Initial Environmental Evaluation

Initial Environment Evaluation Report Document Stage: Draft Project Number: 38456-03 June 2009

PAK: MFF for Power Distribution Enhancement Program (Tranche 2)

Choa S aidan S hah – N. P . S ethe 132 kV Transmission Li ne and U pgradation of N .P S ethe 66 kV Grid Station to 132 kV

Prepared by Islamabad Electric Supply Company (HESCO), Governent of Pakistan for the Asian Development Bank (ADB).

The Initial Environmental Evaluation Report is a document of the borrower. The views expressed herein do n ot n ecessarily r epresent t hose of A DB’s B oard of D irectors, Ma nagement, or s taff, and m ay be preliminary in nature.

Pakistan: Power Distribution Enhancement MFF Project

(Loan 2178 SF-PAK)

INITIAL ENVIRONMENTAL EXAMINATION

Choa Saidan Shah - N.P.Sethe 132 kV Transmission Line and

Up-gradation of NP Sethe 66 kV Grid Station to 132 kV

Tranche 2

Submitted to:

Asian Development Bank June, 2009 by Islamabad Electric Supply Company

Government of the Islamic Republic of Pakistan

Power Distribution Enhancement Multitranche Financing Facility – Tranche 2- Choa Saidan Shah 132 kV Transmission Line and Up-gradation of NP Sethe 66 kV Grid Station to 132 kV

Initial Environmental Examination

Table of Contents

1. Introduction 1 1.1 Overview 1 1.2 Scope of the IEE Study and Personnel 3

2. Policy and Statuary Requirements in Pakistan 4 2.1 Statutory Framework 4 2.1.1 Pakistan Environmental Protection Act, 1997 4 2.1.2 Pakistan Environmental Protection Agency Review of IEE and EIA Regulations, 2000 4 2.1.3 National Environmental Quality Standards 6 2.1.4 Other Relevant Laws 6 2.2 Structure of Report 6

3. Description of the Project 7 3.1 Type of Project 7 3.2 Categorization of the Project 7 3.3 Need for the Project 7 3.4 Location and scale of project 8 3.5 Proposed Schedule for Implementation 10

4. DESCRIPTION OF THE ENVIRONMENT 11 4.1 Project Area 11 4.1.1 General Characteristics of Project Area 11 4.1 Affected Administrative Units 11 4.2 Physical Resources 11 4.2.1 Location, Topography, Geography, Geology, and Soils 11 4.2.2 Climate and Hydrology 12 4.2.3 Groundwater and Water Supply 12 Surface Water 12 4.2.4 Air Quality 13 4.2.5 Noise 13 4.3 Biological Resources 13 4.3.1 Protected Areas / National Sanctuaries 14 4.4 Economic Development 14 4.4.1 Agriculture, Livestock and Industries 14 Energy Sources 15 4.5 Social and Cultural Resources 15 4.5.1 Population Communities and Employment 15 4.5.2 Education and Literacy 15 4.5.3 Health Facilities 15

ii Power Distribution Enhancement Multitranche Financing Facility – Tranche 2- Choa Saidan Shah 132 kV Transmission Line and Up-gradation of NP Sethe 66 kV Grid Station to 132 kV

Initial Environmental Examination 5. Cultural Heritage and Community Structure 16

6. SCREENING POTENTIAL ENVIRONMENTAL IMPACTS AND MITIGATION MEASURES17 6.1 Project Location 17 6.1.1 Impact Assessment and Mitigation 17 6.2 General Approach to Mitigation 17 6.2.1 Cultural Heritage, Mosques, Religious Sites, and Social Infrastructure 18 6.3 Potential Environmental Impacts in construction 18 6.3.1 Encroachment, Landscape and Physical Disfiguration 18 6.3.2 Trees, Ecology and Protected Areas 19 6.3.3 Hydrology, Sedimentation, Soil Erosion 19 6.3.4 Air Pollution from Earthworks and Transport 19 6.3.5 Noise, Vibration and Blasting 20 6.3.6 Sanitation, Solid Waste Disposal, Communicable Diseases 20 6.4 Potential Environmental Impacts in operation 21 6.4.1 Air pollution and noise from the enhanced operations 21 6.4.2 Pollution from oily run-off, fuel spills and dangerous goods 21 6.5 Enhancement 22

7. INSTITUTIONAL REQUIREMENTS & ENVIRONMENTAL MANAGEMENT PLAN 23

8. PUBLIC CONSULTATION AND INFORMATION DISCLOSURE 26 8.1 Approach to Public Consultation 26 8.2 Public Consultation Process 26 8.3 Results of Public Consultation 26

9. CONCLUSIONS 27 9.1 Findings and Recommendations 27 9.2 Summary and Conclusions 27

iii Power Distribution Enhancement Multitranche Financing Facility – Tranche 2- Choa Saidan Shah 132 kV Transmission Line and Up-gradation of NP Sethe 66 kV Grid Station to 132 kV

Initial Environmental Examination Figures and Maps

Figure 1.1 Pakistan EIA Process Figure 1.2 Letter from EPA Figure 2.1 Location of Choa Saidan Shah-N.P.Sethe TL

Attachements Attachement 1 Environmental Management Plan (matrix) Attachment 2 Monitoring Plan (matrix) Attachment 3 Summary of Public Consultation Attachment 4 Preliminary program for design, construction and commissioning Attachment 5 Overall Trees and other productive infrastructures Attachment 6 Villages and infrastructure Attachment 7 Trees affected Attachment 8 Photographs Attachment 9 Typical Bunds for Transformers

Name Initials Date Prepared by Abdul Razzaq Saleemi

Authorized by Javed Rashid

IESCO

iv Power Distribution Enhancement Multitranche Financing Facility – Tranche 2- Choa Saidan Shah 132 kV Transmission Line and Up-gradation of NP Sethe 66 kV Grid Station to 132 kV

Initial Environmental Examination ABBREVIATIONS

ADB Asian Development Bank COI Corridor of Influence CSP Country Strategy Program DFO Divisional Forest Officer DIZ Direct Impact Zone DoF Department of Forests EA Environnemental Assessment EARF Environment Assessment Review Framework EIA Environment Impact Assessment EMP Environmental Management Plan GDP ` Gross Domestic Product GIS Gas Insulated Switchgear GOP Government of Pakistan GS Grid Station GSS Grid Sub-Station LARP Land Acquisition and Resettlement Plan Leq Equivalent sound pressure level MPL Maximum permissible level NEQS National Environmental Quality Standards NGO Non Governmental Organization PC Public consultation PEPA Punjab Environmental Protection Agency PEPAct Pakistan Environment Protection Act 1997 (as regulated and amended) PPMS Project Performance Monitoring System REA Rapid Environmental Assessment SIA Social Impact Assessment S-P Subproject SR Sensitive Receiver TL Transmission line TOR Terms of Reference

Rupee, PKR Unit of Pakistan currency. $US approx Rs. 79.8

v Power Transmission Enhancement Multitranche Financing Facility- Choa Saidan Shah to N.P.Sethe 132 kV Transmission Line and Up-gradation of NP Sethe 66 kV Grid Station to 132 kV Initial Environmental Examination 1. Introduction

1.1 Overview 1. This document is the Initial Environmental Examination for the Tranche 2 sub project - Choa Saidan Shah to N.P.Sethe 132 kV Transmission Line and Up-gradation of NP Sethe 66 kV Grid Station to 132 kV proposed by Islamabad Electricity Supply Company; (IESCO) under Asian Development Bank (ADB) financed Power Distribution and Enhancement Multi-tranche Finance Facility (PDEMFF) proposed by Islamabad Electricity Power Company [IESCO] [Fig1.1 and Fig1.2]. The IEE has been prepared according to the ADB Guidelines.

2. Government of Pakistan (GoP) has requested ADB to provide the PDEMFF to facilitate investments in power distribution and development of networks of eight independent distribution companies (DISCOs) that distribute power to end user consumers. The funding from ADB is expected to be released in stages (tranches). The Power Distribution Enhancement (PDE) Investment Program is part of the GoP long term energy security strategy. The proposed ADB intervention will finance new investments in PDE and assist capacity building of sector related agencies. The investment program will cover necessary PDE development activities in secondary transmission / distribution networks of eight DISCOs. The PDEMFF activities include extension (additional transformers) and augmentation (replacement of transformers with higher capacity) distribution line extensions, new and replacement distribution lines, additional substations, transformer protection and other non network activities such as automatic meter reading, construction equipment and computerized accounting. New distribution lines to and from various network facilities and some of the above activities will also be included in the later trenches. The proposed PDEMFF facility has been designed to address both investment and institutional aspects in the electrical power sector.

3. This IEE presents the results and conclusions of environmental assessment for the Choa Saidan Shah to N.P.Sethe 132 kV Transmission Line and Up-gradation of N.P. Sethe 66 kV Grid Station to 132 kV subproject proposed by IESCO, and is submitted by Pakistan Electric Power Company (PEPCO) on behalf of IESCO. PEPCO has been nominated by Ministry of Water and Power (MOWP) to act as the Executing Agency (EA) with each DISCO being the Implementing Agency (IA) for work in its own area. PEPCO‟s role in the processing and implementation of the investment program is that of a coordinator of such activities as preparation of PC-1s and PFRs (Periodic Financing Request), monitoring implementation activities; that includes submission of environmental assessments for all subprojects in all trenches of the PDEMFF under ADB operating procedures. An IEE has been carried out to fulfill the requirements of ADB Guidelines (May 2003). This IEE study report is used to complete the Summary Initial Environmental Examination (SIEE) for disclosure by ADB if necessary.

4. The environmental assessment requirements of the GoP for grid stations and power distribution subprojects are different to those of ADB. Under GoP regulations, the Pakistan Environmental Protection Agency Review of Initial Environmental Examination and Environmental Impact Assessment Regulations (2000) categorizes development subprojects into two schedules according to their potential environmental impact. The proponents of subprojects that have reasonably foreseeable impacts are required to submit an IEE for their respective subprojects (Schedule I). The proponents of subprojects that have more adverse environmental impacts (Schedule II) are required to submit an environmental impact assessment (EIA). Distribution lines and substations are included under energy subprojects and IEE is required for sub transmission / distribution lines of 11kV and less and large distribution subprojects (Schedule I). EIA is required by GoP for all subprojects involving sub transmission / distribution lines of 11kV and above and for Grid Station [DGS] substations (Schedule II).

Page 1 Power Transmission Enhancement Multitranche Financing Facility- Choa Saidan Shah to N.P.Sethe 132 kV Transmission Line and Up-gradation of NP Sethe 66 kV Grid Station to 132 kV Initial Environmental Examination

5. Initial subproject classification was carried out in 2009 and the Category is „B‟. Most of the construction impacts will take place with only local impacts and there are no potential significant environmental impacts associated with the T2 (tranche two) sub-subproject construction. Initial environmental reconnaissance and REA carried out by consultants under ADB guidelines in May 2009 indicated that all the T2 sub-subprojects will be Category B.1 Environmental Assessment Guidelines (ADB May 20031). Clarification has been sought from

1 Category A subprojects that are deemed by ADB's chief compliance officer to be environmentally sensitive for the purposes of (i) the 120 day rule, and (ii) the environmental management plan requirement could involve subprojects that are near or in environmentally sensitive areas. At this stage no component of the T2 sub-subprojects under consideration is actually within a critical area and therefore the MFF tranche as a whole is Category B.

