to the operational cell. The waste will be unloaded, spread and compacted and once filled and compacted to a height of 4 m, covered with a layer of suitable inert, impermeable cover material. The site will be filled gradually with waste and monitored for any short and long term impacts such as gas and leachate migration and groundwater contamination. 24. The landfills are designed for a minimum operational life of 12-24 years. It makes both economic and operational sense to obtain a site for longer than this where land is available at a single location, since landfills are difficult and expensive to find and operate. In the case of the contiguous sub-group of TMAs of Sukkur, New Sukkur and Rorhi4 it makes economic sense to develop a common facility. In general, each of the landfills will include the following facilities: (i) 2-m high barbed wire fencing over a 1-m high earthen bund around all sites to help provide screening and avoid public access to site.

4 Site construction activities will be amended as necessary based on specific site requirements at detailed design stage.

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(ii) Cut-off drain on upland side of site of average X-section of a least 1 m2 and length as necessary, discharging to the nearest suitable surface water drainage point, to ensure surface water does not run across site. (iii) Site clearance and earthworks to provide cells of 4 m finished depth, to accommodate first 2 years of waste reception, and other earthworks as necessary to form site. (iv) Provision of 0.3 m clay and 1 mm gauge impermeable plastic membrane liner as necessary to cells, cell drainage system and provision of leachate recycling to cell as necessary, and provision for landfill gas venting. (The impermeable membrane liner will be required (i) in cell for emergency disposal of hospital or toxic industrial waste (see below); (ii) where water table raises to within 2 m of finished cell base; or (iii) where formation level of a high permeability is present—e.g. limestone kharst) (v) Access road provision or improvement as necessary to provide 6.7 m wide all-weather access to site (may be graded water-based macadam if suitable and adequate road can be formed or single bituminous surface treated) (vi) Provision of graded site spine road of 6 m width (may be graded water-based macadam if suitable and adequate road can be formed or single bituminous surface treated) (vii) Provision of gate, gatehouse, site office, hardstanding (viii) Provision of secured and impermeable cell for receipt and disposal of incinerated hospital wastes and for emergency storage of toxic and hazardous wastes (only when inadvertently delivered to site). (ix) Provision of 10 sets of 10 m length each of movable litter screens, and 50 linear meters of fabricated steel interlocking temporary roadway. (x) Procurement and installation of weighbridge. (xi) Procurement of landfill equipment—D6 bulldozer or equivalent, water bowser and D957 tracked loader or equivalent with quick-release forks, bucket, landfill blade etc. (xii) Construction of at-least 4 monitoring wells at critical locations 25. Table 2 presents a summary of the sanitary landfill investment for Sukkur Cluster, Khairpur, Shikarpur and Larkana. 26. Operations: The site operation will fall under the duties and responsibilities of NSUSC who are expected to tender out operation of the facility. Initially, a suitable number of cells, each 30 m wide, between 68 m to 184 m long, and 4 m deep, would be prepared as per the specifications described above. In one year four cells would be required. The waste received at each landfill will vary by size: 90 tonnes per day (t/d) at Khairpur, 100 t/d at Shikarpur, 200 t/d at Larkana, and 245 t/d at Rohri. 27. The waste will be transported in closed collection truck. The trucks would be weighed before and after unloading so that inventory of the waste received at the landfill could be maintained. The waste will be unloaded directly in the active cells. Once unloaded, the waste would be moved in place using a bulldozer and a layer of soil will be placed on the top. One cell is designed to last 3 months. Once the capacity of the landfill cell has been fully utilized, the cell will be capped with a final cover consisting of compacted clay and a soil cover capable of supporting appropriate vegetation. A sketch of a typical cell is shown in Figure 2. 28. Three types of plans will be prepared for each landfill: a) An operations and maintenance plan detailing the daily operations and maintenance procedure and requirements; b) A landfill development plan detailing when and how development work on new cells would be started; c) A contingency plan to respond to emergencies such as floods, storms, accidents, and collapse of sidewalls.

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Table 2: Summary of Landfill Sites

Item Sukkur Khairpur Shikarpur Larkana Cluster Landfill site (ha) 40 11.7 25.9 36

Site boundary bund and 5- 2,000 1,500 1,000 1,500 strand barbed wire fencing - in linear meters Cut-off drain on upland side of 1 m2 x 1 km 1 m2 x 1 km 1 m2 x 8 km 1 m2 x 1 km site Site earthworks/excavation (in 55,092 20,327 22,453 45,004 cubic meters)/year Provision of 0.3 m clay liner (in 6,611 2,439 2,694 5,400 cubic meters)/year Provision of 1 mm gauge 5,509 2,033 8,981 18,001 impermeable membrane (in square meters) per year Leachate Collection and 2 2 2 2 Recirculation System stockpile for daily cover soil (0.5 5,509 2,033 2,245 4,500 m thick) in cum/yr Leachate collection pipes (4") in 735 271 299 600 meters/year Gas vents (vertical 2 m)/year 110 41 45 90 Provision of graded and single 6 x 6000 6 x 3000 6 x 3000 6 x 3000 bituminous surface treated site spine road (in meters) Access road (new or improved) 2 0 0 0 (in km) Gate, gatehouse, site office, 1 1 1 1 hardstanding and vehicle washing facilities - item Secured and impermeable cell 1 1 1 1 for receipt and disposal of incinerated hospital wastes - item Movable litter screens ( in linear 10 x 10 m 10 x 10 m 10 x 10 m 10x 10 m meters ) Fabricated steel interlocking 50 50 50 50 temporary roadway – (in meters) No. of Weighbridges 1 1 1 2 Bulldozers 1 1 1 1 Multipurpose Tracked Loader 1 1 1 1 Water Bowser 1 1 1 1 Pickup (Hilux, single cabin) 1 1 1 1 Monitoring wells at critical 4 4 4 4 locations – number

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Figure 2: Design of a Typical Cell at the Landfill Site

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III. ENVIRONMENTAL SETTING

29. Physiographically, Sindh comprises of the Lower Indus Basin. It the second-most populous province after the Punjab and covers 140,914 km2. Topographically, Sindh can be divided into four distinct parts with the dry and barren Kirthar Range in the west, a desert belt in the east, the Indus delta in the south, and a central alluvial plain bisected by the River Indus. The components of proposed projects are located in the northern cities of the central alluvial plains. Most of this region consists of plains overlain by alluvium, trenched with river channels in some places and overridden by raised terraces in others.

A. Seismic Intensity 30. The Geological Survey of Pakistan has classified the area as seismic zone 1 corresponding to Intensity V and VI of the Modified Mercalli Scale of 1931.5 Earthquake of this intensity is felt by all. Zone 1 corresponds to “Minor damage, distant earthquakes may cause damage to structures with fundamental periods greater than one second” The ground average peak ground acceleration in this zone is expected to be in the range 0.03–0.06 g (acceleration due to gravity, which is equal to 9.80 meter per second square). There are no fault lines within 5 kilometer of any proposed landfill site.6

B. Topography and Soil 31. The western half of the Sukkur area forms a vast alluvial plain, broken only at Sukkur and Rohri by low limestone hills which tend to preserve a permanent bank for the Indus at these places. The Khairpur area may be divided into two parts the plain cultivated area in the west and the eastern part which consists of hills and sand dunes. This range of hills starts at the south of Rohri Taluka. The cities of Larkana and Shikarpur are divided into two parts the irrigation tract and eastern riparian tract. 32. The soils of Sukkur and surrounding area are of numerous varieties with each different characteristic. These are “Latiari” a soil formed from the silt of inundation; “Tanak” the hard soil left by repeated inundation; “Thariari” a crooked soil often seen near the river with great crocks in it; “Gesari” a dusty soil; “Rabba” the hollow and “Khariri” an uneven soil; “Pat” a good soil and “Wariasi” a sandy soil and “Kalar” or saline soil , covered on surface with efflorescence of carbonate of soda; and “Thaith Kaller” a very salty soil.

C. Hydrology and Water Resources 33. Indus is the only source of freshwater for the cities in northern Sindh. At Sukkur it passes through the gorge between Sukkur and Rohri towns, the island of Bukkur bisecting the channel. The canal emanating from both sides of the at Sukkur Barrage, irrigate a large area downstream of Sukkur. The rains in the mountains in the west of Larkana and Shikarpur result in the formation of hill torrents, locally known as Nais, that usually dry up after the rainy seasons. Another source of water in the non- irrigated areas are many natural depressions known as Dhunds which retain water for a considerable period after rains. 34. The groundwater aquifers in the area are described as moderately thick and extensive with a potential yield of between 100 and 150 m3/h (Survey of Pakistan,

5 Building Code of Pakistan. 1986. Ministry of Housing and Works, Islamabad. 6 Hydrogeological Map of Pakistan, NG-42/NW (Sukkur). 1991. Pakistan Water and Power Development Authority and Survey of Pakistan.

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1989). Because of their proximity to the Indus River, salinity in the groundwater is low (less than 1,000 mg/l). The groundwater is tapped through hand pumps and wells. The water table in the area is shallow (less than 2 m). The depth of the water table varies significantly during the year with the field irrigation regime and changes in flow in the Indus River and the canals (Nazir, 1993). It has been observed that the water table has risen over time, which can be attributed to increased irrigation. 35. Ground water in Sukkur and surrounding areas is generally saline, except in some pockets where it is in the acceptable limits especially drawing of large quantity of water changes it to more brackish. Source of municipal water supply in Sukkur and Rohri is river and canal. In Larkana and Shikarpur, the main source is the groundwater, as the aquifer is fresh.

D. Climate 36. A weather station is located at Sukkur and Larkana. The climatic description of the area presented in this section is based on weather data of these stations. The climate of the area is broadly described as hot and arid. Broadly speaking, there are four seasons in Pakistan: Winter (December to March), Summer (April to June), Monsoon (July to August), and Post-Monsoon summer (September to November). 37. These seasons are defined on the basis of temperature and the changes associated with the southwest monsoon. The southwest monsoon is a wind system that prevails from April to October in the Indian Ocean, and is characterized by a reversal in wind direction and heavy rainfall over most of the Indian subcontinent. Within Pakistan, considerable variation is found in temperature and monsoonal changes. Thus, the specific characteristics and duration of seasons depend on geographic location. A complete characterization of the climate of the area is illustrated in Table 3.

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Table 3: Seasonal Characteristics of Climate of the Project Area

Season Temperature Humidity Rainfall Wind Summer March is the Morning 5-7 mm of rain Wind starts (Mid March to transition period (Evening) falls in February. changing mid June) from winter to humidity The rest of the direction, from summer. Daily decreases from season is dry— NE to S-SW, maximum 65% (28%) in monthly rainfall near the end of increases from March to about is less than March. The about 27°C at 52% (23%) by 5 mm. average speed the start of the mid April. It also increases month to 34°C at stays around this from 3 knots to the end. It figure for about 4.5 knots by mid continues to a month and June. increase and starts increasing peaks at 44°C in late May and just before the reaches 65% onset of (25%) by June. monsoon in late June. Monsoon High winds and Moisture More than Throughout this (Mid June to mid subsequent associated with 55 mm of rain period, wind September) rainfall lowers monsoon falls during this blows from the the temperature increases period; this south at an by 4-5°C in July. humidity to more accounts for average speed The maximum than 75% in the more than 60% of 3.5 knots. temperature morning and of the total remains around 40% in the rainfall received 38°C in August evening during in the area. and September. July, August and most of September. Post-Monsoon The daily Morning The season is Average wind Summer maximum (evening) dry. Monthly speed drops (Mid September temperature humidity average rainfall below 2.5 knots. to November) drops by more decreases is less than The direction than 10°C from slightly; 5 mm. starts changing early October to however, it back to NE by end of remains above the end of November. 70% (30%). September. Winter The daily Morning The season is Mild wind (less (December to maximum and (Evening) dry. Monthly than 2.5 knots) mid March) minimum humidity average rainfall blows from temperatures increases to is less than northeast averages around nearly 75% 5 mm, except throughout this 24° and 9°C, (35%) in February when season. respectively. December but 5-7 mm of rain is drops to 65% received in the (30%) by end of project area. February.

