Initial Environmental Examination PAK: Karachi Bus Rapid Transit Red Line Project

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Initial Environmental Examination

Project Number: 47279-002 July 2019

PAK: Karachi Bus Rapid Transit Red Line Project

Development of Staging Facility (Underneath Karachi Goan Association Cricket Ground)

Prepared by the Transport and Mass Transit Department, provincial Government of Sindh for the Asian Development Bank.

CURRENCY EQUIVALENTS (as of 19 July 2019)

Currency unit – Pakistan rupee (PRs) PRs1.00 = $0.00625 $1.00 = PRs160

ABBREVIATIONS ADB – Asian Development Bank BRT – bus rapid transit DoF – Department of Forests EA – environmental assessment EAAC – Environmental Assessment Advisory Committee EARF – environment assessment review framework EIA – environment impact assessment EMP – environmental management plan EPA – Environmental Protection Agency GOP – Government of Pakistan GoS – Government of Sindh IA – implementing agency IEE – initial environmental examination KGA – Karachi Goan Association km – kilometer LAA – Land Acquisition Act (of 1984) LARP – land acquisition and resettlement plan Leq – equivalent sound pressure level NEQS – national environmental quality standards NGO – nongovernment organization O&M – operation & maintenance PAP – Project-affected person PC – public consultation PEPAct – Pakistan Environment Protection Act 1997 PFS – prefeasibility study PMU – Project Management Unit RP – resettlement plan SC – Steering Committee SEPA – Sindh Environmental Protection Agency SPS – Safeguard Policy Statement TMTD – Transport and Mass Transit Department tpd – tonnes per day

NOTE In this report, "$" refers to United States dollars unless otherwise stated.

This initial environmental examination is a document of the borrower. The views expressed herein do not necessarily represent those of ADB's Board of Directors, Management, or staff, and may be preliminary in nature. Your attention is directed to the “terms of use” section on ADB’s website.

In preparing any country program or strategy, financing any project, or by making any designation of or reference to a particular territory or geographic area in this document, the Asian Development Bank does not intend to make any judgments as to the legal or other status of any territory or area.

Content Details

S/No. Version Date Summary of Revisions made 1 1 19-7-19 First Draft of IEE report

Table of Content

1 Introduction ...... 1 1.1 Project Background ...... 1 1.2 Project Objective ...... 1 1.3 Environmental Category of the Project ...... 2 1.4 Methodology of IEE Study ...... 2 1.5 Proponent of Project ...... 2 1.6 Structure of the Report ...... 2 1.7 Further Additions & Updating of IEE study ...... 3 2 Policy and Legal Framework ...... 5 2.1 General ...... 5 2.2 National Policy and Legal Framework ...... 5 2.3 Regulations for Environmental Assessment, Pakistan EPA ...... 5 2.4 Sindh Environmental Protection Act, 2014 ...... 5 2.5 Other National and Sindh Government Laws and Regulations ...... 7 2.6 Regulatory Clearances, Sindh EPA ...... 10 2.7 Guidelines for Environmental Assessment, Pakistan EPA ...... 10 2.8 National Environmental Quality Standards (NEQS) 2000 ...... 10 2.9 Interaction with Other Agencies ...... 11 2.10 Provincial EPAs ...... 11 2.11 Provincial Departments of Forests and Wildlife ...... 11 2.12 Provincial Governments ...... 11 2.13 ADB’s Safeguard Policy Statement (SPS), 2009 ...... 11 2.14 ADB’s Access to Information Policy (AIP) 2018 ...... 12 2.15 ADB’s Accountability Mechanism Policy 2012...... 12 2.16 Implications of ADB’s safeguard policies on proposed project ...... 12 2.17 Comparison of International and Local Environmental Legislations ...... 14 3 Description of the Project ...... 19 3.1 Project Overview ...... 19 3.2 Justification and Need for Project ...... 20 3.3 Project Construction Schedule ...... 20 3.4 Construction Camps and Work Force ...... 20 3.5 Machinery Requirement ...... 24 4 Description of Environment ...... 25 4.1 General ...... 25 4.2 Physical Resources ...... 25

4.2.1 Meteorological Parameters ...... 25 4.2.2 Air Quality ...... 30 4.2.3 Noise ...... 33 4.2.4 Climate Change and Effects ...... 33 4.3 Geology, Soils and Groundwater ...... 36 4.3.1 Seismic activity ...... 37 4.4 Hydrology, Water Quality and Sediment ...... 39 4.4.1 Ground Water Quality ...... 41 4.4.2 Climate Vulnerability—Flooding ...... 41 4.5 Biological Resources ...... 42 4.5.1 Flora ...... 42 4.5.2 Fauna ...... 43 4.6 Socioeconomic Resources ...... 46 4.6.1 Population ...... 46 4.6.2 Land Use ...... 49 4.6.3 Physical Infrastructure ...... 50 4.7 Physical Cultural Resources ...... 54 4.7.1 Religious, Historical, Cultural and Archaeological Sites ...... 54 5 Analysis of Alternatives ...... 55 5.1 Overview ...... 55 5.2 ‘No Project’ Option ...... 55 5.3 Rationale for selected Staging Facility Location ...... 55 Alternative Location Options ...... 55 5.4 Assessment of alternatives to prevent demolition of associated facilities .. 56 6 Potential Environmental Impacts and Mitigation Measures ...... 57 6.1 Design/Pre-Construction Phase ...... 57 Avoidance of demolition of Associated Facilities ...... 57 Relocation of Utilities ...... 58 Identification of Locations for Labor Camps and ancillary facilities ...... 58 Development of Traffic Management Plan ...... 59 6.2 Construction Phase ...... 60 Traffic Management ...... 64 Air Quality ...... 66 Noise Levels ...... 70 Excavated Material (Earthworks) Disposal ...... 73 Community Health and Safety ...... 73 Worker Health and Safety...... 75

Water Resources ...... 75 Camp & Batching plant effluent ...... 76 Soil Erosion and Sedimentation ...... 76 Soil Contamination ...... 76 Drainage and Storm Water Run-off ...... 77 Hazardous and Non-Hazardous Waste Management ...... 77 Historical/Archaeological Sites ...... 78 Vegetation and Wildlife Loss ...... 78 Employment Conflicts ...... 79 Communicable Diseases ...... 80 Loss of Access around Project Site ...... 80 Land Use and Aesthetics ...... 80 Natural and Man made Hazards ...... 80 6.3 Operation Phase...... 81 Air Quality ...... 82 Noise Levels ...... 83 Solid Waste disposal ...... 83 Land Contamination ...... 84 Socioeconomic ...... 84 6.4 Cumulative Impacts ...... 84 6.5 Indirect and Induced Impacts ...... 85 7 Environmental Management and Monitoring Plan ...... 86 7.1 Introduction ...... 86 7.2 Environmental Management Plan (EMP) ...... 86 7.3 Objectives of EMP ...... 86 7.4 Environmental Management Framework ...... 87 7.4.1 Roles of TMTD PIU and SMTA ...... 87 7.4.2 Roles of CSC Consultants during Design/Construction ...... 87 7.4.3 Role of the Contractor ...... 87 7.4.4 Role of Sindh EPA ...... 89 7.5 Environmental Management/Monitoring and Reporting ...... 89 7.6 Monitoring Parameters ...... 89 7.7 Environmental Training ...... 89 Capacity Building and Training ...... 89 7.8 Further Additions & Updating of IEE study & EMP ...... 90 7.9 Environmental Management Costs ...... 95 8 Public Consultation and Information Disclosure...... 135

8.1 Introduction ...... 135 8.2 Objective of Consultations ...... 135 8.3 Identification of Main Stakeholders ...... 136 8.4 Approach for Public Consultation ...... 136 8.5 Consultations ...... 137 8.6 Key Discussion points ...... 137 9 Grievance Redress Mechanism ...... Error! Bookmark not defined. 9.1 General ...... 146 10 Conclusions and Recommendations ...... 149 11 References ...... 151

ANNEXURES

Annexure A Rapid Environmental Assessment Checklist

Annexure B NEQS Guidelines

Annexure C Photographs of Project Area Settings

Annexure D Photographs of Public Consultations

Annexure E List of Participants of Public Consultations

Annexure F Photographs of Ambient Air Quality and Noise Monitoring

Annexure G Methodology for Air Quality and Noise Monitoring

Annexure H Results of Air Quality, Noise and Vibration Monitoring

Annexure I Traffic Management Plan

Annexure J Occupational Health and Safety Plan

Annexure K Emergency Response Plan

Annexure L Archaeological ‘Chance Find’ Procedure Annexure M ToRs of Third Party Monitor

Annexure N Certifications of SUPARCO Laboratory

Annexure O Dust Management Plan

Annexure P Site Specific EMP (SSEMP) Guide & Template for Guidance to Contractor

List of Figures

Figure 1.1: Key Map of Proposed Project ...... 4

Figure 3.1: Layout of Mezzanine Level of Staging Facility ...... 21

Figure 3.2: Layout of Ground Floor of Staging Facility ...... 22

Figure 3.3: Detailed Layout of Proposed Staging Facility ...... 23

Figure 4-1: Monthly Average Precipitation (mm) and Evapotranspiration (mm) at Karachi Airport ...... 26

Figure 4-2: Minimum and maximum Precipitation (mm) and Evapotranspiration (mm) at Karachi (2009-2018) ...... 26

Figure 4-3: Monthly Averages for Mean, Maximum and Minimum Temperatures (Deg-C) at Karachi Airport ...... 27

Figure 4-4: minimum, maximum and average temperature of Karachi (2009-2018) 27

Figure 4-5 Average cloud and Humidity of Karachi (2009-2018) ...... 28

Figure 4-6: maximum and average wind speed of Karachi (2009-2018) ...... 29

Figure 4-7: Annual Wind Rose for Karachi ...... 30

Figure 4.8: Monitoring Location for Ambient Air Quality and Noise Levels ...... 32

Figure 4-9: Katchi Settlements Flooded and Dry ...... 36

Figure 4-10: Geological Map of Karachi and Surrounding Area ...... 38

Figure 4-11: Historical Reconstruction of Earthquakes in the Vicinity of Karachi and Southern Pakistan ...... 39

Figure 4-12: Generalized Schematic of Drainage Basins in Karachi Metropolitan Area ...... 41

Figure 4-13: Images of Flooding in Karachi ...... 42

Figure 4-14: Administrative map of Karachi ...... 48

Figure 4-14: Population Distribution by Area, Age and Sex...... 48

Figure 6-1: Predominant Wind Direction & Expected Impact from Dust Emissions from Construction Site ...... 68

Figure 9.1: Grievance Redress Mechanism ...... 148 LIST OF TABLES

Table 2.1: Other National and Sindh Government Laws and Regulations ...... 8

Table 4-1: Humidity and Dew Point Temperature for Karachi ...... 28

Table 4.2: Ambient Noise Monitoring Results (24 hrs) at Staging Facility Project Site ...... 33

Table 4.3: Ambient Air Quality Monitoring Results (24 hrs) at Staging Facility Proposed Location ...... 35

Table 4.4: Comparison of ambient air quality results versus applicable Air Quality standards ...... 35

Table 4-5: Birds of Karachi and Dow University Campuses (1996—2015) ...... 44

Table 4-6: Mammals and Reptiles Historically Present in the Area of Karachi District ...... 45

Table 4-7: District-wise 2017 Population for Karachi Division ...... 47

Table 4-8: Medical Facilities in Karachi ...... 52

Table 4-9: Mortality Statistics of Karachi and Nationwide ...... 53

Table 6.1: Associated Facilities next to KGA ground to be impacted ...... 57

Table 6.2: Screening of Possible Impacts during Construction Phase ...... 60

Table 6.3: Control measures for Fugitive Dust emissions ...... 67

Table 6.4: Construction Equipment Noise Ranges, dB(A) ...... 71

Table 6.5: Summary of Possible Impacts during Operation Phase ...... 81

Table 7.1: Pre-Construction Monitoring Requirements...... 91

Table 7.2: Construction Phase Monitoring Requirements ...... 92

Table 7.3: Operation Phase Monitoring Requirements...... 94

Table 7.4: Capacity Development and Training Programme ...... 95

Table 7.5: Annual Cost Estimates for ‘Pre-Construction Phase’ Environmental Monitoring ...... 96

Table 7.6: Annual Cost Estimates for ‘Construction Phase’ Environmental Monitoring ...... 96

Table 7.7: Annual Cost Estimates for ‘Operation Phase’ Environmental Monitoring 96

Table 7.8: Estimated Costs for EMP Implementation ...... 96

Table 7.9: Environmental Management and Monitoring Plan ...... 98

Table 8.1: Summary of Public Consultations ...... 139

EXECUTIVE SUMMARY

Project Overview

1. This IEE study has been prepared for development of a BRT vehicle staging facility under the Karachi Goan Association (KGA) ground, adjacent to Numaish station. A map of the project area is provided as Figure ES-1.

2. The KGA ground will be reconfigured to house an underground commercial area as well as a staging facility for the BRT network. The total floor area of KGA mezzanine level is 23,520 square meters.

3. As per the preliminary designs, the existing structures on the KGA ground will need to be demolished during construction, the concept design proposes to reconstruct the ground and its associated facilities on top of the Mezzanine floor at ground level. The associated facilities possess a rich historical and cultural value since they are over 100 years old, although they are not listed as national and cultural heritage by the Government of Sindh. However, during the detailed design phase, all efforts need to be made to prevent demolition of the associated facilities of the KGA ground as far as possible by considering all alternatives (technical and location related) and through continuing of the stakeholder consultative process.

4. The staging facility is proposed to be constructed at the KGA ground which will be an underground facility consisting of 2 floors having a basement or the underground level which will be used for bus lanes, drivers sitting area, dispatch center and washrooms. The Mezzanine level will be for the commuters and will have the ticketing booths, waiting and commercial areas.

5. It will also provide ease of transfer of passengers from one line to the other and include parking lots for the buses, maintenance of buses, offices, ticketing booth, waiting areas and turnaround facility for the routes that terminate at Numaish.

6. As all BRT corridors converge at Numaish station, this location holds importance in permitting customer interchange between routes. This area also holds importance as a BRT vehicle staging facility for the following reasons:

▪ Since limited space is available along the M. A. Jinnah Road to hold BRT vehicles, in order to cater the difference in demand between peak and off-peak periods, Numaish is an ideal location to stage vehicles and thus optimize operations.

▪ A staging facility at Numaish shall ensure interoperability between all corridors by ensuring physical and operational integration.

▪ A large number of BRT vehicles and people will pass through Numaish station; this gives Numaish an additional significance for potential Transit-Oriented Development (ToD).

7. Commercial activities within the system will not only enhance non-fare revenue, but also provide a sense of security around the station area.

Project Need

8. The staging facility will help in optimizing and adjusting fleet operations as the demand varies along the day. Additionally, it shall provide a turnaround facility for routes that terminate at Numaish, and will thus reduce the dead mileage for operations without passengers.

Study Methodology

9. Primary and secondary data has been collected and used to assess the environmental impacts of the Project. Detailed baseline monitoring in the project area to assess potential impacts on air quality and noise levels has been conducted and presented in this study. This IEE report highlights all potential environmental impacts associated with the Project and recommends mitigation measures. Any environmental impacts associated with the project need to be properly mitigated, through the existing institutional arrangements described in this report.

10. The significance of impacts from the proposed project were then assessed and for those impacts requiring mitigation, suitable measures were proposed to reduce impacts to within acceptable limits as per local and international applicable regulations. A detailed environmental management and monitoring plan was developed to ensure compliance to the proposed measures during the project development.

Public Consultation Process

11. Detailed and extensive consultations with different key stakeholders have been conducted to date, consisting of the KGA Ground management and the local communities residing in close proximity to the proposed project site and their comments/concerns/suggestions were obtained. Furthermore, representatives of the relevant public sector agencies such as the Karachi Municipal Corporation were also consulted. The details of the persons consulted are provided as Annexure E.

12. The key comments and concerns raised as a result of the consultations as part of the scoping activity are as follows:

▪ Prior notice should be provided before commencement of works for the staging facility. ▪ Dust and noise levels must be minimized through all possible measures. Sprinkling must be conducted as much as possible so that huge clouds of dust do not reach their residences. ▪ Expressed positive views about the staging facility with a major reason that the existing conditions will be restored. ▪ He mentioned that it must be ensured by the Contractor that the existing route being used for the Green Line works is used by the vehicles for the staging facility development. ▪ Access of the residences around the KGA must be blocked any more than the existing situation due to the Green line works.

▪ It was hoped that some employment opportunities will be provided for the residents for the proposed Staging facility development. ▪ It was mentioned that work in the evening hours onwards must not be allowed or must be restricted as far as possible to enable the residents to rest properly in the evenings and night-time.

▪ It must be ensured that ground is restored as per existing situation to ensure the aesthetics of the area are not adversely affected. ▪ Proper safety barricading must be installed around the work site since a deep pit will be created due to excavation and the safety of the community, particularly its children must be ensured.

▪ A Contractor that has experience and reputation for timely completion of works must be engaged to ensure the works are not delayed as is the case for the Green Line. ▪ Water sprinkling and all other required measures must be implemented to minimize dust emissions. ▪ It must be ensured that worker camps are not developed near our residences to ensure our safety and proper sanitary facilities must be provided to them to ensure they do not defecate openly. ▪ Contractor must conduct works in accordance with international best practices. ▪ Safety and convenience of the local communities must be kept a priority during the project works. Analysis of Alternatives

13. The ‘No Project’ alternative was considered, which is not a viable option since the development of the staging facility, to be part of the BRT system, will benefit millions of people using public transport in Karachi city each day that would otherwise not benefit from a sustainable, more efficient, more economical and safer transport system and would continue to suffer congestion and traffic accident risks in the city.

14. Alternative Location Option: As all BRT corridors converge at Numaish station, this location holds importance in permitting customer interchange between routes. This area also holds importance as a BRT vehicle staging facility for the following reasons:

▪ Since limited space is available along the M. A. Jinnah road to hold BRT vehicles, in order to cater the difference in demand between peak and off-peak periods, Numaish is an ideal location to stage vehicles and thus optimize operations.

▪ A staging facility at Numaish shall ensure interoperability between all corridors by ensuring physical and operational integration.

▪ A large number of BRT vehicles and people will pass through Numaish station; this gives Numaish an additional significance for potential Transit-Oriented Development (ToD).

15. Due to the factors mentioned above, the KGA ground site was selected to be the most suitable along with having the required land available to meet the Staging facility requirements.

16. As mentioned above, in order to make efforts to prevent demolition of the associated facilities located next to the KGA ground, during the detailed design phase, all potential alternatives related to technical and location related aspects of the proposed staging facility development will need to be reviewed and assessed.

Potential Major Impacts

Traffic Management

17. The traffic management plan shall be prepared by the Contractor and approved by the GoS and ADB prior to commencement of the project construction activity. The main objectives of the plan shall be to maximize the safety of the workforce and the travelling public while keeping the traffic flowing as freely as possible.

Disruption to Utilities

18. The project will require demolishing and relocating some of the structures within the ROW such as water supply pipes, drainage structures, power and communication cables. Temporary suspension of services (planned or accidental) can affect the economy, industries, businesses and residents’ daily lives.

19. All required mitigation measures shall be implemented such as planning of activities through coordination with relevant line departments to minimize impacts on utilities at

work sites in the project area, advance notices to communities to enable them to prepare for utility outages etc.

Ambient Monitoring (Air Quality & Noise Levels)

20. The EPA certified and well-reputed laboratory, SUPARCO, was engaged to conduct ambient monitoring for air quality and noise levels at the project site.

Air Quality

21. The potential impacts on air quality have been assessed for both the construction and operation phases of the project. The major impacts expected during the construction phase of the project are due to dust emissions resulting from vehicular movement, emissions from construction machinery, use of generators and construction vehicles. These impacts will be mitigated through employing of best practices such as water sprinkling, tuning and maintenance of construction equipment and vehicles, covering of materials susceptible to dust formation during transportation etc.

22. Detailed air quality monitoring at the project site has been conducted and the results

have been presented in this IEE report. As can be observed, SO2, PM2.5 and PM10 are already exceeding the permissible limits, which indicates that the airshed is already quite degraded. Thus, all possible efforts will need to be made during the construction phase through adoption of best practices to minimize any further worsening of the pollutant concentrations in the airshed of the project area.

Construction Noise impacts

23. Based on the ambient monitoring, the noise levels have been observed to be considerably exceeding the permissible levels. Thus, it will need to be ensured as part of the mitigation measures that during the construction works, at no time must the noise levels be permitted to exceed 3 dB from the ambient noise levels as per IFC guidelines.

24. As measured, existing average noise levels at the project site during daytime is 76.3 dB, in accordance to the IFC guidelines, the noise limit will be 79.3 dB. Also, duration of the anticipated noisy construction activities are expected to be short and during daytime. Therefore, residences may not object to the noise.

Land Acquisition & Resettlement

25. No land acquisition and/or resettlement shall be required for the development of the Staging facility.

Cumulative Impacts

26. The construction works for the BRT – Green Line are presently ongoing along the entire western face of the proposed KGA ground. The ongoing activities consist of major earthworks in order to develop the Numaish station and BRT corridor. However, considering the progress and completion status of these existing activities, they will

have already been completed by the time the proposed Staging Facility related construction works would commence. Thus, no Cumulative impacts are expected.

Indirect and Induced Impacts

27. The potential impact of development of the proposed Staging facility at the KGA cricket ground location has been examined, which has indicated that the existing and planned infrastructure such as water supply, wastewater collection and treatment, municipal solid waste collection and disposal would be adequate to accommodate any potential population intake as a result of the proposed project development. Impacts on the environment from air emissions, traffic and community noise, and treated effluent discharge have also been assessed and have found to be acceptable and within the carrying capacities of the environmental media. Thus, negative indirect and induced impacts from this project are not expected.

Institutional Arrangements

28. During the construction phase, the overall responsibility for the implementation and monitoring of the EMP rests with the Project Director (PD). The PD through assistance from the Supervision Consultant’s Environmental staff and the Environment team of TMTD, will supervise the implementation of the proposed mitigation measures and monitor the implementation progress in the field. Monthly environmental monitoring data/reports will be incorporated in the project implementation progress reports to be shared with ADB and such monthly reports will be consolidated into bi-annual monitoring reports and submitted to ADB for review and clearance. Upon clearance, all such reports will be uploaded on the TMTD and ADB websites.

Conclusion & Recommendations

29. An action plan with clear roles and responsibilities of stakeholders has been provided in the report. The TMTD, Contractors and the Construction Supervision Consultant are the major stakeholders responsible for the action plan. The action plan must be implemented prior to commencement of construction work.

30. Mitigation will be assured by a program of environmental monitoring conducted during construction and operation to ensure that all measures in the EMP are implemented and to determine whether the environment is protected as intended. This will include observations on and off-site, document checks, and interviews with workers and beneficiaries, and any requirements for remedial action will be reported. The engaging of external environmental monitoring consultants for ensuring efficient and effective implementation of the mitigation measures is also under consideration.

31. Therefore, the proposed Staging Facility development is likely to cause certain significant adverse impacts, mostly during the construction phase, that shall be mitigated through necessary measures. The potential adverse impacts that are associated with design, construction, and operation can be mitigated to standard levels without difficulty through proper engineering design and the incorporation or

application of recommended mitigation measures and procedures. Based on the findings of this IEE study, the classification of the Project as Category ‘A’ is confirmed. It is concluded that the proposed project should proceed, with appropriate mitigation measures and monitoring programs identified in the IEE.

32. As a result of this IEE study, it has been determined that any adverse or harmful impacts shall be effectively mitigated through implementation of necessary measures and through regular monitoring. The project falls under the Category ‘B’ of ADB's Guidelines and thus an IEE has been prepared for the proposed project.

Figure ES-1: Project Area Map

1 Introduction

1.1 Project Background 33. The proposed Staging facility will be developed as part of the BRT network being developed in Karachi city. The Asian Development Bank (ADB) will be financing the development of the BRT – Red Line, the 2.4 km Common Corridor along M.A Jinnah Road (Municipal Park to Tower) and this proposed Staging Facility, located opposite Numaish station.

34. The KGA ground will be reconfigured to house an underground commercial area as well as a staging facility for the BRT network. The total floor area of KGA mezzanine level is 23,520 square meters.

35. As all BRT corridors converge at Numaish station, this location holds importance in permitting customer interchange between routes. This area also holds importance as a BRT vehicle staging facility for the following reasons:

▪ A staging facility at Numaish shall ensure interoperability between all corridors by ensuring physical and operational integration.

▪ A large number of BRT vehicles and people will pass through Numaish station; this gives Numaish an additional significance for potential Transit-Oriented Development (ToD).

36. Commercial activities within the system will not only enhance non-fare revenue, but also provide a sense of security around the station area.

37. This IEE study report presents the screening of potential environmental impacts of the proposed project and contains the mitigation measures in order to eliminate or reduce the negative impacts to an acceptable level, describes the institutional requirements and provides an environmental management plan.

The project area map of the proposed project is provided as Figure 1.1 below.

1.2 Project Objective 38. The development of the Staging facility will help in optimizing and adjusting fleet operations as the demand varies along the day. Additionally, it shall provide a turnaround facility for routes that terminate at Numaish, and will thus reduce the dead mileage for operations without passengers.

Introduction 1 | Page

1.3 Environmental Category of the Project 39. According to ADB’s Safeguard Policy Statement (SPS) 2009, a Rapid Environmental Assessment (REA) Checklist was prepared (Annexure-A). The Pakistan Environmental Protection Agency’s “Guidelines for the Preparation and Review of Environmental Reports (2000)” were also consulted. Based on the initial findings, it was ascertained that limited adverse environmental impacts are expected due to development of the proposed Staging Facility and thus it has been classified as Category ‘B’ from environmental safeguards perspective. Thus, this IEE study has been prepared.