Page 2 Power Transmission Enhancement Multitranche Financing Facility- Choa Saidan Shah to N.P.Sethe 132 kV Transmission Line and Up-gradation of NP Sethe 66 kV Grid Station to 132 kV Initial Environmental Examination Pakistan EPA on the requirements for environmental assessment for certain energy subprojects and for sub transmission / distribution lines. A Framework of Environmental Assessment (FEA) power extensions and augmentation subprojects was prepared by consultants and submitted to the Pakistan EPA, after hearings with provincial EPAs. In response to the FEA submitted by IESCO to the Pakistan EPA2 it has been clarified that all proponents must follow section 12 of the Pakistan Environmental Protection Act for all subprojects. Pakistan EPA has also assumed that all proponents will consult with the relevant provincial EPAs (PEPA) and follow their advice. In 2006 Punjab EPA requested disclosure of the scope and extent of each subproject in order that the Director General of PEPA can determine if additional land is required and the need for IEE or EIA. A review of the need for EIA/IEE for submission to GoP is therefore required by the relevant environmental protection agency, in this case the Punjab Environmental Protection Agency.

1.2 Scope of the IEE Study and Personnel 6. The Study Area included the identification of irrigation facilities, water supply, habitable structures, schools, health facilities, hospitals, religious places and sites of heritage or archaeological importance and critical areas (if any) within about 100m of the Transmission Line and DGS boundary. The works are generally envisaged to involve construction of the 132 kV transmission line from Choa Saidan Shah to N.P.Sethe and up-gradation of 66 kV DGS at N.P.Sethe. Construction of the bases, foundation pads and towers to support the distribution line will be carried out also under the same subproject by IESCO and supervised by the IESCO management.

7. The field studies were undertaken by the subproject‟s environment team with experience of environmental assessment for power subprojects in Pakistan. Mr. Abdul Razzaq Saleemi conducted preliminary scoping, survey and assessment activities, coordinated the field sampling and analysis, and were also responsible to supervise collation of information and co-ordinate the various public consultation activities. The team conducted preliminary scoping, survey and assessment activities, and carried out the report writing. Dr David Green (International Environmental Consultant of BPI) provided leadership and guidance in planning the field work and in finalization of the report. The environmental team also benefited from technical support and other information on the impacts of the proposed power works provided in feasibility summaries prepared with IESCO by expert consultants of BPI dealing with engineering, power distribution, socio-economic, re-settlement and institutional aspects.

8. A scoping and field reconnaissance was conducted on the subproject site, during which a Rapid Environmental Assessment was carried out to establish the potential impacts and categorization of subproject activities. The methodology of the IEE study was then elaborated in order to address all interests. Subsequently primary and secondary baseline environmental data was collected from possible sources, and the intensity and likely location of impacts were identified with relation the sensitive receivers; based on the work expected to be carried out. The significance of impacts from construction of the DGS was then assessed and, for those impacts requiring mitigation, measures were proposed to reduce impacts to within acceptable limits.

9. Public consultation (PC) was carried out in May 2009, in line with ADB guidelines. Under ADB requirements the environmental assessment process must also include meaningful public consultation during the completion of the draft IEE. In this IEE the PC process included verbal disclosure of the sub-subproject works as a vehicle for discussion. Consultations were conducted with local families and communities along transmission line and around proposed 132KV substation N.P.Sethe SP site and staff of the subproject management. The responses from correspondents have been included in Attachment 3 and summarized in Section 6 of this IEE.

2 Letter dated 29th June 2007 – Ref 2(1)2004-W/KCP-DD from Pak EPA Sajjad Hussein Talpur, Dy Director (EIA/Mont) to LESCO, Muhammad Tahir Khan, Subproject Director PPTA, LESCO, WAPDA House, Lahore.

Page 3 Power Transmission Enhancement Multitranche Financing Facility- Choa Saidan Shah to N.P.Sethe 132 kV Transmission Line and Up-gradation of NP Sethe 66 kV Grid Station to 132 kV Initial Environmental Examination 2. Policy and Statuary Requirements in Pakistan

10. Direct legislation on environmental protection is contained in several statutes, namely the Pakistan Environmental Protection Act (1997) the Forest Act (1927) the Punjab Wildlife Act (1974). In addition the Land Acquisition Act (1894) also provides powers in respect of land acquisition for public purposes. There are also several other items of legislation7 and regulations which have an indirect bearing on the subproject or general environmental measures.

2.1 Statutory Framework 11. The Constitution of Pakistan distributes legislative powers between the federal and the provincial governments through two „lists‟ attached to the Constitution as Schedules. The Federal List covers the subjects over which the federal government has exclusive legislative power, while the Concurrent List contains subjects regarding which both the federal and provincial governments can enact laws. “Environmental pollution and ecology” is included in the concurrent list, hence both the federal and the provincial governments can enact laws on this subject. However, to date, only the federal government has enacted laws on environment, and the provincial environmental institutions derive their power from the federal law. The Punjab Environmental Protection Act 1996 is now superseded by the Pakistan Environmental Protection Act (1997). The key environmental laws affecting this subproject are discussed below.

2.1.1 Pakistan Environmental Protection Act, 1997

12. The Pakistan Environmental Protection Act, 1997 is the basic legislative tool empowering the government to frame regulations for the protection of the environment. The act is applicable to a wide range of issues and extends to air, water, soil, marine, and noise pollution, as well as to the handling of hazardous wastes. The key features of the law that have a direct bearing on the proposed subproject relate to the requirement for an initial environmental examination (IEE) and environmental impact assessment (EIA) for development subprojects. Section 12(1) requires that: “No proponent of a subproject shall commence construction or operation unless he has filed with the Federal Agency an initial environmental examination [IEE] or, where the subproject is likely to cause an adverse environmental effect, an environmental impact assessment [EIA], and has obtained from the Federal Agency approval in respect thereof. The Pakistan Environmental Protection Agency has delegated the power of review and approval of environmental assessments to the provincial environmental protection agencies, in this case the Punjab EPA. (Fig 1.1)

2.1.2 Pakistan Environmental Protection Agency Review of IEE and EIA Regulations, 2000

13. The Pakistan Environmental Protection Act, 1997 (PEP Act) provides for two types of environmental assessments: initial environmental examinations (IEE) and environment impact assessments (EIA). EIAs are carried out for subprojects that have a potentially „significant‟ environmental impact, whereas IEEs are conducted for relatively smaller subprojects with a relatively less significant impact. The Pakistan Environmental Protection Agency Review of IEE and EIA Regulations, 2003 (the „Regulations‟), prepared by the Pak-EPA under the powers conferred upon it by the PEP Act, categorizes subprojects for IEE and EIA. Schedules I and II, attached to the Regulations, list the subprojects that require IEE and EIA, respectively.

14. The Regulations also provide the necessary details on the preparation, submission, and review of IEEs and EIAs. The following is a brief step-wise description of the approval process (see also Figure 1.2):

(i) A subproject is categorized as requiring an IEE or EIA using the two schedules attached to the Regulations. (ii) An EIA or IEE is conducted as per the requirement and following the Pak-EPA guidelines. (iii) The EIA or IEE is submitted to the concerned provincial EPA if it is located in the provinces or the Pak-EPA if it is located in Islamabad and federally administrated areas. The Fee (depending on the cost of the subproject and the type of the report) is submitted along with the document. (iv) The IEE/EIA is also accompanied by an application in the format prescribed in Schedule IV of the Regulations. (v) The EPA conducts a preliminary scrutiny and replies within 10 days of the submittal of a report, a) confirming completeness, or b) asking for additional information, if needed, or c) returning the report requiring additional studies, if necessary. (vi) The EPA is required to make every effort to complete the IEE and EIA review process within 45 and 90 days, respectively, of the issue of confirmation of completeness.

3 The Pakistan Environmental Protection Agency Review of Initial Environmental Examination and Environmental Impact Assessment Regulations, 2000

Page 4 Power Transmission Enhancement Multitranche Financing Facility- Choa Saidan Shah to N.P.Sethe 132 kV Transmission Line and Up-gradation of NP Sethe 66 kV Grid Station to 132 kV Initial Environmental Examination (vii) Then the EPA accords their approval subject to certain conditions: (viii) Before commencing construction of the subproject, the proponent is required to submit an undertaking accepting the conditions. (ix) Before commencing operation of the subproject, the proponent is required to obtain from the EPA a written confirmation of compliance with the approval conditions and requirements of the IEE. (x) An EMP is to be submitted with a request for obtaining confirmation of compliance. (xi) The EPAs are required to issue confirmation of compliance within 15 days of the receipt of request and complete documentation. (xii) The IEE/EIA approval is valid for three years from the date of accord. (xiii) A monitoring report is to be submitted to the EPA after completion of construction, followed by annual monitoring reports during operation.

15. Distribution lines and grid substations of 11 kV and above are included under energy subprojects in Schedule II, under which rules EIA is required by GoP. Initial environment examination (IEE) is required for distribution lines less than 11 kV and large distribution subprojects (Schedule I). A review of the need for EIA/ IEE submission is therefore required by the relevant EPA, in this case the Punjab Environment Protection Agency (EPA) as the proposed subproject will be located in Punjab.

16. There are no formal provisions for the environmental assessment of expanding existing distribution lines and grid substations but Punjab EPA have requested disclosure of the scope and extent of each subproject in order that their Director General can determine if additional land is required and the need for statutory environmental assessment1. The details of this subproject will be forwarded to the Punjab EPA, in order to commence the local statutory environmental assessment process.

Page 5 Power Transmission Enhancement Multitranche Financing Facility- Choa Saidan Shah to N.P.Sethe 132 kV Transmission Line and Up-gradation of NP Sethe 66 kV Grid Station to 132 kV Initial Environmental Examination 2.1.3 National Environmental Quality Standards

17. The National Environmental Quality Standards (NEQS) were first promulgated in 1993 and have been amended in 1995 and 2000. The following standards that are specified in the NEQS may be relevant to the Tranche 1 subprojects:

18. 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)

19. Maximum allowable concentration of pollutants (2 parameters) in gaseous emissions from vehicle exhaust and noise emission from vehicles.

2.1.4 Other Relevant Laws

20. There are a number of other federal and provincial laws that are important in the context of environmental management. The main laws potentially affecting subprojects in this MFF are listed below.

21. The Punjab Wildlife Protection Ordinance, 1972 empowers the government to declare certain areas reserved for the protection of wildlife and control activities within in these areas. It also provides protection to endangered species of wildlife. As no activities are planned in these areas, no provision of this law is applicable to the proposed subproject.