E. Demography and Socioeconomics 38. Although there is no formal definition of ‘Northern Sindh’, eight out of the 23 districts of Sindh are generally considered to be in northern Sindh. The proposed landfill sites will be located in four of these districts, Sukkur, Khairpur, Larkana, and Shikarpur and

10/19/08 Page 16 of 59 Sindh Cities Improvement Investment Program IEE Report for Solid Waste Management Sector Subprojects will serve the urban centers of Sukkur, Rohri, Khairpur, Larkana, and Shikarpur. Administratively, each district is divided into talukas. The municipal administration of urban centers is with the respective Taluka Municipal Administration (TMA). For administrative purposes, the of Sukkur is divided between two TMAs, Sukkur and New Sukkur. The landfill sites of Khairpur, Larkana, and Shikarpur would be located in their respective TMAs. The landfill site for the cluster towns of Sukkur, New Sukkur, and Rohri, would be located in Rohri taluka of . 39. The demographic and socioeconomic data of the target districts and towns is presented in Table 4. The urbanization is between 24-29%, except in the Sukkur district where it has reached 51%. The total population of the towns in which the subprojects are proposed is about 17% of the total population of the district and about 56% of the total urban population of the four districts. Literacy among urban population aged 10 years and above is over 55%. The same in the rural areas is between 24 and 32%. 40. Housing data is also provided in the table. A clear difference can be seen between the urban and rural areas. Whereas more than 55% of the houses in the target towns are made of brick and mortar, in the rural areas the ratio is only 15%. It is reported that more than 50% of the houses in the target towns have access to potable water whereas in the rural area the ratio is only 13%. In case of electricity connection, the discrepancy is not as stark as with other indicators. As compared to the target towns where 94% of the houses have electricity, the penetration in the rural areas is nearly 70%. In the rural areas of Larkana it is almost 81%. Another important indicator is the household size. In the rural areas, the household size is less than 5.7 and in the target towns the size is 7.6. The pressure on housing in the urban areas is clearly indicated by these figures.

F. Waste Generation, Collection and Disposal 41. The key data on the waste generation is provided in the Table 5. The current process is described below. 42. Collection: Household waste is the major waste stream in all the towns. Temporary containers such as crates, oil cans and baskets are used to store waste at source by households. When the container is full, the waste is generally transferred to a plastic bag and either placed outside the main door for sweepers to collect, or is taken to the nearest concrete bin, open space or end of the street by the householders for disposal. Shops and small commercial units leave their waste on the streets when business is finished for the day. This is then collected by sweepers early in the morning before the shops open again. In low income areas, the waste is brought to the nearest secondary collection space, which is generally located on the nearest vehicle-accessible road. 43. Teams of sweepers are assigned streets by Union Councils and in a few cases by TMA contractors to carry the waste to the nearest point for transportation in trucks. The street sweepers also clean open drains, sweep streets and carry street sweepings to intermediate disposal points. However, the efficiency of the manual system is low, and sweepers have neither the equipment nor inclination to carry the waste away from the residential areas. Storage: The waste carried by householders, or collected by sweepers from streets, houses and open spaces is brought to various designated secondary storage points for storage before transportation in collection vehicles. There are three types of secondary storage point, which may serve from a few to several hundred households: a) Open walled (3 walls) spaces for storage on the sides of streets or in open areas; b) Larger open areas with boundary walls (usually 3) to store the waste and provide space for vehicle maneuvering; c) Informal dumps in open spaces with no confining construction.

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Table 4: Demographic Data and Socioeconomic Indicators

Literate Total Pacca Houses with Houses with Average Population Total Houses Population Houses** Potable Water Electricity Household Size 10+ Entire District Khairpur 1,546,587 35% 255,261 21.1% 16.0% 65.9% 6.1 Larkana 1,927,066 35% 328,063 22.6% 17.1% 84.0% 5.9 Shikarpur 880,438 31% 149,758 13.9% 20.3% 70.0% 5.9 Sukkur 908,373 46% 138,553 38.9% 37.7% 73.5% 6.6 As Percent Rural Parts of the District of Total Khairpur 1,181,371 76% 31% 201,576 16.2% 12.1% 62.0% 5.9 Larkana 1,370,054 71% 28% 247,078 14.6% 12.4% 80.9% 5.5 Shikarpur 668,459 76% 24% 120,403 8.7% 16.2% 65.3% 5.6 Sukkur 446,268 49% 32% 79,008 21.3% 14.6% 59.2% 5.6 As Percent Target Towns of Urban Khairpur 105,637 29% 59% 14,070 53.3% 48.3% 90.3% 7.5 Larkana 270,283 49% 58% 36,693 52.2% 26.2% 96.2% 7.4 Rohri 45,731 10% 63% 6,072 65.5% 79.6% 94.9% 7.5 Shikarpur 134,883 64% 58% 17,460 43.1% 50.7% 94.4% 7.7 Sukkur*** 335,551 73% 58% 43,643 63.6% 71.2% 92.9% 7.7 Notes: * Data is based on 1998 census ** House made of brick and mortar *** Includes both Sukkur and New Sukkur

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Table 5: Key Data on Current Waste Generation

Waste Streams Household (70%) 0.45 k/p/d Industrial and Commercial (30%) 0.11 k/p/d Waste recycled 0.02 k/p/d Net waste generation 0.54 k/p/d Waste Composition At source Household: Recycleable waste (Mainly metals, plastic, glass, paper); Food waste Commercial and industrial: Vegetable, Leaves and grass; Animal waste; Metals; Plastic; Glass; Rubber; Paper At disposal site Vegetable and food waste – 20% by weight Leaves and grass – 15% Animal waste – 15% Fines, silt and other inert material and debris – 30% Moisture – 20% Waste bulk density 750-1000 kg/m3 Recycling Estimated as 8% of the total waste generated at source Estimated Waste Generation Khaipur (Population 167,300) 90 t/d Shikarpur (Population 184,800) 100 t/d Larkana (Population 370,400) 200 t/d Sukkur (Population 286,400) 155 t/d New Sukkur (Population 103,800) 56 t/d Rohri (Population 63,200) 34 t/d

44. Transportation: The waste from secondary storage points is loaded manually onto vehicles (invariably trailers drawn by tractors) and transported away from the residential areas. Each vehicle makes 3 to 4 trips daily from the collection area to one or more disposal sites. The collection vehicles are managed by the TMAs, some of whom have a range of vehicles for waste transportation, although tractors and trailers of capacity 2 to 3 tons per trip are by far the most common type of vehicle. As the vehicles as not designed for this purpose and also in many cases the vehicles are very old as many of them are more than 10 years old, there are major maintenance problems with frequent needs for the major repair of vehicles. 45. Disposal: The most common method of the final disposal of waste is the practice of ‘Bharaee’, a local term for filling of depressed land—such as that previously used in the excavation of clay for brick kilns. Government or private land owners identify land and ask truck drivers or supervisors to divert waste trucks to these lands. Most of these lands are areas where the groundwater table is high, and in some cases, these are natural wetlands which host wetland vegetation and provide wetland wildlife habitat. While high density inert waste may provide a physically suitable material for filling artificial depressions, this is not the case for mixed municipal waste, the uncontrolled disposal of

10/19/08 Page 19 of 59 Sindh Cities Improvement Investment Program IEE Report for Solid Waste Management Sector Subprojects which provides potential health and environmental risks. Most of these lands are close to residential areas and the current practice of indiscriminate dumping is both a health and environmental hazard, particularly in the areas where there is heavy reliance on underground water resources. The conversion of wetlands with waste in this manner can lead to severe environmental damage and degradation of the area. 46. Hospital Waste: Waste from hospitals and healthcare facilities in the towns are currently co-disposed with other waste and there is no separation of infectious and hazardous waste from the general waste stream within the hospitals. In some cases, the infectious and clinical waste is disposed of in spaces behind the hospital and there is no separate collection of hospital waste. Waste pickers have been observed sorting through waste piles and separating used medicine and other medical materials for recycling or resale. 47. Recycling: The separation of resalable waste at source is common and households regularly separate newspapers, oil cans, bottles etc. before disposing of waste. These are then sold to agents for who come to collect them. Further, separation takes place at waste bins or from outside the home by the waste pickers or the sweepers. These are collected and sold to agents at the prevailing price. Because of the nature of waste and separation at source and during collection, the incidence of waste picking at the final disposal sites is either minimal or non-existent—there is little of value remaining.

G. Environmental Conditions in the Vicinity of the Proposed Sites 48. In Table 6, a comparison of the four sites on environmental and social parameters is presented. 49. Rohri: The proposed site for Sukkur, New Sukkur, and Rohri Landfill is located on the National Highway N5, east of Sukkur and Rohri. It is about 500 m from the highway and about 5-8 km from the waste collection centers of the three towns. The area is a limestone quarrying area. Active quarrying continues in the area, however, there are areas where all limestone has been removed and quarrying has ceased. One such area has been proposed for this landfill (Figure 3). The land is state-owned and has never been sold before, however, it was leased for quarrying. The lease has expired. The terrain is hilly and exposed rocks with no sign of vegetation. Because of the rocky terrain, water table in the area is not established. The nearest settlement to the site is the Cattle Colony located about 1.5 km to the west of the site. There are no wetlands or other ecologically important sites within the vicinity. 50. Khairpur: The Khairpur site is located near the village of Shadi Shaheed on the southeast of Khairpur. The site is accessible from a black-top road. Its distance to the center of the waste collection area is about 15 km. It is a low-productivity privately owned agricultural land (Figure 4) with several owners. The land will be acquired for the landfill. The terrain is flat. Currently, the land is not cultivated; the only vegetation on the site is the native wild bushes. The water table in the area is reportedly more than 10 m deep with subsoil water at more than 3 m. The northern side of the site is bounded by a water channel constructed for drainage of sub-soil water. Normally, the water is not used for any purpose, however, in periods of heavy rain or excess water in the irrigation canals freshwater is also released in this drain. For this period, water from the drain is also used for irrigation. There are several large date palms in the area; the nearest to the site is about 150 m. The nearest settlement to the site is about 500 m to the southwest of the site, however, a single house is located about 150 m to the north of the site. The village of Shadi Shaheed is located about 2 km to the south of the site. It is a culturally and religiously important shrine of Loung Faqir and has been visited not only by the residents of the area but also by people of northern Sindh and southern Punjab particularly during the annual urs. The urs (religious festival) is held according to the Islamic calendar and thus the date shifts ahead by about 10-11 days every year. This year it is scheduled to