1.4 Methodology of IEE Study The following methodology was employed for this IEE study:

40. Available secondary data was reviewed from the existing EIA report for the Main Red Line, the finalized PC-1 document, EIA report for the Green Line and any other documents that were found to be relevant to the environmental assessment of this proposed Staging Facility.

41. Field visits were undertaken consisting of preliminary scoping through surveys and assessment activities along with primary data collection such as ambient monitoring (air quality and noise levels) and stakeholder consultations to establish the potential impacts and categorization of activities and the Rapid Environmental Assessment (REA) was completed. The key receptors and stakeholders within the project area were identified.

42. Detailed and extensive stakeholder consultations have been conducted with key stakeholders such as KGA ground management, local businesses, government and local government bodies etc. in line with the national and ADB requirements.

43. The significance of impacts from the proposed project were then assessed and for those impacts requiring mitigation, suitable measures were proposed to reduce impacts to within acceptable limits as per local and international applicable regulations.

44. A detailed environmental management and monitoring plan was developed to ensure compliance to the proposed measures during the project development.

1.5 Proponent of Project 45. The Transport and Mass Transit Department (TMTD), Government of Sindh (GoS) is the proponent of the Project and all planning and execution activities will be accomplished through a designated Project Director (PD).

1.6 Structure of the Report 46. The IEE report contains eleven chapters as follows:

▪ Introduction

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▪ Policy and Legal Framework

▪ Description of the Project

▪ Description of Environment

▪ Analysis of Alternatives

▪ Assessment of Environmental Impacts and Mitigation Measures

▪ Institutional Requirements Environmental Management Plan

▪ Public Consultation

▪ Grievance Redress Mechanism

▪ Findings, Recommendations and Conclusions

▪ References

1.7 Further Additions & Updating of IEE study 47. This version of the report shall be further updated once the detailed design is completed and any other details of the proposed staging facility become available over the coming weeks and months. These revisions shall be incorporated into any subsequent updated versions of this IEE report.

Figure 1.1: Key Map of Proposed Project

Introduction 4 | Page

2 Policy and Legal Framework

2.1 General 48. This section provides an overview of the policy framework and national legislation that applies to the proposed project. The project is expected to comply with all national legislation relating to the environment in Pakistan, and to obtain all the regulatory clearances required.

2.2 National Policy and Legal Framework 49. The Pakistan National Conservation Strategy (NCS) that was approved by the federal cabinet in March 1992 is the principal policy document on environmental issues in the country (EUAD/IUCN, 1992). The NCS outlines the country's primary approach towards encouraging sustainable development, conserving natural resources, and improving efficiency in the use and management of resources. The NCS has 68 specific programs in 14 core areas in which policy intervention is considered crucial for the preservation of Pakistan's natural and physical environment. The core areas that are relevant in the context of the proposed project are pollution prevention and abatement and increasing energy efficiency while conserving biodiversity.

50. Prior to the adoption of the 18th Constitutional Amendment, the Pakistan Environmental Protection Act (PEPA) 1997 was the governing law for environmental conservation in the country. Under PEPA 1997, the Pakistan Environmental Protection Council (PEPC) and Pak EPA were primarily responsible for administering PEPA 1997. Post the adoption of the 18th Constitutional Amendment in 2011, the subject of environment was devolved and the provinces have been empowered for environmental protection and conservation.

2.3 Regulations for Environmental Assessment, Pakistan EPA 51. Under Section 12 (and subsequent amendment) of the PEPA (1997), a project falling under any category specified in Schedule I of the IEE/EIA Regulations (SRO 339 (I0/2000), requires the proponent of the project to file an IEE with the concerned provincial EPA. Projects falling under any category specified in Schedule II require the proponent to file an EIA with the provincial agency, which is responsible for its review and accordance of approval or request any additional information deemed necessary.

2.4 Sindh Environmental Protection Act, 2014 52. The following articles of the SEPA 2014 have a direct bearing on the proposed Project:

53. Article 11(1): ‘Subject to the provisions of this Act and the rules and regulations therein, no person shall discharge or emit or allow the discharge or emission of any effluent, waste, pollutant, noise or any other matter that may cause or likely cause

Policy and Legal Framework 5 | Page

pollution or adverse environmental effects, as defined in Section 2 of this Act, in an amount, concentration or level which is in excess to that specified in Sindh Environmental Quality Standards.

54. Article 11(2): ‘All persons, in industrial or commercial or other operations, shall ensure compliance with the Environmental Quality Standards for ambient air, drinking water, noise or any other Standards established under section 6(1)(g)(i); shall maintain monitoring records for such compliances; shall make available these records to the authorized person for inspection; and shall report or communicate the record to the Agency as required under any directions issued, notified or required under any rules and regulations.

55. Section 11(3): Monitoring and analysis under sub-section (1) and (2), shall be acceptable only when carried out by the Environmental Laboratory certified by the Agency as prescribed in the rules. All stipulated tests will be regularly performed from designated laboratories approved by Sindh EPA.

56. Article 14 (1): ‘Subject to the provisions of this Act and the rules and regulations, no person shall cause any act, deed or any activity’, including; (b) disposal of solid and hazardous wastes at unauthorized places as prescribed; (c) dumping of wastes or hazardous substances into coastal waters and inland water bodies; and (d) release of emissions or discharges from industrial or commercial operations as prescribed.

57. Article 15 (1): ‘Subject to the provisions of this Act, no person shall operate or manufacture a motor vehicle or class of vehicles from which air pollutants or noise are being emitted in an amount, concentration or level which is in excess of the Sindh Environmental Quality Standards or, where applicable, the standards established under sub-clause (i) of clause (g) of sub-section (1) of section 6’.

58. Article 17(1): ‘No proponent of a project shall commence construction or operation unless he has filed with the Agency an initial environmental examination or environmental impact assessment, and has obtained from the Agency approval in respect thereof.

59. Article 17(2): The agency shall; o a) review the initial environmental examination and accord its approval, subject to such terms and conditions as it may prescribe, or require submission of an environmental impact assessment by the proponent; or o (b) review the environmental impact assessment and accord its approval subject to such terms and conditions as it may deem fit to impose or require that the environmental impact assessment be re-submitted after such modifications as may be stipulated or decline approval of the environmental impact assessment as being contrary to environmental objectives.

60. Article 17(3): ‘Every review of an environment impact assessment shall be carried out with public participation and, subject to the provisions of this Act, after full disclosure of the particulars of the project’.

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61. Article 17(4): ‘The Agency shall communicate its approval or otherwise within a period of two months from the date that the initial environmental examination is filed, and within a period of four months from the date that the environmental impact assessment is filed complete in all respects in accordance with the regulations, failing which the initial environmental examination or, as the case may be, the environmental impact assessment shall be deemed to have been approved, to the extent to which it does not contravene the provisions of this Act and the rules and regulations’.

62. Article 20(1): ‘The Agency shall from time to time require the person in charge of a project to furnish, within such period as may be specified, an environmental audit or environmental review report or environmental management plan containing a comprehensive appraisal of the environmental aspects of the project’.

63. Article 20(2): The report of a project prepared under sub-section (1) shall include: (a) analysis of the predicted qualitative and quantitative impact of the project as compared to the actual impact; (b) evaluation of the efficacy of the preventive, mitigation and compensatory measures taken with respect to the project; and (c) Recommendations for further minimizing or mitigating the adverse environmental impact of the project.

64. Article 20(3): ‘Based on its review of the environmental audit report, the Agency may, after giving the person in charge of the project an opportunity of being heard, direct that specified mitigation and compensatory measures be adopted within a specified time period and may also, where necessary, modify the approval granted by it under section 17’.

65. Section 31(1): The Agency shall cause relevant details of any proposed project regarding which an Environmental Impact Assessment has been received to be published, along with an invitation to the public to furnish their comments thereon within a specified period. (2) In accordance with such procedure as may be prescribed, the Agency shall hold public hearings to receive additional comments and hear oral submissions. (3) All comments received under sub-sections (1) and (2) shall be duly considered by the Agency while reviewing the environmental impact assessment or strategic impact assessment, and decision or action taken thereon shall be communicated to the persons who have furnished the said comments.

2.5 Other National and Sindh Government Laws and Regulations 66. The national laws and regulations are provided in Table 2.1 below.

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Table 2.1: Other National and Sindh Government Laws and Regulations

National and Provincial Brief Description Legislation

Sindh Factories Act 2015 The Sindh Factories Act 2015 deals with regulations related to project area, workers and workplace Environment Health and Safety (EH&S) requirements. The Factories Act also provides regulations for handling and disposal of toxic and hazardous materials. As construction activity is classified as ‘industry’, these regulations will be applicable to the project & construction contractors’ scope of work also. The Protection against It shall be the responsibility of the employer to ensure Harassment of women at the implementation of this Act, including but not limited to incorporate work place Act 2010 the Code of Conduct for protection against harassment at the workplace as a part of their management policy and to form Inquiry Committee referred to in section 3 and designate a competent authority referred to in section 4 of this act. Employment of Child Act 1991 Article 11(3) of the Constitution of Pakistan prohibits employment of children below the age of 14 years in any factory, mines or any other hazardous employment. In accordance with this Article, the Employment of Child Act (ECA) 1991 disallows the child labour in the country. The ECA defines a child to mean a person who has not completed his/her fourteenth year of age. The ECA states that no child shall be employed or permitted to work in any of the occupation set forth in the ECA (such as transport sector, railways, construction, and ports) or in any workshop wherein any of the processes defined in the Act is carried out. The contractor will be bound by this Act to disallow any child labour at the project sites or campsites. Bonded labor system On the commencement of this act, the bonded labor system shall (Abolition) Act 1992 stand abolished and every bonded labourer shall stand freed and discharged from any obligations to render any bonded labor. Sindh Cultural Heritage Act This provincial Act empowers the Government of Sindh to 1994 preserve and protect any premises or objects of archaeological, architectural, historical, cultural, or national interest in Sindh by declaring them protected. Antiquity act 1975 The Antiquities Act relates to the protection, preservation and conservation of archaeological/historical sites and monuments. The Sindh Minimum Wages To provide for the regulation of minimum rates of wages and Act, 2015 various allowances for different categories of workers employed in certain industrial and commercial undertakings and establishments. Workmen’s compensation 1923 The liability of an employer is confined to payment of compensation to a “workman” and then only in respect of an injury caused by “accident arising out of and in the course of his employment”. The liability of employer is limited by ceiling fixed in Schedule to the Act.

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Land Acquisition Act, 1894 This Legislation relates to land acquisition and compensation. The LAA 1894 is, however, is limited to a cash compensation policy for the acquisition of land and built-up property and damage to other owned assets, such as crops, trees and infrastructure. The LAA does not consider the rehabilitation and resettlement of disrupted populations and the restoration of their livelihoods. The Pollution Charge for Related to methods for evaluation and collection of fee for not Industries (calculation and meeting environmental standards. Collection) Rules 2001

The Sindh Forest Act 2012 The law requires review and revision to meet the challenges of management and empower the forest managers to carryout management interventions with full legal support. The new legal instrument should amply address the provision and requirements of UNFCCC, CBD and Convention on Combating Desertification. Legal aspects of carbon sequestration and carbon credit marketing should also be kept in view. The Cutting of Trees It mandates that no person shall, without prior written approval (prohibition) Act, 1992 from authorized officer shall cut, fell or damage trees growing in: First Zone (Area adjacent to and beyond the external frontier of Pakistan to a line at four kilometers measured from the external frontiers of Pakistan) if the number of remaining trees in any field falls short of the number to be calculated at the rate of fifteen trees per acre; and Second Zone (Area adjacent to and beyond the first one extending towards Pakistan to a line at four kilometers measured from the first zone) if the number of remaining trees in any field falls short of the number to be calculated at the rate of ten trees per acre. Sindh Wildlife Protection This ordinance provides for the preservation, protection and Ordinance, 1972 (SWPO) conservation of wildlife by the formation and management of protected areas and prohibition of hunting of wildlife species declared protected under the ordinance. The ordinance also specifies three broad classifications of the protected areas; national parks, wildlife sanctuaries and game reserves. Activities such as hunting and breaking of land for mining are prohibited in national parks, as are removing vegetation or polluting water flowing through the park. Wildlife sanctuaries are areas that have been set aside as undisturbed breeding grounds and cultivation and grazing is prohibited in the demarked areas. Nobody is allowed to reside in a wildlife sanctuary and entrance for the general public is by special dispensation. However, these restrictions may be relaxed for scientific purpose or betterment of the respective area on the discretion of the governing authority in exceptional circumstances. Game reserves are designated as areas where hunting and shooting is not allowed except under special permits.

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Hazardous Substance Rule, These Rules were notified to streamline procedures for issuance 2014 of licenses to industries / businesses that generate hazardous waste, safety precautions for workers and devices them methods for the removal of hazardous wastes in an environmentally friendly manner. The rules also specify procedures to be adopted for import, transport and disposal of hazardous waste; and identify two hundred and forty-three hazardous substances and synthetic chemicals. The rules also specify the requirement of obtaining license from Sindh EPA for the import, transport, storage and disposal of hazardous substances as specified in the rules

2.6 Regulatory Clearances, Sindh EPA 67. In accordance with provincial regulatory requirements, an IEE/EIA satisfying the requirements of the Sindh Environmental Protection Act (2014) is to be submitted to Sindh environmental protection agency (SEPA) for review and approval, and subsequent issuance of NOC before the commencement of construction.

2.7 Guidelines for Environmental Assessment, Pakistan EPA 68. The Pak-EPA has published a set of environmental guidelines for conducting environmental assessments and the environmental management of different types of development projects. The guidelines that are relevant to the proposed project are listed below:

▪ Guidelines for the Preparation and Review of Environmental Reports, Pakistan, EPA1997;

▪ Guidelines for Public Consultations; Pakistan EPA May 1997;

2.8 National Environmental Quality Standards (NEQS) 2000 69. The National Environmental Quality Standards (NEQS), 2000, specify the following standards:

▪ Maximum allowable concentration of pollutants (32 parameters) in municipal and liquid industrial effluents discharged to inland waters, sewage treatment facilities, and the sea (three separate sets of numbers);

▪ Maximum allowable concentration of pollutants (16 parameters) in gaseous emissions from industrial sources;

▪ Maximum allowable concentration of pollutants (two parameters) in gaseous emissions from vehicle exhaust and noise emission from vehicles;

▪ Maximum allowable noise levels from vehicles;

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70. These standards apply to the gaseous emissions and liquid effluents discharged by batching plants, campsites and construction machinery. The standards for vehicles will apply during the construction as well as operation phase of the project. Standards for ambient air quality have also been prescribed.

2.9 Interaction with Other Agencies 71. The Transport & Mass Transit Department (TMTD), GoS is responsible for ensuring that the project complies with the laws and regulations controlling the environmental concerns of the Staging facility construction and operation and that all preconstruction requisites, such as permits and clearances are met.

2.10 Provincial EPAs 72. TMTD will be responsible for providing the complete environmental documentation required by the SEPA and remain committed to the approved project design. No deviation is permitted during project implementation without prior and explicit permission of the SEPA.

2.11 Provincial Departments of Forests and Wildlife 73. No uprooting or clearing of trees is expected for the proposed project. However, any removed trees or vegetation under private ownership will be compensated as per provision that in case of disruption to vegetation or trees, the project contractor will be responsible for acquiring a 'No-Objection Certificate' (NOC) from the concerned forest department. The application for an NOC will need to be endorsed by the TMTD.

2.12 Provincial Governments 74. The TMTD and its contractors must ensure that the project meets the criteria of provincial/district governments as related to the establishment of construction camps and plants, and the safe disposal of wastewater, solid waste, and toxic materials. TMTD will coordinate and monitor environment related issues.

2.13 ADB’s Safeguard Policy Statement (SPS), 2009 75. The ADB’s SPS 2009 requires that environmental considerations be incorporated into ADB funded projects to ensure that the project will have minimal environmental impacts and be environmentally sound. Occupational health & safety of the local population should also be addressed as well as the project workers as stated in SPS. A Grievance Redress Mechanism (GRM) to receive application and facilitate resolution of affected peoples’ concerns, complaints, and grievances about the project’s environmental performance is also established.

76. All loans and investments are subject to categorization to determine environmental assessment requirements. Categorization is to be undertaken using Rapid Environmental Assessment (REA) checklists, consisting of questions relating to (i) the sensitivity and vulnerability of environmental resources in project area, and (ii) the

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potential for the project to cause significant adverse environmental impacts. Projects are classified into one of the following environmental categories:

Category A: A proposed project is classified as category A if it is likely to have significant adverse environmental impacts that are irreversible, diverse or unprecedented. These impacts may affect an area larger than the sites or facilities subject to physical works. An environmental impact assessment (EIA) is required.

Category B: A proposed project is classified as category B if its potential adverse environmental impacts are less adverse than those of category A projects. These impacts are site-specific, few if any of them are irreversible, and in most cases mitigation measures can be designed more readily than for category A projects. An initial environmental examination (IEE) is required.

Category C: A proposed project is classified as category C if it is likely to have minimal or no adverse environmental impacts. No environmental assessment is required although environmental implications need to be reviewed.

Category FI: A proposed project is classified as category FI if it involves investment of ADB funds to or through a financial intermediary (FI).

2.14 ADB’s Access to Information Policy (AIP) 2018 77. ADB’s new Access to Information Policy (AIP), reflects the ADB’s ongoing commitment to transparency, accountability, and participation by stakeholders. The policy contains principles and exceptions to information sharing with external stakeholders, led by a new overarching principle of “clear, timely, and appropriate disclosure.”

2.15 ADB’s Accountability Mechanism Policy 2012 78. The objectives of the Accountability Mechanism is providing an independent and effective forum for people adversely affected by ADB-assisted projects to voice their concerns and seek solutions to their problems, and to request compliance review of the alleged noncompliance by ADB with its operational policies and procedures that may have caused, or is likely to cause, them direct and material harm. The Accountability Mechanism is a “last resort” mechanism.

2.16 Implications of ADB’s safeguard policies on proposed project 79. The objectives of ADB’s safeguards are to:

▪ avoid adverse impacts of projects on the environment and affected people, where possible;

▪ minimize, mitigate, and/or compensate for adverse project impacts on the environment and affected people when avoidance is not possible; and

▪ help borrowers/clients to strengthen their safeguard systems.

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80. ADB’s SPS sets out the policy objectives, scope and triggers, and principles for three key safeguard areas:

▪ environmental safeguards,

▪ involuntary resettlement safeguards, and

▪ Indigenous Peoples safeguards.

81. The objective of the environmental safeguards is to ensure the environmental soundness and sustainability of projects and to support the integration of environmental considerations into the project decision-making process. ADB’s policy principles are summarized in Table 2.2 below.

Table 2.2: ADB Policy Principles

Policy principle Summary

1 Screening and Screening process initiated early to determine the categorization appropriate extent and type of environmental assessment.

2 Environmental Conduct an environmental assessment to identify assessment potential impacts and risks in the context of the project’s area of influence.

3 Alternatives Examine alternatives to the project’s location, design, technology, and components and their potential environmental and social impacts, including no project alternative.

4 Impact mitigation Avoid, and where avoidance is not possible, minimize, mitigate, and/or offset adverse impacts and enhance positive impacts. Prepare an environmental management plan (EMP).

5 Public consultations Carry out meaningful consultation with affected people and facilitate their informed participation. Involve stakeholders early in the project preparation process and ensure that their views and concerns are made known to and understood by decision makers and taken into account. Continue consultations with stakeholders throughout project implementation. Establish a grievance redress mechanism.

6 Disclosure of Disclose a draft environmental assessment in a environmental timely manner, in an accessible place and in a form and language(s) understandable to stakeholders.

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assessment Disclose the final environmental assessment to stakeholders.

7 Environmental Implement the EMP and monitor its effectiveness. management plan Document monitoring results, and disclose monitoring reports.

8 Biodiversity Do not implement project activities in areas of critical habitats.

9 Pollution prevention Apply pollution prevention and control technologies and practices consistent with international good practices. Adopt cleaner production processes and good energy efficiency practices. Avoid pollution, or, when avoidance is not possible, minimize or control the intensity or load of pollutant emissions and discharges. Avoid the use of hazardous materials subject to international bans or phaseouts.

10 Occupational health and Provide workers with safe and healthy working safety conditions and prevent accidents, injuries, and disease. Establish preventive and emergency Community safety. preparedness and response measures to avoid, and where avoidance is not possible, to minimize, adverse impacts and risks to the health and safety of local communities

11 Physical cultural Conserve physical cultural resources and avoid resources destroying or damaging them. Provide for the use of “chance find” procedures.

2.17 Comparison of International and Local Environmental Legislations 82. The ADB SPS requires application of pollution prevention and control technologies and practices consistent with international good practice, as reflected in internationally recognized standards. The SPS states that when host country regulations differ from these standards, the EA will achieve whichever is more stringent.

83. In order to select the most stringent standards applicable, a mix of local (NEQS) and international (IFC) regulations have been selected. The IFC Environmental, Health, and Safety (EHS) Guidelines, General EHS Guidelines: Environmental, Noise Management has noise level guidelines for daytime and nighttime, which are applicable. Considering the high baseline noise levels in the project area, it shall be ensured that the increase in noise levels is minimized as far as possible. Also, project related noise levels in the project area are not allowed to increase the existing levels

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by 3 dB or more. Furthermore, it shall be ensured that all necessary noise mitigation measures are implemented to minimize the noise levels in the project area.

84. The Table 2.3 presents IFC workplace noise standards that are applicable to the construction workers. It should also be noted that IFC EHS guidelines advise that where existing ambient noise levels already exceed thresholds, the Project should not result in an increase of more than 3 dB over existing ambient noise at the nearest receptor location off-site.

85. Since measured existing background noise levels along the project alignment in average are 85 dB during the daytime and 79 dB during the nighttime, per IFC guidelines, noise limits could be set at 3 dB above these existing background levels. Therefore, average hourly daytime limit could be 88 dB and nighttime limit could be 82 dB.

86. A comparison of applicable local and international guidelines for ambient air quality has been provided in Table 2.4 below. In the case of most pollutants, the NEQS standards for ambient air quality are more stringent in comparison to USEPA and WHO/IFC standards. The applicable and most stringent parameters for each respective pollutant are highlighted in green.

87. Similar to the standards for air quality, the comparison of noise standards provided in Table 2.5 clearly shows that NEQS standards for noise are more stringent in comparison to the IFC standards. The only exception is the daytime noise level standard for Industrial areas where the IFC standard is more stringent (70 dB(A)) in comparison to NEQS (75 dB(A)) and so for this particular parameter, the IFC standard will be used. Apart from this one exception, the NEQS standards have been used for the proposed BRT project.

88. As far as regulations regarding other environmental parameters are concerned such as acceptable effluent disposal parameters, the local regulations i.e. NEQS take precedence over any other international regulations such as IFC.

Table 2.3: IFC Work Environment Noise limits

Type of Work, workplace IFC General EHS Guidelines

Heavy Industry (no demand for oral communication) 85 Equivalent level Leq,8h

Light industry (decreasing demand for oral 50-65 Equivalent level Leq,8h communication)

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Table 2.4: Comparison of International and local Air Quality Standards*

USEPA WHO/IFC Pak. NEQS Pollutants Avg. Time Standard Avg. Time Standard Avg. Time Standard

3 hrs 0.5 ppm 24 hr 20 ug/m3 Annual Mean 80 ug/m3 SO2 1 hr 75 ppb 10 min 500 ug/m3 24 hrs 120 ug/m3

8 hrs 9 ppm (11 mg/m3) 8 hrs 5 mg/m3 CO - - 35 ppm (43 1 hr 10 mg/m3 1 hr mg/m3)

Annual 100 ug/m3 (53 40 ug/m3 1 yr 40 ug/m3 Annual Mean Mean ppb) NO2 80 ug/m3 1 hr 200 ug/m3 24 hrs 1 hr 100 ppb

8 hrs 100 ug/m3 130 ug/m3 0.07ppm (148 O3 8 hrs 1 hr ug/m3)

Annual Mean 360 ug/m3 TSP - - - - 24 hrs 500 ug/m3

3 3 3 PM10 24 hrs 150 ug/m 1 yr 20 ug/m Annual Mean 120 ug/m

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24 hr 50 ug/m3 24 hrs 150 ug/m3

Annual Average 15 ug/m3 Annual 15 ug/m3 1 yr 10 ug/m3 Mean 3 PM2.5 24 hrs 35 ug/m 35 ug/m3 24 hr 25 ug/m3 24 hrs 1 hr 15 ug/m3

*: The standards highlighted in green for each respective pollutant are the most stringent based on a comparison between local and international regulations and thus shall be applicable for the proposed project.

* In instances where the airshed is significantly degraded and the pollutant levels are already exceeding the ambient pollutant concentrations provided in the table above, it shall be ensured that the project activities cause as small an increase in pollution levels as feasible, and amounts to a fraction of the applicable short term and annual average air quality guidelines or standards as established in the project specific environmental assessment.

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Table 2.5: Comparison of International and Local Noise Standards

Limit in dB(A) Leq

Category of Area/Zone NEQS WHO/IFC

Day Time Night Time Day Time Night Time

06:00 – 22:00 22:00-06:00 07:00 – 22:00 22:00-07:00

Residential area (A) 55 45 55 45

Commercial area (B) 65 55 70 70

Industrial area (C) 75 65 70 70

Silence zone (D) 50 45 55 45

*: The standards highlighted in green for each respective Area/Zone are the most stringent based on a comparison between local and international regulations and thus shall be applicable for the proposed project.

* In instances where baseline noise levels are already exceeding the standards above, it will need to be ensured that the project activities do not cause an increment of more than 3 dB(A) from the baseline noise levels.

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3 Description of the Project

3.1 Project Overview 89. The development of a BRT vehicle staging facility under the Karachi Goan Association (KGA) ground, adjacent to Numaish station is being considered with the layouts of the proposed facility provided as Figures 3.1 to 3.3 below. The KGA ground will be reconfigured to house an underground commercial area as well as a staging facility for the BRT network. The total floor area of KGA mezzanine level is 23,520 square meters.