22. The Forestry Act, 1927 empowers the government to declare certain areas reserved forest. As no reserved forest exists in the vicinity of the proposed subproject, this law will not affect to the proposed subproject.

23. The Antiquities Act of 1975 ensures the protection of Pakistan‟s cultural resources. The Act defines „antiquities‟ as ancient products of human activity, historical sites, or sites of anthropological or cultural interest, national monuments, etc. The Act is designed to protect these antiquities from destruction, theft, negligence, unlawful excavation, trade, and export. The law prohibits new construction in the proximity of a protected antiquity and empowers the Government of Pakistan to prohibit excavation in any area that may contain articles of archaeological significance. Under the Act, the subproject proponents are obligated to ensure that no activity is undertaken in the proximity of a protected antiquity, report to the Department of Archaeology, Government of Pakistan, any archaeological discovery made during the course of the subproject.

2.2 Structure of Report 24. This IEE reviews information on existing environmental attributes of the Study Area. Geological, hydrological and ecological features, air quality, noise, water quality, soils, social and economic aspects and cultural resources are included. The report predicts the probable impacts on the environment due to the proposed subproject enhancement and expansion. This IEE also proposes various environmental management measures. Details of all background environmental quality, environmental impact / pollutant generating activities, pollution sources, predicted environmental quality and related aspects have been provided in this report. References are presented as footnotes throughout the text. Following this introduction the report follows ADB guidelines and includes: Description of the Subproject Description of Environmental and Social Conditions Assessment of Environmental Impacts and Mitigation Measures Environmental Monitoring Plan Public Consultation Recommendations and Conclusions

Page 6 Power Transmission Enhancement Multitranche Financing Facility- Choa Saidan Shah to N.P.Sethe 132 kV Transmission Line and Up-gradation of NP Sethe 66 kV Grid Station to 132 kV Initial Environmental Examination 3. Description of the Project

3.1 Type of Project

25. This Transmission Line Subproject comprise up-gradation of 66 kV N.P.Sethe Grid Station to 132 kV substation and associated 47,614 meters long 132 KV transmission line from Choa Saidan Shah to N.P.Sethe. The sub-station is located in the service area of IESCO presented in Fig. 2.2. Choa Saidan Shah Grid Station is located in the West of Choa Saidan Shah town, district Chakwal while N.P.Sethe Grid Station is on Kalar Kahar to Khushab Road at N.P.Sethe town, district Chakwal. Access road to N.P.Sethe is located on the South of the GS and the land on North while staff colony is on the West and a boys‟ high school is on the East side. The N.P.Sethe grid station currently is of 66 kV capacity and has enough space for up-gradation to 132 kV.

26. This will be a new Transmission line of 47.614 km on the 191 new towers to be constructed in the district of Chakwal (Punjab Province). At the two ends of the Transmission Line grid stations (Chua Saidan Shah 132 kV and N.P.Sethe 66 kV) already exist and all the work at the grid stations of N.P.Sethe under this subproject will be done within its existing boundary walls, so there will be no resettlement issues involved due to up-grading the N.P.Sethe grid station.

3.2 Categorization of the Project

27. Categorization is based on the most environmentally sensitive component of a sub project. The aspects of the subproject with potential of significant environmental impacts need to be assessed in detail and this environmental assessment has therefore focused on the significant impacts possible from the construction activities of the subproject.

28. The Choa Saidan Shah to N.P.Sethe Transmission Line and up-gradation of N.P.Sethe Grid Station SP is categorized as a Category „B‟ sub-project under ADB requirements and this IEE report is based on that assumption.

3.3 Need for the Project 29. The conditions of the power transmission system in Pakistan are inadequate to meet rapidly growing demand for electrical power. This situation limits national development and economic growth. To cope with the constraints, the existing power transmission infrastructure has to be improved, expanded and upgraded. The overall contribution of power infrastructure also requires institutional arrangements and capacity that support strategic management of the sector, and planning and management of investments. Overall the proposed PDEMFF facility has been designed to address both investment and institutional aspects in the electrical power sector.

30. The town of N.P.Sethe has been expanding in all possible directions. In the south and west of the city there is an expansion and development of housing schemes. The housing in the town is expanding. Therefore, the domestic, commercial and industrial power demands in the Town area of N.P.Sethe jurisdiction have increased rapidly, especially in summer months, so that the existing GS are unable to cope up with the increasing demands of the domestic, commercial and industrial sectors. Due to the increased power demand of the area the existing grid stations has become overloaded and insufficient to meet the increased demand. There is need to improve the power supply of the area. For this purpose IESCO is planning to up-grade the grid stations in this area named N.P.Sethe. Fig. 2.1 presents large jurisdiction of IESCO.

Page 7 Power Transmission Enhancement Multitranche Financing Facility- Choa Saidan Shah to N.P.Sethe 132 kV Transmission Line and Up-gradation of NP Sethe 66 kV Grid Station to 132 kV Initial Environmental Examination Figure 2.1: Jurisdiction Map of IESCO

3.4 Location and scale of project 31. This IEE has included field reconnaissance of the proposed site of transmission line from Choa Saidan Shah to N.P.Sethe and surroundings of N.P.Sethe Grid Station. The two Grid stations and proposed transmission line are located within IESCO Jurisdiction Fig 2.2 presents the location of substation.

32. The proposed route of the 132 kV transmission line and up-gradation of N.P.Sethe Grid Station appears to be environmentally feasible and technically appropriate and will join the two GS with a new 132kV line at about 47.614 km. Figure 2.2: Location Choa Saidan Shah-N.P.Sethe

Page 8 Power Transmission Enhancement Multitranche Financing Facility- Choa Saidan Shah to N.P.Sethe 132 kV Transmission Line and Up-gradation of NP Sethe 66 kV Grid Station to 132 kV Initial Environmental Examination

33. This IEE has been conducted based on the assumptions available in May 2009 when the preliminary designs for the GS and TL were completed and the overall requirements for installation of the equipment had been identified. The detailed designs are currently being progressed by IESCO. At this stage, the construction activities under the SP are expected to include the usual localized civil works such as extension of the main yard, including excavation and concreting of foundations for the new transformers, capacitor banks, cable trays and terminal tower (within the GS compound), installation of the transformers, equipment and fittings, erection of the towers, cabling, construction of the control rooms and installation of allied equipment, and construction of the offices and residences. Impacts from construction of the N.P. Sethe SP are envisaged to be minor, since no additional land needs to be acquired for construction of the GS. However, transmission line from Choa Saidan Shah to N.P.Sethe would transverse cultivated land and hilly barren area.

Page 9 Power Transmission Enhancement Multitranche Financing Facility- Choa Saidan Shah to N.P.Sethe 132 kV Transmission Line and Up-gradation of NP Sethe 66 kV Grid Station to 132 kV Initial Environmental Examination

34. The designs for the Tranche 2 (T2) subprojects will be developed under the subproject support component of the MFF. This IEE , however, is based on detailed line route surveys (which includes alternative routes and the route which minimizes the social impacts is chosen) . The line route is then submitted to the design formation which determines the line profiles and tower locations, these towers are then located on ground . The IEE is , therefore based on line design which is final (baring any unforeseen occurrence ) and only is changed at implementation stage if so warranted by new developments .The line design is based on the following parameters .

Permissible Conductor Clearances at 650C Clearance Sr. No.Description m

1 Cultivated land traversed by vehicles 6.7 2 Roads and Streets 7.9 3 Communication and power lines power lines up to 66 kV 2.7 power lines up to 33 kV 2.7 4 Highways 7.9 5 Railroads 7.9 6 Electrified railroads trolley wire 3.85 7 River at high flood 9.1 8 places accessible to pedestrians only 7.9 9 Building roofs not accessible to people 5.2 10 Tops of trees (Orchards) 5 11 Canals 9.1

3.5 Proposed Schedule for Implementation 35. Designs power transmission arrangements, access, review of environmental management and construction processes could take several months. When the detailed designs are completed, tendering and award of contract will take place over about three to six months. The construction period will follow and best estimates indicate about eighteen months to two years. The implementation schedule for Tranche 2 is presented as follow

TIME SCHEDULE - TRANCHE 2 - DISTRIBUTION ENHANCEMENT PROGRAM Responsibility Year 2009 Year 2010 Year 2011 Year 2012 Year 2013 Year 2014 Year 2015 Year 2016 1 2 I II III IV I II III IV I II III IV I II III IV I II III IV I II III IV I II III IV I II III IV Loan Processing Loan negotiation ADB EAD Tranche 2 Approval ADB EAD Loan Effectivity EAD ADB Bidding Documents Bidding Documents Preparation PEPCO DISCOs Evaluation PEPCO DISCOs Contract Awards PEPCO DISCOs Construction Delivery of equipment Contractor Construction & Installation Contractor Testing & Commissioning Contractor Loan Closing ADB PEPCO

Page 10 Power Transmission Enhancement Multitranche Financing Facility- Choa Saidan Shah to N.P.Sethe 132 kV Transmission Line and Up-gradation of NP Sethe 66 kV Grid Station to 132 kV Initial Environmental Examination 4. DESCRIPTION OF THE ENVIRONMENT

4.1 Project Area

4.1.1 General Characteristics of Project Area

36. IESCO provides electricity to N.P.Sethe town and nearby towns through the N.P.Sethe 66 kV Grid station. N.P.Sethe grid station is getting power supply from Chua Saidan Shah 132 kV grid station but through 66 kV Transmission Lines. Due to the increased power demand in the area the power supply has become insufficient. To meet the increased demand of the area IESCO is planning to construct a new 132 kV SDT transmission line from Chua Saidan Shah 132 kV grid station to N.P.Sethe 66 kV grid station and up-grade the exiting 66 kV GS to receive additional power supply. Total length of the new 132 kV (SDT) transmission line will be 47.614 km. Main access of 132 kV Choa Saidan Shah GSS is on west of the town and access of 66 kV N.P.Sethe DGS on main Kalar Kahar to Khushab road. Both GSS are located in a generally rural area with settlements on North and East side of the GS and cultivated land on west and south sides of the GS.

4.1 Affected Administrative Units

37. The area to be indirectly affected by the extension works for the 132kv Choa Saidan Shah –N.P.Sethe SDT circuit TL falls in Tehsil Choa Saidan Shah, District Chakwal and Tehsil Kalar Kahar of District Chakwal. The new transmission line will require 30 meter wide strip for 47.614 km as working corridor during construction work, so an area of 30m x 47.614= 1428.42 sq m will be affected. Transmission line will pass through 13 villages located in Chakwal district (Punjab province) as given below.

Table 1: Villages Transverse Tehsil, District Villages Transverse 1.Tehsil Choa Saidan Choa Saidan Shah, Dalwal, Jagwali Talab, Shah, District Chakwal Badshah pur, Dhok Saeedan, Khairpur, 2.Tehsil Kalar Kahar, Sultan More, Run Syal, Jamrah, Miani, District Chakwal Dughrah, Duraknan, and N.P. Sethe

38. The first 26.0 KM section of the line traverses the farmlands of Tehsil Choa Saidan Shah while 21.552 km section of the transmission line traverses the lands of Tehsil Kalar Kahar. The transmission line will traverse private farmland for almost 1/3rd of its length 18.384 km (36.61 percent) and a major portion of 29.230 km (61.39 percent) uncultivated Government lands (Road, Paths, Hilly barren areas, and IESCO grid stations). As a result, some 171 households, with a total population of 2158 persons will be affected by temporary disruption to land, and loss of 55.15 ha of crops and 148 trees (Attachments 6 & 7).