10/19/08 Page 20 of 59 Sindh Cities Improvement Investment Program IEE Report for Solid Waste Management Sector Subprojects fall in October–November. There are no wetlands or other ecologically important sites within the vicinity. 51. Larkana: The Larkana site is located on the Arija Road, northwest of the city (Figure 5). The site is accessible from the black-top Arija Road. Its distance to the center of the waste collection area is about 8 km. It is a low productivity land owned by military. The land will be acquired from the military for the landfill. The terrain is flat. Currently, the land is not cultivated; the only vegetation on the site is the native wild bushes. The water table in the area is reportedly more than 4 m deep with subsoil water at times within 1.5 m. However, the subsoil water depends on the functioning of the drain pumps located about 1 km north of the site. When the pumps are function, the sub-soil water is drained through a drainage canal located in the vicinity. Their non-functioning affects the productivity of the cultivated lands in the region. The villagers also have their own diesel engine operated pumps that they use in emergency to lower the water table. The nearest settlement to the site is more 500 m away, however, a single house is located about 300 m to the east of the site. A small mosque is located on the road, about 200 from the site towards Larkana. Information provided by the local community indicates that because of lack of population in the vicinity, congregations are not held regularly in the mosque. The mosque appears to be in run-down condition but is definitely less than 75 years old and therefore is outside of the protection of the Antiquity Act, 195. There are no wetlands or other ecologically important sites within the vicinity. 52. Shikarpur: The proposed site for Shikarpur landfill is located on the main Shikarpur- Road, north of Shikarpur (Figure 6). The site is accessible from the highway. It is classified as irrigated agricultural land, but has remained uncultivated because of low productive potential. The land will be acquired for the landfill. Its distance to the center of the waste collection area is about 8 km. The terrain is flat. Currently, the land is not cultivated; the only vegetation on the site is the native wild bushes. The water table in the area is reportedly more than 7 m deep with subsoil water more than 1.5 m. The nearest settlement to the site is more 500 m away. There are no wetlands or other ecologically important sites within the vicinity.

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Table 6: Comparison of the Proposed Sites for Landfill

Sukkur, New Khairpur Larkana Shikarpur Sukkur, Rohri Location National Shadi Shaheed Arija Road Jacobabad Highway Road Coordinates 27°39'30.4"N, 27°28'41.8"N, 27°36'08.1"N, 28°01'53.7"N, 68°54'23.0"E 68°50'35.8"E 68°10'26.5"E 68°36'48.1"E Ownership Government Private Military Private Visual Soil Rocky Clay Clay Clay Composition Drinking Water table Rocky terrain More than 10 m 4 m More than 6 m depth Sub-soil water water No sub-soil More than 3 m 1.5 m More than 1.5 m table depth water Distance from the 4-6 km 15 km 8 km 8 km centre of the collection area Distance from the 500 m 0 0 0 nearest metalled road Distance to nearest 1.5 km About 500 m More than More than Settlement 500 m 500 m General topography Mild hilly terrain Flat with no Flat with no Flat with few of the area and depressions depressions depressions slopes with their stability Vegetation None Local shrubs Local shrubs Local shrubs Wetlands/biodiversity None None None None importance Archeological None Shrine of Loung None None /cultural site Faqeer at Shahdi Sheed

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Figure 3: Landfill Site for Sukkur, New Sukkur, and Rohri

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Figure 4: Landfill Site for Khairpur

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Figure 5: Landfill Site for Larkana

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Figure 6: Landfill Site for Shikarpur

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IV. ENVIRONMENTAL IMPACTS AND MITIGATION

53. This section discusses the potential environmental impacts of the proposed subprojects and identifies mitigation measures to minimize the impacts in the design, construction and operational phases.

A. Screening of Environmental Impacts 54. The proposed intervention in each town has three main components: i) Construction of secondary storage facilities ii) Procurement and operation of secondary collection vehicles and loaders iii) Development of sanitary landfills 55. The proposed secondary storage facilities or collection bins are small concrete structures that will be constructed on the sites of existing communal waste dumps. The land occupied by each facility will be about 6 m2. Due to the small size, the construction of the bin will not have any significant environmental impact. Once operational, the bins can be a potential source of odor, pests, and aesthetic degradation. In cases, where the bins will be constructed at sites of existing dumps, the construction is likely to improve the overall environmental quality around the bins. 56. While selecting the site for bins, whether at existing dump sites or new sites, certain criteria will be used. These criteria pertain to traffic, sensitive receptors, and water body. 57. The collection vehicle will increase traffic on the roads however, compared to the total traffic on the road the volume of additional traffic will be insignificant. Other than routine maintenance of the vehicles and training of the drivers, no other environmental controls are proposed at this stage. 58. The main environmental impact of the proposed intervention will be from the landfill sites. The sites that have been selected for the four landfill sites have the following key environmental and social features: i) All sites are on non-productive or low productivity lands. ii) All sites are at least 500 m from any settlement. For two sites, isolated houses are located within 500 m but even in these cases a distance of 150 m from the edge of the field is available. iii) No site is located on or near any ecologically, culturally, or archeologically important site. 59. The above features eliminate many of the potential environmental impacts that are typically associated with the landfill sites. This also means that although the sites are located far apart, their environmental impacts would be similar. 60. The potential environmental impacts of the landfills for the construction and operation phases are shown in Table 7 and Table 8, respectively. Due to the site selection criteria adopted, no significant environmental impacts are envisaged. Few impacts that are likely to have moderate significance are mainly due to presence of single house within the vicinity of two sites. Appropriate mitigation measures are introduced to avoid any potential adverse impact.

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Table 7: Screening of Environmental Issues – Design and Construction

Environmental Rohri Khairpur Larkana Shikarpur Component and Source of Impact

Public Health

Noise from N – No SR within M –The nearest SR M –The nearest SR N – No SR within construction work at 500 m (single house) at (single house) at 500 m site 200 m from the 200 m from the proposed site. proposed site.

Dust from N – No SR within M –The nearest SR M –The nearest SR N – No SR within earthwork at the 500 m (single house) at (single house) at 500 m site 200 m from the 200 m from the proposed site. proposed site.

Noise and N – Traffic on M – Traffic on small M – Traffic on N – Traffic on major Community safety highway road; passes smaller road; road bypassing the from construction through the town passes through the city traffic city

Socioeconomic

Land Acquisition N – State land S – Involves N – State land M – Involves acquisition of acquisition of private land from a private land from a number of owners single owner

Employment M – Expectations M – Expectations of M – Expectations of M – Expectations of of employment employment employment employment

Cultural Issues N – No SR M - Cultural N – No SR N – No SR sensitivities associated with shrine at Shadi Shaheed N = Negligible; M = Moderate; S = Significant

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Table 8: Screening of Environmental Issues - Operations

Environmental Rohri Khairpur Larkana Shikarpur Component and Source of Impact

Public Health

Noise from N – No SR within M –The nearest SR M –The nearest SR N – No SR within operations at site 500 m (single house) at (single house) at 500 m 200 m from the 200 m from the proposed site. proposed site.

Dust from N – No SR within M –The nearest SR M –The nearest SR N – No SR within earthwork at the 500 m (single house) at (single house) at 500 m site 200 m from the 200 m from the proposed site. proposed site.

Noise and N – Traffic on M – Traffic on small M – Traffic on N – Traffic on major Community safety highway road; passes smaller road; road bypassing the from waste truck through the town passes through the city traffic city

Gas emission N – No SR within M –The nearest SR M –The nearest SR N – No SR within Biogas from waste 500 m (single house) at (single house) at 500 m 200 m from the 200 m from the proposed site. proposed site.

Waste dispersion N – All trucks will N – All trucks will N – All trucks will N – All trucks will be enclosed and be enclosed and all be enclosed and all be enclosed and all all sites would be sites would be sites would be sites would be fenced fenced fenced fenced

Odor N – No SR within M –The nearest SR M –The nearest SR N – No SR within 500 m (single house) at (single house) at 500 m 200 m from the 200 m from the proposed site. proposed site.

Infectious disease N – No SR within N – No SR within N – No SR within N – No SR within 200 m; Hospital 200 m; Hospital 200 m; Hospital 200 m; Hospital waste to be waste to be waste to be waste to be confined. confined. confined. confined.

Groundwater N – No M – Leachate from M – Leachate from M – Leachate from contamination groundwater the waste can the waste can the waste can contaminate the contaminate the contaminate the soil, sub-soil and soil, sub-soil and soil, sub-soil and the groundwater. the groundwater. the groundwater. Management Management Management measures would be measures would be measures would be required to prevent required to prevent required to prevent any risk. any risk. any risk.

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Environmental Rohri Khairpur Larkana Shikarpur Component and Source of Impact

Socioeconomic

Employment M – Expectations M – Expectations of M – Expectations of M – Expectations of of employment employment employment employment

Cultural Issues N – No SR N – No SR N – No SR N – No SR N = Negligible; M = Moderate; S = Significant

B. Design Related Impacts and Design Principles 61. The proposed landfills at the four locations will have approximately similar design and facilities, although the sizes would be different. The layouts will be modified at the detail designs stage to suit the shape of the sites. The key design-related environmental impact relates to the selection of the site and the surrounding land uses. The sites have been selected based on the key criteria that a) the land should not be a productive agricultural land; b) a buffer should exist between the site and the surrounding SR; c) distance to the site from the city should be as short as possible but not so close that the city should encompass the site during the life of the landfill; and d) the site should not encroach upon any archeologically, culturally, or ecologically sensitive area. 62. The specific design mitigation measures are as discussed below. These will be presented to the design engineers by NSUSC at the commencement of their design commission.

H The IEE/EMP will be revised and updated at implementation to take account of any new, modified, increased or unexpected impacts. The revised document will be submitted to the ADB for approval prior to issuance of tender document.

H Wherever possible the design should be conceptualized to permit the maximum use of prefabricated materials in order to minimize construction impacts.

H The waste bins will be located at least 100 m from any school, hospital, or mosque. It will not be placed within 50 m of any water body such as canal, wetland, and river. The waste bins will be located such that they do not block traffic or access to any house, business, or other buildings.

H The distance from the landfill and the nearest residential area will be the maximum achievable and justifiable on technical grounds in line with good site layout and efficient operation. A distance of at least 300 m will be maintained between sensitive receptors and the gas vents.

H The site layout shall be designed to facilitate access and egress through the existing road network with the minimum of impact to local traffic. At the detailed design stage consultation should take place with the local population and the traffic authorities to optimize routes in and out of the site.

H The design shall provide space for truck parking which shall be at least 150 m from the nearest residential area.

H Bund will be constructed around the full perimeter of the site to retain dust and provide a visual barrier.

H The road network within the perimeter will be leveled and sealed to a smooth impervious finish to permit easy cleansing of the site.

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H Perimeter drains and collection chamber will be designed to permit regular cleansing and removal of settled solids that can then be transferred to the disposal facilities with solid other wastes.

H The design will be reviewed by the NSUSC prior to the finalization of the design to ensure that all environmental requirements are being met and the layout option will allow mitigation of environmental impacts to an acceptable level. The IEE and EMP will be revised and updated to take account of any new, modified, increased or unexpected impacts.