90. The existing structures on the KGA ground will need to be demolished during construction, the concept design proposes to reconstruct the ground and its associated facilities on top of the Mezzanine floor at ground level.

91. The staging facility is proposed to be constructed at the KGA ground, which will be an underground facility consisting of 2 floors having a basement or the underground level which will be used for bus lanes, drivers sitting area, dispatch center and washrooms. The Mezzanine level will be for the commuters and will have the ticketing booths, waiting and commercial areas.

92. It will also provide ease of transfer of passengers from one line to the other and include parking lots for the buses, maintenance of buses, offices, ticketing booth, waiting areas and turnaround facility for the routes that terminate at Numaish.

93. As all BRT corridors converge at Numaish station, this location holds importance in permitting customer interchange between routes. This area also holds importance as a BRT vehicle staging facility for the following reasons:

▪ A staging facility at Numaish shall ensure interoperability between all corridors by ensuring physical and operational integration.

▪ A large number of BRT vehicles and people will pass through Numaish station; this gives Numaish an additional significance for potential Transit-Oriented Development (ToD).

94. Commercial activities within the system will not only enhance non-fare revenue, but also provide a sense of security around the station area.

Project Need

95. The staging facility will help in optimizing and adjusting fleet operations as the demand varies along the day. Additionally, it shall provide a turnaround facility for

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routes that terminate at Numaish, and will thus reduce the dead mileage for operations without passengers.

3.2 Justification and Need for Project 96. The staging facility will help in optimizing and adjusting fleet operations as the demand varies along the day. Additionally, it shall provide a turnaround facility for routes that terminate at Numaish, and will thus reduce the dead mileage for operations without passengers.

97. It is important to mention that the Staging Facility shall be a part of the overall Karachi BRT system, which will deliver a sustainable urban transport system that focuses on accessibility and people's mobility needs. The BRT system will aim to organize urban growth and public space along the BRT corridors through integration of land-use and transport planning, improving quality of life, and providing a holistic solution for integrated urban mobility. The purpose of this project is to develop a sustainable urban transport system that delivers fast, affordable, comfortable, safe, and secure services to all.

3.3 Project Construction Schedule 98. The project construction phase is expected to last for a total of 12 months with the activity expected to commence in the third quarter of 2019 and completed by the third quarter of 2020.

3.4 Construction Camps and Work Force 99. The construction activity is expected to span over approximately twelve months. There shall be a number of contracts for a variety of works. The selected Contractor shall have the option to select suitable site(s) located near the project site to establish his labor camps.

100. The work bases shall be setup by the contractor in consultation with the engineering teams. Essential for the work bases is easy approach, availability of a suitable place for temporary storage of material and availability of water for construction in the vicinity. Presence of shade from trees close to the work bases can add to the comfort of the labor while taking rest during the hot season.

101. The location of storage materials and camps will be critical. Since the project contractor(s) will be responsible for identifying the suitable locations for storage and labor camps from the private sector, thus there will need to be clear guidelines for this process, which will need to be closely monitored by the implementing agency. As far as possible, the project design team shall be assigned the task to identify the suitable location(s) for storage of materials since inappropriate storage of materials may result disruption of the traffic movement.

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Figure 3.1: Layout of Mezzanine Level of Staging Facility

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Figure 3.2: Layout of Ground Floor of Staging Facility

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Figure 3.3: Detailed Layout of Proposed Staging Facility

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3.5 Machinery Requirement 102. For storing materials, stocking equipment and parking machinery and vehicles, the Contractor shall require open and accessible sites close to the labor camps. The Contractor, at his own expense, but keeping in view his contractual obligations to honor the NEQS regarding level of pollution, shall make the arrangements.

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4 Description of Environment

4.1 General 103. The description of various features of the project area environment including the physical, ecological, cultural and socio-economic environmental aspects are presented in the following sub-sections.

4.2 Physical Resources

4.2.1 Meteorological Parameters 104. Karachi is located just above the tropical zone on the coast of the Arabian Sea at 24.9 N latitude and 67.13 E longitude at about 20 m ASL (airport weather station). It is classified as BWh (arid/desert/hot) under the Köppen system. According to Budyko’s criteria, Karachi is characterized by the following parameters:

▪ Radiation index of Dryness: 7.54 ▪ Budyko Evaporation 211 mm/year ▪ Budyko Runoff 1 mm/year ▪ Budyko Evaporation 99.5 % ▪ Budyko Runoff 0.5 %

105. The best estimate of annual rainfall is 212 mm. Net moisture allowance follows the pattern shown in the Figure 4-1 below and as can be seen, precipitation is exceeded by evapotranspiration for every month (arid/desert), hence, it is only during heavy rains that Karachi experiences runoff. Note that these values as well as other data in this section are long term averages compiled by the FAO and available through its “Climate Estimator”1. No particular year is represented in Figure 4-1 below. On the other hand, Figure 4-2 depicts the last 9 years maximum and minimum precipitation at Karachi.

1 The FAO Climate Estimator is a software program and database that provides estimates of average climatic conditions at locations throughout the world. The program can be used to create climatic maps and extract data in various formats for further processing, available at http://www.fao.org/nr/climpag/pub/en3_051002_en.asp. Description of Environment (25)24 July 2019

Figure 4-1: Monthly Average Precipitation (mm) and Evapotranspiration (mm) at Karachi Airport

100 days

75 days

50 days

25 days

0 days

Figure 4-2: Minimum and maximum Precipitation (mm) and Evapotranspiration (mm) at Karachi (2009-2018)

Source: Pakistan Metrological Department

106. The temperature ranges are shown in Figure 4-3 below. Cool weather can prevail during the night from November through March; however, daytime temperatures are generally hot. Temperatures may reach 40°C during May (considered the hottest month), and extreme temperatures of greater than 45°C are not uncommon. No Description of Environment 26 | P a g e

particular year is represented in Figure 4-3 below. On the other hand, the Figure 4-4 depicts the last 9 years maximum, minimum and average temperature of Karachi.

Figure 4-3: Monthly Averages for Mean, Maximum and Minimum Temperatures (Deg-C) at Karachi Airport

Figure 4-4: minimum, maximum and average temperature of Karachi (2009-2018)

Source: Pakistan Metrological Department

107. Despite arid conditions, humidity is relatively high throughout the year. The average annual relative humidity is 75.9% and average monthly relative humidity ranges from

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60% in December to 85% in August (Table 4-1). The Figure 4-5 depicts the last 9 years average cloud and humidity of Karachi.

Table 4-1: Humidity and Dew Point Temperature for Karachi Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec Aver Relative Humidity (%) 61 70 77 79 83 83 83 85 84 79 67 60 75.9

Average Dew Point 12.2 15.4 20.2 23.2 26 27.5 26.6 25.7 25 23.5 18.6 13.4 21.5 Temperature °C ( °F) (53.9) (59.8) (68.4) (73.8) (78.8) (81.5) (79.9) (78.3) (77.1) (74.4) (65.6) (56.1) (70.6)

Comfor Comfor Very Severely Severely Severely Very Comfor Very Interpretation Humid M uggy M uggy Humid table table humid high high high humid table humid

Figure 4-5 Average cloud and Humidity of Karachi (2009-2018)

Source: Pakistan Metrological Department

108. Karachi weather is considered pleasant by some due to its breeze from the sea. The wind speed has highest velocities during the summer months, when the direction is south-west to west. The last nine years’ maximum and average wind speeds are given in Figure 4-6 and the Onshore winds from the Arabian Sea contribute to humid conditions, with winds from the west-southwest and southwest being 57% of the time and are depicted in the wind rose in

109.

110.

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111. Figure 4-7 below.

Figure 4-6: maximum and average wind speed of Karachi (2009-2018)

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Source: Pakistan Metrological Department

Figure 4-7: Annual Wind Rose for Karachi

4.2.2 Air Quality 112. The main sources of air pollution in Karachi include motor vehicles, uncontrolled waste burning, and industry, including metal working shops, chemical and engineering works, an oil refinery, railroad yards, jute and textile factories, printing and publishing plants, and food processing plants. Re-suspended dust, and small scale unlicensed businesses using ‘dirty fuels’ for manufacturing and production purposes are also contributors.

113. Air pollutant emissions are directly related to fuel consumption. Pakistan’s consumption of petroleum products is growing at 6 per cent annually, of which one- half is consumed by the transport sector. The high content of sulphur in diesel (0.5-1 %) and furnace oil (1-3.5 %) is a major contributor to air pollution. Energy from waste fuels such as waste paper, wood and textile waste contribute a disproportionate load. Industrial emissions are further compounded by the widespread use of small diesel generators in commercial and residential areas in response to the poor reliability of electricity supplies. (Hashmi, et.al 2005)

114. Air pollution from vehicles is severe, with high concentrations gaseous emissions, and fine particulate that cause respiratory problems for an exposed population. The number of diesel trucks and buses has increased. A major share of the emission load from motor vehicles can be attributed to low quality diesel fuel and oil burning two- stroke engines. Description of Environment 30 | P a g e

115. To offset this trend, Karachi has witnessed an increase in vehicles fuelled by compressed natural gas (CNG) in recent years and many formerly diesel fuelled vehicles have been converted to run on CNG. However, there has been a greater increase in traffic overall and Karachi has a preponderance of old buses that run on diesel fuel and produce high emissions. Buses and trucks cause significant air pollution and since the main sources of pollutants are traffic, and traffic has increased on the Red Line corridor, it is assumed that air quality has deteriorated as a result.

116. The main air pollutants in Karachi City are nitrogen oxides (NOX) sulphur dioxide

(SO2) particulate matter (PM10, PM with diameter of 10 microns or smaller and PM2.5, i.e. PM 2.5 microns or smaller) and carbon monoxide (CO). Motor vehicles are the major source of PM pollution. Most of the PM pollution (>80%) comes from diesel-run vehicles. Sindh Environmental Quality Standards (SEQS) for these parameters in

addition to lead (Pb) and ozone (O3) are set by the Government and have been promulgated at provincial level by the Government of Sindh as well as standards for vehicle emissions in line with Euro II. Finally, the Government has promulgated tailpipe emissions standards.

117. The EPA certified and well-reputed laboratory, SUPARCO, was engaged to conduct monitoring for ambient air quality near the proposed project site for the Staging facility development with the results provided as Annexure H.

The location selected for the monitoring activity is shown on the map as Figure 4.8 below.

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Figure 4.8: Monitoring Location for Ambient Air Quality and Noise Levels

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118. Detailed 24 hourly ambient air quality monitoring at the proposed project site for the Staging facility has been conducted and the results of this monitoring are provided as Table 4.3 below. Furthermore, a comparison of these monitoring results with the applicable air quality guidelines is also presented in Table 4.4 below. As can be

observed, SO2, PM2.5 and PM10 are already exceeding the permissible limits, which indicates that the airshed is already quite degraded. Thus, all possible efforts will need to be made during the construction phase through adoption of best practices to minimize any further worsening of the pollutant concentrations in the airshed of the project area.

4.2.3 Noise 119. Traffic is a major contributor of noise pollution in all the big cities of the World. Karachi is noted for its high level of noise from improperly maintained vehicles, weak and ineffective noise pollution regulations and lack of enforcement.

120. The results of this monitoring activity are provided in Table 4.2 below. Since the ambient noise levels have been observed to be exceeding the permissible levels, thus it will need to be ensured as part of the mitigation measures that during the construction works, at no time shall the noise levels be permitted to exceed 3 dB from the ambient noise levels.

Table 4.2: Ambient Noise Monitoring Results (24 hrs) at Staging Facility Project Site

Monitoring Location Parameter Noise Reading Results

Day Time Readings (0600 to 2200)

Staging Facility Project Site dB(A) Leq* 76.3

Night Time Readings (2200 to 0600)

Staging Facility Project Site dB(A) Leq* 67.6

Source: SUPARCO Monitoring Report, June 2019 *dB(A) Leq: Time weighted average level of sound in decibel on scale which is relatable to human hearing

4.2.4 Climate Change and Effects 121. Climate change acting hand-in-hand with urban dislocation and growth promises to exert a significant negative impact on Karachi’s urban infrastructure systems and services, its built environment and ecosystem services, and therefore on its urban population and economy. As one of the region’s coastal mega cities, which includes Manila, Bangkok, Jakarta, Mumbai and Shanghai, Karachi will face increased flooding and damage from unpredictable weather patterns along with other forms of extreme event including drought with attendant risks on water supply, heat waves with attendant effect on fuel consumption and water use, sea level rise that impacts mangrove and other ecosystems, flood water removal, and complicity with tropical cyclones. (Anwar 2012)

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122. Another prominent study (Hasan et.al. 2017) maintains that Karachi, being a city of migrants located in the midst of an alien and unwelcoming province, suffers from a disconnect of governance that bodes ill for dealing with the effects of climate change:

“Of the estimated 3.35 million ‘illegal’ immigrants in Pakistan, 75 per cent (or 2.5 million) are settled in more than 100 migrant-concentrated residential areas in Karachi. Living conditions in these settlements are mostly cramped, and services such as clean drinking water, sanitation and solid waste disposal are hard to come by. Research from the region suggests that processes and structures of unplanned rapid urbanisation, environmental change and social exclusion reinforce urban vulnerability for migrants.” (p. 6)

123. The report concludes with recommendations to enhance capacity and political support for institutional reforms, reconstitute the low-cost housing market and support private and public-sector cooperation in health and housing provision, as means for reducing vulnerabilities among the Katchi Abadi population.

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Table 4.3: Ambient Air Quality Monitoring Results (24 hrs) at Staging Facility Proposed Location

NO NO2 CO SO2 O3 PM2.5 PM10 SPM Monitoring Location Parameter (ug/m3) (ug/m3) (ug/m3) (ug/m3) (ug/m3) (ug/m3) (ug/m3) (ug/m3)

Min 5.6 25.0 2.2 16.0 5.7 Staging Facility Max 19.6 98.0 6.4 30.0 31.5 61.5 133.8 385.6 Project Site Average 11.5 58.5 3.5 24.0 16.7

Source: SUPARCO Monitoring Report, June 2019

Table 4.4: Comparison of ambient air quality results versus applicable Air Quality standards

NO NO2 CO SO2 O3 PM2.5 PM10 SPM Monitoring Location Parameter (ug/m3) (ug/m3) (ug/m3) (ug/m3) (ug/m3) (ug/m3) (ug/m3) (ug/m3)

Applicable Guideline - 80 - 20 - 25 50 500 (ug/m3) for 24 hrs

Min 5.6 25.0 2.2 16.0 5.7 Staging Facility 61.5 133.8 385.6 Project Site Max 19.6 98.0 6.4 30.0 31.5

Average 11.5 58.5 3.5 24.0 16.7

Exceeding applicable guidelines for acceptable pollutant levels Within’ applicable guidelines for acceptable pollutant levels

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Figure 4-9: Katchi Settlements Flooded and Dry

4.3 Geology, Soils and Groundwater 124. The physical features of Karachi and the hinterland in southern Sindh includes plains, hills, rivers, valleys and coasts. The city covers an area of approximately 3,530 km2, comprised largely of flat or rolling plains, with hills on the west and north demarcating the limits of urban expansion.

125. The Arabian sea beaches line the southern coastline of Karachi. Dense mangroves and creeks of the Indus Delta can be found toward the southeast along the coast. Cape Monze, an area marked with projecting sea cliffs and rocky sandstone promontories is located toward the North West. Beaches can also be found in this area including nesting locations for the green turtle, like Hawkes Bay.

126. Rocks ranging in age from Eocene to recent, deposited under shallow marine deltaic conditions are exposed. Karachi is a part of major synclinorium stretching from Ranpathani River in the east to Cape Monze in the west. (Hamid et.al. 2013) Mehar and Mol mountains lie in the north. Within the synclinorium a number of formations are exposed. The Geotechnical report prepared for the BRT-Red Line project (MML 2018) identifies these as:

▪ Kirthar Formation (Eocene) ▪ Nari Formation (Oligocene) ▪ Gaj Formation (Miocene) ▪ Mancher Formation (Pliocene) ▪ Dada Formation (Pleistocene) ▪ Terrace Deposits ▪ Piedmont and Sub-piedmont Deposits 127. The geological map of Karachi and surrounding areas is attached as Figure 4-10 below. Various rock formations have been folded to form anticlinal hills and synclinal valleys, with moderate to gentle dips. The fold axes run approximately north-east to south west and there are two main zones. The first zone is to the east and northeast and is characterized by relatively more intense folding and faulting. Rocks ranging in age from Palaeocene to Oligocene are also exposed in this zone. The second zone is located in the center and to the west and southwest and comprises a large area that opens towards the south and consists of horizontal or near horizontal strata that form gentle undulations in the form of synclines and anticlines with low dips of 2 to 6 degrees (rarely up to 10 degrees). These folds have a general southward plunging direction.

128. According to the geological map, most of the project lies in the TMG designation, comprised of shales and limestones of the Gaj formation in the Kirthar range. The Gaj Formation is divided into Lower (Mol) and Upper (Sharji) members. The lower

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member (Mol) is comprised of clay in the lower part and limestone in the upper part. The limestone unit is very hard, thinly-bedded, light brown to cream colored, massive and nodular. It is siliceous in some parts and may be fossiliferous, coralline and chalky where found exposed in a weathered escarpment. It is generally about 68 m thick and decreases in thickness toward the east. The Gaj formation, whether exposed or underground, encompasses most of Karachi and in particular around the project area.

4.3.1 Seismic activity 129. Karachi is located in a moderate earthquake zone. Pakistan falls into three seismic zones. Zone-III is the most severe and Zone-I the least. The Karachi Building Control Authority has placed Karachi in Zone-II. Based on the actual events, past observations of fault movement and other geological activities, Karachi is situated in a region where moderate earthquakes may occur of magnitude 5.0 to 6.0 equivalent to intensity between VII and VIII on Modified Mercallis Scale (M).

130. On the basis of earthquakes experienced from 1970 to 2005 (see Figure 4-11), four seismically active zones have been identified in and around Karachi. One seismic zone lies to the west of Karachi, shown as the Ornach Nal Fault merging into the regional Chaman Fault. The zone extends southwest into the Arabian sea and is aligned with the submarine Murray Ridge; to the north it extends towards Uthal-Bela areas. No large earthquake is known historically on the Ornach Nal system.

131. The second seismic zone follows the south-eastern margin of Kirthar Range from the north to the south, swinging ultimately towards the southwest. This zone includes Thano Bula Khan, Lakhra, Jhimpir, Jungshahi, Thatta and areas further south. The third zone passes across the eastern vicinity of Badin in the northeast-southwest direction along the eastern margin of the Indus Delta. The fourth seismic zone straddles the Pakistan-India border. Earthquakes of low to moderate magnitudes — 3.1M to 4.0M and 4.1M to 5.0M — dominate in these zones. (Sarwar and Alizai 2013) Quakes of higher magnitudes (above 5.0M) take place to the southeast in the Rann of Kutch, which is a known high-risk area. Records show that earthquakes of low to moderate magnitudes have occurred in the following zones – Murray Ridge- Sonmiani-Uthal, south-eastern Kirthar, and NESW Badin. Moderate magnitude earthquakes in Jangshahi, Thatta, Jhimpir and Thano Bula Khan Area produce low to moderate intensity shocks in Karachi, as experienced in 1985.

132. The seismic zoning for Karachi was revised after the 2005 earthquake. Probabilistic Seismic Hazard Assessment (PSHA) carried out for revision of seismic provisions of the Building Code of Pakistan shows that Karachi falls in Zone 2B. The Zone 2B has Peak Ground Acceleration (PGA) in the range of 0.16g to 0.24g for a return period of 475 years and is considered to be at ‘Moderate’ risk of a major earthquake event. It is recommended that project structures be designed for the requirements of Zone 2B. (MML 2018)

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Figure 4-10: Geological Map of Karachi and Surrounding Area

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133. Some earthquakes of more than 4M have taken place in the west of Karachi in the Arabian sea but the earthquakes were not felt in Karachi. The great Bhuj earthquake of 2001, measured 8.0 on the Richter scale and caused enormous damage in Ahmedabad and its surrounding areas but did not cause much damage in Karachi or Hyderabad; even though these two Pakistani cities are situated not far away from the epicentre at Ahmedabad. (Bilham et.al. 2007)

134. Bilham et.al. (2007) traces the historical record with the destruction of the major population centre of Bhaminabad around 980 A.D., and other major seismic events, to show the potential for a major earthquake in the Karachi area. Sarwar and Alizai (2013) support the hypothesis of increasing activity among faults and subduction zones near Karachi, and the potential for tsunamis to add to the earthquake threat.

Figure 4-11: Historical Reconstruction of Earthquakes in the Vicinity of Karachi and Southern Pakistan

From Bilham et.al. 2007

4.4 Hydrology, Water Quality and Sediment 135. Four drainage systems are said to encompass Karachi City, the Lyari, the Malir, the Budnai, and small streams referred to collectively as the coastal basin. These can be seen generally on the following map (Figure 4-12). The Malir River Basin and the Lyari River Basin contribute about 80% of the surface runoff from the City.

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136. Thus, the natural drainage system of Karachi city includes mainly the tributaries of the Malir and Lyari rivers. While these are perennial streams, instream flow is intermittent, and fresh water inflow depends on rainfall and runoff; both rivers also intercept discharges from sewer lines and outfalls and carry sewage to the sea from all parts of the City. The Budnai Basin and the Coastal Basin are minor basins. The Malir river flows from the east towards the south and centre, and the Lyari river stretches from north of the city to the southwest ending in the Arabian Sea. Karachi Harbour is another hydrographic landmark, and is a sheltered bay to the southwest of the city, protected from storms by Sandpit Beach, Manora Island and Oyster Rocks.

137. Drainage channels collect surface runoff through hundreds of small/large side channels and lined nullahs (drains) that serve as important components of the drainage network. These are generally dry built channels and streambeds that flow into the main rivers described above. Whenever a heavy rain takes place, the huge amount of runoff that course through these channels may cause the rivers to overflow their banks and spread over adjacent floodplains. In any event, the drainage network of the city is severely stressed due to increased runoff from paved surfaces, and encroachment on drainage channels.

138. The Lyari river is an ephemeral stream having a substantial catchment area starting from as far back as the Badra range of hills, some 100 km north of the city. Its catchment covers an area of 700 km2, out of which approximately 150 km2 is in the metropolitan area.

139. The river is the main contributor to an estimated amount of 200 MGD of sewage that enters the Arabian Sea. A large number of industries including leather tanning units, pharmaceuticals, petrochemicals, refineries, chemical, textile, paper and pulp, engineering works and thermal power stations, located along the river, regularly discharge their untreated industrial waste, including the waste flows from the SITE industrial estate in Orangi that flows via the Orangi Nala to the Lyari and thence to the ocean. (Nergis et.al. 2013) A range of contaminants affect the marine ecology along the coastal shelf.

140. Malir river is shorter with a smaller drainage area. It is ephemeral and is constituted from two major tributaries, the Mol and Khadeji, as well as some minor tributaries. Khadeji is a perennial stream that originates at Khadeji falls and gains flow as it travels across the Malir Basin. The Malir and Khadeji River basins include dry hill torrents and flow depends upon precipitation during rains. Once the Malir enters urban space, it receives large amounts of industrial effluent from the Korangi industrial area, and discharges into the sea. Data by the World Bank (2006) report values of 650 and 1,250 mg-COD/L for the Lyari and Malir rivers, respectively.

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Figure 4-12: Generalized Schematic of Drainage Basins in Karachi Metropolitan Area

from Akhtar and Dhanani 2012.

4.4.1 Ground Water Quality 141. Karachi obtains its drinking water from the Indus river, about 120km to the east and the Hub river in the west. Some limited groundwater is extracted for private use in the Karachi area, but groundwater resources in the Karachi area are limited. The aquifers close to the coastal belt are mostly saline and unusable for domestic purposes. Aquifers near the Hub river are well developed and serve as sources of water for agriculture and domestic use. The aquifers are estimated to lie at depths of 50-100 m.

4.4.2 Climate Vulnerability—Flooding 142. Despite dry conditions, flash flooding is common (see Figure 4-13). Pakistan’s regional flooding in 2010 left one-fifth of the country’s land area submerged. Flooding of Karachi on 1 Sept 2017 left 16 dead. These and other similar events seem not to be addressed in a statistical fashion in the literature, though causative factors are mentioned, including blocking of drainage channels through land encroachment by both wealthy and poor inhabitants. Drainage is enough of a critical factor to be overly compensated for in the design of streets for the more affluent parts of the city.

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Figure 4-13: Images of Flooding in Karachi

143. Although the climate of Karachi is arid and rainfall is low and highly variable, whenever torrential rain comes and heavy rainfall occurs, within a short duration surface runoff intensifies. This is because the rate of water percolation into soil is lower than the amount of rainwater falling on the surface. Heavy showers take place in the city either due to the effects of tropical storms usually in June, which rarely affect coastal areas but bring heavy showers for short periods and cause flooding. As the result of a tropical storm (6 June 2010), Karachi received 130 mm rain within a day, which caused huge surface runoff. The heavy monsoon rain mostly occurs in July and August and is the main cause of flooding in the city. However, its reoccurrence is estimated to occur at between about 3 to 5-year intervals. Flood affected areas of the city and areas susceptible to flooding include the old city areas such as Kharadar, Mithadar, Bunder Road, Ram-swami and Arambagh.

4.5 Biological Resources

4.5.1 Flora 144. The definitive source of information on Karachi’s flora is Jafri (1966). In his taxonomy, he included 72 families, 249 genera and 403 species, excluding some of the commonly cultivated and almost naturalized taxa. Work by Hussain et. al. (2010) and others have documented species loss. Their assessment is that, for more than 35 % of the species mentioned in Jafri’s Flora of Karachi can now be included in the Red Data book for threatened species, and categorized as extinct, endangered, vulnerable, rare, indeterminate, or threatened. (Hussain et.al. 2010)

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145. Hussain et.al. (2010) lists 16 native tree species that are threatened, 11 threatened species of shrub, and 29 species of understory shrub species, also considered threatened. Threatened woody climber species number 11, and herbaceous climbers that are threatened number seven (7); while herbaceous plants (herbs) considered threatened number 59. The authors state that among trees Tecomella undulata has become locally extinct, along with three other tree species that are endangered, and one (1) in the rare category (Mimosa hamata).