39. Interviews were conducted with the public near the GS site and TL corridor (Attachment 3) to obtain their views on the subproject, and any perceived impacts.

4.2 Physical Resources

4.2.1 Location, Topography, Geography, Geology, and Soils

40. The district lies between 71o 48‟ to 73o 16‟ east and 32o 33‟ to 33o -12‟ north . Geographically placed in the Salt Range and the Potohar plateau, the physical features of Chakwal are typical of the region. The south and south-east is mountainous and rocky, covered with scrub forest. Interspaced with flat lying plains; the north and north-east consist of softly undulating plains area with patches of rocky areas, known as Kihuddar in the local dialect, ravines and gorges and some desert areas. The plains of the district are being cultivated, even those which lie in the hilly regions, and a considerable area is covered by forests.

Geology 41. The area of Chakwal can be classified into mountains, hills, rocks, plains, weather rocked plains, piedmont plains, loess plains and river plains. The soil of the area has developed from wind and water transported materials consisting of loess alluvial deposits, mountain outwash and recent stream valley deposits. A part of the soil has also been derived from shales and sand stones.

Page 11 Power Transmission Enhancement Multitranche Financing Facility- Choa Saidan Shah to N.P.Sethe 132 kV Transmission Line and Up-gradation of NP Sethe 66 kV Grid Station to 132 kV Initial Environmental Examination Mountains and Hills 42. The mountain ranges which exist in Chakwal, though they may not fall within the precise definition of mountains, are the Kallar Kahar hills, the Choa Saidan Shah hill range leading into Kallar Kahar on one side and Jhelum on the other, both falling in the Salt Range, and the Diljabban hill. These ranges are dry and rocky, covered by deciduous forests.

4.2.2 Climate and Hydrology

43. There is no variation of altitude above sea level in the land along the alignment and due to the short length of the distribution line means no variation between the climate of the subproject area. Both Grid Stations fall under district

44. Chakwal district however, lies in the sub-tropical regions and its climate is typical of the area, with the exception that it varies a little on the cooler side, owing to its elevation, from central Punjab. Winter temperatures normally range from 4 to 25 degree centigrade. Temperature in summers ranges from 22 to 40 but sometimes goes up to 45 degree centigrade.

45. The project area lies within the monsoon range, and apart from occasional rainfall, there are two rainy seasons, the first, caused by the monsoon winds originating from the Bay of Bengal, begins from 15th of July and continues up to around 15th of September, the second, caused by Mediterranean winds lies in the last two weeks of December and the first two weeks of January. The average rainfall is 22 to 25 inches. Choa Saidan Shah Tehsil has the maximum rainfall in the district.

4.2.3 Groundwater and Water Supply

46. Groundwater sources exist in the area. The strata of the subproject area are water bearing and alluvial deposits, giving groundwater potential throughout the district. The water table is not seasonal and dug wells do not generally run dry. The local population is generally reliant on supply from the hand pumps in rural areas while in urban areas population using drinking water from WASA piped water supply scheme.

47. Around 25 per cent of the housing units are using piped water, majority of which has that facility in their own houses. About 45 per cent are using hand pump for drinking water. In the rural areas 22 per cent households are using wells to collect potable water. Rest of the population is dependent on ponds or other sources to collect potable water. The 132 kV Chua Saidan Shah and 66 kV N.P.Sethe GS have piped water supply from Water and Sanitation Authority (WASA).

Surface Water

Rivers and Tributaries 48. The whole sub-project area lies under rain fed conditions. There is no river passes through Chakwal district except Soan. The Soan river enters Chakwal district from the Pindi Gheb area, passes through Hasli- Warwal into Talagang sub-division, flows across Tamman and finally falls into the Indus on the border of Mianwali- Kohat district. During the summer and rainy season, there is heavy flow of water in the river, but in winter it takes the shape of a rivulet.

49. A number of Nullahs (carrying seasonal water) cross through sub-project area, overall in the district the more important of Nullahs are Nullah Soj, Nullah Wahan, Nullah Gabbir, Nullah Tarapi, Nullah Dharabi and Nullah Banhaa.

50. Chakwal is not a marshy area. Seasonal inundation may occur near the Nullahs but it never turns into marshy land. The only lake that exists in Chakwal district is the very well known lake of Kallar Kahar which is fed by the surrounding mountain streams. Transmission line passes in the east at a distance of 1,000 meters of the Kalar Kahar Lake.

Irrigation 51. Chakwal is an un-irrigated, or what is called a barani (dependent on rain) area in local language, and there is no canal system in the district like those which exist in the other parts of the Irrigated Punjab. However, a number of small dams have been constructed in the districts which irrigate a small acreage of cultivated land through water channels. The names of the important dams are: Khokharzer dam, Surrlah dam, Dhurnal dam,

Page 12 Power Transmission Enhancement Multitranche Financing Facility- Choa Saidan Shah to N.P.Sethe 132 kV Transmission Line and Up-gradation of NP Sethe 66 kV Grid Station to 132 kV Initial Environmental Examination Ghurab dam, Wallana dam, Nikka dam, Bughtal dam, Dhoke Qutb Din dam, Kot Raja Dam, Pira Fathial dam, Dhoke Tahilan dam.

52. Agricultural land is thus dependent largely on rains. However, in some parts of the district farmers lift water from seasonal nullahs and or small dams and irrigate their fields. Along the transmission line, however, none of the irrigation source was found during field visit. Total area was dependent on rains for cultivation.

4.2.4 Air Quality

53. Air quality in most of the project area appears good based on observation during the study period. Emissions should be controlled at source under the EMP. There will be a few items of powered mechanical equipment to be used in the construction of the GSS works that may give rise to complaints of dust and other emissions; however these should be minor and easily dissipated. Domestic sources of air pollution, such as emissions from wood and kerosene burning stoves as well as small diesel standby generators in some households, are minor.

54. Although there are some industries of cement but there are no other industrial pollution sources in the vicinity of the Choa Saidan Shah –N.P.Sethe sub-project area. The project area is distant from major sources of air pollution like industries or urban type traffic, domestic sources such as burning of wood and kerosene stoves, etc. or fugitive sources such as burning of solid wastes. Air quality in the project area appeared very good during the study period . Air quality measurements in major urban centers , carried out by Pak-EPA , revealed that CO, SO2 and NO levels were in excess of the acceptable levels in some areas but the average levels were found below WHO standards . Air quality testing by DISCOs (average values are : TSP 1.09 mg/m3 , CO 634 ppb , SO2 24.34 ppb, NO2 23.73 ppb ) through various consultants has reveled that most sub stations have NO2, Co2 and CO values below international standards although TSP levels at some locations was higher than international standards .

55. There should be no source of atmospheric pollution from the project. In the operational phase the industrial facilities with fuel powered mechanical equipment will be the main polluters. All such emissions will be very well dissipated in the open terrain and there will be no cumulative effect from the project.

56. The other major source of air pollution is dust arising from construction and other ground or soil disturbance, during dry weather, and from movement of vehicles on poorly surfaced or damaged access roads. It has been observed that dust levels from vehicles may even be high enough to obscure vision significantly temporarily.

4.2.5 Noise

57. Noise from vehicles and other powered mechanical equipment is intermittent. There are also the occasional calls to prayer from the PA systems at the local mosques but there are no significant disturbances to the quiet rural setting. However, the construction from the proposed power expansion will use powered mechanical equipment. Subjective observations were made of background noise and also of individual vehicle pass by events. Based on professional experience background daytime noise levels are probably well below 55dB (A) L90. DISCOs have carried out noise level measurements at various sub stations and transmission line locations within the system .These analyzed to calculate Leq values have resulted in Leq values much below the 85 dBA limit prescribed under the NEQs established by the EPA or the 75 dBA used by DISCOs/NTDC/PEPCO in the equipment specifications . Typical values were : average 46.21 dBA ; high 63.14 dBA ; and low 34.35 dBA .

4.3 Biological Resources

Flora 58. There is a very wide range of plant and animal species in the district. Amongst plants, the species which are most abundant in the district are kau or wild olive (Olea cuspidate). Phulai (Acacia modesta), Sanatha (Dodones viscose). Gurgura (Monotheca buxifolia), and Pataki (Prosopis juifloro), and Karir (Capparis aphylla). All these plant species are found throughout the district. Common vegetation found in subproject area is Dalbergia sisso, [Shisham], Poplar, Kikar (Accacia arabica) trees in the areas near the works, but natural forest cover in the district has significantly reduced in the past due to clearance for vegetation.

59. However, there is a little vegetation in the ROW for the line (Attachment 5). Along, and on the sides of the distribution line alignment, Dalbergia sisso, Acacia Arabica, Eucalyptus and Phulai (Acacia modesta), Sanatha (Dodones viscose), and Karir (Capparis aphylla) trees were found during field visit.

Page 13 Power Transmission Enhancement Multitranche Financing Facility- Choa Saidan Shah to N.P.Sethe 132 kV Transmission Line and Up-gradation of NP Sethe 66 kV Grid Station to 132 kV Initial Environmental Examination Fauna 60. There are no areas of wildlife significance near the subproject area. Apart from the very common bird and animal species which are more or less evenly distributed throughout Punjab, exist in various areas of Chakwal district. These are: Gray partridge, black partridge, Chakore, see partridge, quail, houbara bustard, common crance, ducks, peacock. Ducks do come to Kalar Kahar Lake seasonally. Hunting is prohibited by the government in the Lake.

4.3.1 Protected Areas / National Sanctuaries

61. In Pakistan there are several areas of land devoted to the preservation of biodiversity through the dedication of national parks and wildlife sanctuaries. There is no wetland except Kalar Kahar Lake which is even far away from the project area. Similarly there is no protected area or national sanctuary near the area of works and subproject area.

4.4 Economic Development 4.4.1 Agriculture, Livestock and Industries

62. Farming is the main occupation of the people of Chakwal. With the exception of a few large land-holders in sub-division Talagang, holdings are small in the district and farming is conventional, though new techniques and methods are being introduced by the Barani Agricultural Institute, Thoa Bahadur, Chakwal. The farmers have also begun to use fertilizer and pesticides and capital intensive time saving inputs like tractors and harvesters, are being used ever since their introduction in the country.

63. The total area of the district 1,652,443 acres and the total cultivated area is 786,212 acres. The main crops of the district are; Wheat, Groundnut, Oil Seeds, Grams, Lentils: Masoor, Mung, Mash, Maize, Millets, Jawar, Vegetables. Along the RoW only rain fed agriculture is practiced. Farmers plant mostly wheat in the winter and only a few farmers plant Maize or Millets in summer subject to rain.