H Noise, dust and odor mitigation measures will be reviewed once the detailed layout has been finalized and the mitigation measures will be revised and updated to take account of any new, modified, increased or unexpected impacts.

H In Khairpur, Larkana, and Shikarpur, eucalyptus trees will be planted along the boundaries of the site along the perimeter wall to minimize the visual impact of the facilities and to help in keeping the water table low.

H All sites will have leachate monitoring system. This will include a) groundwater monitoring wells; b) perforate pipes below the lining that to collect any seepage and direct to the sump for monitoring. 63. Seismic Risk: The landfill sites are located in low risk seismic activity area. No active fault zone exists in the vicinity of any of the site. If the land has been prepared (levelled and compacted) properly, no damage to lining, the berm, or drainage structure from seismic activity is envisaged. The Rohri site is located on a hilly terrain that has been subjected to mining activities in the past including the use of dynamite. While selecting the location of the cells at this site, following precautionary measures shall be taken: a) the cells shall not be located on cracked or fissured rock; b) Cells shall not be placed on sloping rock; and c) A layer of compacted clay shall be provided at the bottom of each cell. 64. Storm water Run-off: The detailed design will include control measures for storm water runoff with the objective of minimizing the water the volume of contaminated water. To achieve this, the drainage system of the potentially contaminated areas will be separated from the non-contaminated areas. The potentially contaminated areas include all areas where waste is stored or handled, truck-parking area, and leachate processing area. Run- off from these areas shall be directed to a common sump. Depending on the design, the run-off from the active cell may also be included in this or may be sent to the leachate tank. A perimeter drains will be constructed within the perimeter walls around the full perimeter of the site to capture non-contaminated surface runoff. The perimeter drains will run to a collection chamber and settling tank with volume sufficient to capture the first 15 minutes runoff from the whole site. The bund wall around the site will be designed in such a way that surface water from adjacent areas during storm events do not flow to the landfill site. To ensure minimum infiltration on the surface of the active cells and thus minimize leachate generation, the soil used for covering waste in the active cells will be well compacted and fine-grained. The side grades will be sloping at a maximum of 30% to enhance runoff.

C. Construction Related Impacts 65. Dust: 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 will be generated on a particular day will depend on the magnitude and nature of activity and the atmospheric conditions prevailing on the day. 66. Among the variety of options to control dust emissions from construction sites the most effective is wet suppression. Spraying water on exposed surfaces and soil with adequate frequency to keep soil moist at all times can reduce the total dust emission from the project

10/19/08 Page 31 of 59 Sindh Cities Improvement Investment Program IEE Report for Solid Waste Management Sector Subprojects by as much as 75%.7 The following mitigation measures will be implemented at each site during construction to control emission of particulate matter:

H Water will be sprayed twice daily on all exposed surfaces to suppress emissions of dust. The frequency of sprayed will be increased as necessary but controlled such that the surface remains moist at all times, particularly when wind is blowing towards any nearby sensitive receivers.

H Dust emission from soil and aggregate storage stockpiles will be reduced by appropriate measures. These may include: covering the pile with tarpaulin or thick plastic sheets when not in use and at the end of the working day, erecting windshield walls on three sides of the piles such that the walls project 0.5 m above the top of the pile, keeping the material moist by sprayed of water at appropriate intervals, to prevent emission.

H All roads within the sites that are to be paved will be paved as early as possible after the commencement of construction work. Until the roads are paved, they will be sprinkled regularly to prevent dust emission.

H The construction vehicles will maintain a speed limit of 20 km/h or less on all unpaved areas within the construction site and the access route for the duration of the construction. Speed limit signposts will be erected in highly visible positions along the access road and within the site and maintained for the duration of the construction.

H Construction materials will be transported to the site and around the site in trucks securely covered with tarpaulins or equivalent to prevent dust emission during transportation. 67. Noise: Noise nuisances can be minimized by various measures. Noise will be reduced in the construction of the landfill sites by a) avoiding construction work during night time 21:00hrs to 06:00hrs within 300 m of sensitive receivers; b) prevention of blowing of horns by the project vehicles except in emergencies; c) use of powered mechanical equipment that is acoustically insulated to reduce noise impacts; d) tuning and proper maintenance of construction equipment and vehicles. 68. Employment: At its peak, the construction activities can generate more than 100 jobs for each site. It will be expectation of the communities that maximum jobs would be provided to them. It is preferable that all unskilled jobs be given to local communities. A general practice is that the nearest the community is to the project site, the higher is its right to jobs. Before the start of the construction, the contractor(s) will consult the communities and agree upon a job sharing formula from each community, keeping in view the total labour requirements. 69. Cultural Conflict: By maximizing the hiring of labour from the local communities, the risk of cultural conflict between the local communities and the labour from outside communities can be minimized. The contacts between the non-local staff and the communities will be minimized by prohibiting the entrance of the non-local staff into the communities.

D. Operations Related Impacts 70. Odour and Pests: The landfill sites are potential source of odour and pest. Odour from the waste is generated mainly from the organic components of the waste. Storage of the waste in the open is the main source of generation of odour. Another issue relates to pest. Accumulated waste tends to attract mice, insects and other pests. Eventually these pests

7 El Dorado County Air Pollution Control District. 2002. Guide to Air Quality Assessment: Determining Significance of Air Quality Impacts Under the California Environmental Quality Act. First Edition. http://co.el-dorado.ca.us/emd/apcd

10/19/08 Page 32 of 59 Sindh Cities Improvement Investment Program IEE Report for Solid Waste Management Sector Subprojects can spread to surrounding areas and becomes a nuisance for the community and can become a health hazard. 71. Some of these impacts are eliminated through measures incorporated in the design. The design measures and other mitigation measures are the following:

H No temporary storage of waste will take place in the open or in an area that is exposed to rainwater.

H Unloading of waste will be planned in such a manner that the need for temporary storage at the site is eliminated. All incoming vehicles will unload the waste directly to the active pit.

H Periodic disinfection will be carried out at the site. 72. Gas Emission: Biogas emission from the landfills is a potential hazard. In sites where the sensitive receptors are more than 500 m from the site, this may not be significant issue. However, in Khairpur and Larkana, single houses are located at 200m from the site. In these areas, the vents for the cells located within 300 m of the houses would be collected though a piping network and directed to an exhaust at least 300 m from the nearest boundary. 73. Groundwater Contamination: The landfill sites are potential source of groundwater contamination. Leachate is generated, either from the existing moisture in the waste or from percolation of rainwater through the waste. The quantity of leachate generated is not available at this time. However, the quantity of waste is not expected to be significant. The moisture content of the waste delivered at the landfill is of the order of 20%. The leachate will be collected and re-circulated to stabilize the waste. The moisture content in stabilized waste is typically 15-20%. Thus the total leachate generated is likely to be less than 20 liters per ton of waste. As the sites are located in hot and dry climate, rapid evaporation is likely to reduce the leachate generation significantly and the expected volume that may require disposal would be less than 1%. Based on this, the leachate generation at the four sites is estimated to be between 0.5 m3/d to 2 m3/d. This amount can be easily disposed of in a small evaporation basin at the site. To prevent any potential impact, design measures and other mitigation measures are proposed as follows:

H The landfills will be lined with clay and with synthetic impervious layer wherever the water table is within 2m of the water table

H Leachate collection and disposal system would be installed at each site.

H The entire leachate collection, storage, and handling system, would be made of impervious material

H An evaporation pond of appropriate size will be provided at each site.

H Provisions would be made for collection and disposal of the leachate at the municipal wastewater disposal plant, if needed, during rainy season, when leachate generation is likely to increase. 74. Waste Dispersal: Waste dispersal can take place from open trucks and from unloading area. To avoid this:

H Waste will be transferred only in closed trucks

H The waste will be covered with soil as soon as possible after unloading

H In windy season, wind shields will be installed around the active pits. 75. The landfill sites are potential source of groundwater contamination. Leachate is generated, either from the existing moisture in the waste or from percolation of rainwater through the waste. To prevent any potential impact, design measures and other mitigation measures are proposed as follows:

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H The landfill will be lined with clay and with synthetic impervious layer

H Leachate collection and disposal system would be installed at each site.

H The entire leachate collection, storage, and handling system, would be made of impervious material. 76. Waste Collection Vehicle Traffic: Access to all the sites will be available through black-top roads. To avoid congestion on the road during operations, the movement of the waste collection vehicles would be planned and managed in order to avoid peak traffic hours, particularly on the smaller access roads. 77. A traffic management plan will be developed for the operations phase for community safety. The measures will include: a) All waste collection vehicle drivers will undergo defensive driving training, following which they will have to pass a defensive driving test b) Speed limits will be set for the vehicles on the segments of the road passing through the populated area; c) For Khairpur, waste will only be transported during off peak hours; d) Waste collection from densely populated areas will be avoided during the night. 78. The following measures will be taken to ensure vehicles are mechanically fit: a) Waste collection vehicles will be designed so that waste does not spill out during transportation b) Vehicles will be periodically inspected to ensure any damage or wear and tear is detected at an early stage c) Vehicles will undergo a periodic maintenance program to ensure that they are mechanically sound in all respects; and d) vehicles will be covered to prevent emission of odours.

E. Positive Impact 79. The subproject if designed, constructed, and operated, in the manner conceived in the project document has the potential to bring remarkable changes to the target towns. The direct and indirect benefits include: a) the waste that is a potential source of disease would be removed from the community efficiently; b) cleaner roads and streets would contribute to the aesthetic enhancement; c) flow of effluent in drains and sewers would improve; d) municipal services and efficiency would improve through the private-public partnership; e) new jobs would be created.

V. STAKEHOLDERS CONSULTATION

80. The objectives of the stakeholder consultation process was to disseminate information on the project and its expected long-term and short-term impacts among primary and secondary stakeholders, and to gather information on relevant issues so that the feedback received could be used to address these issues at an early stages of project design. Another important objective was to determine the extent of the negative impact of different project activities and suggest appropriate mitigation measures. A. Identification of Stakeholders and Methodology

81. Stakeholders are people, groups, or institutions that may be affected by or can significantly influence, or are important to the achievement of the stated purpose of a proposed intervention. 82. For the solid waste management sector, all the residents of the towns are stakeholder, in general, and the residents of the area where the landfills are proposed, in particular. 83. Consultations with the community were carried out by one-to-one meetings and small group meetings in the potentially affected areas. At the start of the meeting, the purpose of the meeting and the role of the consultants, the TMA and the ADB were described. The proposed interventions were described in detail. Further clarifications were provided on the

10/19/08 Page 34 of 59 Sindh Cities Improvement Investment Program IEE Report for Solid Waste Management Sector Subprojects project, its design, construction, and potential environmental impact, wherever requested by the participants. 84. Consultations with the officials of the local government were carried out in their offices. No relevant NGO could have been identified. B. Consultations’ Summary

85. Consultations with the communities in Sukkur, Rohri, Khairpur, Larkana, and Shikarpur were carried out during the preparation of this IEE. In 41 all community representatives and 10 government officials and elected representatives were consulted. The details are provided in Appendix A. 86. There are no houses within 200 m of any of the site. Based on the assessment of the satellite image (see Figures 3-6), the estimated number of houses within 1 km of each site is: Shikarpur (2), Larkana (5); Khairpur (22), and Rohri (0). 87. Further consultations have been conducted during the development of the project concept. Details of these are also provided in Appendix A. C. Discussion Summary

88. The issues discussed in the stakeholders’ consultation are summarized below: (i) The communities living near the landfill sites were particularly concern about its impact. A general concern was that the landfill sites in the neighborhood will a source of diseases. It was felt that the communities, their children and the livestock would be affected by the spread of disease. (ii) Odor was another concern of the communities (iii) Opinion was also expressed that the crop on the surrounding fields may be affected by the landfills (iv) The risks to the community associated with the construction work needs to be minimized. (v) When explained to community about the measures that would be taken, some concerns were expressed on ways in which the measure would be undertaken. The community was worried that if the measures are nto implemented, it would result in creation of a dumping site for waste.