146. Some time back, Karachi University campus provided the best representation of the flora of Karachi. As of 2010, many have been eradicated, so that the main repositories remaining of Karachi’s native and indigenous plants are in the protected and enclosed areas of Malir cantonment, Shah Faisal cantonment, Masroor Airport area and Korangi, and PAF base area. (Hussain et.al. 2010)

147. The principal habitats are arid hills and low lying sandy areas found in and between the courses of the Lyari and Malir rivers that run through Karachi city. Hillside vegetation comprises mainly camelthorn (Prosopis spicigera), wild caper (Capparis decidua) and large succulents such as Euphorbia caudicifolia. Sandy areas are typically vegetated with a sparse cover of small trees such as Acacia senegal, Zizyphus nummularia and Prosopis cineraria (mesquite), and shrubs such as Leptadenia pyrotechnica, Colotropis procera, Rhazya stricta, Inula grantioides, Zygophyllum, simplex and Sueda fruticosa. Species on calcareous hills include Vernonia cinerascens, Commiphora wightii, Grewia tenax and Euphorbia caducifolia. Shallow slopes with varied soils at low altitudes are populated by (trees) Zizyphus nummularia, Salvadora oleoides, and Capparis deciduas. Shrubs such as Grewia tenax, Seddera latifolia, and Rhazya stricta are the most commonly found species, together with the grasses Ochthochloa compressa, Cymbopogon jawarancuss and Aristida funiculata.

148. Prosopis cineraria (mesquite), Indigofera oblongifolia, a perennial shrub found in a range of habitats including grassland, bushland and sandy soils, and Euphorbia caducifolia, a succulent that grows profusely on sandy soils, form the most common combination of native vegetation of Karachi City.

149. However, a wide variety of trees have been introduced over the years and the Karachi University Botanical Garden, opened to the public in 2008, exemplifies many of these species, with over 2,000 exotic and indigenous plant species represented. While the Garden is located on 80 ha of land at the campus near the alignment, KUBG is set back sufficiently far so as not to be affected by the project.

150. Destruction of native plants occurs through clearing of brush and ‘cleanliness drives’, where those instigating these moves are unaware of the plants being eradicated. Habitats have shrunk and species numbers been reduced placing many on the threatened species list.

4.5.2 Fauna Avian Fauna

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151. Shaukat and Raza (2016) conducted long-term observations of avian species at Karachi University and Dow University campuses (1996-2015, K.U. and 2008-2015 D.U.H.S.) Bird species identified over the period are listed in Table 4-5.

Table 4-5: Birds of Karachi and Dow University Campuses (1996—2015)

Scientific Name Common Name

Streptopelia tranquebarica Little Brown Dove Streptopelia senegalensis Laughing Dove Columba livia Blue Rock Pigeon Corvus splendens Sindh House Crow Dendrocitta vagabunda Rufous Treepie Passer domesticus House Sparrow Passer pyrrhonotus Sind Sparrow Alauda arvensis Eurasian Skylark Hirundo rustica Barn Swallow Motacilla alba White Wagtail Motacilla flava Western Yellow Wagtail Lanius vittatus Bay-Backed Shrike Lanius meridionalis Southern Grey Shrike Acridotheres ginginianus Bank Myna Acridotheres tristis Common Myna Sturnus roseus Rosy Starling Pycnonotus cafer Red Vented Bulbul Pycnonotus leucogenys White Cheeked Bulbul Cinnyris asiaticus Purple Sunbird Phylloscopus collybita Chiffchaff Estrilda amandava Red Avadavat Lonchura punctulate Scaly-Breasted Munia Amandava amandava Red Avadavat Dicrurus macrocercus Black Drongo Phoenicurus ochruros Black Redstart Copsychus fulicatus Indian Robin Turdoides striata Jungle Babbler Coturnix coturnix White Wagtail Francolinus pondicerianus Grey Partridge Francolinus francolinus Black Partridge Upupa epops Hoopoe Merops orientotalis Green Bee-Eater Coracias benghalensis Indian Roller Halcyon smyrenensis White-Throated Kingfisher Alcedo atthis Common Kingfisher Milvus migrans Black Kite Circaetus gallicus Short-Toed Snake-Eagle Circus aeruginosus Western Marsh-Harrier Accipiter badius Shikra Egretta garzetta Little Egret Bubulcus ibis Cattle Egret Ardeola grayii Indian Pond Heron

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Scientific Name Common Name

Vanellus indicus Red-Wattled Lapwing Psittacula krameria Rose-Ringed Parakeet Eudynamys scolopacea Asian Koel Tyto alba Barn Owl Athene brama Spotted Owlet Pterocles exustus Sandgrouse Dipnopium benghalensis Golenbacked Woodpecker (Shaukat and Raza 2016)

Mammals and Reptiles

152. EMC (2015) listed some 19 mammals, of which six are domesticated bovines, and six species of reptile, known to have been present in Karachi district as shown in Table 4-6 below. Only a few would be found in the typical urban space of the built-up City, and even less along the median where construction takes place. Most information in the literature related to fauna currently inhabiting areas near Karachi in Sindh province focuses on the coastal zone including its mangrove embayment fringe and areas around Buleyji that are rich in marine biodiversity.

Table 4-6: Mammals and Reptiles Historically Present in the Area of Karachi District

Common Scientific Name Status

Mammals Indian Hedgehog Paraechinus micropus Very rare Asiatic Jackal Canis aureus Rare Chinkara Gazalla bennetti Very rare Indian Fox Vulpes bengalensis Rare Small Indian Mongoose Herpes javanicus Common Indian Pangolin Manis crassicaudata Rare Indian Desert Cat Felis silvertris ornate Rare Indian crested porcupine Hystrix indica Rare Ratel or Honey badger Mellivora capensis Vulnerable Hog Deer Axis porcinus Very rare Cairo Spiny Mouse Acomys cahirinus Rare Grey spiny mouse or Rock mouse Mus saxicola Rare Desert cat Felis libyca ornate Rare Hares, rabbits Common Domestic Bovines: Domestic Sheep Ovis aries Domestic Cattle Bos Taurus Domestic Goat Capra hircus Indian Water Buffalo Bubalus arnee Arabian Camel Camelus dromedaries Domestic Horse Equus caballus Reptiles Spiny tailed lizard Uromastyx hardiwickii Common Krait Bangarus caerulus Vulnerable

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Common Scientific Name Status

Indian Python Python molurus Very rare/ Endangered Mugger Crocodylus palustri Vulnerable Gharial Gavialis gangeticus Endangered Marsh crocodile Crocodulus palustris Endangered

4.6 Socioeconomic Resources 153. There are many reports and documents available describing the socioeconomic setting of Karachi. The USAID/IMMAP Pakistan Development Perspective report (USAID/IMMAP, undated) provides a comprehensive overview with data and graphics, but without any particular theme. The work by Anwar et.al. (2013) is aimed at characterizing gender themes in the development of the city, and provides much detailed and quantitative data. ADB’s Megacity Final Report (ADB 2005) also contains extensive textual and tabular data related to development themes. Infrastructure conditions along roadways are described in the ITDP final report related to Karachi NMT & Parking Improvement Plan & Design (ITDP 20115a). A number of transport planning documents, such as the KTIP reports and others, also contain excellent through somewhat dated summaries of Karachi’s urban environment. Results obtained from primary socioeconomic survey and the above mentioned reports have been used to describe the socioeconomic conditions of Karachi in overview, and then, to the extent possible, for the areas nearby the Red Line alignment.

154. The project is located in Karachi the capital of Sindh province and Pakistan’s biggest commercial hub. The city accounts for more than 90 per cent of Pakistan’s foreign trade and contributes to more than 30 percent of Pakistan’s industrial production. The city is made up of 20 contiguous towns. The pattern of incomes shows that 9.5% are extremely poor and another 14 per cent are transitorily poor. It may be said that 50 percent of the population are below the poverty line. There is a continuous growth in the slum areas.

4.6.1 Population 155. Provisional results of the 2017 census show urban Karachi with a population of 14,910,352 capita, an increase of 58% over the 1998 urban population 9,448,808. Karachi’s population increase was outstripped over the same period by Lahore (116%), Peshawar (100.4%) and Islamabad (91.8%). Karachi grew at an average annual rate of 2.43%.

156. Karachi’s urban population is divided into six districts, two of which also contain rural populations (see

157.

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158. Table 4-7). Cantonment areas are not counted and are generally considered not to be part of the city.

Table 4-7: District-wise 2017 Population for Karachi Division

POPULATION - 2017 1998- 2017 Sex Population average Administrative units Households Male Female Tsxual Total ratio 1998 annual 2017 growth rate KARACHI DIVISION 2,770,074 8,439,659 7,610,365 1,497 16,051,521 9,856,318 110.9 2.6 RURAL 193,871 606,588 534,499 82 1,141,169 407,510 113.49 5.56 URBAN 2,576,203 7,833,071 7,075,866 1,415 14,910,352 9,448,808 110.7 2.43

Districts KARACHI CENTRAL 538,983 1,543,950 1,427,349 327 2,971,626 2,277,931 108.17 1.41 KARACHI EAST 509,239 1,528,019 1,379,225 223 2,907,467 1,472,896 110.79 3.64 KARACHI SOUTH 327,518 943,546 848,010 195 1,791,751 1,478,047 111.27 1.02 KARACHI WEST 634,459 2,065,847 1,848,553 357 3,914,757 2,089,509 111.75 3.35 RURAL 44,051 149,220 134,014 13 283,247 73,568 111.35 7.34 URBAN 590,408 1,916,627 1,714,539 344 3,631,510 2,015,941 111.79 3.14 KORANGI 421,618 1,284,015 1,172,737 267 2,457,019 1,561,742 109.49 2.41 MALIR 338,257 1,074,282 934,491 128 2,008,901 976,193 114.96 3.86 RURAL 149,820 457,368 400,485 69 857,922 333,942 114.2 5.08 URBAN 188,437 616,914 534,006 59 1,150,979 642,251 115.53 3.11

Data from the USAID/IMMAP report shows population density in some areas reaching as high as 60,000 cap/sq km and the largest demographic between 5 – 9 yrs. (Figure 4-15)

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Figure 4-14: Administrative map of Karachi

Figure 4-15: Population Distribution by Area, Age and Sex.

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From USAID/IMMAP undated.

4.6.2 Land Use City-wide Aspects

159. From a city-wide perspective, two aspects of land use predominate. One is the presence of the katchi abadi, or squatter developments that dominate in some areas of the City. According to ADB (2005), rapid and uncontrolled growth of the city has resulted in unregulated development and inappropriate land-use changes, with an estimated 50% of the population living in unplanned, poorly serviced and heavily polluted informal settlements. Karachi has been noted for an extreme level of violence over the last ten years, with one of the highest murder rates of any city in the world. The general discourse holds that violence originates in these closely packed informal settlements. While the abadis may be centers for crime and violence, they also constitute the living space of poor and vulnerable people. According to UN research, most of the migrants who end up living in such vulnerable circumstances tend to be women (Anwar et.al. 2013). The growth of ‘Abadis' in Karachi has been extensive, increasing from 212 distinct areas in 1958 to more than 500, as identified by Arif and Hamid (2008).

160. As described in Anwar et.al. (2013), a series of decrees have been passed to regularize and formalize the abadis, which have been more or less successful in achieving some permanence for their inhabitants. The Sindh Katchi Abadis Act (1987) set out criteria for formalizing unplanned settlements, as did the Sindh Gothabad Act (1987) and others. These decrees for land regularization also set out exceptions such as the minimum number of households (40) that must be present in order to establish eligibility for regularization. Without regularization, those who reside in an unplanned settlement may not receive financial or livelihood support.

161. Unplanned settlements define the city’s spatial landscape and remain critical in housing over 60% of its population. Unplanned settlements have grown at twice the rate of planned settlements, fuelling Karachi’s urban expansion. (Anwar et.al. 2013)

162. Another aspect of land use is characterized by guarded communities for the wealthy. These developments are situated along new infrastructure corridors such as the Super Highway where the city’s rapidly expanding middle and upper-middle class population resides. (Anwar et.al. 2013) The upper classes tend to reside in securitized and well-served suburban housing estates, some located in close proximity to the city centre, such as the Defense Housing Authority (DHA) area near Clifton Cantonment. High concentrations of wealth can be found in these estates where new areas of commerce and services have emerged.

163. There are of course many other aspects of city-wide land use, such as the old city areas that are mainly built up with five to six storey buildings surrounding MA Jinnah Road. The Central Business District (CBD) is located here and in the direction of the

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Port. Buildings are older and support mixed use with commercial, shipping offices, and residential space.

164. The Central Business District (CBD) is formed by Saddar Town and neighboring Keamari and Jamshed Towns, and is an area of concentrated commercial and business activities. The main municipal administration buildings are located in the CBD, Keamari and Saddar Town. The next most important area for upscale commercial development is Clifton Cantonment. Otherwise, commercial land use is primarily observed along the main roads. Industrial land use is primarily in the hinterland of the Port of Karachi and Port of Bin Qasim, SITE Town, Korangi Town and Landhi Town.

4.6.3 Physical Infrastructure 165. Karachi Water & Sewerage Board (KWSB) is the sole public water service provider, supplying water for around 90% of the population through pipelines or by tank truck. The remaining 10% of the population depends on groundwater. KWSB pumps water from the Dumlottee Well Field, located on the banks of Malir River about 30 km to the northeast of the city, which is mostly depleted. The Indus River now serves as the main source of water for Karachi. About 550 MGD is taken at the Kotri Barrage through the Kalri Baghar feeder to temporary storage at Kinjhar Lake. Another major source of water for Karachi is Hub Dam. About 100 MGD of water is supplied to Karachi from the dam. The Hub Dam forms a multi-purpose reservoir along the Hub River approximately 50 km to the north-west of Karachi.

166. Telecommunications are provided by Pakistan Telecommunications Ltd. (PTCL) and other private companies. Pakistan Telecommunication Authority (PTA) regulates the establishment, operation and maintenance of telecommunication systems and the provision of telecommunication services across the Country.

Public Transportation Facilities

167. Railways use more than 100 km of track length for commuter services within the Karachi metropolitan area. Some important stations connecting this system are located near the KBRT project. These stops are on the Karachi Circular Railway (KCR).

168. The KCR began its operation in 1964 using trains pulled by diesel locomotives to make some 12 round trips a day around the City. The system deteriorated and transport volume declined annually, adversely affecting profitability. The system ceased to operate in December 1999. The Karachi Transportation Improvement Project (KTIP) identified the KCR as an important element in Karachi’s future public transport system. KCR operations were resumed on one section of the main line, and a study was done to evaluate repairing the existing 30 km of the circular section and 14 km on the main line, with a provision to extend services to Karachi International Airport. Full-scale restoration has not been implemented due to lack of funds, and rejuvenation of the KCR system is still in proposal stage.

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169. Air travel is dominated by Pakistan International Airlines, a state-owned airline headquartered at Jinnah International Airport. PIA operates scheduled services to 23 domestic destinations and 30 international destinations in 27 countries across Asia, Europe and North America. Its main bases are Karachi, Lahore and Islamabad/Rawalpindi, with secondary bases at Peshawar, Faisalabad, Quetta, Sialkot and Multan. The airport location is relatively near the eastern end of the KBRT Red Line corridor.

Employment and Livelihoods

170. Karachi’s burgeoning population is in part attributed to good employment opportunities in trade and industry. Karachi is said to have an “overtly industrial character” in contrast to its “agricultural hinterland”, a development trend likely to further the polarization between urban Karachi and rural areas, and inevitably widen the gap between the city and its hinterland. (ADB 2005) Other sources also point out the extreme difference in income among different social groups and also between provinces.

171. Unemployment remained around 5 % post 1993-1999, but increased sharply to over 8 % in 2002. Following that, the rate fell during 2003-7 and reached a low point of around 5 % in 2008-9. It rose again to 5.6 % in 2009. Overall, there has been a decline in unemployment since 2003-4.

172. Economic growth contributes to real wage increase, employment and poverty alleviation. Forces of supply and demand in the labor market jointly determine wage rates and numbers of people employed. Labor demand is linked to remittances from overseas Pakistanis as well as to the structure of the economy, as represented by land ownership and control over financial assets.

173. Also, there is a demographic transition taking place in Pakistan, and youth employment opportunities take centre stage, since new arrivals to the work force must be absorbed productively. While the labor force is growing every year, opportunities for employment are declining. Even so, youth unemployment in Pakistan is below the global average.

174. Trends in age-specific unemployment rates differ considerably for males and females in the labor force. Male unemployment has increased in the last two decades, whereas female unemployment has decreased. The gap between the projected female working age population and the projected labor force is likely to increase sharply over time. While a reduction in this gap is desirable, and unemployment among females has historically been higher than among males, the gender gap has narrowed considerably over time.

175. Many unemployed males are students enrolled in colleges, universities, and professional and technical education institutes. The rates of employment in electricity, gas and water, construction, manufacturing, trade (including restaurants and hotels) in urban Sindh are much higher than in the nation. Urban Sindh’s participation in finance

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is almost double the national rate. According to one estimate, 90 % are migrants from different backgrounds and the population is estimated to be growing at about 5 % per year, mainly as a result of internal rural-urban migration, including an estimated 50,000 migrant workers coming to the city every month from different parts of Pakistan. (USAID/IMMAP undated)

176. Employment is in a variety of sectors. Several industrial zones including Landhi, Korangi, FB Area, North Karachi, Dhabeji and Port Qasim were built during the 1990s. Korangi Creek Industrial Park (KCIP) commenced operations from 2013, contributing around Rs 40 billion annually to the national GDP and providing approximately 30,000 direct and 180,000 indirect jobs.

177. Karachi has a large industrial base located in these industrial zones on the fringes of the main city. Karachi has over 15,000 industries in the organized sector while there are more than 50,000 units in the informal sector that are not under the purview of the Labor Department. About 70 % of total industry of Pakistan is located in Karachi and in the Bin Qasim Industrial Area, mostly in the Sindh Industrial Trading Estate (SITE), Landhi Industrial Trading Estate (LITE), Korangi Industrial Area, and West Wharf Industrial Area. In addition, Karachi has a vibrant cottage industry and there is a rapidly flourishing Free Zone with an annual growth rate of nearly 6.5%. Karachi has an Expo Centre, which hosts many regional and international exhibitions. Karachi is home to major industrial associations.

178. Karachi is a major seaport and contains the country’s two major ports, the Port of Karachi and Port Mohammad Bin Qasim. The city also is an important hub for the fishery industry in Pakistan, and major fishing ports include Karachi and Korangi Fishing Ports. About 300,000 people are connected with the fishing industry; subsidiary industries provide employment for another 400,000 people. (USAID/IMMAP undated)

Public Health

179. Public Health System facilities in Karachi include:

▪ Outreach and community-based activities that focus on immunization, malaria control, maternal and child health, family planning and the Lady Health Workers program; ▪ Primary care facilities that focus on outpatient care; ▪ Taluka and district headquarters hospitals for basic inpatient and outpatient care; ▪ Tertiary care hospitals; and ▪ Teaching hospitals and centres of excellence

Table 4-8: Medical Facilities in Karachi

Sr. No Karachi Division Total number of Hospital,

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dispensaries & Laboratories

1 Karachi Central 88

2 Karachi East 88

3 Karachi Korangi 90

4 Karachi Malir 111

5 Karachi South 111

6 Karachi West 150

7 Along the alignment 04

180. Vaccination rates are good indicator of attention to public health. Rates given for Karachi (2011) for children 12-23 months that have been immunized (by type of antigen (%)) are as follows:

BCG DPT1 DPT2 DPT3 POLIO1 POLIO2 POLIO3 MEASLES (TB) 97 97 96 94 92 91 88 92 181. According to IMMAP, 74.5 % of children under 12 are fully Immunized (2011-2012), and 91 % of pregnant women have received tetanus toxoid Injection. Mortality statistics are given in Table 4-9.

Table 4-9: Mortality Statistics of Karachi and Nationwide

Sr. Type of Mortality Number of Lives National Average*

1 Infant Mortality 81/1000 64/1000 2 Maternal Mortality 314/100,000 178/100,000 3 Under 5 Mortality 101/1000 79/1000

* The World Bank data at https://data.worldbank.org/indicator/SH.STA.MMRT.

182. Karachi mortality rates are higher than the national average on all three indicators.

HIV/AIDs

183. HIV has shown to be a serious and tenacious problem for Pakistan. However, as reporting in NACP/UNAIDs 2015, conservative religious values and cultural normative systems have contributed to keeping the epidemic from becoming generalized, remaining concentrated in key populations, persons who inject drugs (PWID), men who have sex with men (MSM), transgender persons (TG), and female sex workers (FSW). In general, Pakistan has done poorly in controlling HIV and AIDs, and following a 2013 mid-term review of its program in meeting UN general assembly goals, Pakistan was found not to be on target for over 50 per cent of their targets. A report in the national news gives a gloomy performance of the Sindh Aids Control

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Programme, wherein “only five treatment centres are working in the entire Sindh province, with Karachi leading the patient burden. Non-availability of medicines is another crucial hindrance in tackling the disease.”(Geo TV 2016) According to one report (Memon 2012), Karachi’s HIV prevalence in risk groups in 2011 was 5.9% among MSW (male sex workers), 12.3% for HSW (Hijra sex workers), 1.9% for FSW (female sex workers) and 42.2% among IDUs (intravenous drug users). From 2003 to 2007, HIV prevalence among IDUs in Karachi rose from 0.3% to 23% in 2004 and has reached 42% in 2011. (Samo et.al. 2013).

4.7 Physical Cultural Resources

4.7.1 Religious, Historical, Cultural and Archaeological Sites 184. A number of mosques can be found along University Avenue, and the Mausoleum for also known as the Jinnah Mausoleum or ,( مزار قائد :M.A. Jinnah. Mazar-e-Quaid (Urdu the National Mausoleum, is the final resting place of Quaid-e-Azam ("Great Leader") Muhammad Ali Jinnah, the founder of Pakistan. Designed in a 1960s modernist style, the mausoleum also contains the tomb of his sister, Māder-e Millat. The mausoleum is set back some 130 m from the edge of the right-of-way. Mosques within the area of the alignment include the Al-Raheem Mosque, Jama-Masjid-Taqvee, M-Ibn-Tamiayah Mosque, Masjid Bait-ul-Mukaram, and other lesser known mosques.

185. As per antiquities act 1975 and amended 1992 ‘notwithstanding anything contained in any other law for the time being in force, no development plan or scheme or new construction on, or within a distance of two hundred feet of a protected immovable antiquity shall be undertaken or executed accept with the approval of the Director General.

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5 Analysis of Alternatives

5.1 Overview 186. The main purpose of this section is to compare feasible alternatives to the proposed Staging facility development, including the ‘without-project’ situation. The potential environmental impacts of each alternative and feasibility of mitigation of these impacts along with their suitability under local conditions are also compared.

5.2 ‘No Project’ Option 187. The proposed Staging facility is to be developed as part of the overall Karachi BRT system being developed in order to provide ease of transfer of passengers from one line to the other and include parking lots for the buses, maintenance of buses, offices, ticketing booth, waiting areas and turnaround facility for the routes that terminate at Numaish.

188. In addition, the proposed staging facility will help in optimizing and adjusting fleet operations as the demand varies along the day. Additionally, it shall provide a turnaround facility for routes that terminate at Numaish, and will thus reduce the dead mileage for operations without passengers.

189. Considering all these aspects, the ‘No project’ scenario is not a viable option since the BRT system will not be able to operate efficiently and economically without a Staging facility while the commuters will also face great hardship and inconvenience in their daily commute if this facility is not developed as part of the BRT system.

5.3 Rationale for selected Staging Facility Location

Alternative Location Options 190. As all BRT corridors converge at Numaish station, this location holds importance in permitting customer interchange between routes. This area also holds importance as a BRT vehicle staging facility for the following reasons:

▪ A staging facility at Numaish shall ensure interoperability between all corridors by ensuring physical and operational integration.

▪ A large number of BRT vehicles and people will pass through Numaish station; this gives Numaish an additional significance for potential Transit-Oriented Development (ToD).

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191. Due to the factors mentioned above, the KGA ground site was selected to be the most suitable along with having the required land available to meet the Staging facility requirements.

5.4 Assessment of alternatives to prevent demolition of associated facilities 192. As per the preliminary designs, the existing structures on the KGA ground will need to be demolished during construction, the concept design proposes to reconstruct the ground and its associated facilities on top of the Mezzanine floor at ground level.

193. The associated facilities possess a rich historical and cultural value since they are over 100 years old, although they are not listed as national and cultural heritage by the Government of Sindh. However, during the detailed design phase, all efforts need to be made to prevent demolition of the associated facilities of the KGA ground as far as possible by considering all alternatives (technical and location related).

194. If any suitable alternatives are developed during the detailed design stage that prevent demolition of the associated facilities, these shall be included as part of the update of this chapter of the IEE report.

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6 Potential Environmental Impacts and Mitigation Measures

195. This chapter presents the potential environmental impacts related to design, construction and operation phases of the proposed Staging facility. Following is a description of the environmental impacts and the proposed mitigation measures to minimize the negative impacts, if any.

6.1 Design/Pre-Construction Phase

Avoidance of demolition of Associated Facilities Impacts

196. As per the preliminary design, the existing associated facilities located next to the KGA ground, consisting of the main pavilion building along with some smaller structures (details of these structures provided in Table 6.1 below) will need to be completely demolished and then reconstructed once the staging facility has been developed. These associated facilities, although not listed as cultural and historical heritage, possess a rich historical value since they are over 100 years old and their demolition would pose a great cultural and historic loss. As per ADB SPS 2009, cultural interest may be at the local, provincial, national or international level’. Furthermore, it is not necessary that only gazetted physical cultural resources need to be protected – their significance can also be established by experts.