Horticulture 64. A large number of rose gardens have been planted by farmers in the Kallar Kahar area and the quality of roses produced at this place is probably better than the roses produced at any other place in the country. The roses are of Desi (local) variety and are used primarily for the distillation of rose water and the preparation of Gulqand (a mixture of rose petals and sugar).

65. Other than the Kallar Kahar rose gardens horticultural activities are confined to the domestic lawns of the people of the middle and upper middle classes of the cities of Chakwal and Talagang, and to some extent to the people of rural areas, which are supplied by seven nurseries present in the district.

Livestock 66. The rich hilly prairies and grazing lands of Chakwal provide a very good environment for sheep and cattle rearing. The majority of the farmers maintain their own sheep and goat herds and cattle.

67. The bulk of the livestock in the district is consequently being reared in the informal sector based on traditional methods. However, a number of poultry and cattle farms have been established in the private sector which utilize modern technology of breeding and rearing and are commercially oriented. There was no poultry or cattle farm located near the TL RoW.

Industry 68. Chakwal is a predominantly rural district with an agrarian economy. The industrial sector does exist but is relatively small and agro-based, mainly comprising textile and spinning mills, and some feed and flour mills. Three cement factories have been established in recent years. All the factories are far away from TL and none of the factory falls with in Row of TL.

Communication

69. There is no railway line available in the district. Roads in the district have been constructed by the Highway Development. Chakwal district is quite developed in roads. All tehsil headquarters, major towns and villages are connected through asphalt roads. The main Motorway runs from Peshawar to Lahore passes through Chakwal district.

Page 14 Power Transmission Enhancement Multitranche Financing Facility- Choa Saidan Shah to N.P.Sethe 132 kV Transmission Line and Up-gradation of NP Sethe 66 kV Grid Station to 132 kV Initial Environmental Examination 70. Telephone facility in the district is also provided by the Pakistan Telecommunication Corporation. The only means of communication which covers each and every area of the district is the postal service.

Energy Sources

71. About 86 percent housing units are using wood as cooking fuel in their houses while 9 percent are using gas for their purpose. Five percent are using kerosene oil and other sources of cooking fuel in their houses.

4.5 Social and Cultural Resources

4.5.1 Population Communities and Employment

72. The total population of Chakwal district was 1,083,725 according to the latest enumeration in March 1998. The urban population was 131,692 or 12.2 per cent of the total population of the district. There are two Municipal committees and one Town Committee in the district.

73. Population of the district is predominantly Muslims i.e. 99.2 per cent. The next higher percentage is of Christians with 0.5 points, followed by Ahmadis 0.2 per sent. While other minorities like Hindu (Jati), Scheduled Castes etc, are very small in number. The population of Muslims is higher in rural areas, 93.3 per cent, as compared to their counterparts in urban areas, 98.4 per cent; Christians are mostly living in urban areas representing 1.5 per cent as compared to just 0.4 per cent in rural areas. Ahmadis are more in rural as compared to their proportion in urban areas. Punjabi is the predominant (97.7 per cent) language spoken in the district followed by Pushto speaking 1.2 per cent, Urdu 0.9 per cent and Siraiki 0.2 per cent.

74. The economically active population as enumerated in the last census was 17.0 per cent of the total population or 23.0 per cent of the population 10 years and over i.e. the population exposed to the risk of entering the economically active life at any time.

75. Of the total male population 33.8 per cent were economically active, while 66.2 per cent not economically active, 28.0 per cent were land lords, property owners, retired persons, disabled etc. The participation rate is slightly higher in urban as compared to people living in rural areas.

4.5.2 Education and Literacy

76. The education infrastructure in Chakwal is physically well developed. The government has provided the maximum possible educational facilities so that a fair opportunity is provided to the people of Chakwal to invest in their human capital. At present there are 5 degree colleges, 2 intermediate colleges, 10 higher secondary schools, 131 high schools, 170 elementary schools, 937 primary schools and 208 Maktab (mosque) schools in the district. The Literacy ration for males is 73.4 per cent as against 42.2 per cent for female. The ration is much higher in urban when compared with rural areas both for male and female.

4.5.3 Health Facilities

77. Medical facilities in the district are fairly well established. There is a District Headquarters Hospital in Chakwal and a Tehsil Headquarters Hospital at Talagang. There are 9 Rural Health Centers, 66 Basic Health Units, 6 Rural Dispensaries and 2 Mother and child Health Centers in the district. The health establishment is looked after by the district Health Officer. Apart from the medical facilities provided by the government a large number of hospitals and dispensaries exist in the private sector also.

Page 15 Power Transmission Enhancement Multitranche Financing Facility- Choa Saidan Shah to N.P.Sethe 132 kV Transmission Line and Up-gradation of NP Sethe 66 kV Grid Station to 132 kV Initial Environmental Examination 5. Cultural Heritage and Community Structure

78. Quite a number of historical sites lie in the undulation of Chakwal, the more important of which are: Kallar Kahar lying 48 kilometers south-west of Chakwal on the Chakwal-Sargodha road Kalar Kahar has always been renowned throughout the country for its peacocks, its fresh water lake and for the Takht-e-Babri, a flat stage built of stone by emperor Baber to address his army while coming down from Kabul in question of the crown of Delhi. During his stay at Kallar Kahar he also planted a garden, which still exists, called the Bagh-e-Safa.

79. With the construction of the motorway which passes by the edge of the lake, the number of tourists visiting Kalar Kahar has increased manifold, and the town surrounded by verdant hills, promises to become a tourist attraction if properly developed. A museum of fossils of the area has also been built by the Archaeology Department in the District Council Rest house.

80. Katas Raj katas Raj, a medieval town sacred to the Hindus, lies about 2 kilometers west of Choa Saidan Shah on the Choa-Kallar Kahar road. Its importance is derived from the fact that it contains over a 1000 years by its Hindu Rajas. Some of these temples are dilapidated but a large number of then have been well maintained. Hindu pilgrims from all over Pakistan and India frequently visit this town to worship.

81. Malot Fort. The ruins of Malot fort lie midway between Kallar Kahar and Choa Saidan Shah. The fort is believed to be over 800 years old but owing to disrepair only the foundations and fallen walls remain.

82. All the above mentioned historical places are far away from the work place or the sub-project area.

83. Eighty per cent of the people living in Chakwal are ethnically Punjabis of Aryan origin. The remaining 20 per cent are settlers, Muhajirs, Pakhtoons from the settled and tribal areas of the NWFP and from Afghanistan.

Page 16 Power Transmission Enhancement Multitranche Financing Facility- Choa Saidan Shah to N.P.Sethe 132 kV Transmission Line and Up-gradation of NP Sethe 66 kV Grid Station to 132 kV Initial Environmental Examination 6. SCREENING POTENTIAL ENVIRONMENTAL IMPACTS AND MITIGATION MEASURES

6.1 Project Location

6.1.1 Impact Assessment and Mitigation

84. This Tranche 2 subproject will involve the construction of 132kV 47.614 km TL, implying an expansion of facilities, at one grid station within the existing boundaries of the 66 kV N.P. Sethe GSS on land presently owned by IESCO. There are a few sensitive receivers (SR), including some houses, schools, colleges, factories, which are more than 125m away from the GSS boundary and TL ROW, and there are no sensitive receivers close to the TL ROW which could be possibly affected by certain activities of the SP works. However, there are some other sensitive receivers (SR) as TL will cross some roads and a motorway, and could require the removal of some trees, but there are no other sensitive receivers on its route, which could be affected by the works.

86. The location and scale of the works are very important in predicting the environmental impacts. Therefore, it is essential that a proper analysis is carried out during the subproject planning period. This process of impact prediction is the core of the IEE process and it is critical that the recommendations and mitigation measures are carried out according to, and with reference to the conditions on the ground in the affected areas in the spirit of the environmental assessments process. In this section the potential environmental impacts are reviewed. Where impacts are significant enough to exceed accepted environmental standards, mitigation is proposed in order to reduce residual impact to acceptable levels. In this regard, the impact prediction plays a vital role as these predictions are used for developing mitigation measures and any alternative options, if appropriate. When the detailed designs are completed the impacts and mitigation measures will need to be further reviewed to take account of how the contracts are set up and in the light of any fine tuning of the subproject proposals.

87. The environmental management plan (Section 5 and EMP matrix Attachment - 1) has been reviewed based on the assessment and shall be reviewed in due course at subproject inception and through construction in order to provide a feed back on any significant unpredicted impacts. It is based on the analysis of impacts, primarily to document key environmental issues likely to arise from subproject implementation, to prescribe mitigation measures to be integrated in the subproject design, to design monitoring and evaluation schedules to be implemented during subproject construction and operation, and to estimate costs required for implementing subproject mitigation measures. The EMP must be reviewed in the subproject inception by the subproject management and approved before any construction activity is initiated, to take account of any subsequent changes and fine tuning of the proposals.

6.2 General Approach to Mitigation 88. Based on professional experience on some projects, contractors have put emphasis on the financial compensation for nuisances. This may be acceptable for some social impacts where evacuation is necessary or where houses have been accidentally damaged, however it is not best international practice to accept payment for environmental impacts. An approach whereby the subproject contractor pays money for nuisances rather than control impacts at source will not be acceptable. This practice should not be allowed, and financial compensation shall not be allowed as mitigation for environmental impacts or environmental nuisance.

89. During the preparation for the subproject construction phase the future contractors must be notified and prepared to co-operate with the executing and implementing agencies, subproject management, construction supervising consultants and local population in the mitigation of impacts. Furthermore the contractor must be primed through bidding stages and the contract documentation to implement the EMP in full, and be ready to engage or train staff in the management of environmental issues and to audit the effectiveness and review mitigation measures as the subproject proceeds. The effective implementation of the EMP will be audited as part of the loan conditions and the executing agency (IESCO) must be prepared for this. In this regard the IESCO must fulfill the requirements of the law and guidance prepared by Pak EPA on the environmental aspects of power subprojects and the recommendations already made for the subproject in this IEE and under Pakistan‟s PEP Act.

90. The location of the residences, mosques, schools, hospitals and civic, cultural and other heritage sites has been reviewed in Section 3. There could be some potential impacts in the construction stage from disturbance and significant noise and dust. However, the alignment is through cultivated fields and or hilly barren area, and no receptors such as residences, mosques or schools close enough to the alignment to be significantly affected by the works.

Page 17 Power Transmission Enhancement Multitranche Financing Facility- Choa Saidan Shah to N.P.Sethe 132 kV Transmission Line and Up-gradation of NP Sethe 66 kV Grid Station to 132 kV Initial Environmental Examination 91. Work on the tower sites could cause some generation of air borne dust, but any nuisance from this is likely to be very localized and temporary. Other project activities, e.g. movement of heavy vehicles on unpaved tracks during the works, could generate considerable dust. Water is available in the study area, although surplus water may not always be available to suppress dust at vulnerable locations in the dry season. Therefore as a general approach it is recommended that where works are within 15m of any residential sensitive receivers, the contractor should install segregation between the works and the edge of the sensitive receivers. The segregation should be easily erectable 2.5m high tarpaulin sheet and designed to retain dust and provide a temporary visual barrier to the works. Where dust is the major consideration the barrier can take the form of tarpaulins strung between two poles mounted on a concrete base. These can be moved along from tower base to tower base as the work proceeds.