D. Future Consultation

89. Further consultation will be carried out during project implementation phase. These will be carried out during and after the detailed designs of the specific interventions and components. The consultation will be carried out in the in the communities. The objective of the consultations will be to discuss the timing of work, overall schedule, sensitivities, minimizing disturbance to businesses, and public safety issues.

VI. INSTITUTIONAL REQUIREMENTS AND ENVIRONMENTAL MANAGEMENT PLAN

A. Institutional Arrangements

90. Roles and responsibilities for the environmental performance of the subprojects will be vested into a number of different institutional actors as outlined below. The institutional arrangements for environmental management during Tranche 1 will differ from arrangements for subsequent tranches because (i) NSUSC, the Tranche 1 Implementing Agency (IA) for subprojects will become fully operational only during Tranche 1; and (ii) new USCs will

10/19/08 Page 35 of 59 Sindh Cities Improvement Investment Program IEE Report for Solid Waste Management Sector Subprojects emerge in subsequent tranches and will assume responsibility for environmental management. 91. Planning and Development Department: Planning and Development Department (P&DD) of the Government of Sindh, based in Karachi, will act as the Investment Program Executing Agency (EA) and will oversee overall sector reform strategy, final appraisal of subprojects proposed for inclusion in subsequent tranches prior to submission to ADB, and provision of counterpart finances, including environmental management finances for the Program Support Unit. P&DD will monitor the subprojects’ compliance with this IEE and EMP through a Program Support Unit (PSU). The monitoring will be based on the monthly monitoring reports provided by the NSUSC and the external monitoring reports (see below). 92. Concerning environmental management, the PSU will be entrusted with tranche appraisal coordination, inter-agency liaison; internal monitoring; and finance administration. IEE preparation functions for the first tranche will be initiated by the PSU until NSUSC is sufficiently established. Environmental management tasks within the PSU will be carried out by qualified safeguards staff comprising one environmental and one social safeguards specialist, reporting to the PSU Program Director 93. The North Sindh Urban Services Corporation: Under the first tranche of the Investment Program, the NSUSC will be established and will function as an Implementing Agency (IA).8 NSUSC will assume the IEE implementation tasks under Parts B and C of the Investment Program. NSUSC will also operate and maintain the facilities financed under the Investment Program. Headed by a Managing Director (MD), the NSUSC will include, among others, qualified personnel in the areas of (i) water supply and wastewater services; (ii) solid waste management; (iii) finance; (iv) capital works development and procurement; and (v) social and environmental safeguards. Social and environmental safeguards tasks will be assigned to a Safeguards Cell under the Capital Works Unit, comprising two permanent staff with extensive experience in land acquisition and resettlement and environmental protection. The Safeguards Cell will be set up within the initial three months of NSUSC establishment and loan effectiveness, and supported intermittently by international experts in resettlement and environment. The Safeguards Cell will be responsible for the preparation and implementation of IEE and EMP and any subsequent changes to them. B. Complaints and Grievances Redress

94. For the purpose of addressing grievances by the community about the implementation of IEE and EMP, a Grievance Committee will be established for each subproject town as soon as subproject implementation in each site commences. 9 However, with careful observance of the provisions of the EMP by all stakeholders involved, grievances can be avoided. If necessary, the aggrieved person will first address the NSUSC Safeguards Cell, whose officers will strive for an informal settlement within 10 days of lodging of the complaint. If the complaint cannot be settled, the grievance will be referred to the Grievance Committee. Within 30 days the committee will discuss the matter and refer grievances to NSUSC Safeguards Cell, and obtain a resolution. If the complaint still remains unresolved, it can be re-lodged by the aggrieved person within one month of the Safeguards Cell decision with the Grievance Committee, which refers it to the Management of NSUSC. The Management of NSUSC will rule on the issue(s) within 21 days of its re-lodging with the Grievance Committee. The NSUSC decision must be in compliance with the provisions of the IEE. If the grievance redress mechanism fails to satisfy the aggrieved person, s/he can approach the Sindh Environmental Protection Agency.

8 Under subsequent Program tranches, similar urban services corporations (USCs) will be established and will assume the same responsibilities for IEE; this is subsequently referred to as NSUSC. 9 A similar committee is also proposed for complaints regarding land acquisition and resettlement plan (LARP) implementation. Given the local conditions and the scale of land acquisition work, only one committee responsible both for LARP and EMP is recommended.

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95. The Grievance Committee will normally comprise the Mukhtiarkar and Tapadar of the relevant Taluka and Tapa, the elected Taluka Councilor of the respective Tapa, the TO Infrastructure and Services of the concerned TMA, the Social Safeguards Staff of the Safeguards Cell of NSUSC, and a representative of the community. C. Environmental Review and Approval

96. Environmental regulations of the Government require proponents of projects that have reasonably foreseeable qualitative and quantitative impacts are required to submit an IEE for their respective projects (Schedule I). Proponents of projects that have more adverse environmental impact (Schedule II) are required to submit an environmental impact assessment (EIA) to the respective provincial Environmental Protection Agency (EPA). Disposal facilities with capacity less than ten thousand cubic meters requite IEE. Waste disposal facilities for domestic wastes with an annual capacity of more than ten thousand cubic meters’ require EIA (Schedule II). Disposal facilities with capacity less than ten thousand cubic meters requite IEE. 97. Therefore prior to implementation and commencement of construction of the subprojects, PSU will need to notify the provincial EPA (SEPA) of the location and scale of the subprojects and comply with any environmental requirements and, if IEE or EIA is required, obtain approval “No Objection Certificates” and SEPA clearance (under the Environmental Protection Act 1997). Whatever the SEPA requirements, IEEs must be prepared for all components for ADB. PSU will also need to liaise and coordinate with SEPA. 98. Overall implementation of the EMP will become NSUSC’s responsibility. Other parties to be involved in implementing the EMP are as follows: (i) Contractors: responsible for implementing all measures required to mitigate environmental impacts during construction; and (ii) Other government agencies: such as UC, Towns authorities and regional EPA office monitoring the implementation of environmental conditions and compliance with statutory requirements in their respective areas.

D. Environmental Management Plan

99. This IEE concludes that the construction impacts will be manageable if the mitigation measures are implemented thoroughly. The Environmental Management Plan is based on the type, extent and duration of the identified environmental impacts. The EMP has been prepared by close reference to best practices and in line with ADB’s Environmental Policy (2002) and Environmental Guidelines (2003). 100. Implementation of construction of the SWM subprojects will need to comply with several environmental requirements and clearance will be required from SEPA for environmental assessment. NSUSC will also need to confirm that contractors and their suppliers have complied with all statutory requirements. NSUSC should check that contractors have all the necessary valid licenses and permits for all powered mechanical equipment, permissions and licenses for use of powered mechanical equipment if necessary and the use of local water supplies (and to construct and operate plants such as concrete batching in line with all environmental regulations and license conditions from EPA). The measures and the cost are summarized in Table 9 and Table 10, respectively. 101. The effective implementation of the EMP should be audited as part of the loan conditions and the executing agency must be prepared for this. In this regard the NSUSC must be prepared to guide the design engineers and contractors on the environmental aspects. 102. Prior to implementation of Tranche 1 and again before Tranche 2 the EMP shall be amended and reviewed by the NSUSC/PSU in due course after detailed designs are

10/19/08 Page 37 of 59 Sindh Cities Improvement Investment Program IEE Report for Solid Waste Management Sector Subprojects complete and contracting arrangements are known. Such a review shall be based on reconfirmation and any additional information on the assumptions made at the feasibility stage on location scale and expected operating conditions of the subprojects. For example, in this case if there is additional land required for installation of facilities or pipelines the designs may be amended and the environmental significance must be reviewed. Although no major additional impacts would be anticipated based on the information provided to date, the performance and evaluation schedules to be implemented during project construction and operation can be reviewed, updated, and costs estimates can be revised if necessary. 103. The EMP must be reviewed by the NSUSC and approved before any construction activity is initiated on Tranche 1, to take account of any subsequent changes and fine tuning of the proposals. It is recommended that this takes place before the Tranche 1 contracts are worked out in detail and before pre-qualification, so that the environmental status of the existing treatment plants and pipelines is carried out as a baseline for benefit monitoring, using the EMP as the performance indicator. 104. This IEE including the EMP should be used as a basis for an environmental compliance program and an updated EMP should be included in the revised contract documentation for all components. The updated EMP, any conditions of the environmental clearance from the SEPA and any subsequent licenses and approvals from EPA should also be included in the environmental requirements for the contractors in the compliance program. Therefore, continued monitoring of the implementation of mitigation measures, the implementation of the environmental conditions from environmental clearance, and monitoring of the environmental impact related to the construction of all future works to complete the treatment plants and pipelines should be properly carried out and reported periodically in monthly progress reports. Compliance with all of the EMP requirements shall also be reported in other periodic project performance reports. 105. The impacts from construction and operation of the subprojects will be manageable and no insurmountable impacts are predicted providing that the updated EMP is included in the contract documents and implemented to its full extent. The details of the current summary EMP (Appendix) are in the form of the matrix and may require revision as the project reaches detailed design. The impacts have been classified as per the design/preparation stage, construction stage and operation and maintenance stage. The matrix details the mitigation measures recommended for each of the identified impacts, approximate location of the mitigation sites, time span of the implementation of mitigation measures, an analysis of the associated costs and the responsibility of the institution. The institutional responsibility has been specified for the purpose of the implementation and the supervision. The matrix is supplemented with a monitoring plan for the performance indicators. An estimation of the associated costs for the monitoring is given with the plan. The EMP has been prepared following best practice and the ADB Environmental Assessment Guidelines 2003. E. Monitoring and Evaluation

106. The environmental performance of the subprojects will be monitored both, internally and externally. Internal monitoring will be conducted by NSUSC, assisted by the Engineering Design and Construction Supervision Consultant. External monitoring will be assigned to an organization hired by P&DD and approved by ADB. The organization will be chosen among local consultants, NGOs, social research organizations or private sector companies. External monitoring will be undertaken in the form of periodic audit, for which ADB will prepare the terms of reference (ToR). 2. Internal Monitoring. Internal monitoring will be routinely by NSUSC, and the results will be communicated to ADB through the quarterly project implementation reports. Indicators for the internal monitoring will be those related to process and immediate outputs and results. This information will be collected directly in the field by NSUSC Safeguards Cell and reported monthly to the Program Support Unit of P&DD to assess the environmental

10/19/08 Page 38 of 59 Sindh Cities Improvement Investment Program IEE Report for Solid Waste Management Sector Subprojects performance of the project and to adjust the work program, if necessary. The monthly reports will be consolidated quarterly in the standard supervision reports to ADB. A sample report format is provided in Figure 7. Specific monitoring benchmarks will be:

(i) Information campaign and consultation with stakeholders; (ii) Contractor(s) compliance with EMP; (iii) Complaints received and addressed by the NSUSC and Grievance Committee; (iv) Environmental effects.