Table 6.1: Associated Facilities next to KGA ground to be impacted

S.No. Structures Type Size Sq.ft

1 Pavilion Concrete 3,204

2 Office Block Concrete 282

3 Canteen Concrete 178

4 Gymnasium Concrete 1977

5 Tennis Court Open Hard 351 Surface

6 Store Room Concrete 132

Mitigation measures

197. During the detailed design phase, all potential alternatives, both in terms of technology as well as location specific aspects need to be considered and all efforts need to be made to avoid demolition of the associated facilities as far as

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possible. As part of the review process, the relevant key stakeholders must also be engaged to find a suitable alternative strategy to prevent demolition of the existing associated facilities.

Relocation of Utilities Impacts

198. The project will require demolishing and relocating some of the structures at the KGA ground site such as the pavilion and other existing buildings on the premises, water supply pipes, drainage structures etc. Temporary suspension of services (planned or accidental) can affect the economy, industries, businesses and residents’ daily lives.

Mitigation measures

199. TMTD, as the implementing agency, will be responsible for ensuring all permits and clearances are obtained prior to commencement of work at the project site. In addition, TMTD will ensure that detailed contingency plans are prepared prior to commencement of construction activities at the project site to mitigate any potential impacts resulting from outage of utilities.

200. Contractors will assess construction locations in advance for potential disruption to services and identify risks prior to starting construction. Any damage or hindrance/disadvantage to local businesses caused by the premature removal or insufficient replacement of public utilities is subject to full compensation, at the full liability of the contractor who caused the problem.

201. If temporary disruption is unavoidable, the contractor will, in collaboration with relevant local authorities such as power company, water supply company and communication company, develop a plan to minimize the disruption and communicate the dates and duration in advance to the affected persons.

202. Communities shall be informed in advance regarding storage of water when their utilities are about to be relocated. Also, water pipes located/crossing through the project site may be moved slightly away or provision of service duct may be considered.

203. Construction billboards, which include construction contents, schedule, responsible person and complaint phone number, will be erected at each construction site.

204. In case any material(s) is encountered that contains asbestos, it must be ensured that international best practices/established protocols related to handling of asbestos based materials are followed since no national regulations on handling asbestos materials exist.

Identification of Locations for Labor Camps and ancillary facilities Impacts

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205. The duration of the construction activity for the proposed project is expected to be 12 months and a considerable amount of work force will be engaged. As a result, worker camps will need to be developed and ancillary facilities will need to be provided such as electricity, washrooms for labor with suitable effluent and sewage disposal facilities as well as water for their everyday use for drinking and bathing etc.

Mitigation measures

206. In order to prevent a nuisance, specific locations shall be designated near the proposed project site for development of the labor camp(s). All necessary facilities and amenities shall be provided in these camps such as electricity, sufficient supply of water, solid and liquid effluent waste disposal facilities etc.

207. The use of proper planning while identifying locations for the labor camps will ensure there is minimal disturbance to key receptors in the project area and the traffic is not disrupted by labor camps being set up next to the construction site.

Development of Traffic Management Plan Impacts

208. The construction related traffic for the development of the proposed Staging facility will use the existing traffic routes being presently used by the BRT Green line. Furthermore, due to the ongoing works for the BRT Green line, a large area has already been cordoned off with no traffic permitted.

209. However, there is a possibility that new traffic routes for the construction related traffic might need to be developed from an economic efficiency standpoint and in order to save time.

Mitigation measures

210. The traffic management plan shall be prepared by the Contractor for implementation prior to commencement of the project construction activity. The main objectives of the plan shall be to maximize the safety of the workforce and the travelling public while keeping the traffic flowing as freely as possible.

211. The detailed traffic plan shall ensure that traffic is diverted to alternate routes wherever possible and will minimize traffic jams and bottlenecks near the project site and also minimize the chances of traffic related accidents.

212. The plan will include consideration of the following:

▪ Lane availability and minimization of traffic flows past the works site

▪ Establishment of acceptable working hours and constraints

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▪ Agreement on time scale for works and establishment of traffic flow/delay requirements

▪ Acceptability of diversion routes where necessary

▪ Need for road closures and necessary orders

▪ Co-ordination with other planned road and street works

▪ Establishment of incident management system for duration of the works

The plan shall be approved by TMTD and necessary resources will be provided to implement the plan with the involvement of the traffic police. An indicative traffic management plan is provided as Annexure K.

6.2 Construction Phase 213. The screening of potential impacts during the Construction phase are provided in Table 6.2 below.

Table 6.2: Screening of Possible Impacts during Construction Phase

Potential Issue from Potential of S/No. Environmental Aspect Mitigation Measures Environmental Impact Aspect

1 Traffic Management Vehicle Major negative Traffic management plan to movement and impact be prepared beforehand by possibility of Contractor and implemented traffic during construction work congestion on the roads leading to the project site

2 Air Quality Dust emissions Major negative Regular water sprinkling on from site impact the exposed surfaces to preparation, reduce dust emissions and excavation, Dust emissions proper maintenance of all material expected at equipment at regular handling & other work site and at intervals to minimize impact construction the residential of exhaust emissions activities at site. settlements around the site. However, minor and short-term impact expected

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which will be temporary in nature, particularly since the wind direction in Karachi will divert any dust away from majority of the residential settlements.

3 Noise Levels Noise generated Major negative Proper noise management from impact plan to be prepared, construction indicating frequency of noise activities, Noise levels monitoring and thresholds to operation of expected to be used. construction vary during machinery, activity based As part of this plan, equipment and upon the nature necessary control equipment their movement. of work being and techniques to be applied conducted. High to control noise levels and noise levels and limit their nuisance effects. disturbance expected for Considering proximity of residential residential settlements to the settlements KGA ground, no works located adjacent should be conducted after to KGA ground. evening hours (1800 hours Impact onwards). expected to be short term in nature.

4 Excavated Material Significant Major negative A detailed Plan for (Earth Works) Disposal volumes of impact management and disposal of clay/mud shall Excavated Material must be be excavated developed. This Plan must from the KGA identify suitable location(s) ground. Unless prior to commencement of a suitable excavation works and require disposal location the engaging of experienced and efficient and credible third parties for transport transport and disposal of this mechanism for material in the most efficient

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disposal of this and effective manner without material is any logistical or management arranged, it delays. could result in major health and aesthetic issues.

5 Community Health and Potential Major negative ▪ Buffer strips or other Safety accidents and impact methods of physical injuries to separation around the communities in project sites project area ▪ Siting and safety could take place engineering criteria shall during be incorporated to prevent construction failures works if required precautions are ▪ Inventories of hazardous not taken. materials shall be reduced ▪ Safety trainings to communities ▪ Vehicle speed limit controls 6 Worker Health and Injuries to Major negative ▪ Contractor must prepare Safety workers could impact health and safety protocols talk place if and submit to ADB for necessary approval. training and ▪ Random audits (possible proper safety unannounced) must be protocols and organized by PMU to equipment such check and issue penalties as PPEs are not if non-compliances are used by workers detected. ▪ Trainings to Labor staff ▪ Provision of PPEs ▪ Monitoring of labor staff by Contractor management 7 Camp Effluent Untreated Minor negative ▪ Closed sewage treatment disposal of impact system will treat the effluent being effluent produced from

worker camps would create a major health issue for all

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residential settlements in project area

8 Soil Erosion and Construction Minor negative ▪ Sediment ponds must be Sedimentation works must impact developed wherever felt protect soil from necessary erosion and ▪ Coverage of unpaved sedimentation areas must be conducted 9 Soil Contamination No Minor negative ▪ Use of spill prevention contamination of impact trays soil due to oils, ▪ Regular inspections hazardous chemicals etc. ▪ Storage of chemicals etc. must be in covered bounded areas permitted.

10 Drainage & Storm water The storm water Minor negative ▪ Compacting of all unpaved Run off run-off from the impact exposed surfaces construction site ▪ Natural drainage must not could carry oil be hampered or blocked and grease if the soil is contaminated or the potentially contaminated areas.

11 Hazardous and Non- Both hazardous Minor negative ▪ Waste management plan hazardous waste and non- impact to be developed management hazardous ▪ Periodic on-site audits of waste must be waste management managed in the most ▪ Records of all waste environmentally generated sustainable manner.

12 Historical/Archaeological Damage to Minor negative Any archaeological finds Sites relics could take impact during works must require place if ‘Chance stopped of works and use of Find’ procedures ‘Chance Find’ procedures. not adopted.

13 Vegetation and Wildlife Trapping of Minor negative ▪ Prohibit willful trapping and animals and/or killing of animals

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Loss damage to impact ▪ Prevent burning of vegetation could vegetation for fuel take place

14 Employment Conflicts Staff to be Minor negative ▪ Transparent hiring policy engaged for the impact ▪ Balanced process of hiring project may engage in conflicts.

15 Communicable diseases Lack of Minor negative Communicable diseases sanitation impact prevention program will be arrangements prepared and hygiene could lead to spread of diseases.

16 Loss of access around It is currently Minor negative The Contractor shall ensure project site not foreseen impact that: that there will ▪ The existing western face, be any access presently being used for the restriction Green Line BRT works will since the only be used for all western front of construction works. No the proposed other access way will be KGA ground is used, thus ensuring the already closed residential settlements off due to the located on the other faces KBRT Green – of the project site are not Line works and disturbed. this access way will be used for all project works. The residential settlements on the remaining faces of the site will not be disturbed.

Traffic Management Impacts

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214. The efficient management of traffic once the construction activity commences will be critical in order to minimize the risk of possible road accidents and construction related hazards.

Mitigation measures

215. Traffic signs and warning instructions shall be displayed at the sites and along the proposed routes being used by the construction traffic for the information of other road traffic as well.

216. Public awareness campaigns through radio and newspaper advertisements shall be conducted to educate the public and sensitize them to cooperate with the construction staff and project focal staff in order to try and avoid the areas under construction as far as possible, particularly during the peak times when traffic volumes and pedestrian movement is the highest.

217. The potential risks of accidents to pedestrians and commuters while in the immediate vicinity of construction sites shall be conveyed to them in order to educate them and gain their cooperation and minimize the risk of accidents.

218. Employ flag persons to control traffic at the work sites for safety reasons when construction equipment is entering or leaving the work area.

219. Provide sufficient lighting at night within and in the vicinity of construction sites.

220. Regularly monitor traffic conditions along access roads to ensure that project vehicles are not causing congestion.

221. Define and observe schedules for different types of construction traffic trips (e.g., transport of pre-cast sections, haulage of spoils, delivery of construction materials, etc.).

222. As much as possible, schedule delivery of construction materials and equipment as well as transport of spoils during non-peak hours.

223. Avoid movements of noisy vehicles during night time in vicinity of the residential settlements.

224. Implement suitable safety measures to minimize risk of adverse interactions between construction works and traffic flows through provision of temporary signals or flag controls, adequate lighting, fencing, signage and road diversions.

225. Ensure relocation of any affected public transport infrastructure (but stops, shelters etc.) prior to commencement of works.

226. Provide advance notification to the community regarding changes to public transport facilities or routes.

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227. Comply with traffic regulations and avoid, where possible, roads with the highest traffic volumes, high density of sensitive receivers or capacity constraints are not used as access to and from the construction areas and spoil disposal sites.

228. Install temporary accesses to properties affected by disruption to their permanent accesses.

229. Reinstate good quality permanent accesses following completion of construction.

Air Quality Impacts

230. Additional sources of dust from construction of the proposed Staging facility and from general handling of materials are likely to create significant additional impacts, particularly where the works are close to the residential settlements, located around the project site.

231. 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, combustion of liquid fuel in equipment and vehicles, land excavation, and concrete mixing and batching.

232. Vehicles carrying construction material are expected to result in increased SPM levels near the haul roads. This can be of potential importance if the vehicles pass through the areas with a high concentration of sensitive receptors such as the residential settlements located around the project site.

233. At the construction yard, the dust levels are also expected to increase due to unloading of construction materials. It shall be ensured that most of the excavated material will be used within the project, with minimal cut and fill material to come from outside the site.

234. 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. Due to the uncertainty in values of these parameters, it is not possible to

calculate the quantity from a ‘bottom-up’ approach, that is, from adding PM10 emissions from every activity on the construction site separately. Typical and worst- 2 case PM10 emissions from construction sites have been estimated as 0.27 megagram per hectare per month of activity (Mg/ha-month) and 1.04 Mg/ha- month, respectively.

235. As can be seen in Figure 6.1 below, the predominant wind direction in Karachi city is quite favor in the context of our project setting and any dust emissions will blow away from the majority of the residential settlements located next to the project site.

2 Gaffney, G. and Shimp, D. 1997. Improving PM10 Fugitive Dust Emission Inventories. Sacramento, CA. California Air Resource Board.

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Fugitive Dust Control 236. The source wise fugitive control measures are provided in Table 6.3 below.

Table 6.3: Control measures for Fugitive Dust emissions Source Control Measures

Earth Moving For any earth moving that is to take place in the immediate vicinity from the site boundary, watering must be conducted as required to prevent visible dust emissions

Disturbed Apply dust suppression measures (clear vegetation only from areas Surface Areas where work is to commence, plant or mulch areas that will not receive traffic, construct artificial wind breaks or wind screens) frequently to maintain a stabilized surface.

Areas that cannot be stabilized, such as wind driven dust, must have an application of water at least twice a day.

Inactive Apply dust suppressants (clear vegetation only from areas where Disturbed work is to commence, plant or mulch areas that will not receive traffic, Surface Areas construct artificial wind breaks or wind screens) in sufficient quantity and frequency to maintain a stabilized surface

Unpaved Roads Water all roads used for any vehicular traffic at least twice per day during active operations and restrict vehicle speed to 20 kmph.

Open Storage Apply water to at least 80 percent of the surface areas of all open Piles storage piles on a daily basis when there is evidence of wind driven fugitive dust or install an enclosure all along the storage piles

Track-out Wash down of construction vehicles (particularly tires) prior to Control departure from site.

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Figure 6-1: Predominant Wind Direction & Expected Impact from Dust Emissions from Construction Site

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Mitigation measures 237. A wide variety of options exist to control emissions from construction sites. The most effective means of reducing the dust emission is wet suppression. Watering exposed surfaces and soil with adequate frequency to keep soil moist at all times can reduce the total dust emission from the project by as much as 75%.3 This measure alone can bring down the dust level to less than 100 μg/m3.

Water can be sprinkled by handheld sprays or with the help of automatic sprinkler systems as required. 238. In case surplus water is not available to suppress dust at certain locations, it is recommended that if works are within 10 meters of the residential settlements, the contractor shall install segregation that will be easily erectable 2.5 meter high hoarding /fiber boards and/or steel sheets to make protection fences around the construction site within which all construction works can take place.

239. The need for large stockpiles shall be minimized by careful planning of the supply of materials from controlled sources. Stockpiles should not be located within 50 m of the residential settlements, schools or hospitals or other public amenities and shall be covered with tarpaulins when not in use and at the end of the working day to enclose dust. If large stockpiles (>25m3) of crushed materials are necessary, they should be enclosed with side barriers and also covered when not in use.

240. Construction materials that are susceptible to dust formation will be transported only in securely covered trucks to prevent dust emission during transportation.

241. Aggregate material will be delivered to the batching plant in a damp condition, and water sprays will be applied, if needed, to reduce dust emissions.

242. A minimum distance of 300 meters will be ensured between the batching plant(s) and the nearest community.

Vehicular & Equipment Emissions 243. It shall be ensured that the following measures are taken to control emissions from vehicles being used in the construction activity:

▪ Periodically check and conduct maintenance of the construction machinery and haul vehicles. ▪ Regularly change the engine oil and use new engines/machinery/equipment having good efficiency and fuel burning characteristics. ▪ Use of catalytic converters and low Sulphur fuels. ▪ The stack height of generators will be at least 3 meters above the ground. ▪ Training of the technicians and operators of the construction machinery and drivers of the vehicles. ▪ Air quality monitoring at the project site during the construction phase.

3 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.

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Noise Levels Impacts 244. The assessment of the noise impacts on the sensitive receptors located around the project site depend upon:

▪ Characteristics of noise source (instantaneous, intermittent or continuous in nature)

▪ Time of day at which noise occurs, and

▪ Location of noise source

245. Each construction phase has its unique noise characteristics due to use of different equipment items. The potential sources of noise and vibration during the preparation, construction, and worksite closure phases of the Project include equipment, machinery, and transportation used for the construction activities. The heavy equipment used for construction will be the major sources of noise and vibration. Due to the relative high density of population in the areas adjacent to the project site, noise-related disturbance to humans is very likely during the various construction activities. There will be temporary noise impacts in the immediate vicinity of the project site.

246. The construction activities will include piling along with excavation for foundations and grading of the site as well as the construction of structures and facilities. Powered mechanical equipment such as generators, excavators, bulldozers, drills, graders, vibratory rollers, concrete mixing trucks and back up alarms can generate significant noise. Impact pile driving creates the highest noise levels by far from any other construction activities.

247. Since various modern machines are acoustically designed to generate low noise levels, any high noise levels that might be generated will only be for a short duration during the construction phase.

248. Depending on the construction equipment used and its distance from the receptors, the community and the workers may typically be exposed to intermittent and variable noise levels. During the day, such noise results in general annoyance and can interfere with sleep during the night. In general, human sound perception is such that a change in sound level of 3 dB is just noticeable, a change of 5 dB is clearly noticeable, and a change of 10 dB is perceived as a doubling or halving of sound level.

249. Due to the various construction activities, there will be temporary noise impacts in the immediate vicinity of the project site. Crushing plant, asphalt production plants, movement of heavy vehicles, loading, transportation and unloading of construction materials produces significant noise during the construction stage. However, these increased noise levels will prevail only for a short duration during the construction phase.

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250. The Table 6.4 below represents typical noise levels from various construction equipment items. It should be noted that the values indicated in the table may differ depending on the brand and age of machinery provided/used by construction company.

Table 6.4: Construction Equipment Noise Ranges, dB(A)

Equipment Peak Typical Typical Construction Phase Noise Peak Sound ‘Quieted Earthworks Structure Installation Range at Level in a Equipme nt’ s 15 m Work Sound Cyclea at Levelb at 15 15 m m Batching plant 82-86 84 81 Y Concrete mixers 76-92 85 82 Y Cranes 70-94 83 80 Y Y Excavators 74-92 85 82 Y Impact pilling 95-103 100 n/a Y Front loader 77-94 85 82 Y Y Y Water bowsers 85-93 88 85 Y Y Y Graders 72-92 85 82 Y Bulldozers 65-95 85 80 Y Pavers 87-89 88 80 Y Pumps 68-72 76 75 Y Y Y Diesel generators 72-82 81 77 Y Y Vibratory rollers 68-82 74 70 Y Drilling machines 82-98 90 87 Y Y Compressors 74-88 81 71 Y Dumpers 77-96 88 83 Y Y Dump/flatbed Truck 75-85 80 77 Y Y Y Sources: USEPA, 1971; http://www.waterrights.ca.gov/EIRD/text/Ch11-Noise.pdf; http://www.lacsd.org/LWRP%202020%20Facilities%20Plan%20DEIR/4_6_Noise.pdf; http://newyorkbiz.com/DSEIS/CH18Construction.pdf Notes: a. Where typical value is not cited in literature, mean of the peak noise range is assumed b. Quieted equipment can be designed with enclosures, mufflers, or other noise-reducing features. Where data is not available, a 3 dB reduction is assumed 251. Precise information on the type, quantity, location and utilisation of plant and equipment to be used during the construction phase is not available at this stage and will be dependent on the working methods of the selected contractors. However, preliminary calculations have been conducted to provide a general magnitude of the noise levels during various construction phases.

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Mitigation measures 252. The following are examples of typical noise mitigation measures that can be utilized:

▪ Unnecessary revving of engines will be avoided and equipment will be switched off when not in use; ▪ Install temporary noise barriers made of plywood or acoustical blankets around noisy operation where necessary to comply with project noise limits; ▪ Internal haul routes will be kept well maintained; ▪ Drop heights of materials will be minimised; ▪ Plant and vehicles will be sequentially started up rather than all together; ▪ Use of effective exhaust silence systems or acoustic engine covers as appropriate; ▪ As far as reasonably practicable, sources of significant noise will be enclosed; ▪ Plant will always be used in accordance with manufacturers’ instructions. Care will be taken to site equipment away from noise-sensitive areas. Where possible, loading and unloading will also be carried out away from such areas; ▪ Regular and effective maintenance by trained personnel will be undertaken to keep plant and equipment working to manufacturers specifications; and ▪ Screening e.g. noise barriers and blinds will be used as appropriate. ▪ Record and respond to complaints according to the established grievance redress mechanism. ▪ Keep nearby residences informed in advance about noisy activities during various construction phases.

253. In addition to the mitigation measures listed above, the following mitigation measures control noise:

▪ Vehicles and mechanical plants used for the purpose of the works shall be fitted with effective exhaust silencers, maintained in good and efficient working order and operated in such a manner as to minimise noise emissions. The construction contractor shall ensure that all plant complies with the relevant statutory requirements; ▪ Machines in intermittent use should be shut down or throttled down to a minimum when not in use; ▪ Compressors should be fitted with properly lined and sealed acoustic covers which should be kept closed whenever in use. Pneumatic percussive tools should be fitted with mufflers or silencers of the type recommended by the manufacturers; ▪ Equipment which breaks concrete, brickwork or masonry by bending or bursting or "nibbling" shall be used in preference to percussive tools. Where possible, avoid the use of impact tools where the construction works is close to occupied premises; ▪ Rotary drills and busters activated by hydraulic, chemical or electrical power shall be used for excavating hard or extrusive material; ▪ Equipment powered by mains electricity shall be used in preference to equipment powered by internal combustion engine or locally generated electricity; ▪ Neither any part of the works nor any maintenance of plant shall be carried out in such a manner as to cause unnecessary noise except in the case of an

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emergency when the work is absolutely necessary for the saving of life or property or the safety of the works; ▪ Plant shall be maintained in good working order so that extraneous noise from mechanical vibration, creaking and squeaking is kept to a minimum; and ▪ Noise emitting machinery which is required to run continuously shall be housed in a suitable acoustically lined enclosure. ▪ Train staff in construction best practice. ▪ Construction operation times shall be limited to 07:00 to 22:00 daily ▪ Perform independent periodic noise monitoring to demonstrate compliance with project noise limits.

254. Acoustic screening can be used to mitigate noise levels. BS5228-1 states: “In the absence of spectral data, as a working approximation, if there is a barrier or other topographic feature between the source and receiving position, assume an approximate attenuation of 5 dB when the top of the plant is just visible to the receiver over the noise barrier, and of 10 dB when the noise screen completely hides the sources from the receiver. High topographical features and specifically designed and positioned noise barriers could provide greater attenuation. Subtract the attenuation from the value Leq,T calculated at the point of interest. Where the point of interest is 1m from the façade of the building, make an allowance for reflection by adding 3 dB to the calculated (free-field) levels.”

255. A 10 dB reduction can be achieved if the noise source completely hides the source from receiver. Therefore, where necessary, noise barriers/acoustic screening that will completely hide the source from the receiver will be implemented, providing 10 dB reduction in noise levels generated by the construction task. This will help to reduce the impact experienced at the nearby receptor.

Excavated Material (Earthworks) Disposal Impacts

256. Significant volumes of clay/mud shall be excavated from the KGA ground. Unless a suitable disposal location and efficient transport mechanism for disposal of this material is arranged, it could potentially result in major health and aesthetics issues.

Mitigation measures

257. A detailed Plan for management and disposal of Excavated Material must be developed. This Plan must identify suitable location(s) prior to commencement of excavation works and require the engaging of experienced and credible third parties for transport and disposal of this material in the most efficient and effective manner without any logistical or management delays.

Community Health and Safety Impacts

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258. The proposed project will involve the use of considerable heavy machinery and the excavation of a significantly deep and wide pit. The risk to community will be significant considering the proximity of the residential settlements to the project site and thus a number of precautionary measures will be necessary to minimize the risk of possible accidents.

Mitigation measures

259. Buffer strips or other methods of physical separation around the project sites shall be ensured to protect the public from major hazards associated with hazardous materials incidents or failure of the structure being constructed. In addition, nuisance issues related to noise, odors or other emissions would also be avoided as a result.

260. Siting and safety engineering criteria shall be incorporated to prevent failures due to natural risks posed by earthquakes, wind, flooding, landslides and fire. To prevent such issues, project structures shall be designed in accordance with engineering and design criteria mandated by site specific risks, included but not limited to seismic activity, slope stability, wind loading etc.

261. Inventories of hazardous materials shall be reduced through inventory management to greatly reduce or eliminate the potential off-site consequences of a release.

262. Process or storage conditions shall be modified to reduce the potential consequences of an accidental off-site release.

263. Improving of shut down and secondary containment to reduce the amount of material escaping from containment and to reduce the release duration.

264. Reduce the probability that releases will occur through improved site operations and control, and through improvements in maintenance and inspection.

265. Reduce off-site impacts of releases through measures intended to contain explosions and fires, alert the public, provide for evacuation of surrounding areas, establish safety zones around each work site, and ensure the provision of emergency medical services to the public.

266. Work areas outside the project site, especially where machinery is involved will be roped off and will be constantly monitored to ensure that local residents, particularly children stay away. Also, no machinery will be left unattended, particularly in running condition.

267. Community will be briefed on traffic safety, especially women who are the main care providers to children.

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268. Speed limit of 20 km/hr will be maintained by all project related vehicles on the section of the roads and passages adjacent to the houses near the project boundary and nighttime driving of project vehicles will be limited where possible.