92. Noise from the construction of the towers should not be a major consideration unless very close to schools or hospitals where construction should be avoided at sensitive times. In addition to the physical effect of mitigating dust and noise with barriers installation of such measures should be discussed with the local population and serve as a vehicle for further public consultation at the implementation stage to assist in public relations.

6.2.1 Cultural Heritage, Mosques, Religious Sites, and Social Infrastructure

93. The location of mosques and other cultural and other heritage SR sites has been reviewed in Section 3. There are no mosques or other religious sites close to the DGS site and TL ROW. The new line will also not affect or disturb any such site (Attachment 6).

94. The nearest clinic / hospital is more than 100m from the edge of the Subproject or TL route, but the nearest school is at 250m from the GS (N.P. Sethe) adjacent to the Subproject, and the nearest houses at about 45m from the DGS. The TL will also cross some road including the Motorway, and a defense road. Apart from these features, there will be sufficient buffer distance between the works and any other SRs, so that no significant impacts should be expected. Public consultation should be undertaken at the implementation stage to ensure nuisances are not allowed to escalate for the SRs close to the DGS sites.

6.3 Potential Environmental Impacts in construction

6.3.1 Encroachment, Landscape and Physical Disfiguration

95. The extent of the proposed power expansion is moderate and should not extend beyond the power corridor (RoW) created by the subproject. No significant landscape impacts are expected from construction of the Choa Saidan Shah –N.P.Sethe subproject.

Cut and fill and waste disposal 96. Disposal of surplus materials must also be negotiated through local authority approvals prior to the commencement of construction. The Subproject work should not involve any significant cutting and filling but minor excavations (down to 4m) and piling may be required to create the foundations for the new transformers and for some towers (if required). It is envisaged (depending on the mode of contract) that the surface under the towers will need to be scrabbled to remove unstable materials, or to stockpile topsoil.

97. Mitigation measures must focus on the minimization of impacts. In order to allow the proper functioning of the settlement sites (access to villages) during construction it is recommended that consideration be given to erect temporary hoardings immediately adjacent to the nearest houses and shops if they are within 15m of the power distribution line tower construction.

98. If surplus materials arise from the removal of the existing surfaces from specific areas, these should be used elsewhere on the subproject before additional soil, rock, gravel or sand is brought in. The use of immediately available material will generally minimize the need for additional rock based materials extraction from outside.

99. The subproject detailed designers have so far estimated that no substantial additional materials will be required subject to confirmation at the detailed design stage.

100. At this stage no areas require removal of woodland. However if specimen trees of religious plantations are affected the owners should be given the resources and opportunity to reinstate the woodland long term and a plantation compensation plan should be drawn up to replant the woodland/trees. In the event that the land is not suitable for plantation then other areas should be identified to replace the cut trees and sufficient areas should be identified to allow plantation of trees at a rate of say 3:1. The replacement ratio should allow for a high

Page 18 Power Transmission Enhancement Multitranche Financing Facility- Choa Saidan Shah to N.P.Sethe 132 kV Transmission Line and Up-gradation of NP Sethe 66 kV Grid Station to 132 kV Initial Environmental Examination mortality rate among the newly planted trees in the dry environment or otherwise as based on advice from the forest authority.

101. Contractual clauses should be included to require each contractor to produce a materials management plan (one month before construction commences) to identify all sources of cement and aggregates and to balance cut and fill. The plan should clearly state the methods to be employed prior to and during the extraction of materials and all the mitigation measures to be employed to mitigate nuisances to local residents. Financial compensation shall not be allowed as mitigation for environmental impacts or environmental nuisance. Mitigation measures shall seek to control the impacts at source in the first place. The engineer shall be responsible to update the subproject cut and fill estimates and create Materials Master Plan to facilitate materials exchange between the different contract areas along the power line and sub-contractors on the power line and to provide an overall balance for materials and minimize impacts on local resources.

6.3.2 Trees, Ecology and Protected Areas

102. There are no Reserved or Protected Forests or trees near the GS site or TL alignment. The proposed line will require the installation of 191 towers which will be installed for TL route disclosed by IESCO (May 2009) will not affect many trees. However, in case of removal of any tree on private or forest land during the works, written permission should be sought.

103. If for some unforeseen reason or change of alignment, any trees with religious significance or other trees need to be removed, written permission should be obtained from the forest authority and the owner after written justification by IESCO. Trees shall be planted to replace the lost trees with three trees planted to replace every cut tree (3:1) or more as agreed with the authority.

104. A requirement shall be inserted in the contracts that no trees are to be cut on the Choa Saidan Shah to N.P.Sethe TL and GS site or outside, without the written permission from the supervising consultant who may permit the removal of trees if unavoidable on safety / technical / engineering grounds after written justification by IESCO and to the satisfaction of the forest authority and the owner.

6.3.3 Hydrology, Sedimentation, Soil Erosion

105. The drainage streams en-route of the subproject should not be impeded by the works. The scale of the works does not warrant hydrological monitoring.

6.3.4 Air Pollution from Earthworks and Transport

106. Field observations indicate that ambient air quality is generally acceptable and that emissions from traffic and other powered mechanical equipment in the area are rapidly dispersed. There will be a few items of powered mechanical equipment to be used in the construction of the distribution line works that may give rise gaseous emissions. However these should be well dissipated. The major sources of complaint will likely be any necessary earthworks and local soil compaction.

107. The material (cement, sand and aggregate) requirement of a typical 132 kV sub station (about 150 cu m) and a 132 kV transmission tower (4.8 cu m, or 40 bags of cement per tower) are not large. In transmission line construction sand and aggregate are delivered directly to the tower location from the quarry / source, there is no intermediate or bulk storage of these materials .Similarly construction materials for the sub station are stored within the sub station site are scheduled as per the work progress (which is staggered as the buildings which require bulk of the construction materials are built in phases over 6 to 12 months period ) , which means that at any given point in time the amount of construction material stored is not significant .The quantities of construction material required for a typical sub station or transmission tower are not so larger that they potentially represent a traffic hazard , these requirements are time dispersed in case of sub stations and time and space dispersed in case of transmission lines . The contractor will be , however, required to provide a traffic management plan before commencement of work at site .Earthworks will contribute to increasing dust, and the foundation earthworks for the transformers and the line poles will generate dust and the following mitigation measures are needed:

Dust suppression facilities (water sprayers / hosepipe) shall be available where earth and cement works are required.

Areas of construction (especially where the works are within 50m of the SRs) shall be maintained damp by watering the construction area.

Page 19 Power Transmission Enhancement Multitranche Financing Facility- Choa Saidan Shah to N.P.Sethe 132 kV Transmission Line and Up-gradation of NP Sethe 66 kV Grid Station to 132 kV Initial Environmental Examination

Construction materials (sand, gravel, and rocks) and spoil materials will be transported trucks covered with tarpaulins.

Storage piles will be at least 30m downwind of the nearest human settlements

All vehicles (e.g., trucks, equipment, and other vehicles that support construction works) shall be well maintained and not emit dark, smoky or other emissions in excess of the limits described in the NEQS.

The need for large stockpiles should be minimized by careful planning of the supply of materials from controlled sources. Stockpiles should not be located within 50m of schools, hospitals or other public amenities such as wells and pumps and should be covered with tarpaulins when not in use and at the end of the working day to enclose dust.

6.3.5 Noise, Vibration and Blasting

108. It is anticipated that powered mechanical equipment and some local labor with hand tool methods will be used to construct the subproject works. No blasting is anticipated. Powered mechanical equipment can generate significant noise and vibration. The cumulative effects from several machines can be significant. To minimize such impacts, the contractor for subproject should be requested by the construction supervision consultants (engineer) to provide evidence and certification that all equipment to be used for construction is fitted with the necessary air pollution and noise dampening devices to meet EPA requirements.

109. A criterion of 70dB (A)Leq (exterior, boundary of GS) has been used for assessment in previous IEE studies. Any noisy equipment should be located within DGS as far from SRs as possible to prevent nuisances to dwellings and other structures from operation.

110. Noise from construction of the power distribution lines and improvements to substations is not covered under any regulations however in order to keep in line with best international practice it is recommended that no construction should be allowed during nighttime (9 PM to 6 AM) and 70dB(A)Leq should be the criterion at other times during the day measured at the boundaries of land from which construction noise is emitted. A criterion of 70dB (A)Leq (exterior, boundary of DGS) has been used for assessment in previous IEE studies. Any noisy equipment should be located within DGS or as far from SRs as possible to prevent nuisances to dwellings and other structures from operation.

111. Vibration from construction of piles to support pads may be required for some tower construction and may be a significant impact but this should be short duration. Where vibration could be come a major consideration (within say 100m of schools, religious premises, hospitals or residences) a building condition survey should take place prior to construction. The physical effect of piling should be assessed prior to construction and measures should be discussed with the local population as well as timing of the works to serve as a vehicle for further public consultation at the implementation stage and to assist in public relations. At nearby schools, the contractor shall discuss with the school principals the agreed time for operating these machines and completely avoid machine use near schools during examination times, if such a need arises.

6.3.6 Sanitation, Solid Waste Disposal, Communicable Diseases

112. The main issues of concern are uncontrolled or unmanaged disposal of solid and liquid wastes into natural drains, improper disposal of storm water and black water and open defecation by construction workers.

113. In order to maintain proper sanitation around construction sites, access to the nearby GS lavatories should be allowed, provision of temporary toilets should be made. Construction worker camps will not be necessary, based on the scale of the works needed. If for some unforeseen reason a larger workforce is needed any construction camp should not be located in settlement areas or near sensitive water resources and portable lavatories or at least pit latrines should be provided.

114. Wherever water is allowed to accumulate, in temporary drainage facilities, due to improper storm water management, or improper disposal of wastewater generated from the site, it can offer a breeding site for mosquitoes and other insects. Vectors such as mosquitoes may be encountered if open water is allowed to accumulate at the N.P.Sethe SP site. Temporary and permanent drainage facilities should therefore be designed to facilitate the rapid removal of surface water from all areas and prevent the accumulation of surface water ponds.

Page 20 Power Transmission Enhancement Multitranche Financing Facility- Choa Saidan Shah to N.P.Sethe 132 kV Transmission Line and Up-gradation of NP Sethe 66 kV Grid Station to 132 kV Initial Environmental Examination

6.4 Potential Environmental Impacts in operation

6.4.1 Air pollution and noise from the enhanced operations

115. The subproject works will extend the power distribution lines but no houses, mosques or schools will be close to the new TL in the operational phase. Nevertheless some houses, a school, a hospital and a hostel are close to the GS. The GS will be up-graded at already functioning 66 kV GS and the extended level of operation of the facility is not likely to cause any appreciable increase in the noise level already generated by the existing equipment. However, it is recommended that an acoustical check be made on the detailed design to determine of any noise barriers are required. There should be no source of atmospheric pollution from the subproject. In the operational phase any nearby industrial facilities with fuel powered mechanical equipment will be the main polluters. All such emissions will be very well dissipated in the open terrain and there will be no cumulative effect from the subproject.