107. External Monitoring. External monitoring will be undertaken in the form of periodic audit, for which ADB will prepare the terms of reference (ToR). The audit will cover the environmental management system (processes for monitoring, documentation, reporting, and taking corrective action) and will also review the monitoring data collected on the impacts (noise, dust, traffic). 108. Monitoring activities during implementation will focus on compliance with license conditions, recording implementation of mitigation measures, recording environmental parameters, reviewing contractor environmental performance and proposing remedial actions to address unexpected impacts during construction. Some of these tasks can be assigned to the contractors and managed by the NSUSC and its Safeguard Cell. The monitoring plan (Tables 9 and 11) was designed based on the likely subproject cycle. 109. During the preconstruction period, the monitoring activities will focus on (i) checking the contractor’s bidding documents, particularly to ensure that all necessary environmental requirements have been included; and (ii) checking that the contract documents’ references to environmental mitigation measures requirements have been incorporated as part of contractor’s assignment. Where detailed design is required the checking of updated designs must be carried out. During the construction period, the monitoring activities will focus on ensuring that environmental mitigation measures are implemented, and some performance indicators will need to be monitored to record the subproject’s environmental achievements and to guide any remedial action to address unexpected impacts. 110. Monitoring activities during project operation will focus on (i) volume of waste received; (ii) ambient air quality; (iii) groundwater quality; (iv) biogas emission rate; (v) efficiency of waste collection system. The operation phase Environmental Monitoring Plan is provided in Table 11. 111. To facilitate EMP implementation, during preparation for construction the contractors must be prepared to cooperate with the Safeguard Cell staff and the local population in the mitigation of impacts. However, experience suggests that contractors may have little impetus or interest in dealing with environmental problems in the absence of performance-linked criteria. Therefore, the required environmental mitigation must be clearly described in a memorandum of understanding and other contract documents at the bidding stage; the completion of mitigation should be linked to payment milestones. F. Training

112. The trainings that will be provided as part of the subproject include the following: (i) At the beginning of the Investment Program implementation, an environmental expert, supported by ADB Safeguards Unit, will design and conduct training to build the capacity of the TMAs, NSUSC staff, relevant district and provincial field staff, the PSU and the senior staff of contracting firms in accordance with sound environmental practices in conformity to the ADB Environmental Policy and Guidelines. Subsequent periodic training for construction staff will be conducted internally by the NSUSC. (ii) Training of drivers of collection vehicles in defensive driving.

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(iii) Training of landfill site operators in safe operation and maintenance of the landfills. A private operator with expertise in SWM will be hired under a performance-based contract to operate the landfill sites. The contractor will be required to train the operating staff and provide evidence of the training to the NSUSC.

Figure 7: Monitoring Report Format

Environment/Social Monitoring Report -Reporting Period-

(Indicative Outline)

I. Introduction

(Describe scope of report and reporting period, and overall project implementation progress)

II. Progress in implementing the following (where applicable) environmental management plan/environmental assessment and review framework or procedure; or resettlement plan and/or resettlement framework; or indigenous peoples’ development plan and/or indigenous peoples’ development framework

III. Compliance with ADB loan covenants and applicable government laws, regulations and requirements

IV. Significant events or issues encountered, or changes in project scope (including alignment or footprint in case of horizontal infrastructure) and corresponding safeguard measures undertaken, if applicable

V. Summary of monitoring report findings

VI. Follow-up actions required (if any)

VII. Summary/Conclusion

Notes: 1. Above outline is indicative and could be tailored-fit to the project. 2. Monitoring reports on environment, involuntary resettlement and indigenous peoples could be prepared separately. 3. In case a project is assisted by an external or independent Panel, the Panel’s environmental or resettlement monitoring report will suffice.

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Table 9: Environmental Monitoring Plan for Tranche 1 SWM Subprojects

No. Environmental Monitoring Tasks10 Implementation Implementation Responsibility Schedule 1 Design Phase 1.1 Audit project bidding documents to ensure NSUSC through Prior to issue of bidding IEE and EMP is included. environmental officer documents. 1.2 Disclosure of subproject to SEPA NSUSC 1.3 Monitor final alignment and its environmental NSUSC through Prior to NSUSC compliance with EMP environmental officer approval of detailed designs. 1.4 Monitor the performance of environmental NSUSC through Ongoing, prior to and training and briefings and of the environmental officer during implementation of environmental awareness of project staff works and operation. 2 Construction Phase 2.1 Regular (monthly) monitoring and reporting NSUSC through Continuous throughout (quarterly) of contractor’s compliance with environmental officer construction period. statutory environmental requirements 2.2 Regular (monthly) monitoring and reporting NSUSC through Continuous throughout (quarterly) of contractor’s compliance with environmental officer construction period. contractual environmental mitigation measures 2.3 Regular (monthly) monitoring and reporting NSUSC through Continuous throughout (quarterly) of complaints and responses or environmental officer construction period. environmental mitigation measures 2.4 Monitor adjustments to the EMP and the NSUSC through During all phases of the thorough implementation of detailed EMP environmental officer subprojects 2.5 Commissioning phase monitoring of as built NSUSC through At commissioning. equipment and facilities versus environmental officer environmental contractual performance criteria 3 Operation and Maintenance Phase 3.1 Observations during routine maintenance NSUSC through As per NSUSC inspections of facilities. Inspections will environmental officer inspection schedules include monitoring implementation of operational mitigation measures versus environmental criteria specified in EMP for operational impacts 3.2 Implement Landfill O&M Plan. NSUSC through During the life of the Implement the Landfill O&M Plan; Landfill environmental officer project Development Plan; and Contingency Plan

10 Monitoring of issues related to compensation of landowners for land acquisition and loss of production, etc. are addressed in the Resettlement Action Plan.

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Table 10: Summary of Estimated Costs for EMP Implementation

Item Sub Item Estimated Total Costs (PRs) Staffing, audit and 2 persons for 1 years 1,500,000 monitoring Monitoring activities As detailed under EMP 9,600,000 10 water samples per site per month @ PKR 5,000 per sample for 2 years 1 air quality assessment per site per year for 2 years @ PKR 600,000 per assessment Equipment for monitoring such as noise meter Mitigation measures As prescribed under EMP and IEE - (included in the project cost) Transport 2 vehicle for 1 years 1,000,000 Contingency 7% contingency 900,000 Total 13,000,000

Table 11: Operations Phase Environmental Monitoring Plan

Parameters Frequency Landfills Waste received Quantity Daily Groundwater Quality (nearby E.coli, bacteriological analysis, Monthly wells) TDS, sulfate, BOD, COD. Ambient Air Quality Dust, NH3, H2S Annually Biogas emission NH3, H2S Annually Collection Collection Efficiency Physical, chemical, and biological Monthly or when significant parameters, residual chlorine11 change in raw water quality is suspected Waste dispersion at bins Quantity of waste outside the bins Once in six months

VII. FINDINGS AND RECOMMENDATIONS

113. This IEE study was carried out when the MFF Tranche 1 subproject were at the stage of conceptual design. Essentially secondary data were used to assess the environmental impacts in a comprehensive manner and public consultation and site reconnaissance were carried out in order complete the environmental assessments and recommend suitable mitigation measures.

11 These shall be monitored against the National Drinking Water Quality Standards drafted by the Pakistan Environmental Protection Agency

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114. Several actions are required during the detailed design stage to minimize impacts to acceptable levels and described in the EMP. The subproject ahs potential of having negative environmental impacts during construction and operations stages. The construction impacts should be very predictable and manageable and with appropriate mitigation few residual impacts are likely. 115. Some key actions are required after the detailed designs are developed. The EA should update the EMP and together with the IEE recommendations all mitigation measures should be included as contractual requirements, accepted by all contractors prior to signing the contract(s). Certain mitigation management plans (Landfill O&M Plan; Landfill Development Plan; and Contingency Plan) should be deliverable by the contractors before the operations commences. 116. At the detailed design stage a review should be conducted of the monitoring activities proposed in this IEE to establish the parameters to be checked during the construction and operation. Reference should also be made to the recommend monitoring plan for performance indicators (Table 11) from this study. If necessary baseline monitoring should be carried out prior to the commencement of construction to redefine the parameters and frequency of monitoring to be checked during subprojects construction and operation. Provisions should be made in the contract documentation to allow integration of the results of the baseline review into the contract to establish performance action thresholds, pollution limits and contingency plans for the contractor’s performance. Impact and compliance monitoring activities will focus on compliance with license conditions, recording implementation of mitigation measures, recording environmental parameters, reviewing contractor environmental performance and proposing remedial actions to address unexpected impacts and complaints. 117. The IEE, including the EMP, should be used as a basis for an environmental compliance program and be included in the contract documentation. The EMP shall be reviewed at the detailed design stage. In addition, any conditions that are part of the environmental clearance from the SEPA should also be as a basis for the environmental compliance program. Therefore, continued monitoring of the implementation of mitigation measures, the implementation of the environmental conditions for work and environmental clearance, and monitoring of the environmental impact related to the operation of the subprojects should be properly carried out and reported monthly to track and determine the net environmental benefits that have accrued. These should be summarized by the EA in regular quarterly progress reports to ADB also summarized at least twice per year as part of the ADB project performance report. The negative environmental impacts from subprojects will mostly take place during the construction. There are no operational impacts to be addressed in the detailed designs. If the projects are managed in line with internationally accepted environmental auditing procedures very significant environmental benefits can be expected to be demonstrated in the operational stage. 118. The implementation of the environmental mitigation measures during the construction period will be assigned to the contractors. However, experience suggests that contractors may have little impetus or interest to deal with environmental problems in the absence of performance linked criteria. Therefore, the required environmental mitigation must be clearly described in the contract documents at the bidding stage and the completion of mitigation should be linked to payment milestones.

VIII. CONCLUSIONS

119. Environmental impacts associated with the construction and operation of the subprojects needs to be effectively mitigated and institutional arrangements are available. Additional human and financial resources will be required by NSUSC to complete the

10/19/08 Page 43 of 59 Sindh Cities Improvement Investment Program IEE Report for Solid Waste Management Sector Subprojects detailed designs and incorporate the recommendations effectively and efficiently in the contract documents, linked to payment milestones. The proposed mitigation and management plans are practicable but require additional resources. 120. Monitoring activities in the design and construction phase will need to focus on compliance with IEE conditions, recording implementation of mitigation measures, recording environmental parameters, reviewing contractor environmental performance and proposing remedial actions to address unexpected impacts. Monitoring activities in the operational phase will need to focus on full implementation of the recommended monitoring requirements in the EMP to ensure good system performance, delivery of water of the expected quality and control of pollution due to waste from treatment plants. The operational controls must ensure efficient measurement of ambient air quality, groundwater quality parameters and recording of water, waste and wastewater to allow and ensure feedback of results to management to propose remedial actions to address unexpected problems and amend monitoring as necessary. 121. The water sector subprojects in Sindh are sustainable environmental options but thorough implementation of the EMP, that includes operational monitoring, is required throughout the construction and operation of the subprojects in order to deliver quality water efficiently, minimize impacts and retain public support for the project. .