Worker Health and Safety Impacts

269. The project construction activity will be conducted in a thickly populated area with high volumes of pedestrians and vehicular traffic. The risk of accidents taking place will be high, particularly from falling objects during work being conducted on elevated structures, falling of beams and metal rods as well as the potential of accidents of vehicles with construction machinery.

270. The general track record of Contractors in the country with regards to following safety protocols during construction work is not very impressive with safety precautions mostly felt to be an impediment to fast pace of work.

Mitigation measures

271. Keeping in view the significant risk posed by the construction work to the surrounding commuters and pedestrians, it shall be ensured that the Contractor provides his staff with a provided detailed orientation on the safety protocols to be followed at all times during the construction work to minimize the risk of accidents.

272. The Contractor shall provide bi-monthly refresher sessions to his staff on the safety precautions to be followed during the construction activity.

273. The Contractor will closely monitor his staff at all times and will take strict action against any non-compliance with these protocols and will ensure at all times that the safety of the commuters and traffic in the vicinity of the project site are kept a priority.

Water Resources Impacts

274. Water shall be used during the project construction in the labor camps for the everyday use of the laborers for cooking, drinking and bathing etc. Also, water shall be used at the sites in the project area for sprinkling to suppress dust emissions. In addition, water shall also be used during the construction activity itself for mixing of gravel in the batching plant etc.

275. Water is available in sufficient quantities in the project area and will be sourced either through pipes taken from the nearest municipal connection or through bowzers that shall be brought to the project area. If felt necessary, temporary bore wells will be dug and will be restored to their original condition once the construction activity has been completed.

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276. Even though there is no issue with water availability and the project construction will only be requiring limited quantities of water that will be easily manageable, however, it shall be ensured through monitoring that wastage of water is prevented both at the project sites as well as at the labor camps.

Mitigation measures

No measures required.

Camp & Batching plant effluent Impacts

277. The staff and labor camps for the construction of the proposed Staging facility will be a source of wastewater generated from the toilets, washrooms and the kitchen. The wastewater will not meet the national environmental standards and will therefore need treatment prior to disposal.

278. The project site where construction is being conducted must not be treated by the project staff and/or labor as a public toilet or for disposal of camp effluent.

Mitigation measures

279. It will be ensured that no untreated effluent is released to the environment.

280. A closed sewage treatment system will treat the effluent, which will then be disposed of in a soak pit or will be used for plantation. The sewage treatment plants will be installed at each respective labor camp based on the number of laborers residing at the respective camp.

281. Water being released from any batching plant(s) must be treated as per requirements of SEQS prior to release to sewerage system/any other water body.

Soil Erosion and Sedimentation Impacts

282. The majority of the works proposed will consist of earth works and thus there will be a high possibility of soil erosion and sedimentation taking place if the exposed soil surfaces are not protected.

Mitigation measures

283. Any drainage structures, culverts or pipes crossing the project site may need to be modified or protected and the detailed designs must make provisions to protect or re-provision all infrastructure that may be affected by the construction works.

Soil Contamination Impacts

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284. During the project construction, spills of fuel, lubricants and chemicals can take place while transferring from one container to another or during refueling. Also, during maintenance of equipment and vehicles, through leakages from equipment and containers and as a result of traffic accidents.

285. Depending on the nature of the material, location of spill and quantity of spill, the soil can get contaminated.

Mitigation measures

286. It will be ensured that spill prevention trays are provided and used during refueling. Also, on-site maintenance of construction vehicles and equipment will be avoided as far as possible. In case on-site maintenance is unavoidable, tarpaulin or other impermeable material will be spread on the ground to prevent contamination of soil.

287. Regular inspections will be carried out to detect leakages in construction vehicles and equipment and all vehicles will be washed in external commercial facilities.

288. Fuels, lubricants and chemicals will be stored in covered bounded areas, underlain with impervious lining. Appropriate arrangements, including shovels, plastic bags and absorbent materials will be available near fuel and oil storage areas.

Drainage and Storm Water Run-off Impacts

289. The storm water run-off from the construction site could carry oil and grease if the soil is contaminated or the potentially contaminated areas (oil and grease storage areas, maintenance areas and workshops) are in hydrological contact with the surrounding areas. Any risk may be eliminated by taking measures to avoid spillages and taking immediate remedial measures in case of accidental spillage of oil.

Mitigation measures

290. All unpaved exposed areas at the project sites will be compacted to minimize water erosion and all areas containing potentially hazardous materials will be hydrologically isolated from the remaining site.

291. It shall be ensured that natural drainage is not hampered or blocked in any way at any of the sites.

Hazardous and Non-Hazardous Waste Management Impacts

292. In the absence of national or domestic regulations and a waste management system in the project area, waste disposal can potentially become a serious

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environmental issue, particularly with the local contractors. To avoid any potential issue, the project proponent will have to impose adequate internal controls.

Mitigation measures

293. A waste management plan will be developed prior to the start of construction. This plan will cater to sorting of hazardous and non-hazardous materials prior to disposal, placing of waste bins at the sites in the project area for waste disposal and an onsite hazardous waste storage facility.

294. Periodic on-site audits of waste management will be undertaken along with auditing of waste disposal contractors and disposal facilities on regular basis to check that procedures are being followed.

295. Records of all waste generated during the construction period will be maintained. Quantities of waste disposed, recycled or reused will be logged on a Waste Tracking Register.

296. Licensed waste contractors will be engaged to dispose off all non-hazardous waste material that cannot be recycled or reused.

297. Training will be provided to personnel for identification, segregation and management of waste.

Historical/Archaeological Sites Impacts

298. There are no historical buildings and/or monuments at the project site.

Mitigation measures

299. If evidence of any archaeological remains is found during the construction activities, the excavation work will be stopped immediately and necessary next steps taken to identify the archaeological discovery based on the ‘Chance Find’ procedures provided as Annexure H.

Vegetation and Wildlife Loss Impacts

300. The proposed project site is an existing cricket ground with minimal or non-existent vegetation cover. However, during construction, any vegetation cover present will be removed.

301. The impact of project activities on the wildlife in the area is likely to be insignificant as the area has a long area of human occupation, to which most of the animal species have adapted over time.

Mitigation measures

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302. Wherever trees have to be felled, mitigation will be required in the form of reinstatement and compensatory planting.

303. In case existing trees and topsoil (down to 0.5 meters) is removed, the top soil shall be retained for elsewhere in the project. The wood that would be cut will not be burnt on site. All stumps and surplus vegetation shall be disposed of at landfills via routes or other destinations as designated and instructed by TMTD focal points.

304. It will be ensured that willful killing; trapping and trade of faunal species will be strictly prohibited.

305. Tree plantation will be undertaken at the project site to compensate for the vegetation lost during construction in the minimum ratio of 3:1 i.e. 3 saplings to be planted for every tree felled given the possible difficulties with establishing trees and low survival rates of young trees.

306. Burning of vegetation as fuel will be prohibited.

Employment Conflicts Impacts

307. The proposed project is not likely to create any significant permanent job opportunities. Even unskilled and semi-skilled employment opportunities that are likely to be created will be for a short period while the project is constructed. As persons with relevant skills may be available locally within Karachi, people from the project area are likely to fill a significant number of the semi-skilled and skilled jobs.

308. This issue of provision of jobs can become particularly problematic if it is perceived by the local population that a significant number of construction-related jobs opportunities are not given to people from the local community. This can result in friction between local residents and construction workers from outside of the community.

Mitigation measures

309. The Construction Contractor will adopt a transparent hiring policy. Prior to the commencement of the construction activity, the local communities in the project area will be informed of the employment policy in place and number of people that can be employed for this project.

310. It will be ensured that maximum number of unskilled and semi-skilled jobs will be provided to the residents of Karachi city.

311. TMTD will ensure a balanced process of employment of the communities in the project area with preference given to those most directly affected by the project.

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Communicable Diseases Impacts

312. Communicable diseases such as HIV may be introduced due to the immigration of workers associated with the project.

Mitigation measures

313. A communicable diseases prevention program will be prepared for construction workers or residents near the construction sites.

Loss of Access around Project Site Impacts

314. It is currently not foreseen that there will be any access restriction since the western front of the proposed KGA ground is already closed off due to the KBRT – Green Line works and this access way will be used for all project works. The residential settlements on the remaining faces of the site will not be disturbed.

Mitigation measures

315. The Contractor shall ensure that:

▪ The existing western face, presently being used for the Green Line BRT works will only be used for all construction works. No other access way will be used, thus ensuring the residential settlements located on the other faces of the project site are not disturbed.

Land Use and Aesthetics Impacts

316. The proposed staging facility will build on the existing road with a minor change in the land use pattern of the area. Aesthetic and visual impacts during the construction phase will be visible in the project area and particularly in areas that are congested. However, the construction of the Staging facility and BRT system in general will have a positive impact on the urban aesthetics and architectural beauty they will bring to the city’s real estate line. The construction of BRT related infrastructure will add structural beauty and value to the city.

Mitigation measures

No mitigation measures required.

Natural and Man made Hazards Impacts

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317. Natural disasters include windstorms, floods, earthquakes may be experienced during the construction phase. However, the likelihood of such events is quite low and the effect on the project in the case of an occurrence of such a natural calamity on the health and safety of the workers and affected population can be minimized by adopting appropriate and adequate mitigation measures.

318. Fire accidents and terrorist/sabotage activities are something that cannot be predicted or foreseen but can be prepared for by taking precautionary measures such as training of staff and acquiring extra safety and security measures.

Mitigation measures

No mitigation measures required.

6.3 Operation Phase 319. The operation of the Staging facility will involve the movement of modern BRT buses with low emissions coupled with removal of older buses from the traffic fleet is expected to deliver some reductions in ambient levels of noise and air pollution.

320. The impacts in the operation phase are critically important since the impacts in the operation phase of the project are ‘long term’.

321. The summary of potential impacts during the Operation phase are provided in Table 6.5 below.

Table 6.5: Summary of Possible Impacts during Operation Phase

Environmental Potential Issue from S/No. Potential of Impact Mitigation Measures Aspect Environmental Aspect

1 Ambient Air Particulate and gaseous The newer buses No negative Quality emissions from buses running on CNG impacts. However, are expected to be vehicle maintenance more efficient and and emission emit fewer controls to be pollutants conducted in the compared to the long term to protect existing public air quality transport vehicles, which are quite old and mostly run on diesel.

2 Noise Levels Noise resulting from The newer buses No negative movement of buses are expected to impacts. produce lesser noise due to

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quieter and more efficient engines compared to the existing public transport fleet, which is old and quite noisy due to inefficient diesel engines.

3 Solid Waste The operation of the Staging Large volumes of Waste collection and Disposal facility along with the BRT solid waste being management plan buses will result in domestic generated and must be in place and garbage being generated leading to pollution implemented. from stations and buses. in the city

4 Land Accidental fuel and material No negative impact Proper waste contamination spills expected. management plan and spill response plan to be implemented

5 Socio- Increased job opportunities Overall positive Project sustainability economy impact expected must be ensured Improvement of and socio- through regular and infrastructure facilities economic proper maintenance conditions of region of infrastructure. Wider economic growth can improve Reduced health risk and accidental hazards

Air Quality Impacts

322. There is strong evidence from different BRT projects (including Staging facilities that are part of the BRT systems) implemented across the world to suggest that a significant improvement in air quality in the project area can be expected once the proposed project is operational. The concentrations of key pollutants such as CO,

NOx, PM10 and PM2.5 have been observed to be reduced significantly. This is attributed to a number of reasons such as reduced traffic congestion on the roads with a larger number of persons using the BRT and the avoidance of traffic jams ensuring the idling times for vehicles is significantly reduced.

Mitigation measures

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323. Regular maintenance of BRT buses shall be conducted and optimal engine efficiency shall be ensured through use of high quality fuel.

324. Regular monitoring will be conducted of the PM levels. Any sections in the project area of the Staging facility where PM levels are found to be increasing shall be closely examined and potential sources of PM shall be identified and customized mitigation measures developed to reduce PM levels at that particular section.

325. Buses and all mechanical equipment such as generators shall undergo regular maintenance and shall be tuned to maintain engine efficiency and minimize emissions in compliance of NEQS limits.

326. Stack height of generators (if any) will be at least 3 meters above the ground.

Noise Levels Impacts

327. Results of the noise analysis conducted for the proposed BRT systems indicate that there would be drop of almost 20 dB in the daytime traffic noise levels for the areas where there will be only BRT buses. This is a substantial reduction in the noise levels. There would be almost no traffic noise during the night hours where roadway is dedicated to the BRT buses only when there would no buses. Thus, this means that in the vicinity of the Staging facility as well, there would be an overall reduction in noise levels.

Mitigation measures

328. No noise mitigation measures are needed because future peak hour average traffic noise levels would not be more than the existing noise levels.

329. BRT buses and all mechanical equipment shall be regularly maintained to ensure compliance with NEQS limits for noise.

330. Strict protocols for driving into and out of the Staging facility shall be followed and honking shall not be allowed and pre-set speed limits shall be followed.

Solid Waste disposal Impacts

331. The operation of the Staging facility and the BRT buses will result in domestic garbage being generated from stations and buses consisting of dinner boxes, aluminium cans, plastic bottles, tissue paper/paper, newspapers, nutshells and food waste.

Mitigation measures

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332. A proper solid waste management plan will be prepared and implemented to ensure waste containment, collection, transfer and disposal. Also, monitoring will be conducted at specific locations in the vicinity of the Staging facility to ensure strict compliance with the EMP in implementing the measures for solid waste management.

Land Contamination Impacts

333. Accidental fuel and material spills could take place from the different BRT buses visiting the Staging facility on a daily basis.

Mitigation measures

334. Proper waste management plan and spill response plan will need to be implemented.

Socioeconomic Impacts

335. The operational phase of the Staging facility will contribute to the local economy by providing job opportunities to the residents of Karachi. These benefits will increase the socio-economic status of the region and the overall impact will bring about a positive change.

Improvement of Infrastructure Facilities

336. The development of the proposed project will also create and improve the amenities/ services such as power, road infrastructure, communication etc. and thus improve the overall living conditions for the residents of Karachi.

Economic Growth

337. The proposed project will increase the economic activities around the area, creating avenues for direct/indirect employment in the post project period.

338. A wider economic impact is expected in terms of generating opportunities for other businesses linked to the proposed project such as marketing, repair and maintenance tasks etc.

Mitigation measures

No mitigation measures required.

6.4 Cumulative Impacts 339. The construction works for the BRT – Green Line are presently ongoing along the entire western face of the proposed KGA ground. The ongoing activities consist of

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major earthworks in order to develop the Numaish station and BRT corridor. However, considering the progress and completion status of these existing activities, they will have already been completed by the time the proposed Staging Facility related construction works would commence. Thus, no cumulative impacts are expected.

6.5 Indirect and Induced Impacts 340. The potential impact of development of the proposed Staging facility at the KGA cricket ground location has been examined, which has indicated that the existing and planned infrastructure such as water supply, wastewater collection and treatment, municipal solid waste collection and disposal would be adequate to accommodate any potential population intake as a result of the proposed project development. Impacts on the environment from air emissions, traffic and community noise, and treated effluent discharge have also been assessed and have found to be acceptable and within the carrying capacities of the environmental media. Thus, negative indirect and induced impacts from this project are not expected.

341. Negative indirect and induced impacts from this project are not expected.

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7 Environmental Management and Monitoring Plan

7.1 Introduction 342. The Environmental Management and Monitoring Plan (EMP) is developed to eliminate and/or mitigate the impacts envisaged at the design, construction and operation stages and provide specific guidelines for long term monitoring by identifying the roles and responsibilities of TMTD, Supervision Consultant and Contractor(s).

343. The detailed EMP provided in this section provided as Table 7.1 ensures that the Project has no detrimental effect on the surrounding environment. The Plan shall act as a guideline for incorporating environmental measures to be carried out by the contractors engaged by TMTD, as well as for other parties concerned for mitigating possible impacts associated with the Project and will form part of the Contract documents to be considered alongside the specifications. This Plan shall act as the Environmental Monitoring Plan during construction and operational phases of the Project, and will allow for prompt implementation of effective corrective measures.

7.2 Environmental Management Plan (EMP) 344. The EMP attached with this report ensures the following:

▪ Delivery of the prescribed environmental outcomes during all phases of the Project; ▪ Formulating a system for compliance with applicable legislative and non-legislative requirements and obligations and commitments for the Project; ▪ Ensure that project design process incorporates best practice environmental design and sustainability principles to minimize potential impacts of construction and operation on the environment and community. ▪ Ensure that the construction work procedures minimize potential impacts on the environment and community. ▪ Develop, implement and monitor measures that minimize pollution and optimize resource use.

7.3 Objectives of EMP 345. The EMP provides a delivery mechanism to address potential impacts of the project activities, to enhance project benefits and to outline standardized good practices to be adopted for all project works. The EMP has been prepared with the objectives of:

▪ Defining the roles and responsibilities of the project proponent for the implementation of EMP and identifying areas where these roles and responsibilities can be shared with other parties involved in the execution and monitoring of the project; ▪ Outlining mitigation measures required for avoiding or minimizing potential negative impacts assessed by environmental study;

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▪ Developing a monitoring mechanism and identifying requisite monitoring parameters to confirm effectiveness of the mitigation measures recommended in the study; ▪ Defining the requirements for communication, documentation, training, monitoring, management and implementation of the mitigation measures.

7.4 Environmental Management Framework 346. Near term institutional arrangements are needed to monitor contractor performance in implementing environmental protection measures described in the environmental management plan (EMP). As earlier stated, enforcement will be under the authority of the TMTD PIU, with technical support from the CSC. The following sections describe the environmental management framework for the construction phase.

7.4.1 Roles of TMTD PIU and SMTA 347. Environmental and Social Safeguard specialists are available in PIU and their services will continue to be required, to oversee safeguards monitoring of the Project during construction operations. Positions of Environmental and Safety Officer (ESO) and Equal Opportunity, Gender and Social Specialist (EOGSS) posts will eventually be needed in the operations group, TransKarachi. In case they are established in time, the ESO and EOGSS may be guided by specialist consultants from the CSC during the construction period.

7.4.2 Roles of CSC Consultants during Design/Construction 348. Project Management will be performed by the CSC headed by a full-time Project Manager/Resident Engineer to take responsibility for and manage activities of the CSC. The CSC will be responsible for the following in relation to their works: (i) assisting the PIU in implementing the Project; (ii) carrying out procurement and engaging and contractors; (iii) liaising and coordinating with the TMTD and other authorities; (iv) managing the contractors; and (v) liaising with other stakeholders on the day to day implementation of Project activities. TMTD will receive support from the CSC to implement the environmental and resettlement plans.

349. Safeguard specialists for environment and resettlement will be part of the CSC to oversee implementation of the environmental and resettlement plans prior to the bidding stage to ensure the bidding documents include all environmental management requirements.

7.4.3 Role of the Contractor 350. The civil works contractor will be responsible for fulfilling contract conditions related to environmental mitigation and monitoring. The contractor is responsible for implementing all environmental, health and safety actions described in the EMP and relevant clauses in the bidding documents and contract during the preconstruction and construction period.

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351. The contractor will prepare the Construction SSEMP based on the site-specific construction methodologies it proposes to use the EMP in this IEE. The SSEMP will further develop the EMP and will provide detailed measures on how it will mitigate impacts, including but not limited to air pollution and noise, traffic, health and safety risk, drainage and sediment, spoil and solid wastes, hazardous materials and other impacts identified in the IEE. The CSC acting for the PIU will review the SSEMP before the commencement of construction. Acceptance does not preclude introducing further actions into the plans as required by circumstances, and monitoring will be conducted for compliance with the original requirements of the EMP contained in the IEE.

352. The contractor will appoint an Environmental Management officer (EMO) and a Health and Safety Officer (HSO) who will be responsible for implementing the mitigation measures and specific management plans required under the EMP. Site inspections will be conducted on a daily and weekly basis to check compliance with the approved SSEMP and ensure implementation of all health and safety requirements.

353. The responsibilities of the Contractor include:

▪ Participate in induction on EMP and mitigation measures to be delivered by CSC and PIU prior to preparation of the SSEMP;

▪ Preparing and submitting the SSEMP to the PIU;

▪ Appointing EMO and HSO, confirming that these positions have been filled and by whom with the CSC and PIU before construction commences;

▪ Seeking training and support from PIU on any aspects of environmental management, as required;

▪ Once construction starts, the EMO is responsible for ensuring that the Contractor complies with the clauses in the contract and bidding documents in respect of environment, health and safety;

▪ As required, preparing and submitting for approval, appropriate plans (tree cutting, aggregate extraction, traffic management etc.);

▪ Engaging an Independent Monitoring Group (IMG) to maintain a continuous (quarterly) monitoring record of ambient environmental parameters;

▪ Engaging an approved service provider to undertake HIV/AIDS briefings and awareness raising amongst the contractor’s employees and communities, and reporting on the same;

▪ Coordinating with PIU in respect of community consultation i.e. establishing GRM etc; and

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▪ Participating in monitoring and coordinating with PIU to ensure that environmental management activities are reported in Monthly Progress Reports as required.

7.4.4 Role of Sindh EPA 354. SEPA will review the statutory environmental assessment. Approval will be conditional on the proponent providing commitment to implement all mitigation measures in the environmental assessment and environmental management plan along with any additional requirements set out in the environmental approval.

355. On-going consultation with SEPA will be required during the construction of the project. SEPA will be asked to assist in the monitoring of implementation of the SSEMP and ensure that environmental management and mitigation of the project is undertaken to an acceptable standard. Periodic inspections will take place with SEPA, TMTD PIU, CSC and Contractors.

7.5 Environmental Management/Monitoring and Reporting 356. During the construction phase, the overall responsibility for the implementation and monitoring of the EMP rests with the Project Director (PD). The PD through assistance from the Supervision Consultant’s Environmental staff and the Environment team of TMTD, will supervise the implementation of the proposed mitigation measures and monitor the implementation progress in the field. Monthly environmental monitoring data/reports will be incorporated in the project implementation progress reports to be shared with ADB and such monthly reports will be consolidated into quarterly monitoring reports and submitted to ADB for review and clearance. Upon clearance, all such reports will be uploaded on the TMTD and ADB websites.

7.6 Monitoring Parameters 357. The key environmental parameters such as ambient air quality, noise levels, waste disposal etc. will be monitored at key receptor locations.

358. A monitoring plan for the pre-construction, construction and operation phases of the project, indicating environmental parameters, frequency, locations and applicable standards is provided as Tables 7.1, 7.2 and 7.3 below. Standards set under the NEQS guidelines for the key receptors are also provided as Annexure B.

7.7 Environmental Training

Capacity Building and Training 359. Capacity building and training programs are necessary for TMTD staff in order to control the negative impacts resulting from the project construction and during its operation phase. They will also require trainings on monitoring and inspecting of

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such a project for environmental impacts and for implementation of mitigation measures.

360. The details of this capacity building and training program are presented in the Table 7.4 below.

7.8 Further Additions & Updating of IEE study & EMP 361. This version of the IEE report along with this EMP shall be further updated once the detailed design is completed and any other details of the proposed staging facility become available over the coming weeks and months. These revisions shall be incorporated into any subsequent updated versions of this IEE report and EMP.