116. Noise impacts from the operation of the GS equipment should be reviewed at the detailed design stage. There are/not national noise standards in Pakistan for power distribution noise emissions that would apply in the operational stages. A criterion of 70Db (A) Leq (exterior, boundary of GS) has been used for assessment in previous IEE studies. It is recommended that a check be made on the likely acoustical performance based on makers specifications of the installed equipment at the detained design stage

6.4.2 Pollution from oily run-off, fuel spills and dangerous goods

117. No significant impacts from oily residues such as transformer oil and lubricants are expected to arise in this subproject. However control measures will be needed for oily residues such as transformer oil and lubricants in the case of accidental or unexpected release. Transformer oil is supplied in drums from an imported source and tap tanks are topped up as necessary on site. There are facilities in some subproject GS maintenance yards for recycling (dehydrating) oil from breakers. However the areas upon which these recycling facilities are located have no dedicated drainage which can capture run-off. Oily residues and fuel and any contaminated soil residues should be captured at source and refueling and maintenance should take place in dedicated areas away from surface water resources. Contaminated residues and waste oily residues should be disposed at a site agreed with the local authority. However control measures will be needed for oily residues such as transformer oil and lubricants in the case of accidental or unexpected release. Transformer oil is supplied in drums from an imported source and tap tanks are topped up as necessary on site. There are facilities in some subproject DGS maintenance yards for recycling (dehydrating) oil from breakers. However the areas upon which these recycling facilities are located have no dedicated drainage which can capture run-off. Oily residues and fuel and any contaminated soil residues should be captured at source by installing bunds (Appendix 6) and refueling and maintenance should take place in dedicated areas away from surface water resources. Contaminated residues and waste oily residues should be disposed at a site agreed with the local authority . DISCOs are served by the Technical Services Group (TSG) , TSG prepare a detailed routine maintenance schedule for each piece of hardware .TSG also supervise and monitors the implementation of this schedule by Grid System Operation (GSO) .Transformer oil has a long life (typically over 15 years, which depends upon the level of load the transformer serves ) .Oil spills are very rare and are preempted by routine maintenance .TSG and GSO have a written down procedure to deal with oil spills

118. The DISCO procedures for handling PCB need to be strengthened the maintenance of transformers need to be based on the manufactures instructions. There need to be performance evaluation procedure prescribed and followed for each power transformer. In working areas where PCBs are handled, it is necessary to monitor the levels of chlorinated solvents. In case of emergencies the first step is to attempt to control the spread of the liquid, this is especially relevant during transportation. In case of spills, emergency measures need to be taken by the persons specially trained and wearing protective clothes. Oil absorptive materials are a useful tool and needs to be spread over the spill. All equipment and surfaces exposed to the spill need to be washed with solvent. The best international procedures and guidelines need to be followed; one such guideline is the UNEP PCB transformers and capacitors – Form Management to Reclassification and disposal, May 2002. This however, is not relevant as this IEE is related to the development and construction if a new sub station and PEPCO/DISCOs have already banned the use of any equipment that uses PCB.

119. IESCO already prohibits use of PCBs in new power transformers, there is however, need to prepare an inventory of any PCB carrying equipment in the system and all such equipment be replaced. The maintenance instructions prepared by the Technical Services Group needs to be reviewed and revised to add PCB based equipment maintenance and a procedure for handling any PCB spills. The Kot Lakhpat and Shalimar workshops already follow. Such procedures, however, these need to be reviewed and upgraded in the light of best international practice. This would include provision of special clothing availability of oil absorptive solvents, availability of steel containers. Training to staff on oil spills and special care during transportation of equipment using PCB‟s is required. TSG ensure that the maintenance schedule of each piece of hardware is adhered to .

Page 21 Power Transmission Enhancement Multitranche Financing Facility- Choa Saidan Shah to N.P.Sethe 132 kV Transmission Line and Up-gradation of NP Sethe 66 kV Grid Station to 132 kV Initial Environmental Examination DISCOs have also established a safety unit, which among other tasks , investigates all accidents .Frequency of accidents, on average is about 1 per DISCO per year (based on last 4 years record), about 60 % of these are non- fatal .Most accidents occur due to staff and supervision negligence .Detailed report of each accident is prepared .

6.5 Enhancement

120. Environmental enhancements are not a major consideration within the Choa Saidan Shah – N.P.Sethe subproject site. However it is noted that it is common practice at many such sites to create some local hard and soft landscaping and successful planting of fruit trees and shrubs has been accomplished in many sites. This practice should be encouraged as far as practicable. Other opportunities for enhancements can be assessed prior to construction and proposed enhancements should be discussed with the local population to serve as a vehicle for further public consultation at the implementation stage and to assist in public relations. Trees removed for construction purposes should be replaced as compensation in line with best practice at ratio of three replaced for one removed however additional trees should be planted as enhancements where there is space in the DGS and along the TL.

Page 22 Power Transmission Enhancement Multitranche Financing Facility- Choa Saidan Shah to N.P.Sethe 132 kV Transmission Line and Up-gradation of NP Sethe 66 kV Grid Station to 132 kV Initial Environmental Examination

7. INSTITUTIONAL REQUIREMENTS & ENVIRONMENTAL MANAGEMENT PLAN

121. In this section, the mitigation measures that are required for the Choa Saidan Shah –N.P.Sethe TL and up-gradation of N.P.Sethe GS Tranche 2 subproject, to reduce residual impact to acceptable levels and achieve the expected outcomes of the project, are discussed. The Environmental Management Plan is based on the type, extent and duration of the identified environmental impacts for the under study tranche 2 sub-project. The EMP has been prepared following best practice and by reference to the ADB Environmental Assessment Guidelines 2003.

122. It is important that the recommendations and mitigation measures are carried out according to the spirit of the environmental assessment process and in line with the guidelines. The EMP matrix is presented as Attachment 1. The impact prediction (Section 4) has played a vital role in reconfirming typical mitigation measures and in identifying any different approaches based on the feasibility and detailed design assumptions and any alternatives available at this stage.

123. Prior to implementation and construction of the subprojects the EMP shall be amended and reviewed by the IESCO in due course after detailed designs are complete. Such a review shall be based on reconfirmation and additional information on the assumptions made at this feasibility stage on positioning, alignment, location scale and expected operating conditions of the subprojects. For example, in this case if there are any additional transmission lines or extension of the substation boundaries to be included, the designs may be amended and then the performance and evaluation schedules to be implemented during project construction and operation can be updated and costs estimates can be revised. The IEE and EMP should than be revised on a subproject by subproject basis.

124. The IEE and EMP plan must be reviewed by the project management and approved by the PEPA before any construction activity is initiated. This is also an ADB requirement in order to take account of any sub- sequent changes and fine tuning of the proposals. It is recommended that, before the works contract is worked out in detail and before pre-qualification of contractors, a full extent of the environmental requirements of the project (IEE/EIA and EMP) are included in the bidding documents. Professional experience indicates that past environmental performance of contractors and their awareness of environmentally responsible procurement should also be used as indicator criteria for the prequalification of contractors.

125. In order to facilitate the implementation of the EMP, during the preparation for the construction phase the IESCO must prepare the future contractors to co-operate with all stakeholders in the mitigation of impacts. Furthermore the contractor must be primed through the contract documentation and ready to implement all the mitigation measures. IESCO will need to engage at least one trained environmental management staff and the staff should audit the effectiveness and review mitigation measures as the subprojects are rolled out. The effective implementation of the EMP will be audited as part of the mid term review of loan conditions and the executing agency must prepare for this at the inception stage.

126. The details of EMP given in the Attachment 1 are for the Choa Saidan Shah-N.P.Sethe subproject. The EMP matrix will have much in common for many other future (Tranche 2) substation and line projects that have a similar scale of works and types of location but will be different for more complicated substation and line projects that involve impacts to land outside the existing substations and for lines traversing more sensitive land. In all cases separate dedicated IEEs must be prepared.

127. The impacts have been classified into those relevant to the design/preparation stage, construction stage and operation and maintenance stage. The matrix provides details of the mitigation measures recommended for each of the identified impacts, time span of the implementation of mitigation measures, an analysis of the associated costs and the responsibility of the institution. The institutional responsibility has been specified for the purpose of the implementation and the supervision. The matrix is supplemented with a monitoring plan (Attachment 2) for the performance indicators. An estimation of the associated costs for the monitoring is given with the plan. The EMP has been prepared following best practice and the ADB environmental assessment guidelines 2003.

128. Prior to implementation of the subproject the IESCO needs to comply with several environmental requirements, such as submitting and EIA/IEE to PEPA and obtaining PEPA clearance (“No Objection Certificate” compiling acceptable EMP and Clearance Certificate) under PEPAct (guidelines and regulations 2000) and any other permissions required from other authorities. IESCO will also need to confirm that contractors and their suppliers have complied with all statutory requirements and have appropriate and valid licenses and permits for all powered mechanical equipment and to operate in line with local authority conditions.

Page 23 Power Transmission Enhancement Multitranche Financing Facility- Choa Saidan Shah to N.P.Sethe 132 kV Transmission Line and Up-gradation of NP Sethe 66 kV Grid Station to 132 kV Initial Environmental Examination 129. The EMP (Attachment 1) was prepared taking into account the limited capacity of IESCO to conduct environmental assessments of the subprojects. IESCO has appointed 01 environmental manager and 01 social impact manager with support staff. IESCO ESU is fully functional. However, an environmental manager will be required. It is envisaged that experience in this field should therefore develop in the near future. However it is also strongly recommended that for subprojects in future Tranches that the IESCO be prepared to engage more support where necessary (e.g. senior environmental specialist with at least 3 years experience in environmental management one years site experience in environmental monitoring and auditing) to guide the subsequent formal assessment and submission process under the PEPAct and monitor compliance with the EMP. As of May 2009, the IESCO has demonstrated only limited commitment to developing in-house environmental and social capability.

130. The appointed environmental manager has to have a good level of awareness and will be responsible for addressing environmental concerns for subprojects potentially involving hundreds kilometers of distribution lines and DGS. Whereas some of their work may in future be delegated to consultants they will need more training and resources if they are effectively provide quality control and oversight for the EMP implementation. They will require robust support from senior management staff members and the management consultant if they are to address all environmental concerns for the subprojects effectively. Specific areas for immediate attention are in EMP auditing, environmentally responsible procurement, air, water and noise pollution management and ecological impact mitigation. It is recommended that an environmental specialist consultant with 10 years experience be made available to all the DISCOS to cover these aspects full time for at least the first six months of the PDEMFF project and that on a call off basis with local support those services are retained for the life of the PDEMFF loan. The newly appointed graduate environmental manager can then shadow the environmental specialist to improve awareness and hopefully provide independent quality control and oversight for the EMP implementation for the first 12 months.