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Appendix A: Stakeholder Consultations

1. Consultations for the IEE

No. Name Occupation Resident Comments 1. Ali Nawaz Farming Shadi ΠSmell and disease will affect the Solangi, Shaeed community Ghulam Ali (August ΠWater will become contaminated Solangi 08) ΠGovernment should pay them (Family compensation to move to alternate site living within 200 m of the site), plus 5 others 2. Muhammad Mine workers Hazar ΠAre working in this area Ismail, Mine ΠHave no families in the area Ahmad Area, ΠDo not see any objection to the landfill Hussain, Rohri ΠExpect some employment during Hussain Ali, (Aug 08) Nadir Ali, M construction Ibrahi, Khadim Hussain, Zafar, Muhammad Ali, 3. Inayat, Farming Larkana ΠHave no objection on the landfill site Hussain Aug 08) (Family within 500 of the site), Plus 3 4. Rawal Agriculture Larkana ΠThe community needs are hospitals Khan, Ayaz (26 Oct ΠNo objection to the landfill if not on their Hussain, 07) land Irshad Ali, Ahmad Mir, Azizullah 5. Sher Agriculture Zartaz, ΠNo specific comments Mohammad, Larkana ΠComplained about lack of payment on a Shahid (26 Oct road constructed on their land Hussain, 07) Sikandar Ali, Liaqat Ali 6. Mohammad Farming Haji Abro ΠUsman, Larkana Ghulam (26 Oct Murtaza, Ali 07) Murad, Haji Mahdin

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No. Name Occupation Resident Comments 7. Zakir Shadi ΠThe area is water deficient affecting the Hussain, Shaheed crop production Faqir Mehr (28 Oct ΠLandfill in the hilly area is preferable as Hussain 07) compensation is apid for it ΠEmployment should b eprovided to the community ΠTraffic movement is not an issue since daily tractor trolley traffic on the road is already between 100-150 8. Waris Khan, Farming Shikar- ΠHave no objection to the landfill as long as Arshad Ali, pur (Oct odor, vector, and other adverse impacts Mumtaz 27, 07) are controlled Khan, Dr Ali Bakhsh Khan 9. Ghulam Migratory Shikar- ΠNo issues. Will migrate from the location Abbas community pur (Oct Pathan, near the site 27, 07) Muhammad, Ahmad Sher 10. Hakim Ali Shopkeeper Larkana ΠThe excavation will cause problem in Jonejo terms of public health and safety. ΠChildren play grounds will be affected. ΠSanitation system will be improved. 11. Ghulam Sub Engg. Shikarpu ΠNo specific comments Sarwar Abro Infrastriucture r 12. M Nawaz Technical Khairpur ΠTrucks instead of trolleys should be used Khan Officer (TO) for transportation of waste (Infrastructure) ΠTruk would schedule trip in the early morning and evening to avoid traffic congestion 13. Khalil Executive Khairpur ΠConsidered the project beneficial for the Ahmad Engineer area, however, had not specifc comments Soomro on the impacts. Provided information about the area and infrastructure. 14. Liaqat Ali TO Larkana Mirani (Infrastructure) 15. Agha M TO Shikarpu Naeem (Infrastructure) r 16. Aziz Shaikh TO Rohri (Infrastructure) 17. Ghulam Naib Nazim New Murtaza Sukkur 18. Abdus TO New Shakoor (Infrastructure) Sukkur Mehr 19. Sajjan TO Rohri Dewan (Infrastructure) 20. Abdus TO New

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No. Name Occupation Resident Comments Shakoor (Infrastructure) Sukkur Mehr

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2. General Consultations During Project Development Since December 2007

Date Workshop Venue Topics ADB/PSU Staff 17-18 Dec Taluka Council Sukkur, New Presentation of SCIP Kathie Julian, Anand 2007 Meetings: Sukkur, Rohri, and the design of Chiplunkar, Iqbal Khairpur, Shikarpur NSUSC Memon & Larkana 27 Dec Pre-Test Sessions Khairpur, Rohri Interaction with Asif Shah, Rehana 2007 representatives of Shaikh CSOs and private sector ; Presentation/consultati on on SCIP 23 Jan Consultation Karachi Presentation to civil Kathie Julian, Anand 2008 Workshop: society & private Chiplunkar, Iqbal Sukkur, Rohri & sector on SCIP design Memon Khairpur 25 Jan SAMAs Meetings Karachi Presentation of SCIP Kathie Julian, Anand 2008 and the design of Chiplunkar, Iqbal NSUSC, particular Memon discussion on SAMAs 29 Feb Consultation Khairpur Presentation on the Kathie Julian, Anand 2008 Workshop: concept & design of Chiplunkar, Iqbal Women SCIP to women in Memon program areas 1 Mar Consultation Larkana Inform a range of Kathie Julian, Anand 2008 Workshop: stakeholders about the Chiplunkar, Iqbal Larkana concept & design of Memon SCIP 13 March Consultation with Rohri To discuss the land Ralf Starkloff, Revenue 2008 single affected acquisition and Department officers, person resettlement process Rohri Mukhtiarkar, to the single affected Assistant Mukhtiarkar person and Tapadar, Assistant Director, Sukkur Mines and Minerals Department, Taluka Officer (TO), Rohri and the TO and Deputy TO of TMA Sukkur 13 March Consultation with Lahore/Shikarpur To discuss the land 2008 affected person acquisition and for Shikarpur resettlement process sanitary landfill, to the affected person via teleconference 9 Jun Stakeholder Shikarpur Inform a range of Kathie Julian, Anand 2008 Consultation stakeholders about the Chiplunkar, Syed Workshop: concept & design of Salahuddin Shikarpur SCIP 10 Jun Consultation Sukkur Inform a range of Kathie Julian, Anand 2008 Workshop – stakeholders about the Chiplunkar, Syed SAMAs concept & design of Salahuddin SCIP 11 July Consultation with Khairpur DCO To discuss the land Ralf Starkloff, Taluka 2008 Affected Persons acquisition and Nazim, Khairpur, TMA resettlement process staff, DO Revenue and to affected persons relevant Mukhtiarkar and Tapadar, Revenue

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Date Workshop Venue Topics ADB/PSU Staff Department 21 July Meeting/Consultati Sukkur To review SAMA draft Kathie Julian, Anand 2008 on with TMA and draft Shareholder Chiplunkar, Hanif Nazims/relevant Agreement Channa staff 21 July Taluka Council Sukkur To review SAMA draft Kathie Julian, Anand 2008 Meetings and draft Shareholder Chiplunkar, Hanif Agreement Channa 21 July Taluka Council New Sukkur To review SAMA draft Kathie Julian, Anand 2008 Meetings and draft Shareholder Chiplunkar, Hanif Agreement Channa 22 July Taluka Council Larkana To review SAMA draft Kathie Julian, Anand 2008 Meetings and draft Shareholder Chiplunkar, Hanif Agreement Channa 22 July Taluka Council Shikarpur To review SAMA draft Kathie Julian, Anand 2008 Meetings and draft Shareholder Chiplunkar, Hanif Agreement Channa

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Environmental Objectives Mitigation Measures (MM) Recommended Timing to Locations to Resp Resp Concern Implement Implement Implement Monitor (MM) (MM) (MM) (MM) DESIGN STAGE 1. IEE Approval Ensure statutory Disclose SWM project and design to the SEPA and Commencement All subproject sites Design NSUSC - compliance with clarify what documents are required to be filed with of detailed consultant / ADB PEPA 1997 SEPA to ensure compliance with Secion 12(1) of the design NSUSC PEPA 1997 (as amended). 2. Subproject Ensure EMP Review IEE and EMP and confirm findings and Completion of All subproject sites Design NSUSC – detailed design. sufficient to recommendations. detailed design. consultant / ADB control impacts Submit REA, revised IEE and EMP to ADB for NSUSC and compliance approval prior to issuance of tender documents for with statutory construction. requirements Complete the environmental assessment process in PEPA 1997. line with SEPA and ADB Guidelines. Submit IEE/EIA to SEPA and obtain “No Objection Certificate”. 3. Noise, dust To avoid negative Noise, dust and odor mitigation measures will be Completion of All subproject sites Design NSUSC – and Odor impacts due to reviewed once the detailed layout has been finalized detailed design. consultant / ADB noise, dust and and the mitigation measures will be revised and NSUSC odor updated to take account of any new, modified, increased or unexpected impacts. 4. Retain To avoid negative 1. Detailed design to avoid vegetation removal as 1. Detailed All subproject sites Design NSUSC vegetation and impacts due to much as possible. design output. consultant / landscape unnecessary 2. Landscaping with trees and shrubs shall take place NSUSC. designs removing of at Landfill Sites. Planting of trees/shrubs/ornamental vegetation plants as enhancement. 5. Baseline Monitor baseline Undertake monitoring of the baseline envl parameters. During detailed Locations to be Design NSUSC/A Monitoring conditions. These include the parameters as shown in Envl design. identified and listed consultants/ DB Monitoring Plan (Table 11). in revised WQO&M NSUSC Plan.

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Environmental Objectives Mitigation Measures (MM) Recommended Timing to Locations to Resp Resp Concern Implement Implement Implement Monitor (MM) (MM) (MM) (MM) 6. Waste Bin To avoid negative The waste bins will be located at least 100 m from any impact due bin school, hospital, or mosque. It will not be placed location within 50 m of any water body such as canal, wetland, and river. The waste bins will be located such that they do not block traffic or access to any house, business, or other buildings.