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Table 7.1: Pre-Construction Monitoring Requirements

Project Activity Objective of Parameters to be Measurements Location Frequency Responsibility and Potential Monitoring Monitored Impact Relocation of To ensure no infrastructure (water interruption of pipelines, gas these services Completion of relocation In project area, Process of relocation pipelines, electric takes place once of services to alternate wherever relocation of - TMTD of services cables etc.) construction pathways services is necessary activity commences

To establish CO,NOx & PM10 baseline air quality (particulate matter At one key receptor Twice in total (Once on levels smaller than 10 1-hr and 24-hr Ambient Air Quality location around the a weekday and once on TMTD microns) concentration levels project site a weekend) concentration at receptor level To establish Ambient noise levels A-weighted noise levels – baseline noise 24 hours, readings taken At one key receptor Twice in total (Once on Ambient Noise levels at 15 s intervals over 15 location around the a weekday and once on TMTD min. every hour, and then project site a weekend) averaged

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Table 7.2: Construction Phase Monitoring Requirements

Project Activity Objective of Parameters to be Measurements Location Frequency Responsibility and Potential Monitoring Monitored Impact Noise To determine the Ambient noise level A-weighted noise levels – At two key receptor Monthly Contractor’s Disturbance due to effectiveness of near key noise 24 hours, readings taken locations near project Environmental noise from noise abatement sensitive receptor at 15 s intervals over 15 site officer, TMTD construction activity measures on near project site min. every hour, and then sound pressure averaged levels

Air Quality To determine the CO,NOx & PM10 1-hr and 24-hr At two key receptor Monthly Contractor’s Dust emissions from effectiveness of (particulate matter concentration levels locations near project Environmental construction vehicles dust control smaller than 10 site officer, TMTD and equipment program on dust at microns) receptor level concentration at receptor level Visible dust Visual observation of size Construction sites Once daily Contractor’s of dust clouds, their Environmental dispersion and the officer, TMTD direction of dispersion Dust Fall Amount of dust deposition Construction sites Once daily Contractor’s shall be measured Environmental officer, TMTD Water Resources To prevent Volume of water Visual observations of Construction sites and Contractor’s wastage of water being used versus its water being used at labor camps Environmental Wastage of water Once daily leading to depletion in during the utilization project sites and at labor officer, TMTD water resources construction works camps Landscape scarring To ensure Contractor’s at borrow sites landscape does Environmental - Visual inspection Borrow sites Weekly not lose its officer, TMTD aesthetic value Soil erosion To ensure soil Contractor’s erosion does not - Visual inspection Borrow sites Weekly Environmental take place officer, TMTD

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Project Activity Objective of Parameters to be Measurements Location Frequency Responsibility and Potential Monitoring Monitored Impact Increase in traffic To minimize risk of Number of accidents Construction sites Contractor’s accidents traffic accidents taking place Visual monitoring Once weekly Environmental officer, TMTD Delays in traffic To ensure traffic Number of traffic Construction sites management movement is congestion events Contractor’s Visual inspections Once weekly Environmental efficiently officer, TMTD managed Safety precautions To prevent Number of near miss Construction sites by Safety workers accidents for events and accidents Contractor’s Visual inspections Once weekly Environmental workers and taking place officer, TMTD general public Soil Contamination To prevent Incidents of oil and At construction sites contamination of toxic chemical spills and at vehicle and Contractor’s soil from oil and Visual inspections machinery refuelling & Once a month Environmental toxic chemical maintenance areas officer, TMTD spills and leakages Solid Waste & To check the Inspection of solid Effluent disposal availability of and liquid effluent Insufficient waste generation, collection, procedures for waste management segregation, storage, Once daily. system and recycling and At labor camps and at Contractor’s collection, storage, Visual inspections Liquid effluent to be Environmental implementation disposal will be work sites transportation and tested on quarterly officer, TMTD disposal undertaken at labor basis camps and at all work sites in the project area Protection of To ensure heritage Careful inspections At work sites Heritage Sites sites are protected during excavation Contractor’s Destruction of relic or and any relic found work in case any relic - During excavation work Environmental damage to heritage is recovered is discovered officer, TMTD site without damage

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Table 7.3: Operation Phase Monitoring Requirements

Project Activity Objective of Parameters to be Measurements Location Frequency Responsibility and Potential Monitoring Monitored Impact Noise To determine the Ambient noise level A-weighted noise levels – effectiveness of near receptors in Disturbance due to 24 hours, readings taken at 15 s At one receptor O&M Contractor’s noise abatement project area Environmental noise from operational intervals over 15 min. every location near the Bi-annual measures on officer, Trans activity hour, and then averaged Staging facility sound pressure Karachi levels Air Quality To ensure air Ambient air quality Concentration levels of the Air pollutants can pollutants are not i.e. concentration of pollutant gases At one receptor O&M Contractor’s adversely affect the present above the pollutant gases in air Environmental location near the Bi-annual ambient air quality permissible such as CO, NOX and officer, Trans Staging facility and impact human guidelines PM10 Karachi health Solid Waste To ensure solid Amount of solid waste Records of waste generated Daily records of Management waste is disposed generated and its On-site audits of waste waste generated to O&M Contractor’s Domestic garbage off in an disposal method management be maintained. Environmental Staging Facility from stations and environmentally Audits of the waste disposal Audits to be officer, Trans buses friendly manner contractors and waste disposal conducted monthly. Karachi facilities

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Table 7.4: Capacity Development and Training Programme

Provided by Organized by Contents No. of Duration Cost training (PKR) events Pre-construction Phase Project Director Short seminars and Two seminars Monitoring courses on: for Contractor Consultants/Organization Environmental management 3 days s offering specialized Management Plan staff and TMTD 200,000 each services in environmental and Environmental project staff management and Monitoring Plan monitoring Construction Phase Project Director Short seminars on Two seminars Monitoring Environmental risks for Contractor Consultants/Organization associated with management s offering specialized construction phase. staff and TMTD services in social Development of project staff 3 days management and Environmental dealing in 200,000 each monitoring Performance environment Indicators and social Occupational Health issues and Safety (OHS) issues Operational Phase Project Director Short seminars Two seminars Monitoring relating to monitoring for O&M Consultants/Organization of environmental and Contractor and 3 days s offering specialized social parameters TMTD staff 200,000 each services in Occupational during operational Health and Safety (OHS) phase Issues 600,000 Total (PKR 0.6 million)

7.9 Environmental Management Costs 362. The Table 7.5 below provides cost estimates for ‘Pre-Construction phase’ monitoring while Table 7.6 provides cost estimates for ‘Construction phase’ monitoring and Table 7.7 provides the cost estimates for the ‘Operation phase’ monitoring of key environmental parameters.

363. The costs associated with implementation of the EMP and the necessary mitigation measures are provided as Table 7.8 below. The Table 7.9 below provides the Environmental management and monitoring plan for the proposed project.

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Table 7.5: Annual Cost Estimates for ‘Pre-Construction Phase’ Environmental Monitoring

Monitoring Parameters Quantity Amount Details Component PKR CO, NOx, 2 (Twice only at 1 2 readings @ PKR Air Quality 120,000 PM10 location) 60,000 per sample Noise Levels 2 (Twice only at 1 120,000 2 readings @ PKR dB(A) location) 60,000 per reading Contingencies 12,000 5% of monitoring cost Total (PKR) 252,000

Table 7.6: Annual Cost Estimates for ‘Construction Phase’ Environmental Monitoring

Monitoring Parameters Quantity Amount Details Component PKR CO, NOx, 24 (Monthly basis at 24 readings @ PKR Air Quality 1,440,000 PM10 2 locations) 60,000 per sample Noise Levels 24 (Monthly basis 1,440,000 24 readings @ PKR dB(A) at 2 locations) 60,000 per reading Liquid Effluents Effluent produced As per NEQS 4 (Quarterly basis 80,000 4 samples @ PKR from labor camp and at 1 site) 20,000 per sample construction sites Contingencies 148,000 5% of monitoring cost Total (PKR) 3,108,000 (3.108 million PKR)

Table 7.7: Annual Cost Estimates for ‘Operation Phase’ Environmental Monitoring

Monitoring Parameters Quantity Amount Details Component PKR 2 (Bi-annually at 2 readings @ PKR Air Quality CO, NOx, PM10 120,000 1 location) 60,000 per sample Noise Levels dB(A) 2 (Bi-annually at 120,000 2 readings @ PKR 1 location) 60,000 per reading Contingencies 12,000 5% of monitoring cost Total (PKR) 252,000

Table 7.8: Estimated Costs for EMP Implementation

Item Sub-Item Estimated Total Cost (PKR)

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1 person for 12 months Staff, audit and monitoring (@ 60,000 per month per staff 720,000 cost1 member) Provided separately in Tables 7.5 Monitoring Activities - to 7.7. Mitigation Measures As prescribed under EMP and IEE 11,00,000 (i) Water sprinkling To suppress dust emissions 500,000 (ii) Wastewater collection & From labor camps and construction 300,000 Treatment sites (based on initial estimates) (iii) Solid waste collection & From labor camps and construction 300,000 disposal sites (based on initial estimates) Contingencies 5% of EMP implementation cost 55,000 Total Estimated Cost (PKR) 1,875,000 (1.875 million PKR) 1: To cover staff cost and expenses of Contractor

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Table 7.9: Environmental Management and Monitoring Plan

Environmental Objectives Mitigation Measures Timing to Location to implement Responsibility Concern (MM) recommended implement MM MM Implementation Monitoring Design/Pre-Construction Stage The associated During the detailed facilities, even design phase, all though not potential alternatives, listed by both in terms of Government of technology as well as Sindh as location specific aspects historical and need to be considered cultural and all efforts need to heritage, be made to avoid Avoidance of Prior to possess a rich demolition of the demolition of commencement Detailed historical value associated facilities as Associated of construction Project Area design TMTD since they are far as possible. As part Facilities and demolition consultant over 100 years of the review process, activity old and their the relevant key demolition stakeholders must also needs to be be engaged to find a prevented since suitable alternative it would result in strategy to prevent a great cultural demolition of the and historic existing associated loss. facilities.

To ensure all 1.TMTD, as the Prior to utilities are implementing agency, commencement Relocation of relocated to Respective will be responsible for of construction Project Area TMTD Utilities avoid disruption utility companies and demolition and ensuring all permits activity inconvenience and clearances are

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Environmental Objectives Mitigation Measures Timing to Location to implement Responsibility Concern (MM) recommended implement MM MM Implementation Monitoring to communities obtained prior to and receptors in commencement of project area work at the project site. In addition, TMTD will ensure that detailed contingency plans are prepared prior to commencement of construction activities at the project site to mitigate any potential impacts resulting from outage of utilities.

2. Contractors will assess construction locations in advance for potential disruption to services and identify risks prior to starting construction. Any damage or hindrance/disadvantag e to local businesses caused by the premature removal or

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Environmental Objectives Mitigation Measures Timing to Location to implement Responsibility Concern (MM) recommended implement MM MM Implementation Monitoring insufficient replacement of public utilities is subject to full compensation, at the full liability of the contractor who caused the problem.

3. If temporary disruption is unavoidable, the contractor will, in collaboration with relevant local authorities such as power company, water supply company and communication company, develop a plan to minimize the disruption and communicate the dates and duration in advance to the affected persons.

4. Communities shall be

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Environmental Objectives Mitigation Measures Timing to Location to implement Responsibility Concern (MM) recommended implement MM MM Implementation Monitoring informed in advance regarding storage of water when their utilities are about to be relocated. Also, water pipes located/crossing through the project site may be moved slightly away or provision of service duct may be considered.

5. Construction billboards, which include construction contents, schedule, responsible person and complaint phone number, will be erected at each construction site.

6. In case any material(s) is encountered that contains asbestos, it

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Environmental Objectives Mitigation Measures Timing to Location to implement Responsibility Concern (MM) recommended implement MM MM Implementation Monitoring must be ensured that international best practices/established protocols related to handling of asbestos based materials are followed since no national regulations on handling asbestos materials exist.

1. Specific locations will be strategically selected for development of labor To ensure the camps that contain all labor camps do necessary facilities. Prior to Most suitable locations Locations for not pose any commencement for labor camps TMTD - Labor Camps adverse 2. Camp locations will of construction nearest to the project impacts on the ensure minimal activity site must be identified project area disturbance to residential settlements next to project site.

To minimize 1.The traffic Prior to Development of possibility of management plan Traffic commencement accidents and shall be prepared by At all construction sites TMTD - Management of construction traffic the Contractor for Plan activity congestion implementation prior

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Environmental Objectives Mitigation Measures Timing to Location to implement Responsibility Concern (MM) recommended implement MM MM Implementation Monitoring once to commencement of construction the project commences construction activity. and thus The main objectives of minimize the plan shall be to possible maximize the safety of nuisance for the workforce and the residents of travelling public while Karachi keeping the traffic flowing as freely as possible. 2.The detailed traffic plan shall ensure that traffic is diverted to alternate routes wherever possible and will minimize traffic jams and bottlenecks near the project site and also minimize the chances of traffic related accidents. 3.The plan will include consideration of the following: ▪ Lane availability and minimization of traffic flows past the works site

▪ Establishment of

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Environmental Objectives Mitigation Measures Timing to Location to implement Responsibility Concern (MM) recommended implement MM MM Implementation Monitoring acceptable working hours and constraints

▪ Agreement on time scale for works and establishment of traffic flow/delay requirements

▪ Acceptability of diversion routes where necessary

▪ Need for road closures and necessary orders

▪ Co-ordination with other planned road and street works

▪ Establishment of incident management system for duration of the works

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Environmental Objectives Mitigation Measures Timing to Location to implement Responsibility Concern (MM) recommended implement MM MM Implementation Monitoring Construction Stage Minimize Traffic disturbance of ▪ Traffic signs and During The most important Contractor and TMTD/CSC Management vehicular traffic warning instructions Construction locations to be Engineer and pedestrians Works identified and listed. shall be displayed at during haulage Relevant plans of the of construction the sites and along the Contractor on traffic materials, spoil proposed routes being arrangements and equipment used by the to be prepared and and machinery, construction traffic for available. blocking access the information of roads during works other road traffic as Damage / well. maintenance problems for ▪ Public awareness roads and campaigns through bridges used by radio and newspaper the haulage advertisements shall trucks, dust nuisance to be conducted to residences, educate the public and schools and sensitize them to hospitals. cooperate with the construction staff and project focal staff in order to try and avoid the areas under construction as far as possible, particularly

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Environmental Objectives Mitigation Measures Timing to Location to implement Responsibility Concern (MM) recommended implement MM MM Implementation Monitoring during the peak times when traffic volumes and pedestrian movement is the highest.

▪ The potential risks of accidents to pedestrians and commuters while in the immediate vicinity of construction sites shall be conveyed to them in order to educate them and gain their cooperation and minimize the risk of accidents.

▪ Employ flag persons to control traffic at the work sites for safety reasons when construction equipment is entering or leaving the work area.

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Environmental Objectives Mitigation Measures Timing to Location to implement Responsibility Concern (MM) recommended implement MM MM Implementation Monitoring ▪ Provide sufficient lighting at night within and in the vicinity of construction sites.

▪ Regularly monitor traffic conditions along access roads to ensure that project vehicles are not causing congestion.

▪ Define and observe schedules for different types of construction traffic trips (e.g., transport of pre-cast sections, haulage of spoils, delivery of construction materials, etc.).

▪ As much as possible, schedule delivery of construction materials and equipment as well as transport of spoils during non-peak

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Environmental Objectives Mitigation Measures Timing to Location to implement Responsibility Concern (MM) recommended implement MM MM Implementation Monitoring hours.

▪ Avoid movements of noisy vehicles during night time in vicinity of the residential settlements.

▪ Implement suitable safety measures to minimize risk of adverse interactions between construction works and traffic flows through provision of temporary signals or flag controls, adequate lighting, fencing, signage and road diversions.

▪ Ensure relocation of any affected public transport infrastructure (but stops, shelters etc.) prior to commencement of

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Environmental Objectives Mitigation Measures Timing to Location to implement Responsibility Concern (MM) recommended implement MM MM Implementation Monitoring works.

▪ Provide advance notification to the community regarding changes to public transport facilities or routes.

▪ Comply with traffic regulations and avoid, where possible, roads with the highest traffic volumes, high density of sensitive receivers or capacity constraints are not used as access to and from the construction areas and spoil disposal sites.

▪ Install temporary accesses to properties affected by disruption to their permanent accesses.

▪ Reinstate good quality

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Environmental Objectives Mitigation Measures Timing to Location to implement Responsibility Concern (MM) recommended implement MM MM Implementation Monitoring permanent accesses following completion of construction.

Air Quality To minimize air 1. Water will be During A list of locations to be Contractor TMTD/CSC emissions sprinkled every three Construction included in contract shall maintain effectively and hours and at a higher Works and other sensitive acceptable avoid frequency if felt areas identified by the standards. complaints due necessary, at all CSC in project area. CSC to to the airborne construction sites to supervise particulate suppress dust activities. matter released emissions. to the atmosphere. 2. All heavy equipment and machinery shall be fitted in full compliance with the national and local regulations. (Relevant regulations are in the Motor vehicles fitness rules and Highway Act).

3. Stockpiled soil and sand shall be slightly wetted before loading, particularly in windy conditions.

4. Fuel-efficient and well-maintained haulage

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Environmental Objectives Mitigation Measures Timing to Location to implement Responsibility Concern (MM) recommended implement MM MM Implementation Monitoring trucks shall be employed to minimize exhaust emissions.

5. Vehicles transporting soil, sand and other construction materials shall be covered with tarpaulin.

6. Limitations to speeds of such vehicles necessary. Transport through densely populated area should be avoided.

7. Concrete plants to be controlled in line with statutory requirements and shall not be close to residential settlements.

8.Stack height of generators will be at least 3 meters above the ground.

9. Project traffic will maintain maximum speed limit of 20 km/hr on all unsealed roads

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Environmental Objectives Mitigation Measures Timing to Location to implement Responsibility Concern (MM) recommended implement MM MM Implementation Monitoring within project area.

10. A minimum distance of 300 meters will be ensured between batching plant(s) and the nearest residential settlements.

Noise Levels To minimize ▪ Unnecessary revving During A list of locations to be Contractor TMTD / CSC noise level of engines will be Construction included in contract should increases avoided and Works and other sensitive maintain the during areas identified by the acceptable equipment will be construction CSC in project area. standards activities. switched off when not in use; CSC to ▪ Install temporary noise supervise barriers made of relevant plywood or acoustical activities. blankets around noisy operation where necessary to comply with project noise limits; ▪ Internal haul routes will be kept well maintained; ▪ Drop heights of materials will be

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Environmental Objectives Mitigation Measures Timing to Location to implement Responsibility Concern (MM) recommended implement MM MM Implementation Monitoring minimised; ▪ Plant and vehicles will be sequentially started up rather than all together; ▪ Use of effective exhaust silence systems or acoustic engine covers as appropriate; ▪ As far as reasonably practicable, sources of significant noise will be enclosed; ▪ Plant will always be used in accordance with manufacturers’ instructions. Care will be taken to site equipment away from noise-sensitive areas. Where possible, loading and unloading will also be carried out away from such areas; ▪ Regular and effective maintenance by trained personnel will

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Environmental Objectives Mitigation Measures Timing to Location to implement Responsibility Concern (MM) recommended implement MM MM Implementation Monitoring be undertaken to keep plant and equipment working to manufacturers specifications; and ▪ Screening e.g. noise barriers and blinds will be used as appropriate. ▪ Record and respond to complaints according to the established grievance redress mechanism. ▪ Keep nearby residences informed in advance about noisy activities during various construction phases. ▪ Vehicles and mechanical plants used for the purpose of the works shall be fitted with effective exhaust silencers, maintained in good and efficient working

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Environmental Objectives Mitigation Measures Timing to Location to implement Responsibility Concern (MM) recommended implement MM MM Implementation Monitoring order and operated in such a manner as to minimise noise emissions. The construction contractor shall ensure that all plant complies with the relevant statutory requirements; ▪ Machines in intermittent use should be shut down or throttled down to a minimum when not in use; ▪ Compressors should be fitted with properly lined and sealed acoustic covers which should be kept closed whenever in use. Pneumatic percussive tools should be fitted with mufflers or silencers of the type recommended by the manufacturers; ▪ Equipment which

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Environmental Objectives Mitigation Measures Timing to Location to implement Responsibility Concern (MM) recommended implement MM MM Implementation Monitoring breaks concrete, brickwork or masonry by bending or bursting or "nibbling" shall be used in preference to percussive tools. Where possible, avoid the use of impact tools where the construction works is close to occupied premises; ▪ Rotary drills and busters activated by hydraulic, chemical or electrical power shall be used for excavating hard or extrusive material; ▪ Equipment powered by mains electricity shall be used in preference to equipment powered by internal combustion engine or locally generated electricity; ▪ Neither any part of the works nor any

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Environmental Objectives Mitigation Measures Timing to Location to implement Responsibility Concern (MM) recommended implement MM MM Implementation Monitoring maintenance of plant shall be carried out in such a manner as to cause unnecessary noise except in the case of an emergency when the work is absolutely necessary for the saving of life or property or the safety of the works; ▪ Plant shall be maintained in good working order so that extraneous noise from mechanical vibration, creaking and squeaking is kept to a minimum; and ▪ Noise emitting machinery which is required to run continuously shall be housed in a suitable acoustically lined enclosure. ▪ Train staff in construction best

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Environmental Objectives Mitigation Measures Timing to Location to implement Responsibility Concern (MM) recommended implement MM MM Implementation Monitoring practice. ▪ Construction operation times shall be limited to 07:00 to 22:00 daily ▪ Perform independent periodic noise monitoring to demonstrate compliance with project noise limits.

Excavated Significant A detailed Plan for During Project area Contractor and TMTD/ CSC Material volumes of management and construction the CSC (Earthworks) activity Disposal clay/mud shall disposal of Excavated be excavated Material must be from the KGA developed. This Plan ground. Unless must identify suitable a suitable location(s) prior to disposal commencement of location and excavation works and efficient require the engaging of transport experienced and mechanism for credible third parties for disposal of this transport and disposal material is of this material in the arranged, it most efficient and could potentially effective manner without result in major any logistical or

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Environmental Objectives Mitigation Measures Timing to Location to implement Responsibility Concern (MM) recommended implement MM MM Implementation Monitoring health and management delays. aesthetics issues.

1. Buffer strips or During Project area Contractor and TMTD/ CSC other methods of construction the CSC physical separation activity around project sites shall be ensured to protect public from major hazards.

2. Siting and safety engineering criteria To ensure the shall be incorporated residents and to prevent failures due visitors to the to natural risks posed project area are Community by earthquakes, Health and kept safe during floods, fire, wind etc. Safety the construction

activity at the 3. Inventories of different work hazardous materials sites. shall be reduced through inventory management.

4. Process or storage conditions shall be modified to reduce potential consequences of an accidental off-site

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Environmental Objectives Mitigation Measures Timing to Location to implement Responsibility Concern (MM) recommended implement MM MM Implementation Monitoring release.

5. Improving of shut down and secondary containment to reduce amount of material escaping from containment and to reduce release of duration.

6. Reduce probability that releases will occur through improved site operations and control and through improvements in maintenance and inspection.

7. Reduce off-site impacts of releases through measures intended to contain explosions and fires such as alerting public, provision for evacuation of surrounding areas, establish safety zones

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Environmental Objectives Mitigation Measures Timing to Location to implement Responsibility Concern (MM) recommended implement MM MM Implementation Monitoring around each work site and ensure provision of emergency medical services to the public.

8. Work areas outside project area, particularly where machinery is involved will be roped off and constantly monitored to ensure local residents and children in particular stay away.

9. No machinery will be left unattended, particularly in running condition.

10. Community will be briefed on traffic safety, especially women who are the main care providers to children.

11. Speed limit of 20 km/hr will be maintained by all project related

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Environmental Objectives Mitigation Measures Timing to Location to implement Responsibility Concern (MM) recommended implement MM MM Implementation Monitoring vehicles on section of roads and passages adjacent to houses in project area.

To ensure that Worker Health the CSC, 1. The Contractor will Induction of all All staff members in all Contractor and TMTD & CSC and Safety contractor and provide his staff with a relevant staff categories. Monthly the CSC and to observe workers provided detailed required for induction and six record details and record understand and orientation on the safety implementation of month refresher course success have the protocols to be followed EMP. as necessary until capacity to at all times during the At early stages of contractor complies. ensure the construction work to construction for environmental minimize the risk of all construction requirements accidents. employees as far and 2. The Contractor shall as reasonably implementation provide bi-monthly practicable. of mitigation refresher sessions to his measures. staff on the safety precautions to be followed during the construction activity. 3. The Contractor will closely monitor his staff at all times and will take strict action against any non-compliance with these protocols and will ensure at all times that the safety of the commuters and traffic in the vicinity of the project

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Environmental Objectives Mitigation Measures Timing to Location to implement Responsibility Concern (MM) recommended implement MM MM Implementation Monitoring site are kept a priority. 4. Random Health and Safety audits from PMU and/or a third party shall be conducted.

▪ No untreated effluent During At labor camps Contractor will be released into Construction TMTD/ the environment. CSC

▪ Closed sewage treatment system will treat the effluent, which will then be Prevent disposed of in a soak untreated pit or will be used for Labor Camp effluent from plantation. Effluent being released

into the ▪ Water being released environment. from any batching plant(s) must be treated as per requirements of SEQS prior to release to sewerage system/any other water body. Any drainage structures, During Project site Contractor Soil Erosion culverts or pipes Construction TMTD/ and To prevent soil crossing the project site CSC Sedimentation erosion may need to be modified or protected

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Environmental Objectives Mitigation Measures Timing to Location to implement Responsibility Concern (MM) recommended implement MM MM Implementation Monitoring and the detailed designs must make provisions to protect or re-provision all infrastructure that may be affected by the construction works.

1. It will be ensured that During Project site Contractor spill prevention trays are Construction TMTD/ provided and used CSC during refueling. Also, on-site maintenance of construction vehicles and equipment will be avoided as far as possible. In case on-site maintenance is unavoidable, tarpaulin To prevent or other impermeable Soil contamination material will be spread Contamination of soil on the ground to prevent contamination of soil. 2. Regular inspections will be carried out to detect leakages in construction vehicles and equipment and all vehicles will be washed in external commercial facilities. 3. Fuels, lubricants and

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Environmental Objectives Mitigation Measures Timing to Location to implement Responsibility Concern (MM) recommended implement MM MM Implementation Monitoring chemicals will be stored in covered bounded areas, underlain with impervious lining. Appropriate arrangements, including shovels, plastic bags and absorbent materials will be available near fuel and oil storage areas.

1. All unpaved exposed During Project site Contractor areas at the project Construction TMTD/ sites will be compacted CSC to minimize water erosion and all areas containing potentially hazardous materials will To prevent run be hydrologically Drainage and off and issues Storm water isolated from the due to poor Run-off remaining site. drainage

2. It shall be ensured that natural drainage is not hampered or blocked in any way at any of the sites.

Hazardous and To manage all 1. A waste management During Project site Contractor Non-hazardous hazardous and plan will be developed Construction TMTD/ waste non-hazardous prior to the start of CSC management

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Environmental Objectives Mitigation Measures Timing to Location to implement Responsibility Concern (MM) recommended implement MM MM Implementation Monitoring waste as per construction. This plan international will cater to sorting of best practices. hazardous and non- hazardous materials prior to disposal, placing of waste bins at the project site for waste disposal and an onsite hazardous waste storage facility. 2. Periodic on-site audits of waste management will be undertaken along with auditing of waste disposal contractors and disposal facilities on regular basis to check that procedures are being followed. 3. Records of all waste generated during the construction period will be maintained. Quantities of waste disposed, recycled or reused will be logged on a Waste Tracking Register. 4. Licensed waste contractors will be engaged to dispose all

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Environmental Objectives Mitigation Measures Timing to Location to implement Responsibility Concern (MM) recommended implement MM MM Implementation Monitoring non-hazardous waste material that cannot be recycled or reused. 5. Training will be provided to personnel for identification, segregation and management of waste. Archaeological To protect any If evidence of any During Project site Contractor sites antiquities or archaeological remains Construction TMTD/ relics that might is found during the CSC and be excavated construction activities, department of the excavation work will Archaeology be stopped immediately and necessary next steps taken to identify the archaeological discovery based on the ‘Chance Find’ procedures, provided as Annexure H. Vegetation and To protect 1. Wherever trees have During Along BRT Corridor Contractor Wildlife Loss vegetation and to be felled, mitigation Construction TMTD/ wildlife loss in will be required in the CSC project area. form of reinstatement and compensatory planting. Soft landscaping shall be installed in the median under the elevated sections to improve the appearance of the

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Environmental Objectives Mitigation Measures Timing to Location to implement Responsibility Concern (MM) recommended implement MM MM Implementation Monitoring completed works. In case existing trees and topsoil (down to 0.5 meters) is removed, the top soil shall be retained for elsewhere in the project. The wood that would be cut will not be burnt on site. All stumps and surplus vegetation shall be disposed of at landfills via routes or other destinations as designated and instructed by TMTD focal points. 2. It will be ensured that willful killing; trapping and trade of faunal species will be strictly prohibited. 3. Monitoring of tree survival has to be conducted. 4. Tree plantation will be undertaken at the project site to compensate for the vegetation lost during construction in the minimum ratio of 3:1 i.e. 3 saplings to be planted

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Environmental Objectives Mitigation Measures Timing to Location to implement Responsibility Concern (MM) recommended implement MM MM Implementation Monitoring for every tree felled given the possible difficulties with establishing trees and low survival rates of young trees. 5. Burning of vegetation as fuel will be prohibited. Employment To prevent 1. A transparent hiring During Project area Conflicts conflicts of the policy shall be construction Contractor and TMTD/ CSC project work adopted and local activity the CSC force with the communities in residents in the project area will be project area informed of this policy.