131. In order to achieve good compliance with environmental assessment principles the graduate environmental manager for the project implementation team must be actively involved prior to the outset of the implementation design stage to ensure compliance with the statutory obligations under the PEP Act. It is also recommended that IESCO Board allow direct reporting to Board level from the in-house Environmental and Social Unit (ESU). If the ESU requires resources for larger subprojects then environmental specialist consultants could be appointed through the project implementation unit to address all environmental aspects in the detailed design. It is recommended that the project management unit (PMU) should liaise directly with the ESU to address all environmental aspects in the detailed design and contracting stages. The graduate environmental manager will cover the implementation of environmental mitigation measures in the project packages.

132. Overall implementation of the EMP will become IESCO‟s responsibility. IESCO and other parties to be involved in implementing the EMP are as follows:

133. Contractors: responsible for carrying out the contractual obligations, implementing all EMP measures required to mitigate environmental impacts during construction;

134. The IESCO Board of Directors will be responsible to ensure that sufficient timely resources are allocated to process the environmental assessments and to monitor implementation of all construction and operational mitigation measures required to mitigate environmental impacts, and

135. Other government agencies such as the regional PEPA and state pollution authorities, Department of Forests, Department of Wildlife Services, who will be responsible for monitoring the implementation of environmental conditions and compliance with statutory requirements in their respective areas and local land use groups at the local levels.

136. Considering that other government agencies that need to be involved in implementing the EMP, training or harmonization workshops should be conducted for all Environmental and Social Units (ESUs) in all DISCOS every six months, for the first 2 years (and annually thereafter) to share the monitoring report on the implementation of the EMP in each DISCO and to share lessons learned in the implementation and to achieve a consistent approach decide on remedial actions, if unexpected environmental impacts occur.

137. The monitoring plan (Attachment 1) was designed based on the project cycle. During the preconstruction period, the monitoring activities will focus on (i) checking the contractor‟s bidding documents, particularly to ensure that all necessary environmental requirements have been included; and (ii) checking that the contract documents‟ references to environmental mitigation measures requirements have been incorporated as part of contractor‟s assignment and making sure that any advance works are carried out in good time. Where detailed design is required (e.g. for power distribution lines and avoidance of other resources) the inclusion and checking of designs must be carried out. During the construction period, the monitoring activities will focus on ensuring that environmental mitigation measures are implemented, and some performance indicators will be

Page 24 Power Transmission Enhancement Multitranche Financing Facility- Choa Saidan Shah to N.P.Sethe 132 kV Transmission Line and Up-gradation of NP Sethe 66 kV Grid Station to 132 kV Initial Environmental Examination monitored to record the Subprojects environmental performance and to guide any remedial action to address unexpected impacts.

138. Monitoring activities during project operation will focus on recording environmental performance and proposing remedial actions to address unexpected impacts. The potential to use local community groups contacts for monitoring should be explored as part of the activities in setting up the Environmental and Social Unit which should have regular meetings with the NGOs as a matter of good practice and to discuss matters of mutual concern.

139. At this stage, due to the modest scale of the new power distribution projects and by generally keeping to non-sensitive and non-critical areas the construction and operational impacts will be manageable. No insurmountable impacts are predicted providing that the EMP is implemented to its full extent and required in the contract documents. However experience suggests that some contractors may not be familiar with this approach or may be reluctant to carry out some measures. In order that the contractors are fully aware of the implications of the EMP and to ensure compliance, it is recommended that environmental measures be coasted separately in the tender documentation and that payment milestones are linked to environmental performance, vis a vis the carrying out of the EMP.

140. The effective implementation of the EMP will be audited as part of the loan conditions and the executing agency must be prepared for this. In this regard the IESCO (the IA) must be prepared to guide the design engineers and contractors on the environmental aspects.

Page 25 Power Transmission Enhancement Multitranche Financing Facility- Choa Saidan Shah to N.P.Sethe 132 kV Transmission Line and Up-gradation of NP Sethe 66 kV Grid Station to 132 kV Initial Environmental Examination 8. PUBLIC CONSULTATION AND INFORMATION DISCLOSURE

8.1 Approach to Public Consultation 141. The public consultation (PC) process with various stakeholders has been approached so as to involve public and other stakeholders from the earliest stages. Public consultation has taken place during the planning and design and viewpoints of the stakeholders have been taken into account and their concerns and suggestions for possible improvements have been included where appropriate. Much of the PC process to date has revolved around concerns for the mitigation of construction impacts and the possible side effects from the proximity of high voltage power lines and the GS and its equipment.

142. There is also a requirement for ongoing consultation for land acquisition and resettlement plan (LARP). In this case Resettlement Plan (RP) is documented separately. It is expected that this process will continue through all stages of the subproject in order to accommodate stakeholders' aspirations and to orient the stakeholders positively towards the project implementation and where possible to harness cooperation over access issues in order to facilitate timely completion.

8.2 Public Consultation Process 143. The public consultation process has commenced in the initial feasibility stages (prior to construction) in order to disclose the project information to the stakeholders and record feedback regarding the proposed project and preferences. The stakeholders involved in the process were the population likely to be impacted along the route of the proposed power lines; the village leaders and school teachers.

144. Prior to the implementation of the consultation, feedback, etc. has been carried out to support this IEE and recorded. The focus of attention has been the population near the proposed TL that may be affected by the Subproject implementation. The level of engagement varied from the stakeholder to stakeholder with some registering no major comment but it is noted that none registered any outright opposition to the subproject.

145. The disclosure of the enhancement project in advance and subsequent consultation with stake holders has advantages in the environmental assessment and mitigation of impacts. Public consultation can also provide a conduit for the improvement of the project implementation to better serve the stakeholders.

146. The environmental assessment process under the Pakistan Environmental Protection Act only 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. The locations of consultation and people consulted are listed in the full table of public consultation (male & female) presented in Attachment 3 & 3A.

8.3 Results of Public Consultation 147. The consultations identified some potential environmental and social impacts and perceptions of the affected communities. The male public consultation resulted in 102 and female 32 responses in May 2009 (Attachment 3&3A). The community generally supports the construction of the GS. The local poor people predominantly requested for unskilled and semi skilled jobs on priority basis with the contractors during implementation of the project. No land acquisition and resettlement is involved in this subproject. However, compensation will be paid to the concerned parties / owners of land under the towers and where the loss of some trees and for damage to crops is expected.

148. On the basis of the consultations so far, it appears that the project will have no insurmountable environmental and social impacts but IESCO will have to make sure that compensation and assistance amounts are assessed justly and that skilled and unskilled employment should be preferentially given to the AP as far as is reasonably practicable.

Page 26 Power Transmission Enhancement Multitranche Financing Facility- Choa Saidan Shah to N.P.Sethe 132 kV Transmission Line and Up-gradation of NP Sethe 66 kV Grid Station to 132 kV Initial Environmental Examination 9. CONCLUSIONS

9.1 Findings and Recommendations 149. This study was carried out at the planning stage of the project. Primary and secondary data were used to assess the environmental impacts. The potential environmental impacts were assessed in a comprehensive manner. The report has provided a picture of all potential environmental impacts associated with the Project, and recommended suitable mitigation measures. This study recommends that some further follow up studies are undertaken during project processing in order to meet the ADB requirements.

150. There are some further considerations for the planning stages such as obtaining clearance for the project under the Pakistan Environmental Protection Act (1997) but environmental impacts from the power enhancements will mostly take place during the construction stage. There are also some noise impacts and waste management issues for the operational stage that must be addressed in the detailed design and through environmentally responsible procurement. At the detailed design stage the number of and exact locations for transmission tower enhancements may change subject to detailed surveys but the impacts are likely to be broadly similar at most locations and impacts have been reviewed in the environmental impact section of this IEE report.

151. There are a number of key actions required in the detailed design phase. Prior to construction the IESCO must receive clearance certification from the PEPA and IESCO must complete an EMP that will be accepted by the PEPA and agreed by the contractor prior to signing the contract. The information provided in this report can form the basis of any further submission to PEPA as required in future.

152. No land acquisition, compensation and resettlement are involved. However, some trees will be compensated to the concerned parties, if needed. However, provisions may be made in LARP, based on the proposed alignments these should not be difficult tasks and can be conducted as the detailed designs are worked out and to dovetail with the existing system and minimize adverse impacts and maximize benefits. A social impact assessment and resettlement action plan (LARP) has been completed in tandem with this IEE for the whole subproject. The study has:

(i) Examined and assess the overall social and poverty profile of the project area on the basis of the primary and secondary data sources and preparation of a socio-economic profile of the project districts. (ii) Prepared a social and poverty analysis, taking into account socio-economic and poverty status of the project area of influence, including the nature, extent and determinants of poverty in the project area including assessment. In addition, estimation of the likely socioeconomic and poverty reduction impacts of the project should be included. (iii) Held consultations with relevant officials from the government and other relevant officials, including consultation with affected communities to assess responses to the project and ascertain the nature and scope of local participation in project planning and implementation. (iv) Identified, analyzed and, where appropriate, quantified the potential resettlement impacts (minimal) of the proposed Project on the area and the population.

153. Baseline monitoring activities should be carried out during project detailed design stage to establish the baseline of parameters for checking during the construction stage. The monitoring schedule (Attachment 2) recommends monitoring on two occasions at the site location. The results should be integrated with the contract documentation to establish performance action thresholds, pollution limits and contingency plans for the contractor‟s performance.

154. During the commissioning phase noise monitoring should ensure that statutory requirements have been achieved. Monitoring activities during project operation will focus on periodic recording environmental performance and proposing remedial actions to address any unexpected impacts.

9.2 Summary and Conclusions 155. The construction of the Choa Saidan Shah –N.P.Sethe TL and Up-gradation of N.P.Sethe GS subproject is a feasible and sustainable option from the power transmission, engineering, environmental, and socioeconomic points of view. Implementation of the EMP is required and the environmental impacts associated with the subproject need to be properly mitigated, and the existing institutional arrangements are available. Additional human and financial resources will be required by IESCO to complete the designs and incorporate the recommendations effectively and efficiently in the contract documents, linked to payment milestones. The proposed mitigation and management plans are practicable but require additional resources.

Page 27 Power Transmission Enhancement Multitranche Financing Facility- Choa Saidan Shah to N.P.Sethe 132 kV Transmission Line and Up-gradation of NP Sethe 66 kV Grid Station to 132 kV Initial Environmental Examination 156. This IEE, including the EMP, should be used as a basis for an environmental compliance program and be included as an Attachment to the contract. The EMP shall be reviewed at the detailed design stage. In addition, any subsequent conditions issued by PEPA as part of the environmental clearance should also be included in the environmental compliance program. Therefore, continued monitoring of the implementation of mitigation measures, the implementation of the environmental conditions for work and environmental clearance, and monitoring of the environmental impact related to the operation of the subproject should be properly carried out and reported at least twice per year as part of the project performance report.

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