7. Environmen- Avoid operational Contractor to submit Method Statement and schedule At tender stage Tender evaluators Tender NSUSC tally responsible environmental of environmental mitigation measures with tender. and again to check evaluators procurement pollution and Contractor required to include techniques and during product contractors Method impacts upon machinery selection to minimize impacts and duration acquisition, prior Statements and decommissioning of works. to purchase. proposed . mitigation Choose non polluting equipment. measures and Specify equipment not to contain POP, asbestos, timing. other hazardous or toxic components. Equipment specifications and performance with company certificates / accreditations. 8. Medical waste Safe dispsoal of The medical waste facility will be developed according Design stage All facilities where Design NSUSC/A medical waste to accpetable international practice and the Hospital hospital waste will consultants/ DB Waste Management Rules, 2005 of the Government be accepted. NSUSC of Pakistan 9. Seismic risk To prevent any While selecting the location of the cells at Rohri, Design stage Rohri Landfill Design NSUSC/A slippage due to following precautionary measures shall be taken: a) consultants/ DB movement of the the cells shall not be located on cracked or fissured NSUSC ground due to rock; b) Cells shall not be placed on sloping rock; and earthquake, or c) A layer of compacted clay shall be provided at the otherwise bottom of each cell. 10. Stormwater To prevent The detailed design will include control measures for

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Environmental Objectives Mitigation Measures (MM) Recommended Timing to Locations to Resp Resp Concern Implement Implement Implement Monitor (MM) (MM) (MM) (MM) run-off contamination of storm water runoff with the objective of minimizing the groundwater water the volume of contaminated water. To achieve this, the drainage system of the potentially contaminated areas will be separated from the non- contaminated areas. The potentially contaminated areas include all areas where waste is stored or handled, truck-parking area, and leachate processing area. Run-off from these areas shall be directed to a common sump. Depending on the design, the run-off from the active cell may also be included in this or may be sent to the leachate tank. A perimeter drains will be constructed within the perimeter walls around the full perimeter of the site to capture non- contaminated surface runoff. The perimeter drains will run to a collection chamber and settling tank with volume sufficient to capture the first 15 minutes runoff from the whole site. The bund wall around the site will be designed in such a way that surface water from adjacent areas during storm events do not flow to the landfill site. To ensure minimum infiltration on the surface of the active cells and thus minimize leachate generation, the soil used for covering waste in the active cells will be well compacted and fine-grained. The side grades will be sloping at a maximum of 30% to enhance runoff. CONSTRUCTION STAGE 1. Plans to Avoid impacts 1. Temporary traffic management plan Prior to All subproject sites Contractor. NSUSC. control from unplanned 2. Noise and dust control plan construction environmental activities activity 3. Waste management plan and associated Submission to 4. Tree plantation plan impacts. ADB 5. Resource management plan 6. Community Consultation Plan

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Environmental Objectives Mitigation Measures (MM) Recommended Timing to Locations to Resp Resp Concern Implement Implement Implement Monitor (MM) (MM) (MM) (MM) should all be deliverable in final form by the contractors one month before construction commences. 3. Orientation Ensure that the Contractors tenders shall be required to separate Induction for all All site agent staff. Contractor NSUSC & for Contractor, Construction clearly the resources and funds to be applied to the site agents and monthly induction to observe and Workers Contractor and mitigation measures for environmental impacts above and new and six month and workers Contractors tenders shall identify named staff to staff before refresher course record understand and supervise and plan various critical activity and plan commencement as necessary until success. have the capacity of work. contractors Contractual clauses shall be included to tie the to ensure that the comply/improve. implementation of environmental mitigation measures environmental in the above plans to milestone payments. Weekly tool box requirements and talks and mitigation Contractual clauses shall require Contractors to refreshers at measures must conduct special induction briefing and/or on-site early stages of be implemented training for the contractors management, contractors construction for by them. staff, subcontractors and workers to cover the environmental requirement of the project. Contractors all construction shall record and report regularly on record attendance employees as and achievement test for all staff and managers. far as reasonably Contractual clauses shall be included to require practicable. contractors to employ dedicated environmental Include with management staff to conduct/oversee the safety talks. environmental orientation sessions and the implementation of environmental mitigation measures so as to facilitate checking for milestone payments. Contractual clauses shall emphasize that financial compensation shall not be allowed as mitigation for environmental impacts or environmental nuisance without written and environmentally justifiable agreement from the relevant environmental authorities. Engineering controls shall be proposed in the first place by the construction contractors and shall be designed as mitigation measures to control the

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Environmental Objectives Mitigation Measures (MM) Recommended Timing to Locations to Resp Resp Concern Implement Implement Implement Monitor (MM) (MM) (MM) (MM) impacts at source in the first place. 5. Air quality To minimize air Contol all dusty materials at source. Before works All subproject sites Contractor NSUSC impacts 1. All heavy equipment and machinery shall be fitted commence and effectively and in full compliance with the national and local throughout all avoid complaints regulations. construction due to the works 2. Excavated or stockpiled soil and sand shall be airborne slightly wetted before loading, particularly in windy particulate matter conditions. released to the atmosphere. 3. Fuel-efficient and well-maintained haulage trucks shall be employed to minimize exhaust emissions. Smoke belching vehicles and equipment shall not be allowed and shall be removed from the project. 4. Vehicles transporting soil, sand and other construction materials shall be covered. Speeds of such vehicles shall be limited to 10km/h within the works site and on unpaved areas. 5. Transporting materials through densely populated areas should be avoided. 6. Open areas of the sites and nearby roads (50m adjacent either side of the active works areas) shall be sprayed at least twice per day with water to suppress dust. 6. Noise/Ground To minimize Install, maintain and monitor all requisite mitigation as All subproject sites Contractor NSUSC/ Vibration noise level per contract CSC increases and 1. All heavy equipment and machinery shall be well ground vibrations maintained and fitted in full compliance with the during national and local regulations. construction 2. As a rule, the operation of heavy equipment shall operations. be conducted in daylight hours unless agree otherwise with local residents. 7. Construction To minimize the Waste Management Plan to be submitted to the Update once a All subproject sites Contractor NSUSC/

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Environmental Objectives Mitigation Measures (MM) Recommended Timing to Locations to Resp Resp Concern Implement Implement Implement Monitor (MM) (MM) (MM) (MM) Waste Disposal impacts from the NSUSC and approved one month prior to starting month and CSC disposal of works. report quarterly. construction 1. Estimating the amounts and types of construction waste. waste to be generated by the project. 2. Investigating whether the waste can be reused in the project or by other interested parties. 3. Identifying potential safe disposal sites close to the project OR those disposal sites designated in the contract. 4. Investigating the environmental conditions of the disposal sites and recommendation of most suitable and safest sites. 5. Piling up of inert loose soil based material should be done in segregated/protected areas to arrest washing out of soil. Debris shall not be left where it may be carried by water to down stream drains, flood plains, lagoons etc. 6. Used oil and lubricants shall be recovered and reused or removed from the site in full compliance with the national and local regulations. Oily waste must not be burned. Licensed disposal location to be agreed with NSUSC 7. Machinery should be properly maintained to minimize oil spill during the construction. 8. Waste shall not be burned - under any circumstances. Open burning is contrary to good environmemtal practice and ADB guidelines. 8. Worker To ensure that 1. Identify location of worker canteen and toilet UPDATE Once Location map is Contractor NSUSC/ canteen and the operation of facilities in consultation with local communities. a month prepared by the CSC toilet facilities the works and Location subject to approval by the NSUSC. If Contractor. worker facilities possible, canteen and toilet facilities shall include does not drinking water supplies.

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Environmental Objectives Mitigation Measures (MM) Recommended Timing to Locations to Resp Resp Concern Implement Implement Implement Monitor (MM) (MM) (MM) (MM) adversely affect 2. In order to maintain proper sanitation around the surrounding construction routes, temporary toilets will need to be environment and provided. residents in the 3. Drinking water and sanitary facilities shall be area. provided for employees. 4. The Contractor shall organize and maintain a waste separation, collection and transport system. 5. The Contractor shall document that all liquid and solid hazardous and non-hazardous waste are separated, collected and disposed of according to the given requirements and regulations. 6. At the conclusion of the project, all debris and waste shall be removed. All temporary structures, including office buildings, shelters, waste receptacles and toilets shall be removed. 9. Safety To ensure safety 1. Providing adequate warning signs. During Relevant canteen Contractor NSUSC/ Precautions for of workers 2. Providing workers with skull guard or hard hat and construction and worker CSC the Workers and protective boots. sanitation facilities. first aid. 3. Contractor shall instruct his workers in health and safety matters, weekly, and require the workers to use the provided safety equipment. 4. Establish all relevant safety measures as required by law and good engineering practices. 5. Contractor shall provide first aid facilities for the workers and at the worker canteens with at least one qualified first-aider or nurse present at all times. It is recommended that the workforce be given access to a trained doctor at least once per two weeks for routine checks and medical examinations if necessary. Community To maintain good A community consultation plan will be developed and All subproject sites Liaison relationship with implemented. It shall cover the contact persons, the host meeting frequencies, grievance redressal and

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Environmental Objectives Mitigation Measures (MM) Recommended Timing to Locations to Resp Resp Concern Implement Implement Implement Monitor (MM) (MM) (MM) (MM) community reporting. 11. Nuisance to Control Contractor to agree to monitor and enforcement of At all times All subproject sites Contractor CSC / nearby nuisances and implementation of mitigation measures versus NSUSC properties reduce impacts milestone payments for mitigation. on property value Contract clauses to specify acceptable construction or interruption to practices to mitigate nuisances, noise, vibration and neighbouring dust impacts and liaison with local community on land uses. approach to mitigation. No payment unless environmental mitigation measures are implemented and penalty clauses in contract. Incorporating good construction management practices – complaints reported once per month for each site/km of water main under construction. Compensation will be paid for loss of livelihood due to construction disruption in line with ADB guidelines. Set up complaints hot line, recording, response and resolution monitoring. 12. Groundwater To prevent any Design measures and other mitigation measures are At all times All subproject sites Contractor CSC / contamination potential impact proposed as follows: NSUSC on the The landfills will be lined with clay and with synthetic groundwater, impervious layer wherever the water table is within 2m of the water table Leachate collection and disposal system would be installed at each site. The entire leachate collection, storage, and handling system, would be made of impervious material An evaporation pond of appropriate size will be provided at each site. Provisions would be made for collection and disposal of the leachate at the municipal wastewater disposal

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Environmental Objectives Mitigation Measures (MM) Recommended Timing to Locations to Resp Resp Concern Implement Implement Implement Monitor (MM) (MM) (MM) (MM) plant, if needed, during rainy season, when leachate generation is likely to increase. OPERATIONAL STAGE 1. Monitor To monitor Monitoring activities during project operation will focus Throughtout As per the plan in NSUSC NSUSC project impact impact of the on (i) volume of waste received; (ii) ambient air operations the IEE project and take quality; (iii) groundwater quality; (iv) biogas emission appropraite rate; (v) efficiency of waste collection system. measures in case of any unexpected impact on the environment Odor and pest Control odor and The design measures and other mitigation measures pest from the site are the following: No temporary storage of waste will take place in the open or in an area that is exposed to rainwater. Unloading of waste will be planned in such a manner that the need for temporary storage at the site is eliminated. All incoming vehicles will unload the waste directly to the active pit. Periodic disinfection will be carried out at the site. Waste Dispersal To prevent waste Waste will be transferred only in closed trucks dispersal from The waste will be covered with soil as soon as trucks and possible after unloading unloading areas In windy season, wind shields will be installed around the active pits. Traffic To minimize Access to all the sites will be available through black- impacts of waste top roads. To avoid congestion on the road during collection vehicle operations, the movement of the waste collection on existing traffic vehicles would be planned and managed in order to avoid peak traffic hours, particularly on the smaller

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Environmental Objectives Mitigation Measures (MM) Recommended Timing to Locations to Resp Resp Concern Implement Implement Implement Monitor (MM) (MM) (MM) (MM) access roads. A traffic management plan will be developed for the operations phase for community safety. The measures will include: a) All waste collection vehicle drivers will undergo defensive driving training, following which they will have to pass a defensive driving test b) Speed limits will be set for the vehicles on the segments of the road passing through the populated area; c) For Khairpur, waste will only be transported during off peak hours; d) Waste collection from densely populated areas will be avoided during the night. The following measures will be taken to ensure vehicles are mechanically fit: a) Waste collection vehicles will be designed so that waste does not spill out during transportation b) Vehicles will be periodically inspected to ensure any damage or wear and tear is detected at an early stage c) Vehicles will undergo a periodic maintenance program to ensure that they are mechanically sound in all respects; and d) vehicles will be covered to prevent emission of odours.

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