2. It shall be ensured that maximum number of unskilled and semi-skilled jobs will be provided to residents of Karachi and its suburbs.

3. TMTD will ensure a balanced process of employment for communities in project area. Communicable To prevent A communicable During Project area diseases outbreak of diseases prevention construction Contractor and TMTD/ CSC

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Environmental Objectives Mitigation Measures Timing to Location to implement Responsibility Concern (MM) recommended implement MM MM Implementation Monitoring diseases program will be activity the CSC prepared for construction workers or residents near the construction sites. Loss of To ensure to The existing western During Project area Contractor CSC and Access loss of access face, presently being construction TMTD around takes place, activity used for the Green Line project site particularly for the BRT works will only be communities used for all construction residing close works. No other access to the project way will be used, thus site. ensuring the residential settlements located on the other faces of the project site are not disturbed. Impact on To ensure Compensation shall be During Project area Contractor CSC and Vendors vendors are not paid as per Entitlement construction TMTD affected activity Matrix provided in the negatively due to the Resettlement Action construction Plan (RAP) and it shall works be ensured that any grievances received are adequately addressed. Loss of access To ensure no The Contractor shall During Project area Contractor CSC and

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Environmental Objectives Mitigation Measures Timing to Location to implement Responsibility Concern (MM) recommended implement MM MM Implementation Monitoring in project area loss of access ensure that: construction TMTD for businesses, activity residents and ▪ Construction activities any other are phased out stakeholders in project area. ▪ At no point during the construction works will the road be completely closed off ▪ Access shall not be blocked due to construction works/equipment/vehic les to any of the businesses and/or residences.

Operational Stage To ensure 1. Buses and all Once Staging operational mechanical equipment Facility operation phase of such as generators shall commences. Staging Facility undergo regular does not have maintenance and shall adverse impact be tuned to maintain Residential locations O&M Air Quality Trans Karachi on air quality of engine efficiency and around Staging Facility Contractor project area minimize emissions in compliance of NEQS limits.

2.Stack height of

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Environmental Objectives Mitigation Measures Timing to Location to implement Responsibility Concern (MM) recommended implement MM MM Implementation Monitoring generators (if any) will be at least 3 meters above the ground.

3.Regular maintenance of BRT buses shall be conducted and optimal engine efficiency shall be ensured through use of high quality fuel.

4. Regular monitoring of PM levels will be conducted. Residential locations around project site will be monitored for PM levels and potential PM sources will be identified and customized mitigation measures developed and implemented to reduce PM levels, if required. To ensure noise 1. Tuning and levels remain maintenance of within buses and Once Staging Residential locations O&M Noise Levels acceptable mechanical Facility operation Trans Karachi around Staging Facility Contractor NEQS limits equipment such as commences. during Staging buses on regular Facility basis to minimize

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Environmental Objectives Mitigation Measures Timing to Location to implement Responsibility Concern (MM) recommended implement MM MM Implementation Monitoring operation noise levels and comply with NEQS limits.

2. Strict driving protocols shall be followed such as no honking etc.

Solid Waste To prevent Proper waste Once Staging At Staging Facility Disposal contamination management plan will Facility operation of the areas be prepared and commences around the implemented to ensure O&M Trans Karachi Staging Facility waste collection, Contractor due to improper transfer and disposal. solid waste disposal. Land Accidental fuel Proper waste Once Staging At Staging Facility Contamination and material management plan and Facility operation spill response plan will commences spills could take need to be place from the implemented. different BRT O&M Trans Karachi buses visiting Contractor the Staging facility on a daily basis.

TMTD Transport and Mass Transit Department PD Project Director CSC Construction Supervision Consultant

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O&M Operation & Maintenance

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8 Public Consultation and Information Disclosure

8.1 Introduction 364. Public participation and community consultation has been taken up as an integral part of environmental and social assessment process of the proposed Staging facility development. Detailed public consultations have been conducted from March’19 onwards in the project area. Consultation was used as a tool to inform and educate stakeholders about the proposed action both before and after the development decisions were made. It assisted in identification of the problems associated with the project as well as the needs of the population likely to be impacted.

365. This participatory process helped in reducing the public resistance to change and enabled the participation of the local people in the decision making process. Public consultations have been carried out in the project area with the objectives of minimizing probable adverse impacts of the project and to achieve speedy implementation of the project through bringing in awareness among the key stakeholders on the benefits of the project.

366. Public participation and consultation are the major keys to any success in infrastructure development. The sustainability of any infrastructure development depends on the participatory planning in which public consultation plays a major role.

367. Aiming at promotion of public understanding and discussion on the local needs and concerns of the key stakeholders i.e., KGA management, local community members and government officials. Consultations were conducted through individual interviews and formal consultations.

368. The environmental assessment process under the Pakistan Environmental Protection Act 1997, requires the disclosure to the public after the statutory IEE / EIA has been accepted by the relevant EPA, to be in strict adherence to the rules. In this IEE, the consultation process was performed to satisfy the ADB requirements (Social Safeguard Policy 2009).

8.2 Objective of Consultations 369. The basic objective of the consultations is as follows:

▪ Understand views of affected key stakeholders and generate ideas regarding the expected demands of the affected parties; ▪ Disseminate information to the affected persons about the project in terms of its activities and scope of work; and understand the views and perceptions of the people affected and local communities with reference to the proposed staging facility development, including land acquisition and/or loss of property and its due compensation.

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▪ Identify and assess major economic and social information and characteristics of the project area to enable effective social and resettlement planning and its implementation. ▪ Resolve issues related to impacts on community property and their relocation. ▪ Examine PAPs’ opinions on health safety issues during the construction period on garbage materials, waste materials and other pollution issues. ▪ Identify levels and extent of community participation in project implementation and monitoring. ▪ Establish an understanding for identification of overall developmental goals and benefits of the project. ▪ Disseminate information to and develop a thorough coordination with different government, non-government and public private sector stakeholder line agencies ensuring their participation and mobilization of support in the process for the successful planning and implementation of the project. ▪ Assess the local people's willingness to get involved with the project; and enumerate the measures to be taken during the implementation of the project.

8.3 Identification of Main Stakeholders 370. The primary stakeholders identified are the KGA management and the local communities residing in the project area in close proximity to the KGA ground. All these stakeholders have different types of stakes according to their interests and professions.

8.4 Approach for Public Consultation 371. Consultations were planned and conducted with different stakeholders such as the KGA management and the affected persons as well as public sector representatives from different line departments.

372. The approach adopted towards public participation was intended to disseminate information, solicit inputs and develop consensus on issues and subsequently propose mitigation measures. This approach was put into practice through consultations and public meetings with relevant stakeholders in the project area.

373. The project related information was shared with all key stakeholders by engaging local personnel with strong linkages in the project area who jointly helped to explain the project scope to the different stakeholders. Through detailed briefings, it was ensured that complete clarity was provided to the stakeholders regarding the possible environment related issues to be faced by the key receptors in the project area.

374. It is important to emphasize that the public consultation is a continual process that shall be conducted throughout the project development phase with different national and international project stakeholders being consulted and their respective comments and concerns being addressed through dialogue and discussion. These consultations shall continue during the project detailed design phase and shall be completed prior to review of this report for separate approvals from ADB and

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SEPA, with the finalized consultation findings incorporated into the last version of this report.

8.5 Consultations 375. Detailed and extensive consultations with different key stakeholders have been conducted to date, consisting of the KGA management, local communities as the directly project affected persons as well as key officials and representatives of the relevant public sector agencies such as the Karachi Municipal Corporation. The details of the persons consulted are provided in Annexure E.

376. The details of the stakeholders consulted along with the key discussion points and the responses to their comments/concerns/suggestions are provided in the Table 8.1 below.

8.6 Key Discussion points 377. The key comments and concerns raised as a result of the consultations as part of the scoping activity are as follows:

▪ Restoration of existing motorbike parking space along-with the cricket ground must take place. ▪ There are some exposed and uninsulated electricity wires on the M.A Jinnah Road, which should be insulated to avoid any mishap. ▪ The work activities going on at the adjacent Green Line works creates dust emissions and the flats which are facing the M.A Jinnah Road and KGA Ground are exposed to large volumes, particularly in windy conditions. ▪ Prior notice should be provided before commencement of works for the staging facility. ▪ Dust and noise levels must be minimized through all possible measures. Sprinkling must be conducted as much as possible so that huge clouds of dust do not reach their residences. ▪ Expressed positive views about the staging facility with a major reason that the existing conditions will be restored. ▪ He mentioned that it must be ensured by the Contractor that the existing route being used for the Green Line works is used by the vehicles for the staging facility development. ▪ Access of the residences around the KGA must be blocked any more than the existing situation due to the Green line works.

▪ It was hoped that some employment opportunities will be provided for the residents for the proposed Staging facility development.

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▪ It was mentioned that work in the evening hours onwards must not be allowed or must be restricted as far as possible to enable the residents to rest properly in the evenings and night-time.

The detailed comments received from the different stakeholders are provided as Table 8.1 below.

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Table 8.1: Summary of Public Consultations

S/No Name Contact No. CNIC (if Location/Address Remarks/Comments/Suggestions . available) of Interview

1. KGA Gymkhana 03332137429 Not provided KGA Gymkhana - M. ▪ Mr. De Souza expressed his concern that (Assis de A. Jinnah Rd, Jacob no written documents have been provided General Secretory: Mr. Assis Souza) Lines Central Jacob to the KGA regarding the details / timelines and other necessary details de Souza Lines, Karachi. regarding the proposed construction of Staging Facility till now. All they have 03108011103 come to know till now is based on verbal Name of President: Mr. (Lenny Dias) information. Lenny Dias ▪ He expressed satisfaction with the overall project concept plan due to its salient features such as Underground Parking and Restoration of existing Cricket Ground. ▪ Their demands include the following: a- Restoration of existing motorbike parking space along-with the cricket ground.

b- There are some exposed and uninsulated electricity wires on the M.A Jinnah Road which should be insulated to avoid any mishap.

c- Mr. De Souza explained that they pay utility bills of Rs. 600, 000/- approximately per month, which includes payment for water as well. It has been requested that a water

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connection may please be provided to the Cricket Ground after the completion of construction activities.

2. Kaleem Ahmad 03322483711 Not provided Flat No. C. 109 - ▪ Satisfied with the proposed construction Saachi Tower, M.A of staging facility as the original Jinnah Road, environmental setting will be fully restored. Karachi. ▪ Suggested that emphasis should be provided on horticulture, especially on the M. A. Jinnah Road after the completion of corridor / underpass works. 3. Kashif 03132484908 Not provided Flat No. C. 107 - ▪ Expressed his concerns about the Saachi Tower, M.A extremely slow pace of work on the Jinnah Road, adjacent Green Line Underpass, which is causing severe problems to the residents Karachi. while leaving and approaching their residents for everyday activities. ▪ For the staging facility, he was satisfied with the overall plan and components of the facility as the existing environmental setting will be restored with some up

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gradation.

4. M. Ammar 03002906367 42201- Flat No. C. 105 - ▪ The work activities going on at the 9348110-1 Saachi Tower, M.A adjacent Green Line works creates dust Jinnah Road, emissions and the flats which are facing the M.A Jinnah Road and KGA Ground Karachi. are exposed to large volumes, particularly in windy conditions. ▪ Pace of work is extremely slow and it should be enhanced so that the residents could get some relief since their everyday activities are badly disturbed. ▪ For the proposed staging facility, he showed overall positive views and suggested that emphasize should be given on controlling dust as Block-C of Saachi Apartments is directly facing the KGA Ground. ▪ He also requested that, for the day time, they will bear the noise of construction activities as they are already used-to of heavy noise since their residence is located at the Main M.A. Jinnah road, however for the night time, work activities should be restricted. 5. Rashid Aziz 03333713133 Not provided Flat No. C. 106 - ▪ He felt that prior notice should be Saachi Tower, M.A provided before commencement of works Jinnah Road, for the staging facility. ▪ Dust and noise levels must be minimized

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Karachi. through all possible measures. Sprinkling must be conducted as much as possible so that huge clouds of dust do not reach their residences. ▪ Expressed positive views about the staging facility with a major reason that the existing conditions will be restored. 6. Bilal Usman 03219284039 Not provided Flat No. C. 201 - ▪ He mentioned that it must be ensured by Saachi Tower, M.A the Contractor that the existing route Jinnah Road, being used for the Green Line works is used by the vehicles for the staging facility Karachi. development. ▪ Access of the residences around the KGA must be blocked any more than the existing situation due to the Green line works. ▪ Expressed positive views about the staging facility with a major reason that the existing conditions will be restored. 7. Sabeel Khan 03329673229 Not provided Flat No. C. 202 - ▪ He informed that he belongs to a very Saachi Tower, M.A poor family with no personal transport Jinnah Road, (Car or Motorcycle). He mentioned that they are entirely dependent on public Karachi. transport for commuting and unfortunately the public transport system is badly disturbed in the area due to slow pace of construction work activities on the adjacent Green Line Project. ▪ For the proposed staging facility, he expressed the hope to be provided some employment opportunities for the Staging facility development. ▪ Also, he mentioned that work in the evening hours onwards must not be allowed or must be restricted as far as

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possible to enable the residents to rest properly in the evenings and night-time. 8. Touseef Thebo 03002955285 Not provided Flat No. C. 301 - ▪ His major concern was related to dust as Saachi Tower, M.A their apartment is situated on the third Jinnah Road, floor, therefore they are receiving large volumes of dust from the Green Line Karachi. works. 9. Sohail Yunus 03009290821 424011886541 Flat No. C. 302 - ▪ It must be ensured that ground is restored 9 Saachi Tower, M.A as per existing situation to ensure the Jinnah Road, aesthetics of the area are not adversely affected. Karachi. ▪ Proper safety barricading must be installed around the work site since a deep pit will be created due to excavation and the safety of the community, particularly its children must be ensured. 10. Zabih Siddiqui 03218109604 Not provided Flat No. C. 303 - ▪ A Contractor that has experience and Saachi Tower, M.A reputation for timely completion of works Jinnah Road, must be engaged to ensure the works are not delayed as is the case for the Green Karachi. Line. ▪ Water sprinkling and all other required measures must be implemented to minimize dust emissions. 11. Khalid 03052086271 Not provided Flat No. C. 305 - ▪ It must be ensured that worker camps are Saachi Tower, M.A not developed near our residences to Jinnah Road, ensure our safety and proper sanitary facilities must be provided to them to Karachi. ensure they do not defecate openly. ▪ Both noise and dust emissions must be minimized as far as possible by implementing all required measures. 12. Yousaf Mirza 03053442353 424054191188 Flat No. C. 305 - ▪ He requested that for the day time, they Saachi Tower, M.A will bear the noise of construction activities as they are already used-to of

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6 Jinnah Road, heavy noise since their residence is Karachi. located at the Main M.A. Jinnah road, however for the night time, work activities should be restricted. 13. Shafqat Hameed 03346545323 424041886591 Flat No. C. 305 - ▪ Dust and noise levels must be minimized 1 Saachi Tower, M.A through all possible measures. Sprinkling Jinnah Road, must be conducted as much as possible so that huge clouds of dust do not reach Karachi. their residences. ▪ Expressed the desire that works must be completed in the shortest possible duration. 14. Zahid Baloch 03459052346 421408819615 Flat No. C. 305 - ▪ A Contractor that has experience and 4 Saachi Tower, M.A reputation for timely completion of works Jinnah Road, must be engaged to ensure the works are not delayed as is the case for the Green Karachi. Line. ▪ Expressed positive views about the staging facility with a major reason that the existing conditions will be restored. 15. Khanzada Ahsan 03215943325 424886540111 Flat No. C. 305 - ▪ He expressed the hope to be provided 9 Saachi Tower, M.A some employment opportunities for the Jinnah Road, Staging facility development. ▪ Dust and noise levels must be minimized Karachi. through all possible measures. Sprinkling must be conducted as much as possible so that huge clouds of dust do not reach their residences. ▪ Safety and convenience of the local communities must be kept a priority during the project works.

16. Yasir Mehmood 03235538593 418408426541 Flat No. C. 305 - ▪ It must be ensured that ground is restored 9 Saachi Tower, M.A as per existing situation to ensure the Jinnah Road, aesthetics of the area are not adversely

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Karachi. affected. ▪ Proper safety barricading must be installed around the work site since a deep pit will be created due to excavation and the safety of the community, particularly its children must be ensured. 17. Aqib Sultan 03369348856 424865401181 Flat No. C. 305 - ▪ It must be ensured that worker camps are 9 Saachi Tower, M.A not developed near our residences to Jinnah Road, ensure our safety and proper sanitary facilities must be provided to them to Karachi. ensure they do not defecate openly. ▪ Contractor must conduct works in accordance with international best practices.

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8.7 General 378. The ADB Policy (SPS 2009) requires establishment of a local grievance redress mechanism to receive and facilitate resolution of the Displaced/Affected Persons concerns and grievances regarding the project’s social, resettlement and environment performance. The measures have been identified to mitigate any potential social and/or resettlement impacts to be caused due to implementation of the Project works.

379. However, in spite of best efforts, there is every chance that the individuals / households affected by the project or other stakeholders are dissatisfied with measures adopted to address adverse social impacts of the project. To address, such situation an effective Grievance Redress Mechanism (GRM) will be established to ensure timely and successful implementation of the project. It will also provide a public forum to the aggrieved to raise their objections and the GRM would address such issues adequately. It will receive, evaluate and facilitate the resolution of displaced persons’ concerns, complaints and grievances about the social and environmental performance at the level of the Project.

380. The GRM will aim to investigate charges of irregularities and complaints receive from any displaced persons and provide a time-bound early, transparent and fair resolution to voice and resolve social and environmental concerns link to the project.

381. The TMTD and PMU shall make the public aware of the GRM through public awareness campaigns, particularly to any DPs. The name of contact person(s) and his/her phone number, PMU contact numbers and the TMTD, will serve as a hotline for complaints and shall be publicized through the media and placed on notice boards outside their offices, construction camps of contractors, and at accessible and visible locations in the project area, and also shared with the DPs representatives. The project information brochure will include information on the GRM and shall be widely disseminated throughout the project area. Grievances can be filed in writing, via web-based provision or by phone with any member of the TMTD or PMU.

382. First tier of GRM. The PIU is the first tier of GRM which offers the fastest and most accessible mechanism for resolution of grievances. The PIU staff for environment and social safeguards will be designated as the key officers for grievance redressal. Resolution of complaints will be completed within seven (7) working days. Investigation of grievances will involve site visits and consultations with relevant parties (e.g., affected persons, contractors, traffic police, etc.). Grievances will be documented and personal details (name, address, date of complaint, etc.) will be included, unless anonymity is requested. A tracking number will be assigned for each grievance, including the following elements:

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▪ Initial grievance sheet (including the description of the grievance), with an acknowledgement of receipt handed back to the complainant when the complaint is registered; ▪ Grievance monitoring sheet, mentioning actions taken (investigation, corrective measures); ▪ Closure sheet, one copy of which will be handed to the complainant after he/she has agreed to the resolution and signed-off.

383. The updated register of grievances and complaints will be available to the public at the PIU office, construction sites and other key public offices in the project area. Should the grievance remain unresolved, it will be escalated to the second tier.

384. Second Tier of GRM. The PIU will activate the second tier of GRM by referring the unresolved issue (with written documentation) to the SMTA who will pass unresolved complaints upward to the Grievance Redress Committee (GRC). The GRC will be established by SMTA before start of site works. The GRC will consist of the following persons: (i) Project Director; (ii) representative District; (iii) representative of the affected person(s); (iv) representative of the local Deputy Commissioners office (land); and (v) representative of the SEPA (for environmental-related grievances). A hearing will be called with the GRC, if necessary, where the affected person can present his/her concerns/issues. The process will facilitate resolution through mediation. The local GRC will meet as necessary when there are grievances to be addressed. The local GRC will suggest corrective measures at the field level and assign clear responsibilities for implementing its decision within fifteen (15) working days. The contractor will have observer status on the committee. If unsatisfied with the decision, the existence of the GRC will not impede the complainant’s access to the Government’s judicial or administrative remedies.

385. The functions of the local GRC are as follows: (i) resolve problems and provide support to affected persons arising from various environmental issues and including dust, noise, utilities, power and water supply, waste disposal, traffic interference and public safety as well as social issues and land acquisition (temporary or permanent); asset acquisition; and eligibility for entitlements, compensation and assistance; (ii) reconfirm grievances of displaced persons, categorize and prioritize them and aim to provide solutions within a month; and (iii) report to the aggrieved parties about developments regarding their grievances and decisions of the GRC.

386. The SMTA officers will be responsible for processing and placing all papers before the GRC, maintaining a database of complaints, recording decisions, issuing minutes of the meetings and monitoring to see that formal orders are issued and the decisions carried out.

387. Third tier of GRM. In the event that a grievance cannot be resolved directly by the PIUs (first tier) or GRC (second tier), the affected person can seek alternative redressal through the district or sub-district committees as appropriate. The PIUs or

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GRC will be kept informed by the district, municipal or national authority. The grievance redress mechanism and procedure are depicted in the Figure 9.1 below. The monitoring reports of the EMP and RP implementation will include the following aspects pertaining to progress on grievances: (i) Number of cases registered with the GRC, level of jurisdiction (first, second and third tiers), number of hearings held, decisions made, and the status of pending cases; and (ii) lists of cases in process and already decided upon may be prepared with details such as Name, ID with unique serial number, date of notice, date of application, date of hearing, decisions, remarks, actions taken to resolve issues, and status of grievance (i.e., open, closed, pending).

Figure 8.1: Grievance Redress Mechanism

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9 Conclusions and Recommendations

388. This IEE study has been prepared for the Staging facility to be constructed adjacent to the Numaish station, under the existing cricket ground of Karachi Goan Association (KGA), which is a historic part of Karachi city.

389. The development of the proposed Staging facility is necessary as it will help in optimizing and adjusting fleet operations as the demand varies along the day. Additionally, it shall provide a turnaround facility for routes that terminate at Numaish, and will thus reduce the dead mileage for operations without passengers.

390. Primary and secondary data has been collected and used to assess the environmental impacts of the Project. Detailed baseline monitoring consisting of recording ambient air quality and noise levels has been conducted. This IEE report highlights all potential environmental impacts associated with the Project and recommends mitigation measures. Any environmental impacts associated with the project need to be properly mitigated, through the existing institutional arrangements described in this report.

391. Consultations have been conducted with the key stakeholders in the project area consisting of the KGA management, business community, represented by various trade unions through the platform of the Karachi Chambers of Commerce and Industry and representatives of different public sector organizations etc.

392. The majority of the environmental impacts are associated with the construction phase of the project such as community health and safety, deterioration of air quality, high noise levels, traffic management, to name a few.

393. The implementation of mitigation measures during this period will be the responsibility of the Contractor. Therefore, the required environmental mitigation measures will have to be clearly defined in the bidding and contract documents, and appropriately qualified environmental staff retained by the Consultant to supervise the implementation process. The EMP includes measures to minimize project impacts due to noise and air pollution, waste generation etc.

394. The associated facilities located next to the KGA ground possess a rich historical and cultural value since they are over 100 years old, although they are not listed as national and cultural heritage by the Government of Sindh. However, during the detailed design phase, all efforts need to be made to prevent demolition of the associated facilities of the KGA ground as far as possible by considering all alternatives (technical and location related) and through continuing of the stakeholder consultative process.

395. This project has been assigned environmental category ‘B’ in accordance with the ADB’s Safeguard Policy Statement (SPS) 2009 and Schedule I as per EPA, IEE

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and EIA Gazette Notification, 2000. Thus, this IEE study has been prepared for the proposed project.

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10 References

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Gaffney, G. and Shimp, D. 1997. Improving PM10 Fugitive Dust Emission Inventories. Sacramento, CA. California Air Resource Board. www.arb.ca.gov/emisinv/pubs/pm10tmp.pdf

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

Reagan, J. A. and C. A. Grant. Highway Construction Noise: Measurement, Prediction, and Mitigation. Special Report. US. Department of Transportation, Federal Highway Administration. Available from

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EPA, 1997: Guidelines for Public Consultation. Pakistan Environmental Protection Agency, Government of Pakistan

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GoP, 1997: Policy Guidelines for Preparation and Review of Environmental Reports:- Environmental Protection Agency, Government of Pakistan, November

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Survey of Pakistan, 1997. Atlas of Pakistan. Director Map Publication, Survey of Pakistan, Rawalpindi.

World Bank. 2005. OP 4.10 - Indigenous People. The World Bank Operational Manual. The World Bank. July 2005.

World Bank. 2003. Social Analysis Sourcebook, Incorporating Social Dimensions into Bank- Supported Projects. Social Development Department, The World Bank. December 2003.

World Bank. 2001. OP 4.12 - Involuntary Resettlement. The World Bank Operational

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